U.S. Nuclear Regulatory Commission

Question 51: Do 10 CFR 20.2104 (a), 10 CFR 20.2104 (d) and

Footnote 4 to 20.2104 (d) mean that a licensee must

"backfit" effective dose equivalents (EDE) for individuals

who were occupationally exposed before implementation of

the revised Part 20?

Answer: No. Such backfitting is not required. However,

licensees may, if they so desire, make estimates of the EDE

and committed EDE based on the occupational dose records

available for this period. (References: 10 CFR 20.2104

(a), 10 CFR 20.2104 (d), 10 CFR 20.2104 (d) Footnote 4 )