United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

U.S. Nuclear Regulatory Commission

Question 408:


10 CFR 20.2104 states that for each individual for whom

monitoring is required, the licensee must: 1.) Determine

the occupational radiation dose for the current year; and

2.) Attempt to obtain the records of lifetime cumulative

occupational radiation dose. "Records of lifetime

cumulative occupational radiation dose" refers to

occupational dose records prior to the current year. These

records are only used when implementing the planned special

exposure option. Some licensees may use prior year's TEDE

to control an individual's lifetime dose in compliance with

NCRP-91 recommendations or average annual exposure in

compliance with ICRP-60 recommendations. However, other

prior year's dose quantities such as shallow dose

equivalent (SDE) and lens (eye) dose equivalent (LDE) are

not useful to licensees and provide no additional

protection to individuals. Therefore, it was reasonable

and compliant to obtain only TEDE for prior years. Can a

licensee seek only to obtain the TEDE occupational dose

quantity for prior years to comply with the 20.2104 (a) (2)

requirement to "attempt to obtain the records of lifetime

cumulative occupational radiation dose"?

Answer: Yes, provided the licensee does not intend to

authorize planned special exposures for the individuals for

whom the licensee attempts to obtain only the TEDE. For

planned special exposures, the provisions of 10 CFR 20.1206

(e) that limit "lifetime" exposures apply to all

occupational doses having annual limits in 10 CFR 20.1201

(a) (TEDE, organ dose, eye dose, skin dose and extremity

dose), not just the TEDE. The reasons for this requirement

other than for use in cases of planned special exposures

are given in the answer to Question 142 (b). (Reference:

10 CFR 20.2104)

Page Last Reviewed/Updated Thursday, March 29, 2012