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.
table that charts list comparision
Inventory as of this Action
Requested
Previously Approved
03/31/2014
36 Months From Approved
03/31/2011
3,848
0
257
18,410
0
64
0
0
0
NRC Form 4 is used to record the summary of a radiation workerÂs cumulative occupational radiation dose, including prior occupational radiation exposure and the current yearÂs 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.
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 employeeÂs 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).
$122,846
No
No
No
No
No
Uncollected
Doris Lewis 301 251-7559
Reginfo record details
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:
(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;
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.
Form NRC Form 4 NRC Form 4, Cumulative Occupational Exposure History
Final Form 4 SS 102810.doc
NRC Form 4, Cumulative Occupational Exposure History