Question 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, I&E 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
category with regard to remaining available shallow dose
equivalent (skin or extremity) for the year? Based on our
understanding of the intent of I&E Notice 90-48, we believe
that "hot particle" doses should not be subtracted from the
remaining available shallow dose equivalent (skin or
extremity) for the year.
Answer: The intent of the "hot particle" example in the
instructions for Item 21 on Form 5 is simply to give one an
example of how this space on the form might be used. There
is no intention to imply that hot particle doses should be
added to other doses. The question of adding hot particle
skin doses to other skin doses was addressed in IE
Information Notice 90-48, "Enforcement policy for Hot
Particle Exposures," and the enforcement policy enclosed
with that notice, and in Health Physics Position (HPPOS)
246 (in NUREG / CR-5569). The NRC policy and staff positions
in these documents have not been changed by revised Part 20
or the instructions for Form 5 in Regulatory Guide.
Answers to the specific questions are as follows: (a) As
indicated in HPPOS-246, licensees may choose whether or not
to add a hot particle dose to other skin or extremity
doses. However, in either case, the record should be clear
as to the amount of the hot particle dose. In determining
whether or not an overexposure has occurred, the NRC will
consider the hot particle dose alone, without adding it to
other doses.
(b) The hot particle dose should not be subtracted from the
remaining available shallow dose equivalent (skin or
extremity) for the year. (References: 10 CFR 20.2106, 10
CFR 20.2206, Regulatory Guide 8.7).