The NRC Form 4 is used to record the summary of an occupational worker's cumulative occupational radiation dose, including prior occupational radiation exposure and the current year's occupational radiation exposure. The NRC Form 4 is used by licensees, and inspected by the 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 12,824 hours from the previous burden of 18,410 hours to 31,234 hours. This increase has three primary reasons: 1) the increase in the number of transient workers, 2) the increase in the burden estimate by 5 minutes based on the inclusion of the new EDX field on the form, and 3) the inclusion of 3rd party disclosure burden for the NRC Form 4.
In addition to the increase in the number of transient workers, licensees provide an NRC Form 4 (or equivalent) to their employees even if the employee has not participated in a planned special exposure (2007 final rule). Licensees provide an NRC Form 4 (or equivalent) to employees pursuant to 10 CFR 19.13.
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 28,780 transient workers. A review of recent REIRS data shows that as of June 2013, licensees maintained NRC Form 4, or its equivalent, records for an average of 33,518 transient workers annually.
⢠In addition to licensees in the REIRS system, in the current clearance, NRC has included the transient workers employed by 3,946 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 8,760 transient workers. The addition of these 3,946 sites to the estimates has greatly increased the estimated number of respondents.
The second reason for the increase in the estimated burden is an increase in the estimated time to complete NRC Form 4, from 30 minutes to 35 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 primarily use the NRC Form 4 to record an employee's cumulative exposure, the burden estimate was changed to 30 minutes. In this submission, the burden estimate has changed from 30 minutes to 35 minutes to include the new "EDEX" field (5 minutes x 4146 responses = an additional 345 hours of burden associated with this change). The addition of this field is needed so that licensees can comply with the definition of the total effective dose equivalent (TEDE) in 10 CFR 20.1003. The change in TEDE definition was part of the December 2007 final rule on 10 CFR Parts 19, 20, and 50 (72 FR 68043).
Finally, in addition to taking 35 minutes to complete the NRC Form 4, in this renewal, an additional 2 minutes per worker has been added to account for the time spent by licensees to provide a copy of the NRC Form 4 to their workers. The NRC staff estimates that licensees use an additional 2 minutes to print the form (or its equivalent) and provide it to their employees. This resulted in an additional 6,711 hours for this clearance.
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.
$138,230
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 Dose History
Final SS - NRC Form 4.doc
NRC Form 4, Cumulative Occupational Dose History