Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555
September 2, 1994
NRC GENERIC LETTER 94-04: VOLUNTARY REPORTING OF ADDITIONAL
OCCUPATIONAL RADIATION EXPOSURE DATA
Addressees
All holders of operating licenses or construction permits for nuclear power
reactors, radiography licensees, fuel processing licensees, fabricating and
reprocessing licensees, manufacturers and distributors of byproduct material,
independent spent fuel storage installations, facilities for land disposal of
low-level waste, and geologic repositories for high-level waste.
Purpose
The U.S. Nuclear Regulatory Commission (NRC) is issuing this generic letter to
request that all addressees provide to the NRC a voluntary report containing
the occupational radiation exposure data as described below.
Background
The provisions of 20.2206 of 10 CFR Part 20 require seven categories of NRC
licensees to submit occupational radiation exposure reports. The seven
categories are as follows: commercial nuclear power reactors; industrial
radiographers; fuel processors, fabricators and reprocessors; manufacturers
and distributors of byproduct material; independent spent fuel storage
installations; facilities for land disposal of low-level waste; and geologic
repositories for high-level waste. Each of these approximately 500 licensees
submits exposure reports for each of its monitored employees. This data is
computerized by the NRC, and forms the basis for the Radiation Exposure
Information Reporting System (REIRS).
An analysis of the REIRS database is presented in the annual volumes of
NUREG-0713, "Occupational Radiation Exposure at Commercial Nuclear Power
Reactors and Other Facilities." The analysis provides licensees with an
opportunity to compare ALARA performance at their facilities with that of
similar facilities. The data are also used to evaluate occupational doses
against national and international radiation protection recommendations to
determine if further reductions in the occupational dose limits in 10 CFR
Part 20 are needed to achieve the recommended levels. The REIRS database also
provides a historical view of radiation exposure at NRC licensed facilities
9408290302.GL 94-04
September 2, 1994
Page 2 of 5
over the last quarter century. The NRC database can be used to provide
complete individual exposure history to employers to assist them in
demonstrating compliance with the occupational radiation exposure requirements
regarding exposure histories for required individuals. Finally, REIRS is the
largest database of radiation exposures at occupational levels. This makes it
a very valuable epidemiological resource in determining the actual risk of
exposure at occupational levels.
One of the goals fulfilled through the collection of this additional data is
to supplement the information available through the Part 20 reporting and
recordkeeping requirements so that the information vital to carrying out
epidemiological studies will be available. This goal was stated in the
statement of consideration to 10 CFR 20.1001 through 20.2402 published in the
Federal Register on May 21, 1991 (56 FR 23386). The utility of this
information is in conducting such studies and the intention of the National
Cancer Institute to conduct these studies was discussed in an April 20, 1994
letter to Bill M. Morris, Director of the Division of Regulatory Applications,
Office of Nuclear Regulatory Research from Dr. John Boice, Chief of the
Radiation Epidemiology Branch, National Cancer Institute. In the letter,
Dr. Boice states that it is the current workers who have been employed for
many years who are most critical to a successful epidemiological study.
Description of Circumstances
Under the previous requirements of 10 CFR Part 20.1 through 20.602, seven
classes of licensees were required to submit termination reports containing
occupational radiation exposure data for the entire period of work or
employment to the NRC when individuals terminated employment or a work
assignment at their facilities. Thus, at the end of a worker's employment,
the individual's entire exposure record would be part of NRC's exposure
database. In addition, these licensees were required to submit a statistical
summary of the exposures of all individuals occupationally exposed at their
facilities.
Under the new requirements of 10 CFR 20.1001 through 20.2402, which became
mandatory on January 1, 1994, these licensees are now required to annually
submit occupational radiation exposure data to the NRC for all persons
occupationally exposed at their facilities, during that year, for whom
monitoring is required. Termination reports are no longer required. Thus,
as of April 1994 and every April thereafter, the required exposure data for
employees for the previous year is to be submitted to the NRC. With this
change in reporting requirements, the exposure data for current employees,
from the time of their initial employment to the date of implementation of the
new requirements of 10 CFR Part 20.1001 through 20.2402 would not be reported.
Complete data would only be available for employees who finished their careers
prior to the new requirements or new employees who only worked under the new
requirements. Complete data would not be available for any employee who
worked under both the new and old reporting requirements. This gap in the
radiation exposure data would limit the usefulness of the REIRS database for
.GL 94-04 September 2, 1994Page 3 of 5
(1) epidemiology as described by Dr. Boice, (2) supporting decisions on the
necessity and appropriateness of new regulatory requirements for occupational
exposure, and (3) facilitating determinations by new employers of prior
occupational exposure as required by 10 CFR 20.2104.
Discussion
The Nuclear Regulatory Commission, as well as national and international
organizations such as the International Commission on Radiation Protection
(ICRP) and the National Commission on Radiation Protection and Measurements
(NCRP), derives information on occupational exposures from the REIRS database
and uses this information to establish limits on occupational exposure to
ionizing radiation. If the REIRS database is known to be incomplete, it will
not be reliable for determining actual lifetime exposures. This will have
three major consequences. First, NRC would not be able to continue to
provide complete exposure histories to individuals to facilitate the movement
of transient workers from one licensee to another. Second, actual lifetime
exposures could not be determined for the occupationally exposed workers in
the seven categories of licensees. Without this information, NRC may have
difficulty in evaluating whether further limitations on occupational doses are
needed to achieve dose levels recommended by the ICRP. Finally, a large
reliable database, available to the National Cancer Institute for
epidemiological studies on occupationally exposed workers, would not be
available for decades. The ability of agencies such as NCI to rely upon these
data of doses at occupational levels would be lost.
Requested Information
In an effort to provide for a complete and reliable database, the NRC is
requesting that the seven classes of licensees included in the REIRS database
provide a voluntary report of the data missed as a result of the change in
regulations. This report is requested to include the occupational radiation
exposure data of all current licensee employees from the date of employment to
the day prior to implementation of the new requirements of 10 CFR Part 20.1001
through 20.2402 which were otherwise unreported under the reporting
requirements of 10 CFR 20.1-20.602. The information requested is that
normally included on NRC Form 5.
Voluntary Response Requested
Within 180 days from the date of this generic letter, all addressees are
requested to submit a voluntary report containing data for each monitored
individual from the date of employment to the day prior to the implementation
of the new requirements of 10 CFR Part 20.1001 through 20.2402. Data
previously reported on termination reports need not be included. It is .GL
94-04 September 2, 1994Page 4 of 5
preferable that the data be reported by monitoring year, but a single
monitoring period spanning several years is acceptable. If possible, the data
should be submitted electronically.
While the NRC will accept these data in any format, a suggested format as well
as an electronic format is provided in Enclosure 1 in an effort to simplify
submission of the requested data. The electronic format is the preferred
format for the submission of the data.
In addition, a cover letter should be included which gives the name of the
licensee, the NRC license number, the name of a person to contact in case
there are questions, and the phone number at which that individual can be
reached (the same information requested as part of NRC Form 5).
Address all reports to the U.S. Nuclear Regulatory Commission, ATTN: REIRS
Project Manager, Mail Stop T-9 C24, Washington, DC 20555.
Backfit Discussion
This generic letter only requests voluntary submittal of information.
Therefore the staff has not performed a backfit analysis.
A notice of opportunity for public comment was not published in the Federal
Register because of the voluntary nature of the information request.
Paperwork Reduction Act Statement
The voluntary information collections contained in this request are covered by
the Office of Management and Budget, clearance number 3150-0011, which expires
July 31, 1997. The public reporting burden for this voluntary collection of
information is estimated to average 10 hours per response, including the time
for reviewing instructions, searching existing data sources, gathering and
maintaining the data needed, and completing and reviewing the collection of
information. Send comments regarding this burden estimate or any other aspect
of this voluntary collection of information, including suggestions for
reducing this burden, to the Information and Records Management Branch
(T-6 F33), U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, and to
the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202,
(3150-0011), Office of Management and Budget, Washington, D.C. 20503.
Compliance with the following request for information also is purely
voluntary. The information would assist NRC in evaluating the cost of
complying with this generic letter.
.GL 94-04
September 2, 1994
Page 5 of 5
The licensee staff time and costs to prepare the requested reports and
documentation.
If you have any questions about this matter, please contact the technical
contact listed below.
original signed by original signed by
Carl J. Paperiello, DirectorRoy P. Zimmerman
Division of Industrial and MedicalAssociate Director for Projects
Nuclear SafetyOffice of Nuclear Reactor Regulation
Office of Nuclear Material Safety
and Safeguards
Attachments:
1. Format for the Occupational Radiation
Exposure Data Report
2. List of Recently Issued NRC Generic
Letters
Technical contact: Charleen T. Raddatz, RES
(301) 415-6215
Attachment 1
GL 94-04
September 2, 1994
Page 1 of 4
FORMAT FOR THE OCCUPATIONAL RADIATION EXPOSURE DATA REPORT
Electronic Format
Electronic submittal should be on 3.5" or 5.25" PC diskettes or 8 mm magnetic
tape. Each disk, tape, or cartridge submitted should include a transmittal
letter. Each letter should contain the file name, date created, operating
system, the name and phone number of a person knowledgeable about each file,
any other pertinent instructions, signature, and date.
File Structure
Each diskette should contain two file types. The first file type should be a
single header record which provides information about the source of the data
file. The second file type should be an exposure record for each monitoring
period for each monitored individual. Each record should contain only ASCII
or EBCDIC printable characters, terminated with a carriage return (CR) and a
line feed (LF). All empty space should be padded with spaces. Text strings
are expected to be left justified in a field and numbers are expected to be
right justified in a field.
.Attachment 1
GL 94-04
September 2, 1994
Page 2 of 4
Header Record (occurs only once on each diskette, tape, or cartridge)
FIELD
WIDTH
START
COL.
END
COL.
DESCRIPTION
Primary_License
13
1
13
Primary NRC license number
Preparation_Date
8
15
22
Date the record was written to the data file
formatted as 'YYYYMMDD'
Licensee_Name
72
24
95
Name of the NRC licensed facility
Contact
72
97
168
Name of the person to contact for
information about this data file
Phone_Number
14
170
183
Contact's phone number
Other_license_1
13
185
197
Other NRC license number
Other_license_2
13
199
211
Other NRC license number
Other_license_3
13
213
225
Other NRC license number
Other_license_4
13
227
239
Other NRC license number
Other_license_5
13
241
253
Other NRC license number
Other_license_6
13
255
267
Other NRC license number
Other_license_7
13
269
281
Other NRC license number
Other_license_8
13
283
295
Other NRC license number
Other_license_9
13
297
309
Other NRC license number
Other_license_10
13
311
323
Other NRC license number.Attachment 1
GL 94-04
September 2, 1994
Page 3 of 4
Exposure Record (one for each individual, for each monitoring period)
FIELD
WIDTH
START
COL.
END
COL.
DESCRIPTION
Employee_ID
12
1
12
Social Security Number (or Other ID
number)
Primary_License
13
13
25
Primary License Number
First_Name
25
26
50
Employee's first name (no nicknames)
Middle_Initial
1
51
51
Employee's middle initial
Last_Name
25
52
76
Employee's last name. Titles such as "Jr"
should be separated from the last name by
a space. No punctuation should be used in
the title.
Sex
1
77
77
'M'=Male, 'F'=Female
Birth_Date
8
78
85
Employee's date of birth (YYYYMMDD)
Monitoring_Start
8
86
93
Date Monitoring began (YYYYMMDD)
Monitoring_End
8
94
101
Date Monitoring ended (YYYYMMDD). If
possible, report in one year increments.
The end date for the last monitoring period
for a given individual would be on or
before the day immediately prior to
implementation of the revised Part 20.
WB_Dose
8
102
109
Total whole body deep dose in rem for the
entire period, including x, gamma, and
neutron dose. This should be formatted
'9999.999'.
.Attachment 1
GL 94-04
September 2, 1994
Page 4 of 4
If hard copy reports are to be submitted, the following information is needed
for each monitored individual:
Last
Name
First
Name
Init
SSN
Sex
Date
of
Birth
Date
Monitoring
Began
Date
MonitoringEnded
Whole
Body
Dose
(rem)
