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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).