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by Agency
> Nuclear
Regulatory Commission > Questions and Answers (10 CFR
20) 
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NUMBER
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QUESTION
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2
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What are the requirements for including dose from
non-NRC-licensed sources (x-rays, accelerators, NORM) as part of occupational
dose? 10 CFR 20.1001 10 CFR 20.1002 10 CFR 20.1003
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3
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What do you do about hot particles? 10 CFR 20.1201
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4
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How is the dose from radon considered? What about
technologically enhanced radon at a licensed facility? [Note: Technologically
enhanced natural radiation sources have been defined as "truly natural
sources of radiation . . . which would not occur without (or would be
increased by) some technological activity not expressly designed to produce
radiation." Reference: T.F. Gesell and H.M. Prichard, Health Physics 28,
361-366, April 10 CFR 20.1001 10 CFR 20.1002
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5
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Who is responsible for regulating radium - the State
or NRC? 10 CFR 20.1001 10 CFR 20.1002
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6
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What if an NRC licensee hires a DOE employee who
earlier in the year received an internal exposure of less than 5 rems annual
effective dose equivalent, but greater than 5 rems committed effective dose
equivalent? 10 CFR 20.1201
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7
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Relative to 10 CFR 20.1101, radiation protection
programs, what would a typical radiography licensee have to do beyond what
that licensee is doing now?
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8
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Under what circumstances are planned special
exposures permitted?
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9
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A licensee monitors a worker for both external and
internal exposure under 20.1502, but the internal exposure for the year is
less than 10% of the dose limit. Does the licensee add it to the external
exposure? 10 CFR 20.1202
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10
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Why does the revised Part 20 still require Form 4?
10 CFR 20.2104
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11
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Should the Radiation Protection Program be a
stand-alone document or can it be the sum of many documents or manuals (e.g.,
a requirement for HP audits included as part of a QA audit program document)?
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12
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How will the revised Regulatory Guides be used in
determining acceptability of a licensee's implementation of the revised Part
20?
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13
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Why was a 2-hour half-life chosen as a time of
reference for noble gases or short-lived radionuclides, as used in 10 CFR
Part 20, Appendix B and its footnotes?
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14
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Are Design Basis Accident criteria (doses) changed
by the revised Part 20? 10 CFR 50 Appendix A
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15
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Will the reporting criteria of 10 CFR 50.72 and
50.73 have to be changed? 10 CFR 50.72
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16
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Will the Emergency Action Levels (EAL) as part of
the Emergency Plans have to be changed if based on the old Part 20
methodology? 10 CFR 50.47
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17
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Will QA Category 1 requirements discussed in
Regulatory Guide 1.26 have to be changed due to offsite dose requirements of
0.5 rem being changed to 0.1 rem in the revised Part 20?
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18
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For power reactors, the Technical Specification
instantaneous release rate limits are based on old Part 20 doses and
concentrations (relative to an implied 500 mrem/yr limit). Will changes in
the Technical Specifications and ODCMs be required as a result of the
explicit 100-mrem/yr limit in the revised Part 20?
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19
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Current computer codes, such as LADTAP and GASPAR,
calculate individual organ doses for comparison against individual organ dose
limits in 10 CFR 50 Appendix I and/or Technical Specifications. Will the
codes have to be modified to convert whole body and organ doses to effective
dose equivalents?
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20
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Pertaining to 19, will 10 CFR 50 Appendix I and
Technical Specifications have to be modified to reflect a total effective
dose equivalent (TEDE)? 10 CFR 50 Appendix I
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21
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Is it time to update Regulatory Guide 1.109 and its
corresponding codes due to the updated dose conversion factors in the revised
Part 20?
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22
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Alarm setpoints for many radiation monitors are
based on 10 CFR 20 Appendix B concentrations. Will these new changes require
numerous ODCM changes, setpoint change requests, and procedure changes? 10
CFR 20 Appendix B NRR Generic Letter 89-01
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23
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Will all of the libraries of reference data and the
procedures for gamma-ray spectrometry software or appendices that contain 10
CFR Part 20 MPCs have to be changed?
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24
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Will consultants or vendors be able to routinely
come on site to do jobs under the Planned Special Exposure section of the
revised Part 20 if their annual exposure becomes limiting? 10 CFR 20.1003
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25
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Does the definition of a "member of the
public" mean "all" individuals? If so why is the exception
statement added to the definition?
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26
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(a): There has been some confusion about the revised
Part 20 requirements with respect to controlled areas and when individuals
are receiving a public or an occupational dose. Before asking s involving
specific exposure scenarios (in parts b, c, and d of this question), does the
NRC staff have any general guidance on these topics? 10 CFR 20.1003 10 CFR
20.1101 10 CFR 20.1201 10 CFR 20.1207 10 CFR 20.1208 Outdated (see NUREG 1736)
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27
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Do licensees have to post controlled areas (outside
the restricted area) as airborne radioactivity areas if derived air
concentrations (DAC) are exceeded? 10 CFR 20.1003
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28
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How are annual average concentrations (AAC) to be
calculated, and is it acceptable for nuclear power plants to use this AAC in
lieu of instantaneous limits (as currently required by the operating license)
which are derived from NUREG-0133?
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29
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If a licensee controls exposure to members of the
public using the new Part 20.1302(b)(2) at the boundary of the unrestricted
area, how does a licensee ensure that members of the public inside the
controlled area do not exceed this limit?
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30
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If a license condition ties the licensee to a
section in the old Part 20 and there is no corresponding section in the
revised Part 20, does the requirement in the old Part 20 stay in effect after
implementation of the revised Part 20.
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31
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Are students and volunteers subject to the
occupational dose limits? For example, nuclear medicine students, or
"candy stripers" that transport nuclear medicine patients or
perform volunteer work in a nuclear medicine department. 10 CFR 20.1003
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33
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What is the dose limit for visitors entering a
restricted area (e.g., visitors to a hospital, patients' relatives, escorted
tourists)?
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34
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What are the applicable radiation limits in a
controlled area if the licensee does not allow members of the public to enter
the area? 10 CFR 20.1003
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35
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Do posting requirements apply to the hospital room
of a hospitalized nuclear medicine patient if the patient received less than
30 mCi and the dose rate at 1 meter is greater than 5 mrem/hr?
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36
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Part 20 requires that "labelled packages"
be monitored. Is it correct to assume that only packages with White I, Yellow
II, or Yellow III labels must be monitored, and that marked packages (LSA or
radioactive markings) are not required to be monitored?
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37
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Is it necessary to document that employees have been
advised of their annual doses? Is it sufficient to let employees see the
results of the monitoring? Does posting doses on a bulletin board in a common
area, each month, fulfill this requirement?
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38
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Can the results of bioassays alone be used to
determine if the licensee must sum internal and external doses under Part 20?
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39
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Can biological material be defined better in
20.2003? For example, is all organic material biological material? Can animal
fats be released to the sewer?
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40
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Assume a licensee has defined its compliance year as
January 1, 1993 to December 31, 1993. What is the mechanism to change its
definition of year? For example, the licensee wants to monitor from January
31, 1994 to January 30, 1995, how should it account for the lost days January
1 - 30, 1994? Is it acceptable to prorate the doses?
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41
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Licensee A questions a new employee about outside
employment. The employee states that he is only working at that facility.
After 3 months, the employee starts working, in the evenings, at another
licensed facility (Licensee B). The employee does not tell A about B;
therefore, Licensee A does not take the exposure received by the employee at
facility B into account when he calculates the employees annual total
effective dose equivalent (TEDE).
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42
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A nuclear medicine technologist becomes contaminated
with I-131 which results in an internal uptake of iodine. She continues to
breast-feed her baby. Is the licensee responsible for controlling the dose to
the baby as a member of the public in an unrestricted area? If so, what are
the dose limits? 10 CFR 20.1201
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43
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The licensee initially was required to monitor
internal dose. The results indicate that monitoring is not required, i.e.,
levels are positive but less than 10% of the allowable limits. Can the
measured internal dose values be ignored? If yes, will the licensee be in
noncompliance if it sums internal and external doses?
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44
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During 1993, the licensee performed a prospective
dose evaluation, and decided not to measure internal dose. In 1994, the
licensee again evaluates the internal dose and finds that the threshold for
monitoring is exceeded and begins monitoring. Nothing in the facility
(engineering controls or productivity levels) has changed. The licensee
accounts for the internal dose contribution when calculating TEDE for 1994.
Must the licensee go back and adjust TEDE for
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45
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In determining the "eye dose equivalent,"
can credit be taken for shielding provided by eyeglasses/safety glasses?
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46
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Will determination of the "eye dose
equivalent," at a tissue depth of 300 mg/square cm, be included in the
NVLAP personnel dosimetry accreditation program?
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47
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Will the NRC provide guidance on preparation of
applications pursuant to 10 CFR 20.1204 (c) (2) for approval to adjust DAC or
ALI values to reflect the actual physical and chemical characteristics of
airborne radioactive materials (e.g., aerosol size distribution or density)?
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48
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In 10 CFR 20.1301(a)(2), does ". . . 0.002 rem
(0.02 mSv) in any one hour" apply to the dose in any single hour or can
it apply to the average over a discrete period of time.
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49
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For control of access to very high radiation areas,
will physical barriers be needed to preclude unauthorized access?
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50
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Does the footnote to 10 CFR 20.1203 mean that
DAC-hours, and not measurements of external dose (using personal dosimeters),
should be used for determining worker exposures to noble gases?
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51
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Do 10 CFR 20.2104(a), 10 CFR 20.2104(d) and Footnote
4 to 20.2104(d) mean that a licensee must "backfit" effective dose
equivalents (EDE) for individuals who were occupationally exposed before
implementation of the revised Part 20? 10 CFR 20.2104
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52
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Since the technical specification
"exemptions" for nuclear power reactors already apply to locking of
high radiation areas, does this "exemption" continue to apply
pursuant to 10 CFR 20.1008(d) if a 45-cm (18-inch) survey distance is
specified (in technical specifications) versus the rule's 30-cm distance (10
CFR 20.1601(a))? 10 CFR 20.1601 10 CFR 20.1602
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53
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(a) When a package is properly labeled for
transport, shipping papers are still in effect, and a transporter has
accepted responsibility for control of the package, do posting and labeling
requirements remain in effect while the package is on licensee property
outside of the radiologically controlled area? (b) Does the shipment have to
be posted in the protected area? 10 CFR 20.1902 10 CFR 20.1903 10 CFR 20.1904
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54
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Must bioassay be performed for a worker who, without
respiratory protection, is likely to receive an intake in excess of the
applicable ALI(s) but who is not likely to receive such an intake with
respiratory protection? 10 CFR 20.1502
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55
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10 CFR 20.2104(e)(1) prorates the 5-rem annual limit
on the total effective dose equivalent at a rate of 1.25 rems per quarter for
each quarter for which records were unavailable but includes no similar
provisions for the other annual limits (individual organs, eye, skin,
extremities). Is similar proration required for doses covered by the other
limits? 10 CFR 20.1201
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56
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Would areas periodically patrolled, but not
constantly manned, be considered to fall within the exception in 10 CFR
20.2202(a)(2) and 20.2202(b)(2) for "locations where personnel are not
normally stationed during routine operations, such as hot-cells or process
enclosures?" For example, would these exceptions apply "if a
hallway or cubicle in the reactor auxiliary becomes an airborne radioactivity
area and auxiliary equipment operators make their rounds
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57
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The definition of a very high radiation area (10 CFR
20.1003) and the requirement for control of access to very high radiation
areas specify an absorbed dose of 500 rads in an hour. Is this a deep dose, a
shallow dose, or an eye dose? 10 CFR 20.1003
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58
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Before implementing all of the provisions of the
revised Part 20, would a licensee be in violation of 10 CFR 20.1008(a) if the
licensee voluntarily adopted the provisions of 10 CFR 20.1208 for protection
of the embryo/fetus? 10 CFR 20.1008
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59
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How does the U.S. Supreme Court decision in the case
of United Auto Workers (UAW) vs Johnson Controls affect the NRC requirement
in 10 CFR 20.1208, "Dose to an embryo/fetus," and the guidance in
Regulatory Guide 8.13, "Instruction Concerning Prenatal Exposure?"
10 CFR 20.1208
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60
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In a respiratory protection program what records are
needed of evaluations that demonstrate compliance with the requirement for
maintaining the total effective dose equivalent ALARA? For example, must such
an evaluation be made each time an individual is to wear a respirator? 10 CFR
20.1101
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61
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Will the annual reports that are required by power
reactor technical specifications (reports that tabulate occupational
exposures greater than 100 mrem/yr according to work and job functions) still
be required after the revised Part 20 is implemented. 10 CFR 20.2206
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62
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With 10 CFR 20.1101(b) making ALARA a requirement ("shall"
instead of a "should"), does the NRC staff plan or anticipate any
significant change in inspection program focus or in enforcement activity
with respect to ALARA for occupational exposure at nuclear power plants?
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63
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Must doses received in excess of the limits that
were in effect before implementation of the revised Part 20 be subtracted
from the 25-rem lifetime allowance for planned special exposures to obtain
the total remaining dose available for planned special exposures? 10 CFR
20.1201 10 CFR 20.1206 10 CFR 20.2104
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64
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The following question relates to the requirements
of 10 CFR 20.2104(a)(2), 10 CFR 20.2104(c), and 20.2104(d) concerning records
of lifetime cumulative occupational dose. Assuming that (1) the licensee has
obtained, by electronic media, a printed report (or reports) containing the
Form 4 information on an individual's lifetime cumulative dose, (2) the
individual who received the dose signed Form 4, or equivalent, in accordance
with 10 CFR 20.2104(d), and (3)
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65
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The following question concerns OMB approval of the
information collection requirements of the revised Part 20. Section 20.1008
indicates that licensees shall implement the provisions of all sections of
revised Part 20 on or before January 1, 1993 and that if a licensee chooses
to implement revised Part 20 before then, the licensee shall implement all
provisions of revised Part 20 not otherwise exempted by subsection 20.1008(d).
However, 10 CFR 20.1008
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66
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This question concerns restricted area limitations.
At some sites for nuclear power plants the restricted area has been defined
as the site boundary. In some areas routine public access was available with
the understanding that, should the need arise, public use of these areas
could be prohibited. Examples of this type of access include fishing, visitor
centers, and farming. This type of use now appears to fall within the intent
of the 10 CFR 19.12 10 CFR 20.1003 10 CFR 20.1201 10 CFR 20.1206 10 CFR
20.1207
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67
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This question concerns water approaches to nuclear
sites. Several sites for nuclear power plants include portions of navigable
lakes or rivers within their licensed exclusion areas. Obviously, the utility
does not own these areas. Would such boundaries as defined in our licenses
qualify as restricted areas, controlled areas, or unrestricted areas?
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68
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This question concerns demonstration of compliance
with the dose limits for individual members of the public. Section
20.1302(b), in the revised 10 CFR Part 20, permits the licensee to
demonstrate compliance by: 1 "Demonstrating by measurement or calculation
that the total effective dose equivalent to the individual likely to receive
the highest dose 10 CFR 20.1302
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69
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This question concerns radioactive effluent
concentrations. 10 CFR 20.1302(b)(2) addresses the annual average
concentrations, and limits on these concentrations, as they apply to members
of the public. The changes published as conforming amendments to Part 2
uniformly address violations to these effluent limits as instantaneous
values. While it is clear that significant instantaneous concentrations of
these limits constitute a concern to public safety, the
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71
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The "Class" column of 10 CFR 20 Appendix B
covers inhalation, but does not refer to ingestion. When there are two ALIs
for ingestion, how do these relate to the "Class," since they
really were based upon the f1 value for gut absorption? (Note: The f1 value
is the fractional uptake from the small intestine to blood). 10 CFR 20
Appendix B
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72
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Will certain materials licensees (such as
teletherapy and brachytherapy licensees) be required to conduct environmental
monitoring in unrestricted areas to demonstrate compliance with the new dose
limit for individual members of the public? 10 CFR 20.1302
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73
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Table 1004(b).2 does not include entries for
"cold" neutrons, (e.g., 7 x 10E-9 MeV neutrons) which are used in
experiments at some research reactor facilities. What values of the quality
factor, Q, and the fluence per unit dose equivalent should be used for
"cold" neutrons?
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74
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Dose rates are used to establish posting
requirements for radiation areas, high radiation areas, and very high
radiation areas. 10 CFR 20.1601(a)(1), "Control of Access to High
Radiation Areas," refers to a "deep-dose equivalent" in
describing when a control device should be provided to reduce radiation doses
below 0.1 rem in one hour, thus implying that the "dose equivalent"
in the definition of a "high radiation area" is the "deep dose
equivalent" [at 10 CFR 20.1003
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75
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Representatives of the nuclear power industry have
expressed a concern regarding 10 CFR 20.1502, which requires licensees to
monitor individual internal or external doses for each individual likely to
exceed 10% of the applicable annual limit. Licensees are required to maintain
records of individuals for whom monitoring was required under 20.1502 [
20.2106(a)]. The handling of internal doses at less than 10% of the limit is
of particular 10 CFR 20.1502
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76
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The Department of Energy (DOE) does not assign a
50-year dose commitment in the year of intake for its workers exposed to
internally deposited radioactive material. The internal dose is assigned on
an annual basis. Will commercial nuclear power plant licensees be required to
assess internal 50-year dose commitment for workers coming from DOE
facilities? Some radionuclides encountered at DOE facilities may be beyond
the normal 10 CFR 20.1204
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77
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Representatives of the nuclear power industry are
concerned that the additional terms provided in the revised rule to describe
the "real estate" in and around commercial power plants seems to be
overlapping. This could lead to confusion. Access to these various areas may
also affect the category to which individuals working within these areas are
assigned. At nuclear power plants, either the "protected area" or
"radiation controlled area" may serve as the 10 CFR 20.1003
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78
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Under 20.1703(d), licensees must notify the NRC
Regional Director at least 30 days prior to first using respiratory
protection equipment pursuant to 20.1703(a) or (b). All current respiratory
protection programs have been documented under the provisions of 20.103(g)
which contains equivalent language. Do licensees need to "re-notify"
NRC if such notification has already taken place under the "old"
Part 20?
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79
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Many existing reactor Technical Specifications
require commercial power plant licensees to provide statistical personnel
dose summary to NRC annually. The old Part 20 contained provisions for such
reports, but no corresponding requirement carried over to the revised rule.
Why? 10 CFR 20.2206
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80
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The revised Part 20 ( 20.1003) provides definitions
of "member of the public," "public dose," and
"occupational dose." These definitions are not consistent with the
definition of "member(s) of the public" defined (for nuclear power
plants) in Generic Letter 89-01, Supplement 1 (NUREGs 1301 and 1302).
Consider that typically, one would expect any individual entering the
"restricted area" would 10 CFR 20.1003 NUREG-1301
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81
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(a) Are licensees required to provide instruction on
the procedures for declaring her pregnancy to an occupationally exposed woman
if she does not enter a restricted area? (b) Is it necessary to monitor all
(occupationally exposed) declared pregnant women?
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82
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Will workers who enter a restricted area and have
been determined to require monitoring under 20.1502(a) require monitoring in
the controlled area (outside the restricted area)? 10 CFR 20.1003
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83
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If a worker who has been exposed to internal sources
under Department of Energy Order 5480.11 comes to work at an NRC-licensed
facility, will the worker's committed and committed effective dose
equivalents need to be calculated for a fifty-year period by the licensee?
DOE Order 5480.11 only requires a one-year dose commitment calculation. 10
CFR 20.1204 10 CFR 20.2104
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84
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Can a female worker legally declare pregnancy if she
does not yet have documented medical proof? 10 CFR 20.1003
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85
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In 20.1902, posting of areas is based upon
"dose equivalent." Is this "deep," "shallow,"
"lens of eye," "total effective" or some combination of
the above? 10 CFR 20.1003
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86
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Does the term "per unit intake" in
Footnote 1 to 20.1202 refer to one event or to the entire monitoring period?
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87
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Will the numbering sequence of the revised
regulation be changed once the "old" Part 20 expires?
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88
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Will each NRC region hold orientation meetings for
licensees on the revised regulation? When and where might these occur?
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89
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Is it possible to obtain copies of revised NRC
"inspection modules" for inspection for compliance with the revised
regulation? How may these be obtained?
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90
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Can a licensee require its workers to routinely take
potassium iodide (KI) when handling large quantities of radioiodine and take
credit for the reduction in occupational dose that results from the use of
the KI?
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91
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As long as no credit is taken for the protection
provided by the respiratory protection equipment, the old Part 20, in 10 CFR
20.103(c), allows licensees to use this equipment without meeting the
requirements of 10 CFR 20.103(c)(1) through 20.103(c)(4), inclusive. Has this
"loophole" in the old Part 20 been closed in the revised Part 20?
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92
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At power reactor facilities, when the reactor is at
power, very high radiation areas (due to neutron and N-16 gamma radiation
fields) can exist inside the primary containment. At some facilities, these
areas inside containment are not readily locked, without substantial plant
modifications to make them lockable. In recognition of this situation, the
following controls are planned to meet the requirements of 10 CFR 20.1602 as
it relates to a 10 CFR 20.1003
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93
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In the definition of individual monitoring devices,
is there any reason electronic monitoring devices are not mentioned?
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94
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Why was the "controlled area" defined?
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95
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10 CFR 19.12 requires training (instruction) of
workers who enter a restricted area. Do individuals receiving occupational
doses in controlled areas need training?
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96
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(a) The roentgen (R) is not defined or used in
revised Part 20; however, many survey instruments and computer records show
dose rates in terms of "mR/h" or "R/h." Will these survey
instrument face pieces and computer forms have to be changed when revised
Part 20 is implemented? (b) Most radiation instrumentation is currently
calibrated in units of roentgens rather than rads. A roentgen of x- or
gamma-radiation in the energy range of 0.1 - 3 MeV produces 0.96 rad in 10
CFR 20.1003
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97
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10 CFR 20.1201(b) refers to "doses received
during accidents, emergencies, and . . . ." Is there any difference
between an "accident" and an "emergency"?
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98
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The following s concern the requirements of 10 CFR
20.1502 as applied to nuclear power plants. (a) Since the nuclear power
industry has had few intakes approaching the 10% criteria for adding internal
and external doses, is the historical record of intakes plus the
establishment of a corporate (licensee) policy to limit intakes to less than
10% of an ALI sufficient to exclude a
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99
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The following questions concern the relationship of
emergency plans for nuclear power plants to 10 CFR 20.1001
("Purpose") and 10 CFR 20.1101 )"Radiation Protection
Programs"). (a) To what extent do radiation protection programs need to
be established such that during emergency conditions, the revised Part 20 can
be complied with? (b) For example, in order to comply with the new EPA
"Manual of Protective Actions For Nuclear Incidents" October 15,
1991, do germanium 10 CFR 20.1001
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100
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(a) Is any special TLD monitoring of eye dose
equivalent required? (b) Do TLDs for eye dose measurement need to be
physically located near the eye? 10 CFR 20.1003 10 CFR 20.1201
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101
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10 CFR 20.1202(d) requires licensees to evaluate
and, to the extent practical, account for intakes through wounds or skin
absorption. What type of "evaluation" is appropriate for
determining absorption through the skin from skin contamination, and at what
"practical level" should it be accounted for? For what nuclides,
using what criteria can absorption be neglected under a certain threshold,
such as less than 10K, 100K of skin
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102
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Under 10 CFR 20.1302(b)(2)(ii), (a) do the words,
"If an individual were continually present in an unrestricted
area," mean that under these provisions it should be assumed a
hypothetical individual is there, or (b) should occupancy studies be made in
applying this section?
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103
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10 CFR 20.1302(b)(2)(ii) refers to "the dose
from external sources." (a) What are "external sources"? (b)
Are both (1) shine from the facility or from stored contaminated materials
and sources, as well as (2) cloud shine from effluents to be included?
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104
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10 CFR 20.1302 provides two options for
demonstrating compliance with the annual dose limit, in 10 CFR 20.1301, for
members of the public. How does 10 CFR 20.1302(b)(2), the second option,
provide demonstration of compliance with the annual dose limit for members of
the public who are in a controlled area? 10 CFR 20.1003
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105
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How should demonstration be made of compliance with
the 2 mrem in an hour limit [10 CFR 20.1301(a)(2)]? Is it adequate, for a
nuclear power plant, to demonstrate compliance by having effluent control
(trip) systems that prevent effluent releases from exceeding the limits on
the instantaneous release rates, and by performing periodic surveys during
radioactive material storage and movements?
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106
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(a) Are there no limits on airborne radioactivity
concentrations in the controlled area, other than de facto limits for public
dose to keep dose rates less than 2 mrem in an hour? (b) Would stack
effluents creating temporary airborne radioactivity concentrations greater
than DAC levels in the controlled areas be allowed, as long as the public
dose criteria of 10 CFR 20.1301 are met? (c) It appears that these areas
would not need to be "posted" or 10 CFR 20.1201
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108
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Can the surveys of radiographic exposure devices
performed under 10 CFR 34.43(b) and (c) be used to show compliance with 10
CFR 20.1906(f)? If so, is it sufficient to document the survey once, to
satisfy both requirements? 10 CFR 20.1906 10 CFR 34.43
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109
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(a) Can a cardiologist who performs both nuclear
cardiology and cardiac catheterization use a planned special exposure (PSE)
to perform an emergency cardiac catheterization on the last day of the
licensee's monitoring year if his annual exposure as of December 30 is 4.9
rem? It is expected that he will receive greater than 100 mrem during the
procedure. (b) Could the same cardiologist perform multiple cardiac
catheterization as PSEs 10 CFR 20.1003
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110
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Can a radiography licensee consider an individual's
exposure, received during a source retrieval, as a planned special exposure
if an approved generic procedure for source retrieval is on file? Assume that
this procedure addresses all the administrative and recordkeeping
requirements of 10 CFR 20.1206.
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111
|
Section 20.105(a) of 10 CFR Part 20 provides for
Commission authorization of radiation levels in unrestricted areas based on a
criterion of 500 millirems in one year to an individual in such areas. Does
such an authorization for radiation levels in an unrestricted area that could
result in a dose to a member of the public in excess of 100 millirems in a
year continue under 10 CFR 20.1301(c)? In other words is this considered an
"exemption" as 10 CFR 20.1008
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112
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A licensee authorizes a "planned special
exposure" in accordance with 10 CFR 20.1206 and the doses to the
involved individuals are fortuitously much lower than anticipated. In
retrospect, a planned special exposure authorization was unnecessary. May the
doses be assigned as "routine" doses on the Form 5 rather than recorded
as planned special exposure doses? 10 CFR 20.1206
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113
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If an NRC licensee employs an individual formerly
employed at a DOE lab and that individual's DOE lab dose record shows a CEDE
of more than 5 rems (but within DOE limits) must the NRC licensee consider
this an overexposure and reduce this individual's planned special exposure
allowance accordingly? 10 CFR 20.1206 10 CFR 20.1206
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114
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A licensee is required to provide individual
monitoring for each occupationally exposed individual who is likely to
receive, in a year, a dose in excess of 10% of the applicable limits in 10
CFR 20.1201, 10 CFR 20.1207, or 10 CFR 20.1208. Must a licensee account for
the exposure that an individual may receive at another licensee's facility,
if that worker transfers to another licensed facility during the monitoring
year, when determining if it is likely
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115
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The words, "e.g., containment or
ventilation," have been added to 10 CFR 20.1701. Does this mean that
increased emphasis is being placed on glove bags to do valve replacements,
repacks, etc. at nuclear power plants?
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116
|
10 CFR 20.2101(b) requires the licensee to make a
clear distinction among the dose quantities entered on the records and gives
examples of the following different dose quantities: total effective dose
equivalent, shallow dose equivalent, eye dose equivalent, deep dose
equivalent, committed effective dose equivalent. Does this mean (for example)
that the dose rates measured during surveys of external radiation fields must
be recorded in
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117
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Does the requirement of 10 CFR 20.2101(a) to use the
unit curie (for activity) mean that it will not be permissible to record the
results of contamination surveys in units of disintegrations per minute (dpm)
or mrad smearable?
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118
|
10 CFR 20.1101(c) requires that each licensee
"periodically (at least annually) review the radiation program content
and implementation." A nuclear power plant has many reviews and audits
(including quality assurance audits) of various aspects of their radiation
protection programs during a year and reviews are on a schedule that covers
all phases of the program on a 2-3-year review cycle. Is this acceptable to
the NRC?
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119
|
Is it permissible under 10 CFR Part 20 for a
licensee to have a controlled area that is controlled for purposes of
radiation protection but that is not a restricted area?
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120
|
Would a licensee be found to be in noncompliance
with the limit for the dose to an embryo/fetus if, at the time the woman
declared her pregnancy, the dose to the embryo/fetus exceeded 0.5 rem and the
embryo/fetus subsequently received more than 0.05 rem from licensed material
that was in the body of the woman before she declared her pregnancy.
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121
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10 CFR 20.1204(g) provides that when a mixture of
radionuclides in air exists, licensees may disregard certain radionuclides in
the mixture if the licensee uses the total activity of the mixture in
demonstrating compliance with the dose limits in section 20.1201 and if
certain other conditions are met. How can a licensee both disregard certain
radionuclides and use the total activity?
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122
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The conforming amendment to 10 CFR 50.73(a)(2)
states that reports submitted in accordance with 10 CFR 50.73(a)(2)(viii)
also meet the effluent release reporting requirements of 10 CFR
20.2203(a)(3). However, 10 CFR 20.2203(a)(3) requires reporting of
concentrations in an unrestricted area of 10 times any applicable limit in
Part 20 while 10 CFR 50.73(a)(2)(viii) requires reports of airborne or liquid
effluent releases that exceed 10 CFR 20.2203
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123
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In 10 CFR 20.1201(a)(1) does "annual
limit" for dose(s) mean the limit on doses received in a
"year" as defined in 10 CFR 20.1003? 10 CFR 20.1003
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124
|
Do the requirements of 10 CFR 20.1703(a) apply to
respiratory protection equipment that is to be used only in emergencies?
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125
|
10 CFR 20.1301(a)(2) requires that the
"dose" in any unrestricted area from external sources not exceed 2
mrem in any one hour. Which of the many "doses" in new Part 20 is
"the dose" in 20.1301(a)(2). 10 CFR 20.1003
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126
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Individuals performing assigned duties are often
exposed to small amounts of radiation from plant effluents at licensees'
sites under normal operating conditions. (a) If these individuals are likely
to receive, or have already received, in excess of 10% of an occupational
dose limit from external sources, does the licensee have to determine,
record, and report doses from the effluents to comply with the revised Part
20? (b) If so, what are the
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127
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10 CFR 20.1904(a), Labeling containers, indicates in
a parenthetical statement that "the radionuclides(s) present" may
now be intended to be a part of the information required to be included on
labels. In reply to comments on this rule, the preamble (56 FR 23380, first
column) provides a special interpretation for nuclear power plant licensees
as to acceptable methods for compliance for labeling fission and activation
product containers. Taken
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128
|
If a package containing radioactive material is to
be shipped, and marking the package as low specific activity (LSA) is the
only U.S. Department of Transportation (DOT) warning requirement, is labeling
under 10 CFR 20.1904(a) required? 10 CFR 20.1904
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130
|
10 CFR 20.1603(a), Footnote 2, exempts a nuclear
power plant from the requirements of 20.1603 unless a non-self-shielded
irradiator is used at the reactor. (a) If the source used for the calibration
of high-radiation instruments is non-self-shielded, and the absorbed dose at
1 meter distance could exceed 500 rads in 1 hour, is the source an
irradiator? (b) Do the provisions of 20.1603 (a) apply?
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131
|
10 CFR 20.1703(a)(3)(iii) requires that respirators
be tested for operability immediately prior to each use. How is this to be
done?
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132
|
How are nuclear power plant licensees to identify
the "potential" hazard using air sampling techniques as specified
in 10 CFR 20.1703(a)(3)(i)? (Air sampling is only useful in hazard
identification after radioactive material becomes airborne).
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133
|
10 CFR 20.1101(b) requires licensees to use, to the
extent "practicable," procedures and engineering controls based
upon sound radiation protection principles to achieve doses that are ALARA.
The ALARA concept emphasizes dose-reduction techniques that are reasonable
considering costs. However, "practicable" may imply something that
has been proposed and seems feasible but has not
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134
|
10 CFR 20.1101(c) requires a periodic (at least
annual) review of the radiation protection program as defined in 20.1101(a).
10 CFR 20.1101(a) refers to 10 CFR 20.2102 for recordkeeping requirements.
(a) Does the use of the word "audit" in 10 CFR 20.2102(a) require
records for all audits that are performed in addition to the periodic review?
(b) Are the reviews required by 10 CFR 20.1101(c) also considered to be
audits that are subject to the 10 CFR 20.1101
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135
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10 CFR 20.1206 permits a planned special exposure
(PSE) only if the alternatives that might avoid the higher exposure are
unavailable or impractical. Under certain conditions, the collective dose for
a task could be reduced if it could be performed by one worker receiving a
PSE, rather than by a series of several workers each receiving a dose less
than the limit. Under these conditions would the NRC consider the alternative
of using the series of
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136
|
10 CFR 20.1206 states that workers who will receive
a planned special exposure (PSE) must be informed regarding the risk from the
radiation exposure that is expected to be received. Radiation risk
coefficients presently available are applicable to large populations and are
not recommended for risk assessment for a small number of people. The
coefficients are not applicable to individual doses as small as PSEs. How are
nuclear power plant licensees expected to
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137
|
At a nuclear power plant, the individual asked to
approve a planned special exposure (PSE) will need to believe that the
alternatives are impractical or unavailable before doing so. But he or she
must recognize that the NRC inspector who later reviews the PSE report may
not agree, possibly leading to a notice of violation for an overexposure. If
the individual at the nuclear power plant chooses to request it from the
Region, can a decision be
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138
|
Although it is extremely unlikely, long-lived
residual radioactive material in the body of a female worker from her
previous employment could deliver a dose exceeding the limit to a
subsequently conceived embryo/fetus. For example, a former DOE worker who had
been involved in an accident could have a large americium or plutonium body
burden. 10 CFR 20.1208 makes no special provision for this eventuality. What
action would the NRC expect
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139
|
In-vivo measurements for an incoming worker could
indicate that the worker's internal dose, as determined and recorded by the
preceding licensee, was incorrect. What action would the NRC expect the
current licensee to take
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141
|
10 CFR 20.2110 requires adequate safeguards against
tampering with and loss of records. For data stored in electronic systems,
what safeguards are acceptable?
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142
|
(a) In compliance with 10 CFR 20.2104(a)(2), what
constitutes an acceptable attempt to obtain a record of the lifetime dose for
a worker? (b) Since there are no limits for lifetime doses (other than
planned special exposures), and lifetime dose reports to workers are not
required, why must licensees go to the expense of obtaining and recording
these doses?
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143
|
10 CFR 20.2104(c) states in three places that
licensees may accept or obtain dose data from the most recent employer. The
most recent employer may not be the licensee at whose facility the worker was
most recently exposed. Will it be permissible to accept or obtain the data
from the most recent facility at which the worker was exposed? (Small
contractors often do not have the data. Nuclear power plant licensees in
general would much prefer to continue
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144
|
When will licensees be permitted to use weighting
factors other than one to determine and record external whole body dose
(effective dose equivalent from external sources) as the occupational dose of
record?
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145
|
Automated personnel contamination monitors
("portal monitors") are used at nuclear power plants to detect
radioactive surface contamination on the skin and clothing of workers. The
alarm setpoints for these monitors are maintained very low to detect low
levels of surface contamination and hot particles. Implementation of the
"respirator ALARA rule," [10 CFR 20.1702 and 20.1703(b)(1)] may
result in intakes of radioactive material by workers that
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146
|
The term "not present," which is defined
in paragraph 5 of the Note (concerning mixtures of radionuclides) following
Appendix B of the old Part 20, is not defined in the corresponding
"Note" in the revised Part 20. Does this definition from the old
Part 20, which indicates when a radionuclide may be considered as not present
in a mixture, continue to apply in the revised Part 20? 10 CFR 20 Appendix B
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147
|
10 CFR 20.1501(b) requires the licensee to ensure
that instruments and equipment used for quantitative radiation measurements
are calibrated periodically; however, there is no corresponding requirement
in old Part 20. Does this new requirement mean that the accuracy and
frequency of such calibrations that have been found acceptable by the NRC in
the past will not be acceptable under the revised Part 20?
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148
|
What is the dose limit for a member of the public in
a restricted area?
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149
|
10 CFR 20.1003 defines the shallow-dose equivalent
as the dose equivalent at a tissue depth of 0.007 cm. (a) Does this mean that
the dose to the skin of the whole body is the sum of the non-penetrating dose
equivalent (beta and low energy photons) and the deep dose equivalent? (b) Is
it proper to calculate the extremity dose by summing the dose equivalent
measured on an extremity dosimeter (which may only be worn for part of the
monitoring period)
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150
|
10 CFR 20.1003 defines tissue monitoring depths of
0.007, 0.3, and 1 cm for shallow, eye, and deep-dose, respectively; (a) Is it
important to measure at (or extrapolate the measurements to) these exact
depths? (b) could the eye and deep-dose both be determined at 0.3 cm?
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172
|
(a) If the annual limit to the head is five rem deep
dose equivalent, what is the purpose of the 15 rem eye dose equivalent? (b)
How can a person receive 15 rem eye dose equivalent without exceeding the
annual TEDE limit?
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175
|
A health care worker serves in a dual nuclear
medicine and radiology position. The worker wears a dosimeter on the waist
and a dosimeter at the collar. During fluoroscopy procedures, which is the
primary source of exposure, the worker wears a lead apron that covers the
waist dosimeter, but not the collar dosimeter. Over the course of a year, the
worker receives a dose of 5.2 rem as measured by the collar dosimeter and 1.7
rem as measured by the
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176
|
10 CFR 20.1201 (a)(2)(ii) states a limit of "A
shallow-dose equivalent of 50 rem (0.50 Sv) to the skin or to any
extremity." (a) Can a person receive 50 rem shallow dose equivalent to
the skin of the lower arm (extremity) and 50 rem shallow dose equivalent to
the upper arm (non-extremity), without having an overexposure? (b) Can a
person receive 50 rem shallow dose equivalent to the left upper arm, then the
same dose to the right upper arm, 10 CFR 20.1003 10 CFR 20.1201 Outdated (see NUREG 1736)
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177
|
(a) If a worker is exposed to an external source
such that his head is the maximally exposed area of the body, are the doses
to the head limiting, since the head is not included under the definition of
"extremity?" (b) What is the annual dose limit to the head,
assuming no other internal or external dose?
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179
|
If a licensee implements the revised Part 20 in
July, 1993, is the licensee required to go back and evaluate internal dose
for the purpose of determining total effective dose equivalent for the year?
10 CFR 20.1202
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180
|
Does the word "also" as used in 20.1202(c)
mean intake by oral ingestion and inhalation, or oral ingestion and external
exposure? 10 CFR 20.1202
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183
|
If an individual receives an intake of Class Y
material in September and, pursuant to 10 CFR 20.1204(d), the licensee waits
7 months to record the dose (March), what year should the dose be recorded?
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191
|
Is a licensee required to provide dosimeters to an
individual during a planned special exposure (PSE) that would only be worn
during the PSE? 10 CFR 20.1206 10 CFR 20.2105
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192
|
10 CFR 20.1206(e) says that licensees may not
authorize PSEs for workers whose doses from previous PSEs and all "doses
in excess of the limits" exceed certain limits. (a) What and whose
limits apply? (b) Does the actual limit (e.g. 3 rem/quarter, 1.25 rem/quarter,
etc.) apply, or does the equivalent annual limit apply? (c) Do doses from
non-licensed sources (e.g., x-ray sources) that were in excess of the
facility's limits apply, 10 CFR 20.1001 10 CFR 20.1206 10 CFR 20.2104
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201
|
Why is it that releases to sanitary sewers are not
included in the dose limit for members of the public while other effluent
releases are?
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203
|
Can you have radiation levels in excess of 2
millirem in one hour or 100 millirem per year in a controlled area if the
public is not allowed to enter the area?
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204
|
(a) Licensees may apply under 10 CFR 20.1301(c) to
operate at a higher annual dose limit of 500 millirem to individual members
of the public. How long will this 500 millirem limit apply to the licensee?
(b) Can a licensee apply for an authorization to operate at this higher limit
indefinitely?
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205
|
(a) 10 CFR 20.1301(a)(2) requires that the dose in
any unrestricted area from external sources does not exceed 2 millirem
"in any one hour." Since this is not an instantaneous limit, can
the licensee operate at levels much higher than 2 millirem per hour for a
very short period of time (e.g., 90 millirem /hr for 1 minute, then no dose
for the rest of the hour)? (b) If so, how is the 2 mrem in any one hour
inspectable? 10 CFR 20.1301
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206
|
Can a licensee allow radiation levels of 5 mR or
more in one hour in an area without limiting access to the area? 10 CFR
20.1003
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|
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207
|
The dose limits for an individual member of the
public as specified in 10 CFR 20.1301 are specified in terms of rem. Since
rem is an absorbed dose, must an individual be present for the dose limit to
apply? 10 CFR 20.1301
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208
|
Is the licensee required to use the most accurate
method for determining compliance with dose limits or is it allowable to use
any one of the acceptable methods (assuming the acceptable method yields the
lower dose)?
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209
|
(a) Does the revised Part 20 require that meters be
calibrated? (b) If so, is the calibration frequency specified?
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210
|
10 CFR 20.1501(c) requires a dosimetry processor to
be NVLAP accredited. DOE also has an accreditation program. Do
DOELAP-accredited processors meet the requirements of 10 CFR 20.1501(c)?
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211
|
20.1502(a)(2) and (b)(2) say that monitoring is
required for declared pregnant women "...likely to receive, in 1
year,..." a dose in excess of 10 percent of the applicable limits for
the embryo/fetus. (a) What year does this refer to? (b) Since the gestation
period is 9 months (and since monitoring would begin after the declaration,
which may be several months into a pregnancy), why does the regulation use a
year? (c) The licensee badges a declared 10 CFR 20.1003
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212
|
A licensee makes a prospective determination that
adult workers in Department W are not likely to receive doses in excess of
10% of the limits from external sources, so external dosimetry is not
required by 20.1502. The workers in Department W complain when their TLD
badges are taken away, so the licensee decides to leave them badged, but not
to demonstrate compliance with the occupational dose limits of the revised
Part 20. (a) If an inspector finds 10 CFR 20.1502
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213
|
(a) Who is responsible for monitoring a
representative from a service company while the individual is on-site at a
licensee's facility performing duties that may result in an occupational dose
from sources owned/possessed by the licensee? (b) Where should the results of
the monitoring be maintained? 10 CFR 20.1502
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214
|
(a) If the individual had not been monitored at his
previous employer while receiving an occupational dose (i.e., the dose there
had been determined not likely to exceed 10% of the limits), and the current
employer, Licensee Z, determines in advance that the worker's annual dose for
both licensees will exceed 10% (although the dose at Licensee Z will not
exceed 10%), must Licensee Z monitor for external dose? (b) If the individual
worked for 10 CFR 20.1502 10 CFR 20.2104
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215
|
An individual works concurrently at Licensees W, X,
Y, and Z. All four licensees make a prospective determination that external
doses will not exceed 10% of the limits at their own facility. Must any of
the licensees monitor for external dose?
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216
|
Will Regulatory Guide 10.8 be revised to include
guidance on monitoring external dose (and demonstrating compliance with the
annual occupational dose limits) for health personnel working in several
hospitals simultaneously? [Note: This is a common practice for physicians in
Hawaii and there is no good mechanism for licensees to track where the
physicians work outside the facility]
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217
|
How will licensees handle cases where occupationally
exposed workers inform the licensee that they are concurrently being exposed
(and/or monitored) at another facility, but refuse to name the other
facility? (Note that if the worker is under contract, the other facilities
may be competitors of the licensee). 10 CFR 20.1201
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218
|
10 CFR 20.1601(a)(1) says that the control devices
must cause the radiation level to be reduced "upon entry." (a) Must
the devices preclude authorized or unauthorized entry? (b) At what point must
the control devices activate, when a person passes the final 30 cm before, or
entry itself?
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219
|
10 CFR 20.1601 requires control of access to high
radiation areas. It provides an exception for access to hospital areas with
patients containing radioactive material, "provided that there are
personnel in attendance . . ." who will take certain specified
precautions. (a) Does a nursing station within line-of-site of a patient's
room satisfy the requirement? (b) Does a nursing station controlling access
to a ward, but not in the 10 CFR 20.1601
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220
|
10 CFR 20.1602 gives requirements for control for
access to very high radiation areas, and has no exemption clause. 10 CFR
20.1003 defines a very high radiation area. (a) Are teletherapy rooms or
fixed/field radiography facilities, with beams that can deliver in excess of
500 rad in 1 hour at 1 meter, very high radiation areas? (b) Do the
requirements in 20.1602 apply to teletherapy rooms or fixed/field radiography
facilities? 10 CFR 20.1003
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221
|
Since the posting requirements are all in terms of
deep dose equivalent, what requirements should be followed when posting for
low energy beta radiation? 10 CFR 20.1901
|
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223
|
Are radiographers exempt from posting at a temporary
field site, under 10 CFR 20.1903(a), since they perform radiography in each
area less than 8 hours, attend the material to prevent exposure of
individuals in excess of the limits (i.e., have clear sight over the
designated area and are in constant attendance), and control the area (i.e.,
tell individuals to leave if they come too close to the source)? 10 CFR
20.1903
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224
|
10 CFR 20.1903(a) gives exemptions to posting
"caution signs" under certain conditions. Since 10 CFR 20.1902
specifies "danger" signs, instead of caution signs, (e.g.,
"grave danger, very high radiation area"), do the exemptions in 10
CFR 20.1903 apply to these "danger" areas as well? 10 CFR 20.1902
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226
|
(a) Under 10 CFR 20.1904, what is a container? (b)
How big can a container be? (c) Can a room be considered a container? (d) Is
a transportation cask a container when it is not being transported? (e) Are
vehicles (e.g., trailer of a tractor-trailer) containers? 10 CFR 20.1904
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227
|
(a) Must gauge licensees perform a survey of each
gauge package (if the package is labeled with a DOT label) for contamination
and radiation levels upon receipt of the package? (b) What surveys must a
licensee perform during routine operation where portable gauges are
transported daily from site to site, then returned to a storage location? 10
CFR 20.1906
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228
|
A licensee (e.g., radiographer, moisture density
gauge operator, well logger) has a source that the licensee transports to
temporary job sites in a licensee-owned vehicle. 10 CFR 20.1906(f) exempts
the licensee from doing contamination surveys during routine operations, but
does not exempt the licensee from performing surveys for radiation levels.
(a) When must the licensee perform such surveys (i.e., when is the package
"received")? Is it only after returning 10 CFR 20.1906
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229
|
Will the radiographers have to wipe test the sealed
source upon receipt (10 CFR 20.1906(b)(1)) even if the manufacturer has
performed a recent leak test on the source? 10 CFR 20.1906
|
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230
|
10 CFR 20.1906(a) gives specific requirements for
packages containing radioactive material in excess of Type A quantities; it
is not followed by the word "and." 10 CFR 20.1906(b) appears to
apply to all packages as containing radioactive material, or labeled packages
that are crushed, wet, or damaged. Is it a correct statement that 10 CFR
20.1906(b) requirements have nothing to do with Type A quantities, and that
(a) and (b) are independent 10 CFR 20.1906
|
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371
|
10 CFR 20.2104(c)(1) states that a licensee may
accept, as a record of the occupational dose that the individual received
during the current year, a written signed statement from the individual. If
this was done and the statement is false, would a resulting exposure greater
than 5 rem in the year be considered an overexposure and a violation?
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372
|
When monitoring of internal exposure is required by
10 CFR 20.1502, 10 CFR 20.1204(a) requires the licensee to take
"suitable and timely" measurements. Will NRC define what is
suitable and timely to avoid differences of opinion among inspectors? 10 CFR
20.1204
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373
|
What are the minimum requirements for height and
access restrictions of barriers used to prevent entry to locked high
radiation areas (HRAs) and very high radiation areas (VHRAs) at nuclear power
plants? 10 CFR 20.1601
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374
|
In general, do established respirator effectiveness
programs at nuclear power plants meet the intent of the regulation in
providing assurances of the effectiveness of chosen respiratory protection?
10 CFR 20.1502 10 CFR 20.1703
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375
|
In supporting a conclusion that individual
monitoring of internal occupational dose is not required [10 CFR 20.1502(b)]
and, therefore, that summing of internal and external dose is not required
[10 CFR 20.1202(a)], what is considered to be acceptable for bioassay
frequency, DAC-hour administrative limit, and whole-body counting minimum
testing level? 10 CFR 20.1202 10 CFR 20.1502 10 CFR 20.1703
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376
|
"Decay in storage" is one means of waste
disposal authorized in the revised Part 20 [10 CFR 20.2001(a)(2)]. How can
"decay in storage" be used for wastes (a) at nuclear power plants
and (b) at materials facilities?
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377
|
Are licensees required by 10 CFR 19.13 to report to
individuals the results of monitoring performed but not required under 10 CFR
20.1502? 10 CFR 19.13 states that radiation exposure data shall be reported
to the individual, and that "the information reported shall include data
and results obtained pursuant to Commission regulations, orders or license
conditions, as shown in records maintained by the licensee pursuant to
Commission regulations. 10 CFR 19.13
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378
|
If a worker formerly monitored at the licensee's
facility as a "declared pregnant woman," requests that her exposure
records be forwarded to her current employer, should related embryo/fetus
dose records also be forwarded if not specifically requested? 10 CFR 19.13
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379
|
Should radioactive noble gas concentrations be
excluded (a) with regard to evaluating and posting Airborne Radioactivity
Areas and (b) in determining Derived Air Concentration-hours (DAC-hours)? The
definition of Airborne Radioactivity Area refers to areas where airborne
radioactivity concentrations exceed the DAC values or where an individual
could exceed 12 DAC-hours in a week. DAC is defined as the
"concentration of a specific 10 CFR 20.1003
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380
|
Nuclear power plant licensees are required to meet
the quality assurance criteria in 10 CFR Part 50 Appendix B. Regulatory Guide
1.33 describes a program acceptable to the NRC staff to demonstrate
compliance with 10 CFR 50 Appendix B requirements and includes guidance
regarding the documentation, use of procedures and periodic review of
radiation protection programs. Does commitment to and conformance with 10 CFR
Part 50 Appendix B and Regulatory
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381
|
(a) For nuclear power facilities does conformance
with Regulatory Guides 8.8 and 8.10 fully meet the requirements of 20.1101(b)
regarding ALARA programs? (b) If not, does the NRC plan to update these
Regulatory guides to conform to new requirements?
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382
|
Do NRC regulations allow a declared pregnant woman
to "undeclare" her pregnancy? If so, does this withdrawal of a
previous declaration of pregnancy also oblige the licensee to withdraw restrictive
measures and enhanced monitoring established solely to comply with related
embryo/fetus dose limits?
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383
|
Reports of planned special exposures (PSEs) are
required by 10 CFR 20.2204 to be submitted within 30 days of the PSE to the
NRC Regional Office. Complete records of PSEs are required to be maintained
in accordance with 10 CFR 20.2105 and the monitoring results for PSEs should
be recorded on NRC Form 5 or equivalent in accordance with the guidance in
Regulatory Guide 8.7, Revision 1. (a) Are the PSE dose reports also required
to be submitted to 10 CFR 20.1206 10 CFR 20.2204 10 CFR 20.2206
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384
|
Nuclear power plant licensees are required to meet
the criteria in 10 CFR 50 Appendix I and 40 CFR 190 with regards to
maintaining doses to individual members of the public ALARA. Related
Regulatory Guides (e.g., 1.21, 1.109, and 4.1) describe programs which are
acceptable to the NRC staff to demonstrate compliance with 10 CFR 50 Appendix
I and 40 CFR 190 criteria. Specific requirements for monitoring, sampling,
dose calculation and 10 CFR 20.1301
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385
|
Do licensees have discretion regarding the form and
applicability of additional posting and barriers for individual high
radiation areas (HRAs) that are located within a larger area posted and
barricaded (e.g., with a locked door) as an HRA or inside a posted HRA
control point? If licensees must post and barricade such individual HRAs at
each area's entrance, then "double posting" results. Double posting
has long been a concern due to the 10 CFR 20.1601
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386
|
In evaluating whether to require the use of
respirators to limit intakes, it is found that wearing a respirator will
likely increase the total effective dose equivalent (TEDE). However, the
workers request that they be allowed to wear respirators to limit intakes,
despite the results of the evaluation. With regard to NRC regulation, what
discretion may the licensee exercise in this circumstance? 10 CFR 20.1702 Outdated (see NUREG 1736)
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387
|
In evaluating the use of respirators to limit
intakes, in addition to determining the total effective dose equivalent
(TEDE), should the evaluation and subsequent decision on whether to use
respirators also consider industrial safety hazards associated with wearing
respirators? For example, added effort increasing the probability of heat
stress, limited range of vision while climbing, or difficulty of maneuvering
readily while working 10 CFR 20.1702
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388
|
In regard to 91 (previously answered in the third
set of QAs;), can NIOSH approved respiratory equipment which makes use of a
combination particulate filter and iodine sorbent with a protection factor
for particulates be used in a mixed particulate and iodine atmosphere to
limit intakes? This practice would seem valid for equipment that is NIOSH
approved and has a protection factor for particulates. 10 CFR 20.1702
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389
|
The revised 10 CFR 20 includes a new provision that
allows disposal of licensed material "...by decay in storage..."
What criteria should be used in implementing this provision? Is the NRC
planning to develop generic guidance for "decay in storage"?
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390
|
During 1993, there may be radiation workers
transiting between licensees that have, and have not, implemented the revised
Part 20. (a) In the case of a worker whose dose was monitored earlier in the
year at a licensee that has implemented the revised Part 20 and is now in
processing at a licensee that has not implemented the revised Part 20: (1)
Should "whole body dose" be taken as the "total effective dose
equivalent" (TEDE) or as the "deep
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391
|
(a) Are records maintained by nuclear power plants
that satisfy the requirements of 10 CFR Part 50, Appendix I, and related
regulatory guidance sufficient to demonstrate compliance with the
requirements of 20.2107? (b) If not, what additional records are required?
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392
|
What monitoring period should be used in annual
individual monitoring reports submitted, in accordance with 10 CFR 20.2206,
following the first year of revised 10 CFR Part 20 implementation, if the
period of implementation did not encompass the full year? For example, if a
licensee implements the revised 10 CFR Part 20 on July 1, 1993, is the
licensee required to provide annual individual monitoring reports early in
1994 that cover the entire year,
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393
|
Is it acceptable for regulatory purposes that
occupational dose data that are being provided on a voluntary basis (i.e.,
the results of dose monitoring provided that is not required by regulation)
be recorded and reported only in part? The purpose in asking this question is
to establish whether or not the revised Part 20 provides the flexibility for
licensees to record and report the results of "monitoring performed but
not required" without
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394
|
Are the results of dose monitoring of minors and
declared pregnant woman performed in accordance with 20.1502 required to be
reported to NRC as part of the annual reporting of individual monitoring
results? (b) If so, are the records of dose to the embryo/fetus, which may
differ from records of dose to the declared pregnant woman, required to be
submitted as part of the annual reporting of individual monitoring results?
It would seem 10 CFR 20.1208 10 CFR 20.1502
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395
|
If an individual is monitored several times during a
year by the same licensee (e.g., during two monitoring periods separated in
time), how should the monitoring period(s) be designated in the annual
individual monitoring report required by 10 CFR 20.2206 (i.e., on the NRC
Form 5 or equivalent)? Due to the possible limitations in the format and
structure in licensee's computerized occupational dose recordkeeping systems,
it seems that there should
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396
|
The Appendix B tables of the revised Part 20 include
ALIs and DACs for daughter radionuclides, in contrast to the Appendix B
tables in the "old" Part 20, which do not include these daughter
radionuclides. For example, ALIs and DACs for rubidium-88 and cesium-138 are
listed. Are the listed ALIs and DACs expected to be considered separately
with regard to posting and other requirements in the revised Part 20?
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397
|
After implementation of the revised 10 CFR Part 20,
should nuclear power plant licensees report total effective dose equivalent
(TEDE) or deep dose equivalent (DDE) as the "whole body dose" for
annual reports submitted in accordance with reactor technical specifications
and Regulatory Guide 1.16? Regulatory Guide 1.16
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398
|
Regulatory Guide 8.7 (Section C.2.2) states that
"if during the course of the year the dose to date for the year exceeds
1 rem CEDE [committed effective dose equivalent] or the individual receives
an overexposure in another dose category, the CDE [committed dose equivalent]
to the maximally exposed organ must be calculated, recorded and
reported." If an individual arriving from work at another (previous)
licensee's facility within the current 10 CFR 20.1502
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399
|
The NRC Form 5 (Item No. 8) provides for entry of
multiple NRC license numbers. Some licensees may hold multiple licenses and
provide common monitoring (e.g., a single set of dosimeters) for personnel
working under any or all of the licenses. In such cases, it is proposed that
only a single NRC Form 5 would be generated for each individual, listing all
licenses under which they were monitored under 20.1502. Is this acceptable to
satisfy 10 CFR 20.2106 10 CFR 20.2206
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400
|
NRC Form 5 (Item No. 10B) includes the symbol
"V", which is not defined in Regulatory Guide 8.7, Revision 1. (a)
Does the "V" signify "vapor" as used in Federal Guidance
Report No. 11? (b) If so, how is this lung clearance class to be applied in
operational air sampling and internal dosimetry programs? 10 CFR 20.2106 10
CFR 20.2206
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401
|
NRC Form 5 (Item No. 20) provides for the signature
of the licensee's authorized representative responsible for the data and is
not noted as "optional" as is the licensee signature block on NRC
Form 4. Appendix A of Regulatory Guide 8.7, Rev. 1, "Instructions for
Recording and Reporting Occupational Radiation Exposure Data," provides
for the licensee to sign the transmittal letter for electronic transmission
of exposure data to the NRC and 10 CFR 20.2106 10 CFR 20.2206
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402
|
NRC Form 5 (Item No. 21, "Comments")
implies that dose from a "hot particle" should be added to the
shallow dose equivalent, maximum extremity (SDE, ME - Block 14). However, IE;
Notice 90-48 states that "hot particle exposure will not be added to
skin doses from sources other than hot particles." (a) Should hot
particle doses be added to the shallow dose equivalent as implied? (b) If so,
should this dose be subtracted from the applicable dose 10 CFR 20.2106 10 CFR
20.2206
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403
|
NRC Form 5 (Item No. 10) provides for listing of
specific radionuclides in intakes that contribute to the recorded committed
effective dose equivalent (CEDE). When determining the CEDE only
significantly irradiated organs need be included in the calculations [10 CFR
20.1202(b)(3)]. An organ is considered to be significantly irradiated if the
product of the weighting factor and committed dose equivalent, per unit
intake, is greater than 10 CFR 20.2106 10 CFR 20.2206
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404
|
NRC Form 5 (Item No. 10) provides for reporting of
individual radionuclides involved in an intake. How does the NRC plan on
using this data (i.e., what is the NRC's purpose in collecting this data)? 10
CFR 20.2106 10 CFR 20.2206
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405
|
Regulatory Guide 8.25 (Section C.1.7) states that
"to determine whether the concentration exceeds the DAC over the short
term, the sample collection time should not exceed one hour. Shorter sample
collection times may be used if desired, but they are not required." a.)
Does this section mean to imply that the duration of a work zone air sample
should not exceed one hour if it may be used to determine whether an area
needs to be posted or 10 CFR 20.1902
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406
|
Regulatory Guide 8.36, "Radiation Dose to the
Embryo/Fetus," (Section C.1.3) states that "the determination of
external dose should include all occupational exposures of the declared
pregnant worker since the estimated date of conception."(a) If declared
pregnant worker has received occupational dose during this pregnancy while
working for a previous licensee, is it intended that the dose from the
previous licensee be obtained and included in estimating
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407
|
(a) Does Part 20 apply to emergency response
personnel such as city fire fighters? (b) If Part 20 does apply, would the
radiation dose received by the workers be considered to be an occupational
dose or a public dose?
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408
|
Background 10 CFR 20.2104 states that for each
individual for whom monitoring is required, the licensee must: 1.) Determine
the occupational radiation dose for the current year; and 2.) Attempt to
obtain the records of lifetime cumulative occupational radiation dose.
"Records of
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409
|
In complying with the 10 CFR 19.13(c) report
request, is it acceptable to report on a Form-4 dose received in the current
year as one monitoring period and dose received in prior years as another
monitoring period even if the prior years monitoring period exceeds one year?
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411
|
Under 10 CFR 19.12, what is the minimum training
that licensees must provide to visitors who will enter a restricted area
(where the occupational dose limits apply)?
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412
|
This question refers to the answer to Question 26(b)
under 20.1003. What is the basis for using a dose threshold to decide whether
a person is categorized as a member of the public or as occupationally
exposed? The definitions do not specify a dose threshold.
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413
|
This question refers to the answers to Questions 66
and 31 under 20.1003 and 20.1201, respectively, and to Question 26(d) under
20.1003. Simply designating an area as a restricted area so you can control
everyone at occupational dose limits is a perversion of every radiation
protection principle published. Of course, this is just my opinion. I hope
NRC will revise its interpretation of this definition. 10 CFR 20.1003
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414
|
This question refers to the answer to Question 6
20.1201. This answer does not directly answer the implied question, which is,
"if a person is assessed a history of 5 rem or more for the current
year, is that person permitted to receive any occupational dose?"
Implied in the answer is that if monitoring is not required, that person can
receive an occupational dose, presumably up to 500 mrem for 10 CFR 20.1201
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415
|
This question refers to the answer to Question 41
under 20.1201. This answer leaves open what is an acceptable frequency for
querying monitored workers. This is only an issue of monitored workers, isn't
it? In the interest of workload minimization, I suggest that an annual
query/reminder along with the required annual 10 CFR 19 dosimetry report is
adequate.
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416
|
This question refers to the answer to Question 84
under 20.1208. It has also been asserted that the declared pregnant woman
(DPW) declaration can be prospective. Are there any limits on how frequently
or how long a duration a person can declare they are in a DPW, e.g., 10
years? 10 CFR 20.1003
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417
|
This question refers to the answer to Question 29
under 20.1302. The statement that a licensee can require members of the
public to exit a controlled area at any time is not obvious, based on the
published rule. A controlled area is one to which access can be limited, but
that condition might exist only at certain times or under certain conditions
or the access limits might be of a nature other than strict prohibition. For
instance, it might be a 10 CFR 20.1003
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418
|
This question refers to the answer to Question 91 in
20.1703. Please clarify this response, as indicated below. (a) Can NRC
envision any purpose by which a licensee can use respiratory protection
devices without having an approved respiratory protection program, e.g.,
meeting the provisions of 20.1703?
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419
|
This question refers to the
answer to Question 129 in §20.1801. This is a very useful
interpretation, but it certainly is not
evident in the cited regulations. Is there related supporting
justification somewhere?
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420
|
This question refers to the answer to Question 55 in
20.2104. (a) Despite the quoted reference, 20.2104 only refers to
occupational radiation dose (why radiation when the defined term is
occupational dose?), which is defined in terms of "dose." (b) The
definition of dose does not include eye, shallow, or extremity doses. What is
the regulatory basis for including eye, shallow, and extremity doses within the
scope of 20.2104 where it is so 10 CFR 20.1003
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421
|
This question refers to the answer to Question 37 in
"Conforming Changes: 10 CFR Part 19." I sincerely hope that the NRC
will encourage licensees to simply file a memo to the effect that these
reports were done. Otherwise, the volume of paper will be ridiculous.
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422
|
This question refers to Question 95 under 10 CFR
Part 19 and 81 under 10 CFR 20.1502. Clearly there is a significant
population of occupationally exposed persons in unrestricted areas of whom
the licensee has no knowledge. Even among their own employees, the licensed
operation may be a small segment of the whole organization where license
management treats the rest of the organization as general public. So
presumably, the general principle of
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423
|
Standard Technical Specification (STS) 6.12 for
nuclear power reactors provides methods for control of access to high
radiation areas that are alternatives to the methods specified in a CFR Part
20. Power reactor licensees that have adopted this technical specification
are required to provide additional controls for access to high radiation
areas with dose rates greater than 1 rem/h in addition to the controls
required for access to high 10 CFR 20.1601 10 CFR 20.1602
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425
|
It appears that some of the oral ingestion ALIs in
Appendix B of 10 CFR 20 are sometimes associated with the wrong chemical
forms; is this the case?
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426
|
Are the noble gas ("submersion") DACs
based on a dose of 5 rem per year or 50 rem per year? Is the submersion dose
calculated at a depth of 1000 mg/square cm or 7 mg/square cm?
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427
|
The word "external" in 10 CFR
20.1302(b)(2)(ii) refers to any radiation source which could irradiate an
individual from outside the body. Since sources include both airborne
radioactive materials and contained sources, the dose from airborne
radioactive materials could be double-counted -- as a concentration pursuant
to 10 CFR 20.1302(b)(2)(i) and as direct radiation pursuant to 10 CFR 20.1302(b)(2)(ii).
In a situation where the licensee was approaching the 10 CFR 20.1301
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428
|
10 CFR 20.2102(a) requires the use of the units
curie, rad, rem, including multiples and subdivisions, on records required by
Part 20. May a licensee continue to use roentgen-based units (e.g., R, mR,
R/h, mR/h) in exposure control, radiation survey, and instrument and
dosimeter calibration records without conversion to rad or rem, provided that
assessed doses for individuals are recorded in units of rad or rem? 10 CFR
20.1003 10 CFR 20.2101 10 CFR 34.21 10 CFR 34.24 10 CFR 34.33
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429
|
A "Note" added to the answer to Question
126 clarifies the answer with respect to nuclear power plants. Does this
clarification also apply to non-power reactor facilities?
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430
|
Question 373 concerns the minimum requirements for
height and access restrictions of barriers used to prevent entry to locked
high radiation areas (HRAs) and very high radiation areas (VHRAs) at nuclear
power plants. Does this question and answer also apply to non-power reactors?
10 CFR 20.1601
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431
|
Although Question 385 does not refer to any
particular class of licensee (e.g., power reactor, non-power reactor,
materials), the answer to the question mentions only power reactor licensees
and material licensees. Does the answer to this question also apply to
non-power reactor or fuel cycle licensees?
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432
|
Questions 376 and 389 in section 10 CFR 20.2001
concern the use of the "decay in storage" option of 10 CFR
20.2001(a)(2) at nuclear power plants and at materials facilities. However,
it is not clear whether or not these questions and answers also apply to
non-power reactor facilities. How can this option be used at non-power
reactor facilities?
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433
|
Question 397 concerns a reporting requirement in
"reactor technical specifications." Does this , and the answer
provided, apply to non-power reactors?
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434
|
How are occupational dose limits applied in regard
to the revised Part 20 definition of "year"? The purpose of this
question is to obtain additional clarification of the intent and application
of the "year" as it is defined in the revised Part 20 and discussed
previously in Question 40. Apparently, licensees may establish a year that is
other than January 1 through December 31 (e.g., Question 40 addresses a year
that is from January 31 of one year
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435
|
The rule requires that "the assigned deep-dose
equivalent... must be for the part of the body receiving the highest
exposure. [The dose] may be assessed from surveys or other radiation
measurements for the purpose of demonstrating compliance with the occupational
dose limits, if the individual monitoring device was not in the region of
highest potential exposure." In the event of a hot particle exposure to
a portion of the whole body, it is
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436
|
Licensees are required to "reduce the dose that
an individual may be allowed to receive in the current year by the amount of
occupational dose received while employed by any other person." How
should this provision be applied to dose categories required to be monitored
by the current licensee, for which the individual's dose report (e.g., NRC
Form 5) from previous employment during the current year at another
licensee's facility indicates "NR" (not 10 CFR 20.1201 10 CFR
20.2104
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437
|
The rule provides for disregarding certain
radionuclides in a mixture of radionuclides in air if three conditions are
met. The conditions are: a. The licensee uses the total activity of the
mixture in demonstrating compliance with occupational dose limits and
monitoring requirements;
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438
|
In general, the nuclear power industry has concluded
that workers are not likely to exceed 10% of the annual limit on intake, and
therefore internal dose monitoring would not be required. However, some
nuclear power plant licensees plan to continue internal dose monitoring and
record and report monitoring results on a voluntary basis. (a) If the results
of both voluntary monitoring of the committed effective dose equivalent
(CEDE) and required
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439
|
If the employer has been informed, in writing, by a
female worker that she is pregnant, and the employer is not the licensee
(e.g., the employer is a contractor to the licensee), may the employer notify
the licensee of the declaration of pregnancy to establish applicability of
20.1208, Dose to an Embryo/Fetus, or must the woman herself make the
declaration to the licensee? 10 CFR 20.1003
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440
|
In order to terminate a declaration of pregnancy,
i.e., due to termination of the pregnancy or otherwise, must the female
worker inform the licensee or employer in writing? 10 CFR 20.1003
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441
|
If the declared pregnant woman's estimated date of
conception encompasses a previous period of employment at another licensee's
facility, what assumptions should be made by the current licensee for
compliance purposes under each of the following conditions? a. Until records
are received from the previous licensee; 10 CFR 20.1208
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442
|
Is the licensee required to advise personnel of the
provisions for declaring pregnancy, who work in the controlled area, have
been classified as "members of the public," and do not "work
in or frequent" any restricted area?
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443
|
Are licensees required to advise personnel of the
provisions for declaring pregnancy, who enter a restricted area, but do not
"work in or frequent" any restricted area (e.g., visitors on
tours)?
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444
|
In this example, it has been determined that an
individual will receive less than 100 mrems in a year while in the controlled
area, and the individual has therefore been classified as a member of the
public while in the controlled area. The individual also accesses and
performs work in the restricted area. In evaluating whether the individual
requires monitoring in the restricted area, may the evaluation be limited to
only the dose likely to 10 CFR 20.1003
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445
|
In this example, it has been determined that an
individual is not likely to exceed 5 rems shallow dose equivalent from any
sources with the possible exception of dose from hot particles. There is a
potential that exposure to an individual from a hot particle may occur and
that the dose to the individual from a hot particle, should it occur, may
potentially exceed 5 rems shallow dose equivalent. In this circumstance, may
the potential dose resulting
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446
|
In this example, an individual has worked at the
licensee's facility earlier in the current year and was required to be
monitored because the individual accessed a high radiation area. During this
period, the individual's monitored dose did not exceed 10% of a limit. Now
the individual is performing other work at the licensee's facility in the
restricted area, but no longer has access to high radiation area. An
evaluation based on the individual's new job 10 CFR 20.1502
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447
|
Is the spent fuel pool, when containing irradiated
fuel, required to be posted and controlled as a Very High Radiation Area
under any of the following circumstances: a. When there are no activities
underway involving the spent fuel pool? b. When underwater manipulation of
irradiated fuel or other irradiated hardware is underway? 10 CFR 20.1003 10
CFR 20.1602
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448
|
If irradiated hardware, suspended (e.g., on a
lanyard) in the spent fuel pool, is potentially reading greater than 500
rads/hour at one meter (i.e., if it were removed from the pool), does access
to this hardware require posting and control as a Very High Radiation Area?
10 CFR 20.1003 10 CFR 20.1601
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449
|
Detectable, minor intakes may result for some
individuals who do not wear respirators during specific radiological work
activities for the purpose of maintaining the total effective dose equivalent
(TEDE) as low as is reasonably achievable (ALARA), as required by regulation.
Such resulting intakes may involve substantial follow-up activities in terms
of bioassay, internal dose assessment, and responses to various monitor
alarms (e.g., hand-held
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450
|
Licensees are required to "secure from
unauthorized removal or access" licensed materials in storage, and to
"control and maintain constant surveillance" of licensed materials
not in storage, in controlled or unrestricted areas. The following questions
relate to the security and control of licensed materials in controlled areas
only, i.e., the questions are not intended to address unrestricted areas: 10
CFR 20.1003 10 CFR 20.1801 10 CFR 20.1802
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451
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May the codes "ND" (not detectable),
"NR" (not required), and "NC" (not calculated) be used
more generally in the radiation dose data blocks on the NRC Forms 4 and 5
than is implied by the instructions on the forms? The purpose in asking this
question is to clarify the guidance for filling out the forms provided in the
regulatory position and in the instructions on the reverse side of the NRC
Forms 4 and 5. The Form 5 instructions appear to limit 10 CFR 20.2104 10 CFR
20.2106
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452
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The following questions refer to the selection and
use of a half-mask face piece, as described in Appendix A, "Protection
Factors for Respirators": a. Footnote "g" of Appendix A states
that "this type of respirator is not satisfactory for use where it might
be possible (e.g., if an accident or emergency were to occur) for ambient
airborne concentrations to reach instantaneous values 10 CFR 20
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453
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Note 2 of Appendix B provides criteria for
determining the appropriate derived air concentration (DAC) for a mixture of
radionuclides where "the identity of each radionuclide in the mixture is
not known, but it is known that certain radionuclides are not present in the
mixture." In 20.1204, Determination of Internal Exposure, provisions are
made to disregard the concentration of any radionuclide that is less than 10%
of its DAC so 10 CFR 20 Appendix B 10 CFR 20.1202
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454
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What is the specific scope of the reports required
to be provided to workers in accordance with the various provisions of 10 CFR
Part 19.13? The provisions in question are as follows: a. Part 19, 19.13(b)
requires that licensees provide reports to workers annually of dose as shown
in records maintained by the licensee. Is the monitoring period covered by
this section 10 CFR 19.13
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455
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Part 50 license standard technical specifications
define "Dose Equivalent I-131" as "...that concentration of
I-131 (microcurie/gram) which alone would produce the same thyroid dose as
the quantity and isotopic mixture of I-131, I-132, I-133, I-134, and I-135
actually present..." and "the thyroid dose conversion factors used
for this calculation shall be those listed in NRC Regulatory Guide
1.109." (a) After implementation of the revised 10 CFR Part 20,
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456
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FSARs for Part 50 power reactor licensees typically
contain multiple references to current 10 CFR Part 20 concepts and
terminology, primarily with regard to describing aspects of the radiation
protection program. Updating of these references would be editorial in
nature, without any health and safety benefit, but would nevertheless divert
resources from potentially more significant matters. Additionally, these
changes would be submitted to 10 CFR Part 50
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457
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Some licensees have established administrative dose
control levels or guidelines, below regulatory dose limits, as a tool to
support supervisory and management involvement in dose minimization.
Procedures commonly describe certain review actions to be taken at successive
dose levels, with a higher level of management involvement at higher dose
levels. If an administrative dose control level or guideline is exceeded
without all of the described actions
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458
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Some Part 50 power reactor licensees have developed
"weighted" or "effective" derived air concentration (DAC)
values for airborne mixtures of radionuclides, on the basis that the mixtures
are well known and relatively stable, as demonstrated through periodic
analysis of primary sources (e.g., reactor coolant and other process fluids),
airborne and removable contamination samples, and waste streams (i.e., 10 CFR
61 analysis). These 10 CFR 20 Appendix B 10 CFR 20.1203 10 CFR 20.1204 10 CFR
20.1501 10 CFR 20.1502
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459
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In the answer to Question 379, the NRC addressed the
issue of whether noble gases should be included in assessing the requirement
to post an area as an airborne radioactivity area. This is intended to obtain
further clarification with regards to the two separate provisions that
require posting of airborne radioactivity areas. The first provision requires
posting of areas in which concentrations of airborne radioactive materials 10
CFR 20.1003 10 CFR 20.1502
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460
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Appendix B contains only one derived air
concentration (DAC) value for each radionuclide. The DAC provided in Appendix
B is derived from the more limiting of the stochastic or the non-stochastic
annual limit on intake (ALI). In Regulatory Guide 8.34 (Section 3.3) the NRC
provides guidance that the stochastic DAC should be used, in preference to
the non-stochastic DAC, to calculate the committed effective dose equivalent
(CEDE). This 10 CFR 20.1003 10 CFR 20.1502
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461
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Does the word "applicable" in the phrase
"applicable ALI(s)" in 10 CFR 20.1502(b)(1) mean that the
stochastic ALI(s) [SALI(s)] should be used? It is noted that 10 CFR
20.1502(b) requires the licensee to monitor the occupational intake and
assess the committed effective dose equivalent. We believe that the answer to
this question should be yes, if a licensee is operating under XT 707 02/07/95
Question 47: Will the NRC pr preparation of applications pursuant to 10 CFR
20.1204(c)(2) for approval to adjust DAC or ALI values to reflect the actual
physical and chemical characteristics of airborne radioactive materials
(e.g., aerosol size distribution or density)?
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