NRC Form 4, Cumulative Occupational Exposure History

Forms and Documents

Document Name	Status
Form NRC Form 4 NRC Form 4, Cumulative Occupational Exposure History Form and Instruction	Modified
Final Form 4 SS 102810.doc Supporting Statement A	2010-10-28

IC Document Collections

IC ID	Document Title	Status
33127	NRC Form 4, Cumulative Occupational Exposure History Form and Instruction	Modified

ICR Details

OMB Control No: 3150-0005	ICR Reference No: 201006-3150-005
Status: Historical Active	Previous ICR Reference No: 200903-3150-001
Agency/Subagency: NRC	Agency Tracking No:
Title: NRC Form 4, Cumulative Occupational Exposure History
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved without change	Conclusion Date: 03/22/2011
	Date Received in OIRA: 10/28/2010
Terms of Clearance: In accordance with 5 CFR 1320, the information collection is approved for 3 years. Upon resubmission, the agency should clarify which costs are directly related to personnel costs.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	03/31/2014	36 Months From Approved	03/31/2011
Responses	3,848	0	257
Time Burden (Hours)	18,410	0	64
Cost Burden (Dollars)	0	0	0

---

Abstract: NRC Form 4 is used to record the summary of a radiation worker’s cumulative occupational radiation dose, including prior occupational radiation exposure and the current year’s occupational radiation exposure. NRC Form 4 is used by licensees, and inspected by NRC, to ensure that occupational radiation doses do not exceed the regulatory limits specified in 10 CFR 20.1501.

---

Authorizing Statute(s): PL: Pub.L. 83 - 703 1-311 Name of Law: Atomic Energy Act
  

Citations for New Statutory Requirements: None

---

Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

---

Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	75 FR 44815	07/29/2010
30-day Notice:	Federal Register Citation:	Citation Date:
	75 FR 66394	10/28/2010
Did the Agency receive public comments on this ICR? No

---

Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
NRC Form 4, Cumulative Occupational Exposure History	NRC Form 4	Cumulative Occupational Exposure History

---

ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	3,848	257	0	0	3,591	0
Annual Time Burden (Hours)	18,410	64	0	0	18,346	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: The estimated burden has increased by 18,346 hours from the previous burden of 64 hours to 18,410 hours. This increase is due to the fact that licensees have continued to voluntarily provide NRC Form 4 to their employees, despite a 2007 final rule that eliminated the requirement to provide this information unless the employee was involved in a planned special exposure. A review of the REIRS data since both rules went into effect shows that NRC licensees are continuing to provide NRC Form 4 to their employees, despite the fact that it is no longer required (unless there is a planned special exposure). As a result, the NRC has not seen a decrease in burden as anticipated. In fact, due to an increase in the number of transient workers, the number of hours associated with NRC Form 4 is anticipated to be higher in the current renewal cycle than in previous cycles: • In the previous clearance (prior to the 2007 final rule), based on REIRS data, NRC estimated that licensees would maintain NRC Form 4, or its equivalent, records for 20,024 transient workers. A review of recent REIRS data shows that as of June 2008, licensees maintained NRC Form 4, or its equivalent, records for an average of 28,780 transient workers annually. • In addition to licensees in the REIRS system, in the current clearance, NRC has included the transient workers employed by 3,654 additional materials licensees. These licensees are not subject to 20.2206(a); therefore, their data is not included in the REIRS system. These licensees were not included in the estimates in the previous clearance; however, NRC inspection findings indicate that these licensees are voluntarily maintaining NRC Form 4 for their workers. The NRC estimates that these licensees are maintaining Form 4 for an additional 8,019 transient workers. The addition of these 3,654 sites to the estimates has greatly increased the estimated number of respondents. The final reason for the increase in the estimated burden is an increase in the estimated time to complete NRC Form 4, from 15 minutes to 30 minutes. Prior to the 2007 final rule, the estimate to complete NRC Form 4 was 30 minutes. Because it takes less time to complete NRC Form 4 for a planned special exposure, the burden was reduced to 15 minutes. However, because licensees are now primarily using the NRC Form 4 to record an employee’s cumulative exposure, the burden estimate has been changed to 30 minutes. It should be noted that the NRC does not anticipate any planned special exposures during the next three years; therefore, all licensees that use the NRC Form 4 for the next three years will be on a voluntary basis. As a result of these rules, the burden on record for NRC Form 4 is: 15 minutes per response x 257 respondents x 1 response per respondent = 64.25 hours (rounded to 64 hours).

---

Annual Cost to Federal Government: $122,846

Does this IC contain surveys, censuses, or employ statistical methods? No

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

---

Common Form ICR:  No

---

On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 10/28/2010

---