United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

U.S. Nuclear Regulatory Commission

Question 393: Is it acceptable for regulatory purposes

that occupational dose data that are being provided on a

voluntary basis (i.e., the results of dose monitoring

provided that is not required by regulation) be recorded

and reported only in part? The purpose in asking this

question is to establish whether or not the revised Part 20

provides the flexibility for licensees to record and report

the results of "monitoring performed but not required"

without also incurring implied requirements with regards to

NRC Forms 4 and 5, or equivalents. The intent is to be

able to provide useful information, that is not required by

the regulation, on a voluntary basis to the worker and/or

the NRC without unduly taxing available licensee resources.

The specific example outlined below is provided to

illustrate the more general issue of flexibility in

recording and reporting occupational dose information that

is not necessary for compliance with regulatory

requirements.



Some licensees intended to voluntarily record and report

the calculated Committed Effective Dose Equivalent (in

rem), even when internal monitoring is not required by 10

CFR 20.1502. However, it is not intended that related

radionuclide intake data will also be recorded and reported

because of the resources which would be needed to track and

transfer the specific radionuclide data to the NRC Form 5

or equivalent. For example, the licensee may only have

tracked Derived Air Concentration hours (DAC-hrs), using

the appropriate most restrictive DAC, without assessing

specific radionuclide intakes. Accordingly, the "Intake"

section of the NRC Form 5 would be noted as "NR" for "not

required," and no specific radionuclide data would be

recorded. However, the "Instructions and Additional

Information Pertinent to the Completion of NRC Form 5,"

items 10A-D require that intake data be recorded "...for

each radionuclide that resulted in an internal exposure

recorded for the individual." The issue is that these

instructions should not be considered applicable for

recording and reporting performed that is not required.

This approach to the partial recording and reporting of

occupational dose data, when done on a voluntary basis,

appears to be consistent with the flexibility that is

implied in the revised Part 20 and related regulatory

guidance. Note that Regulatory Guide 8.34, Section C.1.4,

states "the results of monitoring provided when not

required by 10 CFR 20.1502 are not subject to [the] dose

recording requirements."



Answer: Yes. The instructions for Form 5 do not apply to

recording and reporting that is not required by Part 20 and

that is being done voluntarily. NRC encourages licensees to

report CEDE voluntarily when monitoring is performed even

though not required. If the intake information is omitted

when reporting voluntarily, licensees should footnote the

CEDE entry with a notation in the comments section that

"monitoring was not required." (Reference: 10 CFR 20.2206).









Page Last Reviewed/Updated Thursday, March 29, 2012