A. INTRODUCTION
B. DISCUSSION
C. REGULATORY POSITION
   1.0  DETERMINATION OF MONITORING REQUIREMENTS
     1.1  IF MONITORING IS NOT REQUIRED
     1.2  IF MONITORING IS REQUIRED
     1.3  DOCUMENTATION OF EXPOSURE IN THE CURRENT YEAR
     1.4  RECORDS OF PRIOR EXPOSURE FOR PERSONS PARTICIPATING IN PLANNED SPECIAL EXPOSURES
     1.5  INDIVIDUALS WITH NO SOCIAL SECURITY NUMBER
   2.  RECORDS OF MONITORING RESULTS FOR INDIVIDUALS FOR WHOM MONITORING IS REQUIRED
     2.1  Multiple Badges
     2.2  DOSE CALCULATIONS FOR CDE AND TODE TO THE MAXIMALLY EXPOSED ORGAN
     2.3  DOSE TO THE EMBRYO/FETUS
     2.4  TRANSMITTAL OF REPORTS TO THE NRC
     2.5  ELECTRONIC REPORTING OF EXPOSURE DATA
D.  IMPLEMENTATION

APPENDIX A

REGULATORY ANALYSIS

Section 20.1502 of 10 CFR Part 20, "Standards for Protection Against Radiation," requires licensees to provide radiation monitoring for all occupationally exposed individuals who might receive a dose in excess of 10 percent of the limits in 10 CFR 20.2101, 20.1207, or 20.1208. In 10 CFR 20.2106, licensees are required to maintain records of the radiation exposures of all individuals for whom personnel monitorin is required (pursuant to 10 CFR 20.1502). According to 10 CFR 20.2104, the dose in the current monitorin year must be determined for all persons who must be monitored, and this information must be recorded on NRC Form 4 or equivalent. In addition,10 CFR 20.2104 requires that, prior to allowing an individual to participate in a planned special exposure, records of all prior exposures must be acquired. Records of prior dose must be maintained on NRC Form 4 or its equivalent. Further, 10 CFR 20.2206 requires certain licensees to submit an annual report to NRC or the results of individual monitoring.

This guide describes an acceptable program for the preparation, retention, and reporting of records of occupational radiation exposures. It includes copies of NRC Forms 4 and 5 and detailed instructions on completing them.

Any information collection activities mentioned in this regulatory guide are contained as requirements in 10 CFR Part 20, which provides the regulatory basis for this guide. The information collection requirements in 10 CFR Part 20 have been cleared under OMB Clearance No. 3150-0014. The existing requirements for NRC Forms 4 and 5 were approved by the Office of Management and Budget under approval numbers 3150-005 and 3150-006. The amended information collection requirements reflected in this guide and contained on the revised NRC Forms 4 and 5 will not become effective until after they are approved by the Office of Management and Budget. Notice of OMB approval will be published in the Federal Register.

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This guide is structured to reflect the process a licensee would go through in deciding whether or not monitoring for occupational exposure to radiation is required under the revised 10 CFR Part 20. The guide goes on to describe the acceptable methods for determination of prior exposures, records of monitoring provided, and reporting that are needed to comply with 10 CFR Part 20. NRC Forms 4 and 5 are provided. A format for electronically reporting exposure data to NRC is provided in Appendix A.

In order to avoid confusion with the acronym for effective dose equivlaent (EDE), the abbreviation LDE is used to represent the eye (lens) dose equivaltent, as defined int 10 CFR Part 20. The term total organ dose equivalent (TODE) has been added, and it means the sum of the deep dose equivalent and the committed dose equivalent to the organ receiving the highest dose.

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According to 10 CFR 20.1502, if an adult is likely to receive in 1 year a dose greater than 10 percent of any applicable limit, monitoring is required. The licensee should perform an evaluation of the dose the individual is likely to receive prior to allowing the individual to receive the dose. This evaluation need not be made for every individual; evaluations can be made for employees with similar job functions or work areas. Further guidance on evaluating the need to provide monitoring is provided in Regulatory Guide 8.34, "MONITORING CRITERIA AND METHODS TO CALCULATE OCCUPATIONAL DOSES".

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If this prospective evaluation shows that the individual is not likely to exceed 10 percent of any applicable limit, there are no recordkeeping or reporting requirements in regard to the individual's exposure. For individuals who received exposure at other facilities in the current year, the previous dose need not be considered in this prospective evaluation. Only dose that could be received at the facility performing the evaluation need be considered when determining the need for monitoring, and therefore, recordkeeping and reporting requirements. If it is determined that monitoring is not required and a subsequent evaluation shows that the 10 percent threshold has or will be exceeded, the dose received when monitoring was not provided should be estimated, recorded, and reported. These estimates can be based on any combination of work location radiation monitoring or survey results, monitoring results of individuals in similar work situations or other estimates to produce a "best estimate" of the actual dose received.

If monitoring is not required to demonstrate compliance with all limits but is required relative to one or more specific limits, the licensee should enter "NM" for "Not Monitored" in the blocks on NRC Forms 4 and 5 to indicate the areas that were not monitored (e.g., extremity or skin doses). Where monitoring was provided but not measurable, the licensee should enter "ND" for "Not Detectable".

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If the prospective evaluation shows that the individual is likely to exceed 10 percent of an applicable limit, monitoring is required (10 CFR 20.1502). Reporting of the results of monitoring performed regardless of the actual dose received, is required by 10 CFR 20.2206(b).

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For those individuals for whom monitoring is required, determination of current year exposure at other facilities is required by 10 CFR 20.2105(a). To document the determination of current year exposure, the individual to be monitored must provide an NRC Form 4 signed by the individual or, a written statement that includes the names of all facilities which provided monitoring for occupational exposure to radiation during the current year and an estimate of the dose received. Although not required by the regulations, it is considered a good health physics practice to verify the information provided by the individual. Verification may be documented with:

1. An NRC Form 5 for each listed monitoring period,
2. Electronic, telephone or facsimile transfer of dose data provided by licensees listed on the written statement, or
3. An NRC Form 4 countersigned by a licensee or current employer.

In addition, 10 CFR 20.2104(a)(2) requires that licensees attempt to obtain the records of lifetime cumulative occupational radiation dose. To demonstrate compliance with this requirement, the individual to be monitored may provide a written estimate of the cumulative lifetime dose or an up-to-date NRC Form 4 signed by the individual. This information need not be verified so long as the individual does not participate in a planned special exposure.

NRC Forms 4, 5, and termination letters or reports, which report the results of monitoring prior to implementation of the revised 10 CFR Part 20, may be used without recalculating dose according to the requirements of the revised 10 CFR Part 20. For the purpose of assessing prior dose, whole body dose in rem, as reported on the old NRC Forms 4 and 5 (1981 or earlier), can be considered equivalent to total effective dose equivalent (TEDE).

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If there are any periods of exposure during the life of the monitored individual that have not been determined and documented, participation in a planned special exposure is not permitted. Acceptable documentation of prior exposure is similar to that required for documenting current-year exposure. Alternately, the licensee may request in writing that a report of the monitored individuals exposure history be provided by the NRC. To request an exposure history, a licensee may send a request signed by the monitored individual to:

     REIRS Project Manager
     Office of Nuclear Regulatory Research
     U. S. Nuclear Regulatory Commission
     Washington, DC 20555

The request should contain the social security number (or other uniquely identifying number) of the monitored individual authorizing release of the information and the name and address of the person or licensee to whom the report should be sent. The REIRS database contains only reports submitted by the seven classes of licensees required by 10 CFR Part 20 to report occupational exposures. Any missing monitoring periods should be obtained directly from licensees.

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Doses to individuals who do not have a social security number, such as citizens of foreign countries, should be reported using another unique identification number. It is important to record the type of identification used in the data block labeled "ID type" which follows the "Identification Number" data block on NRC Form 4 and 5. The appropriate code listed below should be inserted in the blank labeled ID Type.

ID TYPE	CODE
U. S. Social Security Number	SSN
Passport Number	PPN
Canadian Social Insurance Number	CSI
Work Permit Number	WPN
INDEX Identification Number	IND
Other	OTH

The use of licensee generated identification numbers should be avoided whenever possible.

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The preparation of NRC Form 5 with the information clearly and legibly shown, or the collection of all the information requested by NRC Form 5 using paper or electronic media (see Appendix A), is required by 10 CFR 20.2106. Such a record must be maintained for each individual for whom personnel monitoring is required by 10 CFR 20.1502. In addition, certain classes of licensees report the results of this monitoring to NRC pursuant to 10 CFR 20.2206 either by submitting copies of NRC Form 5 or by transmitting the required information to NRC through electronic media. This report is filed annually. Instructions and additional information pertinent to each item are contained on Form 5.

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Further guidance on interpreting the results of multiple dosimetric devices placed at different locations within a single dose category, is provided in Regulatory Guide 8.34, "MONITORING CRITERIA AND METHODS TO CALCULATED OCCUPATIONAL DOSES".

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Licensees are required by 10 CFR 20.2106(a)(6) to record the total organ dose equivalent (TODE) which is the sum of the deep dose equivalent (DDE) and the committed dose equivalent (CDE) to the organ receiving the highest dose. Organ doses need not be calculated if the committed effective dose equivalent (CEDE) does not exceed 1 rem and there are no overexposures in any dose category within the monitoring year, including doses previously reported by other licensees. In this case, the licensee may record "NC" for "Not Calculated" in items 16 and 18 on NRC Forms 4 and 5. If during the course of the year, the dose to date for the year exceeds 1 rem CEDE or the individual receives an overexposure in another dose category, the CDE to the maximally exposed organ must be calculated, recorded and reported. When CDE and TODE to the maximally exposed organ must be calculated, the licensee should refer to Regulatory Guide 8.34, "MONITORING CRITERIA AND METHODS TO CALCULATE OCCUPATIONAL DOSES".

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A declared pregnant worker is a worker who has voluntarily informed her employer in writing of her pregnancy and the estimated month and year of conception. The embryo/fetus dose for the entire gestation period must be recorded (10 CFR 20.2106(e)),but need not be included on NRC Forms 4 and 5. Multiple records are not required in the case of twins, triplets, etc. Any dose measured to demonstrate compliance with 10 CFR 20.1208 must be recorded.

Licensees should be sensitive to the issue of personal privacy with regard to embryo/fetus dose. If requested by the monitored woman, a letter report may be provided to subsequent licensees to document prior embryo/fetus dose. Further guidance on assessing dose to the embryo/fetus is provided in Regulatory Guide 8.36, "RADIATION DOSE TO THE EMBRYO/FETUS".

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Certain licensees are required by 10 CFR 20.2206(c) to submit reports of monitoring for the previous year to NRC on or before April 30. These reports should be sent to:

     REIRS Project Manager
     Office of Nuclear Regulatory Research
     U.S. Nuclear Regulatory Commission
     Washington, DC 20555

According to 10 CFR 20.2206(b), "... the licensee shall use Form NRC 5 or electronic media containing all the information required by Form NRC".

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Licensees are encouraged to record and report these data electronically. The format for reporting radiation exposure data in an electronic, machine-readable format is provided in Appendix A of this guide.

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The purpose of this section is to provide information to applicants regarding the NRC staff's plan for using this regulatory guide.

Except in those cases in which an applicant or licensee proposes an acceptable alternative method for complying with specified portions of the Commission's regulations, the methods described in this guide will be used in the evaluation of applications for new licenses or license renewals and for evaluating compliance with 10 CFR Part 20.1001-20.2401.

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APPENDIX A.

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A separate regulatory analysis was not prepared for this regulatory guide. The regulatory analysis prepared for 10 CFR Part 20, "Standards for Protection Against Radiation" (56 FR 23360), provides the regulatory basis for this guide and examines the costs and benefits of the rule as implemented by the guide. A copy of the "Regulatory Analysis for the Revision of 10 CFR Part 20" (PNL-6712, November 1988), is available for inspection and copying for a fee at the NRC Public Document Room, 2120 L Street N.W., Washington, DC, as an enclosure to Part 20.

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