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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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