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Re: Record Retention Requirement
I have the following information. Hope this helps:
DOE G 441.1-11 REPLACES DOE G-10 CFR 835/H1 - Rev. 1 NOVEMBER 1994
IMPLEMENTATION GUIDE For Use With Title 10,
Code of Federal Regulations, Part 835 OCCUPATIONAL
RADIATION PROTECTION
OCCUPATIONAL RADIATION PROTECTION RECORD-KEEPING
and REPORTING
Section IV, Subsection C - Retention of Records
C. Retention of Records
This section covers retention of records generated in the radiation
protection program and covered by DOE 1324.2A. The records listed in
this section should be destroyed when the retention period expires.
If records exist that are not covered in this guide, a Request for
Records Disposition Authorization may have to be completed and
submitted in accordance with DOE 1324.2A, Chapter I, Paragraph 3.c.
A records management plan should be developed. As a minimum, the
plan should provide for an inventory of records, in accordance with
DOE 1324.2A, Chapter II, and the systematic disposition of records.
1. Individual Employee Radiation Exposure Records
Individual radiation exposure history files for employees and
visitors shall be retained for 75 years and shall contain all
internal and external exposure records, including both negative and
positive results (DOE 1324.2A). As a minimum, the individual exposure
history files shall contain the following (DOE 1324.2A):
-- Records of skin and nasal contamination incidents, including
decontamination details;
-- incidents involving contaminated injuries, along with
decontamination and treatment details;
-- dose results;
-- investigations of intakes of radioactive material in excess of
standards and control guides, missing or unusual data concerning
exposure of personnel to radiation, and radiation doses exceeding
guides or standards; and
-- records of bioassay data including positive results of bioassay
samples and laboratory results indicating no deposition of
radioactive material.
2. Program Records
Program records include the regulations, procedures, and
correspondence that concern or document internal or external exposure
to radiation or radioactive material. (Individual exposure records
are not included in these records but are affected by many of them.)
The following records that affect the internal and external dose
records of individuals shall be retained for the periods specified
(DOE 1324.2A):
-- Results of equipment calibration used to determine exposure
results, e.g., dosimeters, in vivo counting equipment, in vitro
sampling and counting equip- ment, portable instruments used to set
personnel dose rates or contamination levels, shall be retained for
75 years;
-- automatic data processing system programs, codes, instruction
tapes, and discs used for retrieval of personnel exposure records
shall be retained for 75 years; and
-- worksheets, requests for analysis, chart records that must be
further interpreted or modified before use, automatic data processing
system input records, film badges, information used in
interim calculations or to verify recorded data is correct, and
statistical summaries duplicating dose data should be retained until
the exposure records have been verified and approved or for 1 year,
whichever is earlier.
Technical standards (including operating guides, as well as
laboratory, operating, and radiation protection procedures describing
the technical and administrative basis for the radiation protection
program) shall be retained for the period specified below (DOE
1324.2A):
-- A historical file of standards, guides, and procedures,
including revisions, along with background records defining the
philosophy used in development, methods of evaluation, and scope and
practices of the radiation protection efforts shall be retained as
permanent records and should be offered to the National Archives when
25 years old; and
-- the detailed plans for jobs performed within the scope of the
procedures for program records and similar records relating to
routine daily operations should be retained until their purpose is
served or for 1 year, whichever is earlier.
Logbooks that summarize shift and daily activities, including unusual
incidents, radiation and contamination problems, release of
radionuclides to work areas or offsite, interpretation of unusual
chart recordings, and other similar items shall be retained for 75
years (DOE 1324.2A).
Routine radiation and contamination surveys and air sampling records,
including resulting laboratory analyses and equipment calibrations
indicating no unusual health or safety problems, shall be retained
for 75 years (DOE 1324.2A).
Recorder chart records of airborne radioactivity and direct radiation
should be retained until their purpose is served or for 3 months,
whichever is earlier.
Reports and studies of unusual radiation and contamination problems
shall be retained for 100 years (DOE 1324.2A). Radiation safety
records shall be protected from loss by use of vaults, file rooms
with fixed fire suppression, fire retardant cabinets, duplicate
storage, or a combination of these methods (RCM 775.1).
Storage arrangements should address physical damage that could be
caused by temperature extremes, moisture, infestation,
electromagnetic fields, excessive light, stacking, theft, and
vandalism (RCM 775.2).
Minimum protective requirements for storage of records should include
(RCM 775.3):
-- Exposure to fire based on the equivalent to Underwriter's
Laboratory 1.5 hour or greater fire resistance rating;
-- exposure to water damage caused by the 100 year flood; and
-- exposure to windstorm velocities of a 100 year recurrence.
====================
ANSI N13.6, Practice for Occupational Radiation Exposure Systems,
Section 7.1, Retention period for records, states the following:
"..the records identified in 7.1.1 through 7.1.5 should be retained
for 75 years after generation.
Shorter retention periods may be appropriate for the raw data and
other types of records generated by the radiation protection
program."
7.1.1 Retention of individual exposure records
7.1.2 Retention of programmatic records (Technical Basis Documents)
7.1.3 Retention of procedural records (Historical Implementing and
Operating Procedures)
7.1.4 Retention of control and calibration records
7.1.5 Retention of data summary records (Showing that data was
evaluated and interpreted)
===================
NRC Record Retention
§20.2106 Records of individual monitoring results.
(a) Recordkeeping requirement. Each licensee shall maintain records
of doses received by all individuals for whom monitoring was required
pursuant to §20.1502, and records of doses received during planned
special exposures, accidents, and emergency conditions. These
records(5) must include, when applicable --
(f) The licensee shall retain the required form or record until the
Commission terminates each pertinent license requiring this record.
This includes records required under the standards for protection
against radiation in effect prior to January 1, 1994.
Record Retention at Ex-Licensee After a License has been
Terminated
HPPOS-205 PDR-9111210351
Title: Record Retention at Ex-Licensee After a License has
been Terminated
See the memorandum from P. Jehle to C. L. Miller dated
February 27, 1989. The memo states that once a license is
terminated by the NRC, the former licensee is no longer
required to retain records. If the NRC believes record
retention should continue for a term of years, its
termination order could be conditioned on expiration of the
term.
On May 27, 1988, the Commission issued a final rule on the
Retention Periods for Records that affects 10 CFR Parts 4,
11, 25, 30-35, 40, 50, 60, 61, 70, 71, 73, 74, 75, 95, and
110. These parts contain all the regulatory provisions
referring to NRC requirements for retaining records (with
the exception of 10 CFR Part 20). The Commission's
regulations refer only to a "Licensee" or an "Applicant."
There are no references to the applicability of the
regulations to an ex-licensee or former licensee. Because
of the absence of references to ex-licensees, by inference,
record retention regulations do not apply to ex-licensees.
Therefore, once a license is terminated by the NRC, the
former licensee is no longer required to retain records.
This does not suggest that the Commission is without
authority to require the retention of necessary records.
The Commission may place conditions on an order of
termination to be fulfilled before decommissioning is
complete. If the Commission believes record retention
should continue for a term of years, its termination order
could be conditioned on the expiration of the term.
The recordkeeping requirements of 10 CFR Part 20 are the
subject of proposed rulemaking. The proposed rules, in all
but two sections, state that the licensee shall retain
records until the Commission terminates the license
requiring the record. The notice of the proposed rule did
not state that the regulations have been changed to require
that records be maintained until the license is terminated.
Therefore an ex-licensee is not required to retain records
under 10 CFR Part 20 of current or proposed NRC regulations.
Regulatory references: 10 CFR 20.401, 10 CFR 20.2102, 10
CFR 20.2103
Subject codes: 2.1, 11.4
-------------
d) Prior to license termination, each licensee authorized to possess
radioactive material with a half-life greater than 120 days, in an
unsealed form, shall forward the following records to the appropriate
NRC Regional Office:
(1) Records of disposal of licensed material made under §§20.2002
(including burials authorized before January 28, 1981(1)), 20.2003,
20.2004, 20.2005; and
(2) Records required by §20.2103(b)(4).
------------------------------------
Sandy Perle
Vice President, Technical Operations
Global Dosimetry Solutions, Inc.
3300 Hyland Avenue
Costa Mesa, CA 92626
Tel:(714) 545-0100 / (800) 548-5100 Extension 2306
Fax:(714) 668-3149
E-Mail: sperle@globaldosimetry.com
E-Mail: sandyfl@earthlink.net
Personal Website: http://sandy-travels.com/
Global Dosimetry Website: http://www.globaldosimetry.com/
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