Guidance - Use of NRC Form 4 - Listing of Exposure Periods
See the Interpretive Guide in IE Manual entitled as above and dated November 1, 1978. It provides guidance on the use of NRC Form 4 with respect to listing periods of exposure at different licensee's facilities while employed by another single employer who is not necessarily a licensee.
The health physics position was written in the context of 10 CFR 20.102, but it also applies to "new" 10 CFR 20.2104. The Westinghouse in-service inspection division inquired about the listing of periods of exposure on NRC Form 4 for radiation work conducted at many power plant facilities while employed only by Westinghouse. Westinghouse maintains their own Form 4's, recording the highest exposure received for each plant where work was conducted by comparing the facility badge results with their own.
One power plant licensee required a record of each period of exposure for each of the other facilities where inservice work was performed. This would have resulted in several pages for each Form 4 since as many as 30 or more facilities would be involved every six months per man.
Instead, Westinghouse requested that they be permitted to continue to add the cumulative exposures for each place where work was conducted and take the result to the facilities as one total exposure to be used as one entry for the Form 4.
On August 8, 1978, the views of OELD were requested on whether item 5 on NRC Form 4, "name and address of employer" [or item 7 on an up-to-date NRC Form 4 (6-92), "name of licensee or facility not licensed by NRC that provided monitoring"] means each employer or each separate facility where an exposure occurred.
In a written opinion, OELD stated that the term "employer" means just that. Thus, only one entry on the Form 4 is necessary for the exposures received during the time period for which the employer did not change. This view is consistent with the purpose of Form 4 which is to provide a licensee with a history of the individual's exposure. The circumstances of the previous exposures (i.e., numerous small exposures, a few large exposures, location, etc.) is irrelevant information to the licensee as such information is not necessary for the determination of the accumulated dose.
Regulatory references: 10 CFR 20.102, 10 CFR 20.2104
Subject codes: 2.1, 8.1, 8.7