Records and Reports

DOE-STD-1121-98

9.0 RECORDS AND REPORTS

Internal dosimetry records are an important part of an internal dosimetry program, not only to

demonstrate compliance with 10 CFR 835 and the DOE Orders, but also to support the on-going dose

management of individuals following intakes. The minimum requirements for an internal dosimetry

records program are specified in 10 CFR 835.702 and 703, with additional guidance in the Articles 523

and Section 7 of the RadCon Standard (DOE 1999e), and in the Internal Dosimetry Program Guide (DOE

1999b). Prior dose assessments not compatible with committed dose equivalents should be converted to

provide committed organ/tissue and effective dose equivalents. However, constraints discussed in

Section 8.2.3 may limit some reassessments.

Requirements to the annual reports to employees are given in 10 CFR 835.801, with additional

guidance in the RadCon Standard Article 781.1 and the IDG.

The ANSI N13.6 standard on "Practice for Occupational Radiation Exposure Records Systems"

(HPS 1999c) provides guidance for the systematic generation and retention of records relating to

occupational radiation exposure.

9.1 WHAT TO RECORD A GENERAL PHILOSOPHY OF RECORDS

The 10 CFR 835 regulation specifies particular items for which recording is required, including

specific doses, combinations of external and internal doses, and nuclides of intake and their magnitude.

In addition, records are required of pertinent data and information which resulted in the generation of the

dose and intake information. There is a substantial amount of professional judgement needed in deciding

what data to record and how to record it. The development of relational databases has eased much of the

data storage capability but in the process has created some possible pitfalls. The interpretive keys and

professional judgements used in evaluating data may not readily lend themselves to database formats. For

this reason, an internal dose evaluation report consisting of discussion of assumptions and conditions

unique to the individual worker and intake is suggested as the most effective means of documenting the

assessment. The report may include the actual data used and calculations or computer outputs, or may

reference the appropriate supporting documents and databases where the information and results can be

found. Generally, the final doses are entered into a dosimetry database where they can be electronically

summed with appropriate external doses to give the needed combinations.

A guiding philosophy for documenting cases is to imagine that 20 years after an exposure was

evaluated, a knowledgeable health physicist is asked to independently review and critique that evaluation.

The information available in the evaluation should be adequate to lead that health physicist to a complete

and unambiguous understanding of the original evaluator's thought processes in arriving at the intake and

dose assessments. The advance of internal dosimetry and bioassay science in the intervening years might

lead the reviewing health physicist to completely disagree with the conclusions. However, there should

not be any misunderstanding as to the approach and logic of the original evaluation.

9.2 REPORTING PRELIMINARY ASSESSMENTS OF UNPLANNED EXPOSURES

When an unplanned exposure occurs, an investigation and reporting system is set in motion to

determine the severity of the event. A key item of information being sought is the magnitude of any dose

likely to result from the intake. Pressure is often placed on the bioassay and internal dosimetry program

to make immediate and precise assessments for categorizing the event. Unfortunately, bioassay