Question 64: The following question relates to the
requirements of 10 CFR 20.2104 (a) (2), 10 CFR 20.2104 (c),
and 20.2104 (d) concerning records of lifetime cumulative
occupational dose. Assuming that (1) the licensee has
obtained, by electronic media, a printed report (or
reports) containing the Form 4 information on an
individual's lifetime cumulative dose, (2) the individual
who received the dose signed Form 4, or equivalent, in
accordance with 10 CFR 20.2104 (d), and (3) there is no
other signature attesting to the authenticity of the Form 4
record. Is the licensee in compliance with the
requirements in 10 CFR 20.2104 concerning records of
lifetime cumulative occupational dose?
Answer: Yes. As stated in Regulatory Guide 8.7, Section
C.1.3, to demonstrate compliance with the requirement of 10
CFR 20.2104 (a) (2) (to attempt to obtain the records of
lifetime cumulative occupational radiation dose), 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 does not need to
be verified so long as the individual does not participate
in a planned special exposure. However, in the unlikely
event that it was the individual who provided the licensee
with the report by electronic media, Regulatory Guide 8.7,
Section C.1.3, also states that "Although not required by
the regulations, it is considered good health physics
practice to verify the information provided by the
individual." (Reference: 10 CFR 20.2104)