Question 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?
Answer: No. Some general guidance on what is suitable and
timely will be included in Regulatory Guide 8.9, Rev. l,
"Acceptable Concepts, Models, Equations, and Assumptions
for a Bioassay Program." Other than this general guidance,
the NRC staff has no plans to provide a definition of what
is "suitable and timely." That definition depends on the
circumstances of the particular exposure. What is
"suitable and timely" under revised Part 20 is (as before,
under old Part 20) a matter of professional judgement in a
good radiation protection program. NRC management will
resolve any "differences of opinion among inspectors" that
are called to its attention. (References: 10 CFR 20.1204,
10 CFR 20.1502)