United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

U.S. Nuclear Regulatory Commission

Question 41: Licensee A questions a new employee about

outside employment. The employee states that he is only

working at that facility. After 3 months, the employee

starts working, in the evenings, at another licensed

facility (Licensee B). The employee does not tell A about

B; therefore, Licensee A does not take the exposure

received by the employee at facility B into account when he

calculates the employees annual total effective dose

equivalent (TEDE). Will Licensee A be in noncompliance for

not knowing about the dose received by the employee at

Licensee B? If licensee A was made aware of the exposure

at Licensee B after-the-fact, must Licensee A go back and

account for this exposure when calculating TEDE? If

Licensee A finds out about the worker's exposure at

Licensee B after the year's end, and if the sum of the

exposures exceeded the annual limit, is Licensee A

obligated to record and report the overexposure and deduct

it from the 25 rem lifetime PSE limit?



Answer: In order to meet the requirements of 10 CFR

20.1201 (f), the licensee must establish some means to have

each employee inform the licensee when that employee is

receiving occupational dose from sources outside the

licensee's control. It is not sufficient merely to ask

each employee once (as in the example), with no continuing

provision for employee notification. Assuming that

Licensee A made no provision for learning of the new

employees subsequent concurrent employment in other jobs

that resulted in occupational dose, Licensee A would be in

noncompliance for not determining the dose received on the

job at Licensee B. If Licensee A was made aware of the

exposure at Licensee B after-the-fact, Licensee A must go

back and account for this exposure when calculating TEDE.

If Licensee A finds out about the worker's exposure at

Licensee B after year's end, and if the sum of the

exposures exceeded the annual limit, Licensee A is

obligated to record and report the overexposure and to

deduct it from the 25 rem lifetime PSE limit. Although the

question and preceding answer are provided in terms of

Licensee A's responsibilities with respect to doses

received at Licensee B's facility, Licensee B has the same

responsibilities with respect to doses received at licensee

A's facility. (Reference: 10 CFR 20.1201)









Page Last Reviewed/Updated Thursday, March 29, 2012