Health Physics Questions and Answers - Question 398

Question 398: Regulatory Guide 8.7 (Section C.2.2) states that "if during the course of the year the dose to date for the year exceeds 1 rem CEDE [committed effective dose equivalent] or the individual receives an overexposure in another dose category, the CDE [committed dose equivalent] to the maximally exposed organ must be calculated, recorded and reported." If an individual arriving from work at another (previous) licensee's facility within the current year has a CEDE that exceeds 1 rem, does the guidance imply requirements for monitoring, recording or reporting of internal dose, even if the present licensee's prospective evaluation shows that the individual is not "likely to exceed" 10% of an annual limit on intake (ALI)?

Answer: For the situation described in the question, the quoted section of the Regulatory Guide 8.7 indicates that the previous licensee should have calculated, recorded, and should report the CDE to the maximally exposed organ. However, as indicated in Section C.1.1 of Regulatory Guide 8.7, in performing the prospective evaluation (under 10 CFR 20.1502) to determine if monitoring is required "for individuals who received exposure at other facilities in the current year, the previous dose need not be considered in prospective evaluation. Only the dose that could be received at the facility performing the evaluation need be considered when determining the need for monitoring and, therefore, the recordkeeping and reporting requirements."

(References: 10 CFR 20.1502, Regulatory Guide 8.7)