ML20203P964

Request for OMB Review & Supporting Statement Re NRC Form 4, Occupational External Radiation Exposure History. Estimated Respondent Burden Is 7,500 H

ML20203P964
Person / Time
Issue date:	05/02/1986
From:	Norry P NRC OFFICE OF ADMINISTRATION (ADM)
To:
References
OMB-3150-0005, OMB-3150-5, NUDOCS 8605080433
Download: ML20203P964 (9)

Text

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t OMB SUPPORTING STATEMENT FOR NRC FORM 4 OCCUPATIONAL RADIATION EXPOSURE HISTORY Description of the Information Collection 10 CFR Part 20, Section 20.102, " Determination of Prior Dose," requires licensees to record the prior occupational exposure history of certain individuals in order to assure that the individuals' total occupational doses do not exceed the radiation dose limits for individuals in restricted areas (520.101). NRC Form 4, or its equivalent, is used for recording the exposure information for prior employments.

A.

JUSTIFICATION 1.

Need for the Collection of Information In order to protect the health and safety of workers,10 CFR Part 20 requires licensees to control within specified limits the total occupational radiation j

exposure received by workers. The basic whole body external dose limit is 1.25 rems per calendar quarter (520.101(a)).

However, an individual may be exposed to up to 3 rems per calendar quarter, provided that the accumulated occupational dose does not exceed a formula, 5(N-18) rems, where N is the individual's age at his last birthday (520.101(b)).

In order for a licensee to control the dose to a worker within these limits, the licensee needs to know the magnitude of the dose received by the worker in prior employments, so that additional exposure in the licensee's facility will not cause the worker's total occupational dose to exceed the limits.

2.

Agency Use of Information i

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The NRC regulations do not require licensees to send NRC Form 4 to the NRC.

These records of exposure history are to be completed and maintained by NRC 1

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licensees so that they can be reviewed by NRC inspectors to determine compliance with the dose-limiting sections of the regulations.

3.

Reduction of Burden Through Information Technology Less time is now required to complete NRC Form 4 than during earlier requests for 0MB clearance because of the increased use of computers for recordkeeping.

Many NRC licensees have computer systems in which the radiation exposure information required to be collected can be stored.

This allows them to quickly print the information in any desired format.

4.

Effort to Identify Duplication The Federal Information Locator System was searched to determine NRC and other Federal agency duplication, and no duplication was found.

5.

Effort to Use Similar Information NRC Form 4 is the only source of information which summarizes the worker's exposure from prior employments.

There is no similar information which can be readily used to satisfy the needs stated in item #1.

6.

Effort to Reduce Small Business Burden The information required by NRC Form 4 is needed for the employees of small business as well as for the employees of larger business firms.

It is not possible to reduce the burden on small business and still meet the objectives stated in A.1.

However, since smaller businesses usually have fewer employees, their recordkeeping burden will be less.

7.

Consequences of Less Frequent Collection Workers could receive occupational doses in excess of the limits in 520.101 if the doses from prior employments during the calendar quarter are not considered in assessing how much exposure a worker can receive in his current employment.

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8.

Circumstances Which Justify Variation from OMB Guidelines NRC Form 4s and the records used to prepare the forms are to be preserved by the licensees until the Commission authorizes their disposition because they may at some time be necessary to reconstruct an individual's occupational exposure history and the potential health impact due to such exposure.

9.

Consultations Outside the NRC Since the original justification, many individuals (licensees, workers, etc.)

have used, reviewed, or commented on NRC Form 4.

However, no significant changes have been made in the form.

10. Confidentiality of Information The NRC provides no pledge of confidentiality for this collection of information.

The NRC neither receives nor maintains the information collected on NRC Form 4.

11. Justification for Sensitive Ouestions The form contains no sensitive questions.

12.

Estimated Annualized Cost to the Federal Government NRC cost is incurred by the inspector's review of the information on NRC Form 4, or its equivalent, and records maintained by licensees. An average of 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of inspection time per year is spent reviewing such records at each of about 70 reactor sites.

An average of 0.25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> of inspection time per 3 years is spent reviewing such records of about 7,475 materials licensres. Therefore, the total inspection cost would be about $43,680/ year (70 x 1.5 hrs /yr + 7,475 x 0.25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> every 3 years = 728 hrs /yr x $60/hr).

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13. Estimate of Burden a.

NRC Form 4, or its equivalent, must be completed by all 7,500 licensees.

Approximately 300,000 individuals are monitored and, by allowing.a 10%

annual turnover in the workforce, there would be 30,000 NRC Form 4s, or equivalents, required per year.

It is estimated that about 0.25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> of clerical time would be used to prepare the form, or its equivalent, using the data obtained pursuant to Q20.102, or about 7,500 hrs / year (30,000 forms x 0.25 hr/ form).

I Number of recordkeepers 7,500 2.

Annual hours per recordkeeper................

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Total recordkeeping hours 7,500 4.

Recordkeeping retention period.............. until the Commission authorizes their disposition -

There would be a wide range in the number of forms completed and maintained by each licensee because of the tremendous variation in the size of NRC licensees.

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b.

The cost of this requirement is estimated to be about $450,000 (7,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> x $60/hr). An additional 5% or $22,500, is allowed for the cost of maintaining the records. The total cost would be $472,500/yr. Therefore, the estimated annual cost per respondent to respond to the collection is

$63.00.

c.

The burden data and estimates are judgments of NRC staff based on experience gained as licensees and as regulators.

14. Reasons for Change in Burden Under the current OMB Clearance No. 3150-0005, NRC Form 4 has 37,200 total recordkeeping hours in the current OMB inventory. Under this updated request 4

4 for clearance, NRC Form 4 will require 7,500 total recordkeeping hours in the OMB inventory. The difference of 29,700 total recordkeeping hours is an adjustment based on NRC staff's judgment'that NRC licensees will need 0.25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> to prepare each of the 30,000 farms per year, rather than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to prepare I

each of 37,200 forms per year, to determine prior occupational dose. Less time is required because of increased use of computers for recordkeeping.

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15. Publication for Statistical Use t

Not Applicable.

B.

COLLECTION 0F INFORMATION EMPLOYING STATISTICAL METHODS f

Statistical methods are not used in the collection of information.

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i NRC Fonn 4 Approved by OMD (1241) 3150 4005 19 to U. S. NUCLE AR REGULATORY COMMIS$10N Emper*5 4 30 4 3 OCCUPATIONAL EXTERNAL RADIATION EXPOSURE HISTORY See instructions on the Back IDENTIFICATION 1.NAME (PRINT - LAST, FIRST, AND MlOOLEl

2. SOCI AL SECURITY NO.

E

3. DATE OF BIRTH (MONTH, DAY, YE AR)

4. AGE IN FULL YEARS (N)

OCCUPATIONAL EXPOSURE - PREVIOUS HISTORY b PREVIOUS EMPLOYMENTS INVOLVING

6. DATESOF EMPLOYMENT

?. PE RIODS OF EXPOSURE

8. WHOLE 80DY

9. RECORD OR CALCULATED RADIATION EXPOSURE-LIST NAME AND WROM-TOI (REM)

(INSERT ONE)

ADDRESSOF EMPLOYER i,

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10. REMAR KS

11. ACCUMULATED OCCUPATIONAL DOSE

- TOTAL

13. CALCULATIONS. PE RMISSIBLE DOSE 12.CE RTIFICATION:I CERTIFY THAT THE EXPOSURE HISTORY WHOLE BODY:

LISTED IN COLUMNS 5. 6, AND 7 IS COR RECT AND COMPLETE TO THE BEST OF MY KNOWLEDGE AND BELIEF, (A) PERMISSIBLE ACCUMULATED REM DOSE = 5(N-18)

(8) TOTAL EXPOSURE TO DATE REM EMPLOYEE *S SIGNATU RE DATE (FROM ITEM til

14. N A E OF LICENSEE (C) UNUSED PART OF REM

(

PERMISSIBLE ACCUMULATED DOSE (A-0)

INSTRUCTIONS FOR PREPARATION OF NRC FORM 4 This form or a clear and legible record containing all the of the individual 'as calculated under Section information required on this form must be prepared by each 20.102. Dose is to be given in rem.

ficensee rif the Nuclear Regulatory Commission who, pursuant to Section 20.101, proposes to expbse an individual to a radiation

" Dose to the whole body" shall be deemed to in-dose in excess of the amounts specified in Paragraph 20.101(a) ciude any dose to the whole body, gonads, active of the regulations in Part 20 " Standards for Protection Against blood-forming organs, head and trunk, or lens of Radiation," 10 CFR. The requirement for completion of this eye.

form is contained in Section 20.102 of that regulation. The information contained in this form is used for estimating the item 9. After each entry in item 8 indicate in item 9 extemal accumulated occupational daae of the individual for whether dose is obtained from records or calcu-whom the form is completed. A separate NRC Form 4 shall be lated in accordance with Section 20.102.

completed for each individual to be exposed to a radiation dose item.10. Self-explanatory, in excess of the limits specifed in Paragraph 20.101W of Part 20 of the Commission's regulations.' Listed below by item are Total Accumulated Occupational Dose (Whole B vfy) instructions and additional information directly pertinent to com-p g tNs brn:

ltem 11. The total for the whole body is obtained by sum-mation of all values in item 8.

Identification Cartification item 1. Self4xplanatory.

Item 2. Self-explanatory except that,if indrvidual has no social security number, the word "none" shall be Item 12. Upon completion of the report, the employee must inserted.

certify that the information in Columns 5,6, and 7 Item 3. Self-exclanatory, is accurate and complete to the best of his know-Item 4. Enter the age in futi years. This is caned "N" when ledge. The date is the date of his signature.

used in ca!culating the Permissible Dose. N is equal to the number of years of age of the individual on his last birthday.

Calculations item 13. The fjfetime accumulated occupational dose for Occupational Exposure each endividual and the permissible dose under Paragraph 20.101(b) are obtained by carrying out item 5. List the name and address of each previous em-the following steps: The value for N should be ployer and the address of employment. Start with taken from item 4. Subtract 18 from N and multi-the most recent employer and work back.

Oly the difference by 5 rem. (For enample, John Smith, age 32, N = 32, PAD = 5(3218) = 70 rem.)

include only those periods of' employment smce Enter total exposure to date from item 11. Sub-the eighteenth birthday involving occupational tract (b) from (a) and enter the difference under exposure to radiation. For periods of self-employ.

(c). The value in (c) represents the unused part of rnent, insert the word "self employed."

the permissible accumulated dose. This value for item 6. Give the dates of each employment listed in Item 5 perm 6ssible dose is to be carried forward to NRC ltem 7. List periods during which occupational exposure Form 5. " Current Occupat6onal External Radiation to radiation occurred.

Esposure (Whole Body)."

ttem 8. List the done recorded for each period of exposure from the records of previous occupational euposure item 14. Self-explanatory,

'TNs form esewires she monature of the enopsevee eencerned_

PRIVACY ACT STATEMENT Pursuant to 5 U.S.C. 552stel (31, enacted laso tew by secoon 3 of the Prasacy Act of 1974 (PutWie Law 93 6791,the foHowing statement is furmehed to indwiduals who supply information to the Nuclear Regulatory Commission on NRC Form 4. Ttus 6pformation is mamtamed in a system of records dos.gnated as NRC,27 and desenbod at Federal Register a53a4 (October 1,1975).

1. AUTHORtTY Sections 53,63,65,81,103.104,161(bl. and 161tol of the Aton~

ergy Act of 1954, as amended 142 U.S C. 2073,2093,2096,2111, 2133,2134,2201(bl. and 22011o1). The authoney for soliciting the sacusi ucurity nmtw e 10 CF R Part 20.

2. PRINOPAL PUR POSE (S)

The informatHin 6s used by the N RC m its evaluation of the risk of redaetion emposure assooeted with the hcensed actwity and in esercismg its statutory responsebility to monitor and repete the safety and hesith practices of its heensees. The data permsts a meaamgful cunparison of both current one lor eterm evoosure empenence anong types of hceneees and anong bcensees with.n sech type. Data on y< mar esponere to radiation is aweilatWe so you upon rowest.

3. ROUTINE USES T

• e information me, og v, I to provede data to other Feoeral and State agencess involved en monitoring and/or evolvating radesten em.

posure receeved by 6adivir.sla employed as rooi n workers on a permanent or temporary basis and esposure recewed by morutored viators. The information may also be disclosed to en appeopneto Federal, State, or local agency in the event the information md cates a violation or covential violation of law and in ttw course of an administrat*ve or judicial proceeding.

4. WHETHE R DISCLOSURE 15 MANDATORY OR VOLUNTARY AND EF FECT ON INDIVIDUAL OF NOT PROV10 LNG INFORMAflON It is volun.

tary that you turn 6sh the requested informat6on, including soc 6al security number; however, the hcensee must have a corec.4eted NRC Form 4 on each individual whom the licensee proposes so empose to a radiation done m escens of the amounts specified in 10 CF R 20.101(al. Fa. lure to obtam the rowested 6af armation before permetting mach exposure may estwoct the :icensee to enforcement action in a<rordance with 10 CF R 20.601. The socios secunty number is used to esaare that NRC has an accueste identifier not estaect to the co.ncidence of semiser names or b rthostes anong the larga nurnber of persons on whom data is montsened.

5. SYSTEM MANAGER (S) AND AODRESS Detector Otheeof Management and Program Analysis U S. Nucteer Repatory Commesseon. Wash.ngton, D C. 20555 ene ees.m

Sandia National Laboratories Albuquerque. New Mexico 8718S WP ^^0ET CONTRC.

CENIER

,86 f?? 15 All:43 w

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April 15, 1986 M//[ -

Ocd.at.*!0.

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N-Neil M. Coleman b.0btrBu@n:/Es234/7 8M - #

• Hydrology Section Geotechnical Branch Division of Waste Management djl/

U.S. Nuclear Regulatory Commission

{ Return to WM,623 SS) d[

7915 Eastern Avenue Silver Spring, MD 20910

Dear Mr. Coleman:

Enclosed is the monthly report on FIN A-1158, Repository Site Definition and Technology Transfer for March 1986.

Please feel free to contact me if you have any questions or comments.

Sincerely, furO Robert M.

Cranwell, Supervisor Waste Management Systems Division 6431 RMC:6431:ja Enclosure Copy to:

Office of the Director, NMSS Attn:

Program Support Robert Browning, Director Division of Waste Management Malcolm R.

Knapp Division of Waste Management Enrico Conti, Branch Chief Health Siting & Waste Management Division John Randall Division of Radiation Programs and Earth Sciences 6400 R.

C.

Cochtell 6430 N. R. Ortiz 6431 R. M. Cranwell 6431 C.

P. Harlan 6431 G. F. Wilkinson B605080431 860415 PDR WMRES EXISAPL A-1158 PDR l

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PROGRAM:

FIN:

A-1158, Tasks I - V CONTRACTOR:

Sandia National BUDGET PERIOD: 10/85 -

Laboratories s'

9/86' NMSS PROGRAM MANAGER:

N. M. Coleman TOTAL BUDGET AMOUNT: $486K 4

CONTRACT PROGRAM MANAGER:

R. M.

Cranwell FTS PHONE:

844-8368 PRINCIPAL INVESTIGATOR:

G. F. Wilkinson FTS PHOhE:

844-0074 C.

P. Harlan FTS PHONE:

844-8164 Administrative Issues Concerning FIN A-ll58 for March 1986 As mentioned in the February monthly report, we are in the process of dividing case 0976.000 into five subcases to correspond with the five individual tasks involved in FIN A-ll58.

Revision to the SNLA accounting system to reflect this change has not yet been completed, but should appear within the next month or two.

Consequently, costs for Tasks II - IV are included as one item for this month.

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