United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

U.S. Nuclear Regulatory Commission

Question 401: NRC Form 5 (Item No. 20) provides for the

signature of the licensee's authorized representative

responsible for the data and is not noted as "optional" as

is the licensee signature block on NRC Form 4. Appendix A

of Regulatory Guide 8.7, Rev. 1, "Instructions for

Recording and Reporting Occupational Radiation Exposure

Data," provides for the licensee to sign the transmittal

letter for electronic transmission of exposure data to the

NRC and thereby certify the database. If a letter

certifying the database is maintained on file, can the

licensee so note NRC Form 5's which are generated from the

database, e.g., "signature on file," rather than signing

each individual NRC Form?" In particular, this would

facilitate the providing of individual exposure reports

annually to each worker, as required by 10 CFR Part 19.

Answer: Yes, if the exposure data are reported to the NRC

by electronic transmission, the Form 5 exposure report

prepared from the data base and provided to the worker need

not be signed ("signature on file" is acceptable). However,

if the exposure data are provided to the NRC on Form 5,

rather than by electronic transmission, the form must be

signed. As noted in the question, the signature block on

Form 5 is not optional. (References: 10 CFR 20.2106, 10

CFR 20.2206, Regulatory Guide 8.7, Rev. 1).

Page Last Reviewed/Updated Thursday, March 29, 2012