Office Of Management And Budget 83

OFFICE OF MANAGEMENT AND BUDGET 83-I

SUPPORTING STATEMENT

Occupational Radiation Protection

OMB Control Number: 1910-5105

This supporting statement provides information regarding the Department of Energy (DOE) Paperwork Reduction Act Submission request pertaining to occupational radiation protection. The numbered questions correspond to the order shown on the Office of Management and Budget (OMB) Form 83-I, “Instructions for Completing OMB

Form 83-I.”

1. Explain the circumstances that make the collection of information necessary. DOE has amended title 10, Code of Federal Regulations, part 835 (10 CFR 835), “Occupational Radiation Protection,” including provisions that impose collections of information. These regulations were promulgated under authority of the Atomic Energy Act of 1954, 42 U.S.C. § 2201, and the Department of Energy Organization Act,

42 U.S.C. §§ 7191 and 7254. Part 835 codifies requirements currently used within the DOE complex under various contractually implemented directives. DOE has determined that these requirements must be codified to assure that occupational radiation protection programs are adequate and, if violated, would provide the basis for assessment of civil penalties under the Price Anderson Amendments Act of 1998, Publication L, Number 100-408. Although some of the collections of information included in this Paperwork Reduction Act Submission may be covered by existing approved collections of information for DOE’s worker health and safety program, DOE has decided to consolidate all collections of information pertaining to occupational radiation protection in one submission.

2. Indicate how, by whom, and for what purpose the information is to be used. As noted above in question 1, the information obtained by DOE contractors is used to manage radiation protection programs, to provide information to contractors’ employees, and to permit oversight of their programs by DOE management.

Specifically, information collections are required in the following areas:

a. Radiation Protection Program (RPP) Submissions (§835.101): Part 835 requires contractors performing DOE activities to prepare and submit an RPP to DOE for approval, and submit updates of the RPP program to DOE for approval. RPP establishes the commitment of the contractor to comply with the provisions of 10 CFR 835, specifies the manner in which the contractor proposes to comply with these provisions, also specifies those provisions that are not considered applicable and the reason for this determination, and finally indicates provisions for which regulatory relief (i.e., an exemption to 10 CFR 835) is being sought. In the sense that it established the framework for implementing and complying with 10 CFR 835, RPP is analogous to a Nuclear Regulatory Commission license. The DOE contractor used RPP as the overarching plan under which it operates its RPP. DOE approves RPP to ensure the contractors’ commitments are consistent with DOE expectation and requirements and to ensure that these commitments are consistent with resources allocated to implement RPP.

b. Recordkeeping Requirements: Part 835 requires contractors to keep records of planned special exposures to radiation, individual monitoring records, certain workplace monitoring records, and training and other administrative records. These records comprise the bulk of the documentation needed to assess the status of RPP at a DOE site.

(1) Individual monitoring records (§835.702) document the radiation exposure received by DOE contractor employees on a DOE site as a result of radiological activities. Such records are obtained either from measurements taken by radiation detecting devices (dosimeters) worn by individuals or by measurement of radioactive materials taken into the body. Since the purpose of RPP required by part 835 is to control exposure to radiation, individual monitoring records form the primary basis for assessing the success of DOE RPPs by first demonstrating that exposures are below the legal limits and that they are as low as reasonably achievable. In addition, these records are monitored to alert DOE contractors to any adverse trends in radiation protection.

(2) Workplace monitoring records (§835.703) are records of the measurements of the ambient radiation levels or radioactive materials levels in the workplace. These records document the extent to which radiation and radioactive material are being controlled in the workplace environment. Workplace monitoring records differ from individual monitoring records in that the measuring device is not located on an individual and, thus, in many cases, does not provide an accurate measure of the radiation exposure received by an individual. However, these measurements serve as precursors of serious radiological events, such as major releases of radioactive materials, and as a basis for estimating radiation exposures to individuals who are not individually monitored for radiation.

(3) Training and other administrative records (§835.704) consist of those portions of RPP that institute those practices needed to control worker exposure to radiation and radioactive materials. In addition to records documenting the training received by individuals who could be exposed to radiation, part 835 requires records to document the results of internal RPP audits and other reviews of program content and implementation; written declarations of pregnancy; and changes in equipment, techniques, and procedures used for monitoring in the workplace.

(4) Records for release of materials and equipment from radiological areas (§835.1101) are intended to document the radiological measurements used to demonstrate the amount of residual radioactive contamination on these items that are below the specified release criteria. Because members of the public could come into contact with these items, these records are important in demonstrating that such items do not pose a hazard to members of the public.

(5) Records of planned special exposures (§§835.204) do not have any significant impact since the occurrence is planned. Special exposures are very unusual; none have occurred in the last 10 years.

c. Reporting Requirements (§835.801): Part 835 requires contractors to provide radiation dose information to monitored individuals and provide this information to individuals upon termination of employment and on other occasions. On an annual basis, each DOE facility must provide each individual monitored for occupational exposure to radiation a radiation dose report of the occupational exposure received at the facility. Upon request from an individual terminating employment, a DOE facility must provide that individual records of the individual’s radiation exposure. And whenever DOE requirements (other than 10 CFR 835) require reports of an individual’s exposure data to DOE, a report of this information must be sent to that individual.

If these collections were not made, it would be very difficult, if not impossible: (a) for the Department and its contractors to demonstrate that workers were being adequately protected from exposure to radiation; and (b) for both the DOE contractor and DOE program offices to manage and provide oversight of RPPs.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology. Within existing budget and resource constraints, Department program managers and contractors continually work to apply the latest appropriate-level information collection technologies and improve the timeliness and usefulness of management information being collected. This includes automation of previously manual processes where appropriate.

4. Describe efforts to identify duplication. Since this information collection primarily applies to management of RPPs in DOE, meaningful duplication in other Agencies is unlikely.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden. The impact of collecting this information from small businesses is considered in the development of the contract requirements and documents and is minimized to the extent permitted by applicable statutory requirements and other legal and management constraints.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden. The frequency of collection is dictated by sound health, safety, and management practice. When any of these conditions change to permit reduction of the frequency of information collections, the reduction is encouraged. Reports to workers are primarily made on an annual or situational basis. Reporting criteria is specified by statute. No reports are required to be sent to DOE.

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines. This collection of information has been reviewed and justified by departmental management requirements, statutes, external regulations, interagency reporting requirements, departmental orders, or other internal DOE requirements and is collected in a manner consistent with 5 CFR 1320 guidelines.

8. If applicable, provide a copy and identify the date and page number of Publication in the Federal Register of the Agency’s notice, required by 5 CFR 320.8 (d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken in response to the comments. Specifically address comments received on cost and hour burden. Describe efforts to consult with persons outside DOE.

No comments received.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees. Only contractors or grantees receive remuneration from the Department.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. Where confidential information is involved in an information collection, the provisions for dealing with this confidential information are set forth in the contract documents, and the related departmental regulations are normal to the handling of management and program information by the Department.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. Per departmental regulations, any request for information on an individual’s exposure to radiation is handled in accordance with the Privacy Act (5 U.S.C.552a). Other than data on individual exposures, there is no information collected that is of a sensitive or personal nature.

12. Provide estimates of the hour burden of the collection of information. The statement should indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. The estimated burden, expressed in burden hours, is the sum of the burden reported by departmental elements and field organizations as compiled from their respective contractors or estimated by expert personnel familiar with these collections. Computations are based on the number of respondents times the annual reporting frequency times the hours per each response. Annual recordkeeping burden is determined by multiplying the number of recordkeepers by the estimated hours per recordkeeper used to maintain the records on an annual basis. Please note that all calculations have been rounded to the nearest whole number.

Using these calculations, the annual burden for occupational radiation protection is:

Collection burden . . . . . . . . . . . . . . . . . . . . . . . . 40,000

Recordkeeping burden . . . . . . . . . . . . . . . . . . . . 10,000

Total annual burden . . . . . . . . . . . . . . . . . . . . . . 50,000

13. Provide an estimate for the total annual cost burden to respondents or recordkeepers resulting from the collection of information. The estimated annualized cost to contractor respondents for radiation protection data is based on an assumed standard cost of $100.00 per burden hour. This standard cost was provided by the Business Council on the Reduction of Paperwork based on industry experience. Using these standard costs, the annualized cost for respondents or recordkeepers for occupational radiation protection data is:

Business cost, at $100.00/burden hour: $5,000,000

14. Provide estimates of annualized cost to the Federal Government. As noted above in question 1, the Department is not involved in the collection or maintenance of this data. Accordingly, there is no cost to the Department.

15. Explain the reasons for any program changes or adjustments reported in

Items 13 (or 14) of OMB Form 83-I. No changes.

16. For collections whose results will be published, outline the plans for tabulation

and publication. This information collection will not be published for statistical use.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons why display would be inappropriate. The Department is not seeking approval to not display the expiration date for OMB approval of this information collection.

18. Explain each exception to the certification statement identified in Item 19 of OMB Form 83-I. This collection of information has been reviewed and justified by departmental management requirements, statutes, external regulations, interagency reporting requirements, departmental orders or other internal DOE requirements and meets the requirements listed in the “Certification for Paperwork Reduction Act Submissions.”

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