ML20203N662
| ML20203N662 | |
| Person / Time | |
|---|---|
| Issue date: | 01/25/1978 |
| From: | Volgenau E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Devlieger T AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20203N663 | List: |
| References | |
| NUDOCS 8610170027 | |
| Download: ML20203N662 (4) | |
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4 JAN 2 $ D2B Mr. Thomas A. DeVlieger 1501 Edgerton Drive Joliet, IL 60435
Dear Mr. DeVlieger:
This is in response to your letter to me dated January 9,1978, requesting an interpretation by General Counsel concerning how NRC Forms 4 should be used. Contacts with our legal staff have indicated that the questions you ask require largely technical answers and that the questions do not require a legal interpretation by General Counsel as you suggest. Therefore, we have enclosed a separate attachment which provides answers to your questions.
We hope the enclosed discussion and answers to your questions are responsive to your concerns.
Should you have any additional questions or desire further clarification of the use of Forms 4, you may direct them here or to our office in Region III.
Sincerely,
/8/
j Ernst Volgenau Director Office of Inspection and Enforcement
Enclosure:
As stated bec:
N. C. Moseley EVolgenau Reading H. D. Thornburg IE Reading File E. D. Jordan L. N. Haller B. H. Grier, RI J. P. O'Reilly, RII J. G. Keppler, RIII E. M. Howard, RIV R. H. Engelken, RV SEE PREVIOUS YELLOW FOR CONCURRENCES
. 3 B610170027 780125
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i Form 4 Sections 20.101(b) and 20.102 of 10 CFR Part 20 provide a means to i
exceed the limit of 1.25 rems per calendar quarter as specified in Section 20.101(a) provided that the lifetime exposure limit is not exceeded. The lifetime limit is specified in Section 20.101(b) and i
is detemined by the formula 5(N-18) where "N" is a worker's age in years.
In all circumstances the occupational radiation dose limit provided for in Sections 20.101(b) and 20.102 cannot exceed 3 rems per calendar quarter.
However, if during an emergency or accident a lifetime dose is obtained there is nothing to prevent an individual from receiving up to 1.25 rems per quarter as provided in Section 20.101.
The lifetime dose limitation only applies when exceeding 1.25 rems per j
quarter as provided in Section 20.101(b).
In your letter, Section 20.102 is quoted with several key words or phrases underscored.
To obtai_n a certificate on Form NRC-4 requires that your employer make a reasonable effort to obtain the total radiation exposure from each of your previous employers where radiation exposures were received, so~that the information can be entered on the new Form 4.
If the information can not be gotten, theniyour employer may use i
assumed exposures as set out in the table in Section 20.102(c)(1) or restrict you to 1.25 rems per calendar quarter which would require no Form 4.
Each period of time means those periods while in the employ of 1
a single employer; foFexample, if two previous licensees (employers) i were involved, this would constitute two time periods. And of course, f
each Form 4 must be signed by the employee or tse Form 4 is not considered j
valid. The individual's signature on. the Form 4 does not mean that pemission is granted to exceed 1.25 rems per qsarter; it only acknowl-edges that the history is correct and complete t the best of his knowledge. When all of the dose information is received and rgcorded then it is a simple matter to detennine the lifetime dose remaining by using the fomula given above.
f In your letter you list some specific questions in addition to those j
implied. Following are answers in order of the questions listed.
l Q.
Must the individual sign the. form every ttne he exceeds 1.25 j
rems per quarter?
A.
No. The Form is only a history of previous employment exposures and all remaining dose information under tte current employer j
may be found in the exposure records, known as the NRC Form 5 or equivalent as specified in Section 20.4E, which must be
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maintained.
Keep in mind that the Form 4 is only filled out
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and signed once and remains in effect for a long as an j
individual works for that employer.
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Must the Form 4 be filled out every time the 1.25 rems is exceeded Q.
for every quarter it is exceeded?
A.
No.
Q.
If it is not_ required ev_ery time how often must the licensee update and Lhave signedf his Form 4?
-A.
Updating is not necessary as long as the employee works for the same licensee (employer). As indicated earlier current exposure s
infomation is found in the Form 5 or equivalent.
Q.
If the licensee is unsure of exposure is an outdated Form 4 sufficient to exceed 1.25 rems per quarter?
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,A.
A Form 4 cannot be outdated for the same employer since it.is only a previous history.
The Form 5'should be examined for a
'l current update on exposures. With regard to the Form 5 the employer can only be as certain of the expcsuras as entered from analysis of film badge or TLD exposurt data. Usually, the current exposure records (Form 5 data') show for each individual the lifetime exposure used and that remaining as well as current quarter and current year to date exposures.
Q.
Must more than a casual concerned glance be done before the 1.25 rem limit is exceeded?
A.
If a glance is needed to confirm that the enployee has a Fonn 4 in case of doubt, then this may be all that is necessary (assuming that e
the Form 4 was adequately completed and sigted initially.)
In real practice the licensee should obtain a surrent updatYby J'
examining the exposure records (Form 5) and the results of pocket dosimeter readings, if used.
This rray require more tnan a " concerned glance" to make certain t1e employee will w
not exceed 3 rems per quarter.
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Q.'
If the licensee has not filled out a new Fam 4 immediately prior to exceeding 1.25 rems per quarter des Section 20.405(a) apply as regards the thirty day notificatici?
s A.
If a Form 4 has previously been filled out an individual can
' receive up to 3 rems per quarter.
If no Fam 4 has been filled out and an individual exceeds 1.25 rems per quarter, a report pursuant to Section 20.405 is required. An individual cannot be permitted to exceed 1.25 rems per quarter prior to having a Form 4 completed.
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- 3-Q.
Is it possible that a Form 4 signed in February 1974 can be used in December 1977 to exceed 1.25 rems per quarter?
A.
Yes, as discussed above a Fom 4 with the same employer is valid for as long as the employee remains with the employer. Again any updating would be reflected in the exposure records.
Q.
Does not 20.102(b)(1) in its use of the word "obtain" and the
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words "each period of time" force a continual update of the Fom 4 at the time 1.25 rems per quarter is exceeded?
A.
No.
The continual update is obtained on the Form 5 and the phrase "obtain for each period of time" as used in 20.102(b)(1) has been discussed above.
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