Health Physics Questions and Answers - Question 212
Question 212: A licensee makes a prospective determination that adult workers in Department W are not likely to receive doses in excess of 10% of the limits from external sources, so external dosimetry is not required by 20.1502. The workers in Department W complain when their TLD badges are taken away, so the licensee decides to leave them badged, but not to demonstrate compliance with the occupational dose limits of the revised Part 20.
(a) If an inspector finds the TLD badges being worn incorrectly or misused by Department W workers, can the licensee be cited?
(b) Must the doses be reported to the workers? If recording is required, must it be kept on Form 5?
(a) No citation against 10 CFR 20.1502 would be issued, provided the licensee can provide documentation that adequately supports the evaluation that monitoring of external dose is not needed. An inspector may bring the issue of incorrect wearing of dosimeters to the attention of the licensee, and may document this lack of good practice in the inspection report.
(b) No, reporting is not required. If the badges are not used for compliance with the regulations, the licensee is not required to record the results on NRC Form 5 or its equivalent.
(Reference: 10 CFR 20.1502, 10 CFR 20.2106)