Question 408:
Background
10 CFR 20.2104 states that for each individual for whom
monitoring is required, the licensee must: 1.) Determine
the occupational radiation dose for the current year; and
2.) Attempt to obtain the records of lifetime cumulative
occupational radiation dose. "Records of lifetime
cumulative occupational radiation dose" refers to
occupational dose records prior to the current year. These
records are only used when implementing the planned special
exposure option. Some licensees may use prior year's TEDE
to control an individual's lifetime dose in compliance with
NCRP-91 recommendations or average annual exposure in
compliance with ICRP-60 recommendations. However, other
prior year's dose quantities such as shallow dose
equivalent (SDE) and lens (eye) dose equivalent (LDE) are
not useful to licensees and provide no additional
protection to individuals. Therefore, it was reasonable
and compliant to obtain only TEDE for prior years. Can a
licensee seek only to obtain the TEDE occupational dose
quantity for prior years to comply with the 20.2104 (a) (2)
requirement to "attempt to obtain the records of lifetime
cumulative occupational radiation dose"?
Answer: Yes, provided the licensee does not intend to
authorize planned special exposures for the individuals for
whom the licensee attempts to obtain only the TEDE. For
planned special exposures, the provisions of 10 CFR 20.1206
(e) that limit "lifetime" exposures apply to all
occupational doses having annual limits in 10 CFR 20.1201
(a) (TEDE, organ dose, eye dose, skin dose and extremity
dose), not just the TEDE. The reasons for this requirement
other than for use in cases of planned special exposures
are given in the answer to Question 142 (b). (Reference:
10 CFR 20.2104)