U.S. Nuclear Regulatory Commission

Guidance - Use of NRC Form 4 - Listing of Exposure Periods

HPPOS-050 PDR-9111210219

Title: 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

Applicability: All