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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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
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