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Request for OMB Review & Supporting Statement Re Cumulative Occupational Exposure History.Estimated Respondent Burden 11,187 H
	ML20236R060
Person / Time
Issue date:	07/10/1998
From:	Shelton B; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:	;
Shared Package
ML20236Q335	List: ML20236Q333; ML20236R060;
References
	OMB-3150-0005, OMB-3150-5, NUDOCS 9807210219
	Download: ML20236R060 (10)
	v • d • e

.

PAPERWORK REDUCTION ACT SUBMISSION L

Pl:ase r:ad the instructions befora ctmpl; ting this form. For addition 11 forms or tesistinc:s in completing this form, contact your agency's Paperwork Clearance Officer. Send two copies of this form, the collection instrument to be reviewed, the Supporting Statement, and any additional documentation to: Office of Information and Regulatory Affairs, Office of Management and Budget, Docket Library, Room 10102,72617th Street NW, Washyi ton, DC 20503

1. Agency / Subagency originating request

,,1 OMB control number

' U.S. Nuclear Regulatory Commission X

a.

3150 - 0005 b.None J Type of information collection (check onel d Type of review requested (check onel y

a. New collection X

a. Regular submission

c. Delegated

b. Revision of a currently approved collection

b. Emergency. Approval requested by (date):

c. Extension of a currently approved collection

5. Will this information collection have a

,, y,,

s en ant economic impact on a

~

d. Reinstatement, without change, of a previously approved substantial number of smell entities?

X b.No collection for which approval has expired

e. Reinstatement, with chance, of a previously approved X a. Three years from approval date collection for which approval has expired equested 6' expiration date

f. Existing collection in use without an OMB control number 7, Titie

" Cumulative Occupational Exposure History"

8. Agency form number (s) (if applicablel NRC Form 4

9. Keywords -

Nuclear hadiation Monitoring, Radiation Exposure, Dose Umits

10. Abstract NRC Form 4 is used to record the summary of an individual's cumulative occupational radiation dose for the current year to ensure that dose does not exceed regulatory limits, I

} Affacted public thcark primary with *P* and on others that epoly with *X*)

12. obligation to respond thierk swknary with *P* ed og others rhet apply with X*)

X

s. Individuals or households

d. Forma

e. Voluntary P

b. sueiness or other far-profit X

a. Federal Gove amont

b. Required to obtain or retain benefits X

c. Not for-profit institutions

f. State, Local. or Tribal Govemment P

c.. Mandatory

13. Annual reporting and recordkeeping hour burden

14. Annual reporting and recordkeeping cost burden (las thousands of doneral

[

e. Number of respondents -

300

e. Total annualized capitalistertup costs 0

b. Total annuel' roeponses 22.373

b. Total annual costs (ofiM) o pfM

1.~ Percentage of these responses

c. Total annualized cost requested o

collected electronically -

43

d. Current OMB inventory o

c. Total annual hours requested 11,187

e. Difference o

d. Current oms inventory 8,052

f. Explanation of difference

e. Difference 3.135

1. Program change

f. Explanation of differenes

2. Adjustment

1. Program change

~ 2. Adsustment -

3,135

15. Purpose of information collection ^

16. Frequency of recordkeeping or reportm ICheck att that app &l (Mort primary with *P' and eM others that appN with *X*)

T

e. Recordkeeping X

b. Third-party disclosure

e. Application for benefrts

o. Program planning or management

c. Reporting l

b. Progrom ovaluation

f. Research.

x

1. on occasion

2. Weekly

3. Monthly

c. General purpose statistico y

g. Regulatory or compliance

4. Quarterly

6. semi-annually

6. Annually

d. Audit

8. other (describe)

L nW i

17, statisticet methode 1s. Agency contact (person who can best answer questions regerhug the sent of this submission)

Does this information collection t

"Name:

Mary Lynne Thomas, RES

J Yes No Phone

301-415-6230 990721'0219 990710 PDR. ORO hb (Ub Q1 DR ~

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l FINAL OMB SUPPORTING STATEMENT FOR NRC FORM 4 l

(CLEARANCE REVISION)

(3150-0005)

CUMULATIVE OCCUPATIONAL EXPOSURE HISTORY Description of the information Collection Part 20, Title 10 of the Code of Federal Regulations (10 CFR Part 20), provides requirements to licensees who receive, possess, use, transfer, or dispose of byproduct, source, or specht nuclear material or who operate a production or utilization facility under parts 30-36, 39,40, 50, 60,61,70,72 or 76 for compliance with " Standards for Protection Against Radiation." Section 20.2104, " Determination of Prior Occupational Dose," requires that for each individual who is likely to receive, in one year, an occupational dose requiring monitoring as hscribed in i

$ 20.1502, licensees must determine the occupational radiation dose received during the current year and must attempt to obtain the records of cumulative occupational radiation dose.

in addition, licensees must obtain records of cumulative occupational radiation dose for any Individual who is needed to participate in a planned special exposure. This is a third party

'ollection.

l NRC Form 4 is the recommended format for recording prior years' doses and prior doses by multiple licensees within the same calendar year. This information is necessary to ensure compliance with the annual occupational dose limits of 10 CFR Part 20. This information is also i

required by 10 CFR 20.2104 prior to allowing an individual to participate in a planned special exposure.

1 The Information to complete NRC Form 4 comes from NRC Form 5. The NRC Form 5 is i

provided to the monitored individual by previous employers. The licensee need only account for periods that the individual was monitored in the current year. Prior years' doses can be provided by a cumulative estimate supplied by the employee.

A.

JUSTIFICATION 1,

Need for and Practical Utility of the Information Collection in order to protect the health and safety of workers,10 CFR Part 20 requires licensees to control, with:a specified limits, the occupational radiation dose of their workers. The information collection was based, in part, on Presidential Guidance to Federal Agencies for Occupational Exposure published in the Federal Reaister on January 27,1987. NRC Form 4 is to be completed, released upon signed request, and maintained by NRC licensees until the license is terminated by the Commission in accordance with 10 CFR 20.2104. This data can be reviewed l

by NRC inspectors to determine compliance with the dose-limit sections of the regulations and to ensure the health and safety of the workers.

1

The NRC Form 4 is a condensed summary of the information found on NRC Form 5 submitted by all the licensees for an individual for whom monitoring was provided. The NRC Form 4 may be prepared by the monitored individual or by the licensoe once the licensee has determined that monitoring for occupational dose is required.

2.

Aaency Use of Information The NRC uses the information to ensure that licensees are complying.with the appropriate regulations in a manner adequate to protect worker and public safety. The information is also used by the NRC to evaluate licensees' operations to ensure that they are meeting the requirements of their licenses.

3.

Reduction of Burden Throuah information Technoloav i

l As of June 1997,130 of the 300 licensees who reported electronically for 1996 used either the NRC supplied software, Radiation Exposure Monitoring and Information Transmittal (REMIT),

or their own method to record and prepare this information. These same 130 licensees may use REMIT or their own method to prepare NRC Form 4s for transient workers. NRC encourages the use of any applicable information technology to produce and store information.

4.

Effort to identifv Duplication and Use Similar Information The Information Requirements Control Automated System (IRCAS) was searched and no i

duplication was found. There is no similar information available to the NRC.

l l

5.

Effort to Reduce Small Business Burden l

The information required by NRC Form 4 is needed for the em%ma of small businesses as well as for employees of larger business firms to ensure that et copational doses are within the l

limits of 10 CFR Part 20. It is not possible to reduce the burden on small businesses and still i

meet the objectives stated in A.1.

6.

Consequences to Federal Proaram Activit'es if the Collection is not Conducted or is Conducted Less Freauentiv The NRC Form 4 is filled out by an individual at the start of each new employment period. Less frequent collection would mean not checking doses received from previous employment. A worker could receive an occupational dose in excess of the limits of 10 CFR Part 20 if the dose from prior employment during the current year is not considered in assessing the dose a worker could receive during current employment.

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l 2

_________..___..______.___________._______E

7.

Circumstances Which Justifv Variation from OMB Guidelines Records associated with the NRC Form 4 must be retained for the life of the NRC license in order to determine a worker's prior occupational radiation dose, as required by S 20.2104 of 10 CFR Part 20.

8.

Ggnsu!tations Outside the NRC The NRC Form 4 is discussed each year at the Dosimetry Users Conference, with the most recent being held in Phoenix, Arizona, November 5-7,1997. The discussion focused on questions concerning electronic submittals, data entry and recordkeeping and reporting requ;rements. An opportunity to comment on NRC Form 4 information collection requirements was published in the Federal Reaister on March 30,1998 (63 FR 15232). No comments were received.

9.

Envment or Gifts to Respondents.

Not applicable.

10.

Confidentiality of Information This information is subject to the Privacy Act of 1974 and is only available through the NRC's Privacy Act System of Records, NRC-27, REIRS.

11.

Justification for Sensitive Questions l

NRC Form 4 specifies the use of the individual's name, social security number or other ID, date of birth, and Jex. This information is necessary to ensure the proper identification of the l

I individual.

12.

Estimate of Annual Burden The requirement to obtain and maintain the information specified on NRC Form 4 for each individual for whom monitoring is required extends to all of the 109 reactor sites and all 5,877 l

materials licensees. Since this form is filled out each time a worker changes employment l

during the year, the greatest burden is on licensees who utilize transient workers. In 1996, of the licensees who are required to submit annual occupational radiation exposure reports in accordance with 10 CFR 20.2206(a),22,373 transient workers were utilized,21,800 of these worked at reactor sites (200/ site), the remaining 573 worked at matcrials licensees (3/ licensee).

Approximately 0.50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months is required to complete, review, and authorize each NRC Form 4 for an annual burden of 10,900 hours0.0104 days 0.25 hours 0.00149 weeks 3.4245e-4 months for reactor sites, (109 reactors X 0.50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months X 200 transient workers), and 287 hours0.00332 days 0.0797 hours 4.74537e-4 weeks 1.092035e-4 months for materials licensees, (191 materials licensees X 0.50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months X 3 transient workers) for a total annual burden of 11,187 hours0.00216 days 0.0519 hours 3.091931e-4 weeks 7.11535e-5 months . The annual cost to reactor sites for this requirement is $1,427,900 = (10,900 hours0.0104 days 0.25 hours 0.00149 weeks 3.4245e-4 months X $131/ hour), and $35,875 = (287 hours0.00332 days 0.0797 hours 4.74537e-4 weeks 1.092035e-4 months X

$125/ hour) for materials licensees. The total annual cost to licensees is $1,463,775 (See Table 1).

3 l

q

-i r

.13.-

Estimate of Other Additional Cost.

x Not applicable..

.14.

Estimated Annualized Cost to the NRC

' NRC cost is incurred by inspectors reviewing the information on NRC Form 4, or its equivalent, and supporting records maintained by licensees. Annually,109 hours0.00126 days 0.0303 hours 1.802249e-4 weeks 4.14745e-5 months of inspection time is spent reviewing such records,~ at an average of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for each of 109 reactor sites, in addition, 470 hours0.00544 days 0.131 hours 7.771164e-4 weeks 1.78835e-4 months of inspection time is spent reviewing such records an average of 0.08 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for each of 5,877 materials licensees. Annually, the total time spent reviewing these records is approximately 579 hours0.0067 days 0.161 hours 9.573413e-4 weeks 2.203095e-4 months The annual cost for reactor inspections to review these forms is l

1 $14,279 (109 hours0.00126 days 0.0303 hours 1.802249e-4 weeks 4.14745e-5 months X $131/ hour) and the annual cost for mt terials inspections to review these j

forms is $58,750 (470 hours0.00544 days 0.131 hours 7.771164e-4 weeks 1.78835e-4 months X $125/ hour). Annually, the totalinspection cost is approximately

$73,029. The annual NRC in-house printing costs for the forms is approximately $7.

Therefore, the total' cost to the NRC is approximately $73,036 annually (See Table 2). These costs are fully recovered through fee assessments to NRC licensees pursuant to 10 CFR Parts

.170 and 171.

15.

Reasons for Chanae in Burden.

.The previous clearance estimated 'a total of 40,260 responses and a burden of 8,052 hours6.018519e-4 days 0.0144 hours 8.597884e-5 weeks 1.9786e-5 months .

The proposed clearance estimates a total of 22,373 responses with a corresponding burden increase to 11,187 hours0.00216 days 0.0519 hours 3.091931e-4 weeks 7.11535e-5 months . This increase is a result of experience obtained from collecting and analyzing the data used to prepare the annual occupational exposure report, NUREG-0713."

16.

Publication for Statistical Use

-l bbne.

~ 17; Pa=nn for Not Disolavina the Exoiration Date.

~

Not applicable.

18.

Exceotions to the Certification Statement.

l l

Not applicable.

B.

1 COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS Statistical method; are not employed in the collection of information.

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m____

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_._..-__2___-._____.____m_____m 2__

-____u__-.m___--m_.o

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1._

TABLE 1 RECORDKEEPING INFORMATION COLLECTION BURDEN ASSOCIATED WITH NRC FORM 4 NUMBER OF NUMBER OF RECORDS /

HOURS /

ANNUAL ANNUAL RECORDKEEPERS RECORDKEEPER RECORD BURDEN COST Reactors 109 200 0.50 10,900

$ 1,427,900 Materials 191 3

0.50 287 35,875 Totals 300 22,373 11,187

$ 1,463,775 l

L 5

t

O TABLE 2 ESTIMATED ANNUALIZED COST TO THE NRC FOR REVIEW OF RECORDS AND CONDUCT OF INSPECTIONS ASSOCIATED WITH NRC FORM 4 FORM 4 NUMBER OF STAFF STAFF NRC COST LICENSEES HOURS / LICENSEE HOURS i R actors 109 1.00 109 14,279

Matiriils' 5,877 0,08 470 58,750 l NRC In-house Printing Costs 1_.

7 I Total 5,986 579 73,036 l

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