U.S. Nuclear Regulatory Commission

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)