Health Physics Questions and Answers - Question 393

Question 393: Is it acceptable for regulatory purposes that occupational dose data that are being provided on a voluntary basis (i.e., the results of dose monitoring provided that is not required by regulation) be recorded and reported only in part? The purpose in asking this question is to establish whether or not the revised Part 20 provides the flexibility for licensees to record and report the results of "monitoring performed but not required" without also incurring implied requirements with regards to NRC Forms 4 and 5, or equivalents.The intent is to be able to provide useful information, that is not required by the regulation, on a voluntary basis to the worker and/or the NRC without unduly taxing available licensee resources. The specific example outlined below is provided to illustrate the more general issue of flexibility in recording and reporting occupational dose information that is not necessary for compliance with regulatory requirements.

Some licensees intended to voluntarily record and report the calculated Committed Effective Dose Equivalent (in rem), even when internal monitoring is not required by 10 CFR 20.1502. However, it is not intended that related radionuclide intake data will also be recorded and reported because of the resources which would be needed to track and transfer the specific radionuclide data to the NRC Form 5 or equivalent. For example, the licensee may only have tracked Derived Air Concentration hours (DAC-hrs), using the appropriate most restrictive DAC, without assessing specific radionuclide intakes. Accordingly, the "Intake" section of the NRC Form 5 would be noted as "NR" for "not required," and no specific radionuclide data would be recorded. However, the "Instructions and Additional Information Pertinent to the Completion of NRC Form 5," items 10A-D require that intake data be recorded "...for each radionuclide that resulted in an internal exposure recorded for the individual." The issue is that these instructions should not be considered applicable for recording and reporting performed that is not required. This approach to the partial recording and reporting of occupational dose data, when done on a voluntary basis, appears to be consistent with the flexibility that is implied in the revised Part 20 and related regulatory guidance. Note that Regulatory Guide 8.34, Section C.1.4, states "the results of monitoring provided when not required by 10 CFR 20.1502 are not subject to [the] dose recording requirements."

Answer: Yes. The instructions for Form 5 do not apply to recording and reporting that is not required by Part 20 and that is being done voluntarily. NRC encourages licensees to report CEDE voluntarily when monitoring is performed even though not required. If the intake information is omitted when reporting voluntarily, licensees should footnote the CEDE entry with a notation in the comments section that "monitoring was not required."

(Reference: 10 CFR 20.2206)