Question 98: The following questions 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
nuclear power licensee from the requirements for
"monitoring" intakes (10 CFR 20.1502) and adding internal
and external (except for specific intake instances)?
(b) Will the apparent new practice of minimizing TEDE and
allowing some intakes invalidate this historical basis and
essentially require nuclear power licensees to "monitor"
intakes?
(c) In determining whether a worker is likely to exceed
the 10% criteria, on what basis are projections to be made
of the future intake of contract workers (for the remainder
of the year after they leave our site)?
Answer: (a) Yes, assuming that the conditions of exposure
are not expected to change to the extent that they are
outside the bounds of that historical record and that
procedures will be put into effect to implement the policy.
However, "surveys", in accordance with 10 CFR 20.1501 (a),
would still be needed.)
(b) Not likely. However, the resulting potential increase
in intakes will need to be considered in determining
whether or not workers are likely to receive intakes in
excess of 10% of an ALI. The historical record should be
useful in evaluating this potential increase.
(c) Such projections are not required. As indicated in
draft Regulatory Guide DG-8010 ("Criteria for Monitoring
and Methods for Summation of Internal and External
Occupational Doses"), each licensee makes the determination
independently; doses that may have been received, or that
may be received in the future, at another licensee's
facility are not included in the determination of the
monitoring requirement. (Reference: 10 CFR 20.1502).