Information Notice No. 86-41: Evaluation of Questionable Exposure Readings of Licensee Personnel Dosimeters

                                                         SSINS No : 6835  
                                                         IN 86-41          

                                UNITED STATES
                        NUCLEAR REGULATORY COMMISSION
                    OFFICE OF INSPECTION AND ENFORCEMENT
                           WASHINGTON, DC 20555

                                June 9, 1986

Information Notice No. NO 86-41:   EVALUATION OF QUESTIONABLE EXPOSURE 
                                   READINGS OF LICENSEE PERSONNEL DOSIMETERS

Addressees: 

All byproduct material licensees 

Purpose: 

This notice is (1) to alert licensees of cases reported to the NRC where 
questionable exposure readings have been recorded for personnel dosimetry 
devices used by licensee personnel and (2) to provide recipients with 
information on evaluation methodology used by some licensees to evaluate and
report such readings It is expected that recipients will review this notice
for applicability to their facilities However, suggestions contained in 
this information notice do not constitute NRC requirements; therefore, no 
specific action or written response is required 

Description of Circumstances: 

The NRC has encountered a number of cases in which by product material 
licensees have received TLD or film badge reports showing a questionable 
high-exposure reading Licensees' evaluations found such readings to be 
erroneous since the exposure purportedly was recorded on the dosimeter while
it was not being worn by the individual The majority of these cases have 
involved dosimeters that were inadvertently left in high-radiation areas or 
left for long periods of time near byproduct material storage containers 
Notwithstanding the requirements for proper use of personnel dosimeters, 
many licensees do not know how these cases should be evaluated and reported 
to NRC 

Discussion: 

Surveys are necessary to evaluate questionable exposure readings on licensee
personnel dosimeters Improper evaluation of such readings may lead to a 
citation for violation of an NRC requirement and possible enforcement 
action Byproduct material licensees should be aware of their 
responsibilities with respect to 10 CFR Part 20101, which requires that 
licensees control radiation exposure to individuals so that no individual 
receives an exposure in excess of the radiation dose standards 10 CFR 
20201 requires that licensees make or cause to be made such surveys as may 
be necessary for the licensee to comply with the radiation dose standards 
specified in 10 CFR 20101 and that the surveys are reasonable under the 
circumstances to evaluate the extent of radiation hazards that may be 
present As used in the regulations, "survey" means an  

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                                                             IN 86-41      
                                                             June 9, 1986  
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evaluation of the radiation hazards incident to the production, use, 
release, disposal, or presence of radiation under a specific set of 
conditions In some cases, the evaluation may be supported by a physical 
survey 10 CFR 20401 requires each licensee to maintain records showing the 
results of surveys required by 10 CFR 20201 

The information that has been documented by some licensees that meets NRC's 
requirements for a reasonable evaluation of questionable exposure readings 
is as follows: 

o    Signed and dated statements from individuals present at the time of the
     possible false exposure, including helpers or witnesses Such 
     statements have been written by the individuals independently and have 
     included all pertinent information known by them 

o    Documentation of the Radiation Safety Officer's evaluation and 
     conclusions, including results of interviews of personnel involved, 
     records of telephone conversations, examination of equipment (when 
     applicable), surveys, and corrective action to prevent recurrence 

o    Estimation of the actual exposure by measurement, calculation, or other
     appropriate methods 

In addition to the above, reviews of existing documentation have been made 
to ensure that records are complete and up to date Such documents include 
utilization logs, dosimeter logs, exposure files, equipment maintenance 
checks, calibrations, and training 

If a Radiation Safety Officer's evaluation of a high TLD or film badge 
reading cannot conclusively prove that the reading was erroneous, a report 
is made to the NRC in accordance with 10 CFR 20403 or 20405 

No written response to this information notice is required If you have any 
questions regarding this matter, please contact the Regional Administrator 
of the appropriate NRC regional office or this office 


                                   James G Partlow, Director 
                                   Division of Inspection Programs 
                                   Office of Inspection and Enforcement 

Technical Contact:  H Karagiannis, IE 
                    (301) 492-9655 

Attachment:    List of Recently Issued IE Information Notices