You may want to consider asking the right personnel the right questions, i.e., a paid TLD analysis company analyzes badges, rings, etc., they do NOT necessarily know the NRC or agreement state rules.
The scope and intent of the NRC regulations (assuming identical regulations for agreement state) are based on 2 things: maintaining exposures As Low As Reasonably Achievable (ALARA) during a year and providing employees the notice/capability to track their annual exposure over a working lifetime (age 62 when passed?).
I believe the forms you received are equivalent to the Annual Notice of Total Effective Dose Equivalent (TEDE) for annual occupational exposure. While we need to control employees exposures ALARA, we also need to inform employees of their annual TEDE.
We are all constantly exposed to radiation, some employees undergoing certain medical procedures may exposed to significantly higher levels.
When the exposure limits were established, they were based upon an employee being exposed for a working lifetime, maintaining ALARA exposures with limiting exposures to maintain annual exposure limits, consider a planned overexposure.
I believe the NRC Annual Form 5’s received are to show employees a summary of their annual total effective dose equivalent (TEDE). The EMPLOYEE needs to receive a form (the form should have 2 copies, with 2 signature spaces - 1 for employee, 1 for RSO). The RSO should be reviewing the annual exposure results with the employee, both signing the forms. The employees copy should be provided to them. The employers copy should be maintained in the employees medical file. (Occupational dose record covered by OSHA) and any current/previous employee can request a summary which you can provide either via a TEDE summary or a copy of each year’s annual report. This allows the employee (or their physician/oncologist) to total the dose received or each years dose. I would not simply file in your records ant expect to be in compliance.
Please review the “guidance” from the below links.
I recently took over as the RSO for our site and we stopped outsourcing the handling of our dosimetry program. We received the Annual Form 5 from the dosimetry company and my question to the group is what do I need to do with them? I was not sure if they are just for our records or if there is someone else that I needs to receive them. I know Maryland is an agreement state and I have called the dosimetry company. The person I talked to could not answer my questions. I have also contacted Maryland Department of the Environment, but they never seem to return my calls. If they are just for our records, great! I just want to make sure I am in compliance.
J. M. Huber Corporation
907 Revolution Street
Havre de Grace, MD 21078-3700
(410) 939-7291 (office)
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