Question 398: Regulatory Guide 8.7 (Section C.2.2) states
that "if during the course of the year the dose to date for
the year exceeds 1 rem CEDE [committed effective dose
equivalent] or the individual receives an overexposure in
another dose category, the CDE [committed dose equivalent]
to the maximally exposed organ must be calculated, recorded
and reported." If an individual arriving from work at
another (previous) licensee's facility within the current
year has a CEDE that exceeds 1 rem, does the guidance imply
requirements for monitoring, recording or reporting of
internal dose, even if the present licensee's prospective
evaluation shows that the individual is not "likely to
exceed" 10% of an annual limit on intake (ALI)?
Answer: For the situation described in the question, the
quoted section of the Regulatory Guide 8.7 indicates that
the previous licensee should have calculated, recorded, and
should report the CDE to the maximally exposed organ.
However, as indicated in Section C.1.1 of Regulatory Guide
8.7, in performing the prospective evaluation (under 10 CFR
20.1502) to determine if monitoring is required "for
individuals who received exposure at other facilities in
the current year, the previous dose need not be considered
in prospective evaluation. Only the dose that could be
received at the facility performing the evaluation need be
considered when determining the need for monitoring and,
therefore, the recordkeeping and reporting requirements."
(References: 10 CFR 20.1502, Regulatory Guide 8.7).