Question 394: (a) Are the results of dose monitoring of
minors and declared pregnant woman performed in accordance
with 20.1502 required to be reported to NRC as part of the
annual reporting of individual monitoring results? (b) If
so, are the records of dose to the embryo / fetus, which may
differ from records of dose to the declared pregnant woman,
required to be submitted as part of the annual reporting of
individual monitoring results? It would seem that
embryo / fetus dose records are not required to be included
in the annual report, because the embryo / fetus dose records
are developed in accordance with 20.1208, "Dose to the
Embryo / Fetus," and not 20.1502, "Conditions Requiring
Individual Monitoring of External and Internal Occupational
Dose," which is the base reference for the annual reporting
requirement.
Answer: (a) Yes. For a declared pregnant woman, the dose
to be reported in accordance with 10 CFR 20.1502 is the
dose to the woman herself, not the dose to the embryo / fetus.
(b) No. See Section 2.3 of Regulatory Guide 8.7, Rev. 1,
concerning reporting of embryo / fetus dose. (Reference: 10
CFR 20.2206, 10 CFR 20.1502, 10 CFR 20.1208).