Question 212: A licensee makes a prospective determination
that adult workers in Department W are not likely to
receive doses in excess of 10% of the limits from external
sources, so external dosimetry is not required by 20.1502.
The workers in Department W complain when their TLD badges
are taken away, so the licensee decides to leave them
badged, but not to demonstrate compliance with the
occupational dose limits of the revised Part 20. (a) If
an inspector finds the TLD badges being worn incorrectly or
misused by Department W workers, can the licensee be cited?
(b) Must the doses be reported to the workers? If
recording is required, must it be kept on Form 5?
Answer: (a) No citation against 10 CFR 20.1502 would be
issued, provided the licensee can provide documentation
that adequately supports the evaluation that monitoring of
external dose is not needed. An inspector may bring the
issue of incorrect wearing of dosimeters to the attention
of the licensee, and may document this lack of good
practice in the inspection report.
(b) No, reporting is not required. If the badges are not
used for compliance with the regulations, the licensee is
not required to record the results on NRC Form 5 or its
equivalent. (Reference: 10 CFR 20.1502, 10 CFR 20.2106)