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"Questions and Answers Based on the Revised 10 CFR Part 20," (NUREG/CR-6204), is a collection of questions and answers that were originally issued in May 1994 to assist licensees and the public with the 1991 revisions to 10 CFR Part 20, "Standards for Radiation Protection." Although the questions have been reviewed by NRC staff, and represent NRC staff decisions and technical opinions on aspects of the revised 10 CFR Part 20, they do not constitute official legal interpretations.

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NUMBER

QUESTION

2

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

3

What do you do about hot particles? 10 CFR 20.1201

4

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

5

Who is responsible for regulating radium - the State or NRC? 10 CFR 20.1001 10 CFR 20.1002

6

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

7

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?

8

Under what circumstances are planned special exposures permitted?

9

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

10

Why does the revised Part 20 still require Form 4? 10 CFR 20.2104

11

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)?

12

How will the revised Regulatory Guides be used in determining acceptability of a licensee's implementation of the revised Part 20?

13

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?

14

Are Design Basis Accident criteria (doses) changed by the revised Part 20? 10 CFR 50 Appendix A

15

Will the reporting criteria of 10 CFR 50.72 and 50.73 have to be changed? 10 CFR 50.72

16

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

17

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?

18

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?

19

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?

20

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

21

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?

22

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

23

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?

24

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

25

Does the definition of a "member of the public" mean "all" individuals? If so why is the exception statement added to the definition?

26

(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)

27

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

28

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?

29

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?

30

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.

31

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

33

What is the dose limit for visitors entering a restricted area (e.g., visitors to a hospital, patients' relatives, escorted tourists)?

34

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

35

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?

36

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?

37

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?

38

Can the results of bioassays alone be used to determine if the licensee must sum internal and external doses under Part 20?

39

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?

40

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?

41

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).

42

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

43

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?

44

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

45

In determining the "eye dose equivalent," can credit be taken for shielding provided by eyeglasses/safety glasses?

46

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?

47

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)?

48

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.

49

For control of access to very high radiation areas, will physical barriers be needed to preclude unauthorized access?

50

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?

51

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

52

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

53

(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

54

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

55

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

56

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

57

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

58

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

59

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

60

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

61

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

62

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?

63

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

64

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)

65

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

66

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

67

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?

68

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

69

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

71

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

72

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

73

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?

74

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

75

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

76

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

77

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

78

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?

79

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

80

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

81

(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?

82

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

83

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

84

Can a female worker legally declare pregnancy if she does not yet have documented medical proof? 10 CFR 20.1003

85

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

86

Does the term "per unit intake" in Footnote 1 to 20.1202 refer to one event or to the entire monitoring period?

87

Will the numbering sequence of the revised regulation be changed once the "old" Part 20 expires?

88

Will each NRC region hold orientation meetings for licensees on the revised regulation? When and where might these occur?

89

Is it possible to obtain copies of revised NRC "inspection modules" for inspection for compliance with the revised regulation? How may these be obtained?

90

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?

91

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?

92

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

93

In the definition of individual monitoring devices, is there any reason electronic monitoring devices are not mentioned?

94

Why was the "controlled area" defined?

95

10 CFR 19.12 requires training (instruction) of workers who enter a restricted area. Do individuals receiving occupational doses in controlled areas need training?

96

(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

97

10 CFR 20.1201(b) refers to "doses received during accidents, emergencies, and . . . ." Is there any difference between an "accident" and an "emergency"?

98

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

99

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

100

(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

101

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

102

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?

103

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?

104

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

105

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?

106

(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

108

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

109

(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

110

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.

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

112

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

113

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

114

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

115

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?

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

117

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?

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?

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?

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.

121

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?

122

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

123

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

124

Do the requirements of 10 CFR 20.1703(a) apply to respiratory protection equipment that is to be used only in emergencies?

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

126

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

127

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

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

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?

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?

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).

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

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

135

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

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

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

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

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

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?

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?

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

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?

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

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

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?

148

What is the dose limit for a member of the public in a restricted area?

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)

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?

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?

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

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)

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?

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

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

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?

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

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

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?

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?

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?

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

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

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

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)?

209

(a) Does the revised Part 20 require that meters be calibrated? (b) If so, is the calibration frequency specified?

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)?

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

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

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

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

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?

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]

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

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?

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

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

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

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

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

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

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

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

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

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

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?

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

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

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

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

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?

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

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

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

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

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?

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?

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

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

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

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)

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

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

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"?

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

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?

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,

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

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

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

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?

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

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

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

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

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

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

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

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

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

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

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?

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

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?

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)?

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.

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

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

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.

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

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

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?

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?

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

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.

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

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

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?

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?

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

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

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?

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

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?

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?

433

Question 397 concerns a reporting requirement in "reactor technical specifications." Does this , and the answer provided, apply to non-power reactors?

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

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

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

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;

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

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

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

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

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?

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)?

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

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

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

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

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

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

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

451

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

452

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

453

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

454

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

455

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,

456

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

457

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

458

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

459

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

460

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

461

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)?