ML19309G067

Requests Clarification Re Record Keeping Requirements of 10CFR20 for Individual Radiation Exposure & Accumulated Occupational Doses

ML19309G067
Person / Time
Site:	Farley
Issue date:	04/25/1980
From:	Clayton F ALABAMA POWER CO.
To:	Schwencer A Office of Nuclear Reactor Regulation
References
NUDOCS 8005020307
Download: ML19309G067 (2)

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Alabama Power Company 600 North 18th Street 8005020 % 7 Post Office Box 2641 Birmingham. Alabama 35291 Telephone 205 323-5341 nk LboiW2 rtfe'n, Alabama Power the southem electnc system April 25, 1980 Docket No. 50-348 Director Of fice of Nuclear Reactor Regulations U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Mr. A. Schwencer

Dear Sir:

Alabama Power Company requests certain clarifications and/or authori-zations with regards to the record keeping requirements of 10CFR20 as pre-sented below.

10CFR20 - Section 20.401 states in part:

(a) Each licensee shall maintain records showing the radiation exposures of all individuals for whom personnel monitoring is required under 20.202 of the regulations of this part.

Such records shall be kept on Form NRC-5...

(c)(1) Records of individual exposure...shall be preserved until the Commission authorizes disposition.

10CFR20 - Section 20.102 states in part:

(b)(2) Calculate on Form NRC-4...the previously accumulated occupa-tional dose...

(c)(1) In the preparation of Form NRC-4...the licensee shall make a reasonable effort to obtain reports of the individual's previously accumulated occupational dose...

(c)(2) The licensee shall retain and preserve records used in pre-paring Form NRC-4 until the Commission authorizes their dis-position.

Alabama Power Company fully supports the intent of 10CFR20 in general and the record retention requirements of 520.401 specifically. Form NRC-5 is utilized in accordance with 520.401 at the Joseph M. Farley Nuclear Plant and these forms are designated lifetime records.

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Office of Nuclear Reactor Regulations Page 2 April 25,1980 In addition Form NRC-4, certified by the individual in accordance with 520.102(b)(1), is completed and retained as a permanent record.

Since Form NRC-4 is prepared from exposure records obtained from previous employers and since those employers, like Alabama Power Company, are required to maintain permanent records of employee exposure received at their facility and to provide records of such exposure to the employee and the NRC upon termination, such records are available from several sources. Therefore, the requirement of 10CFR20 Section 102(c)(2) is superfluous and burdens our file system.

Therefore, Alabama Power Company requests the following:

1. An interpretation regarding whether or not the records of other employers utilized in preparing Form NRC-4 are required to be retained by Alabama Power Company "until the commission authorizes their disposition".

2. If the interpretation of 1. above is affirmative, please provide authorization to dispose cf such records upon completion and certification of Form NRC-4 for each employee.

This requirement is a very significant administrative burden to this Company. Your cooperation is appreciated.

Yours very truly, ,

I jp ( F. L. Clayton, Jr.

FLCJr/JRC:bbj cc: Mr. R. A. Thomas Mr. G. F. Trowbridge i

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