Some of the issues covered by the questions and answers have changed, but
the NRC staff has decided to make the database available to the public because
it contains much valuable information on health physics issues related to
regulation. The answers to the questions should not be considered authoritative
by themselves and should not be relied on for regulatory compliance.
Because Parts 19 and 20 are constantly being revised and updated, many of
the positions expressed in the databases may no longer be valid or relevant.
It is therefore necessary to check the current statement in the applicable
regulation or recent generic information (e.g., Information Notice, Regulatory
Issues Summary, etc.) to ensure that the requirements addressed in the position
have not changed.
For questions about these issues, consult one of the NRC staff listed below.
To reach a contact by telephone, please see the NRC
Telephone Directory.
See also "Consolidated Guidance: 10 CFR Part 20 - Standards for
Protection Against Radiation" (NUREG-1736).
File Name |
Size |
Date |
Description |
part20questions.pdf |
2M |
09/19/01 |
Eighth Set of Questions and Answers on the Major Revision of 10
CFR Part 20. |
hpqa.exe |
201K |
02/09/95 |
Self-extracting archive of the Questions and Answers Based on 10
CFR Part 20 Database. Place the file into the desired directory for
use and enter 'HPQA;' on the command line to extract database. |
hpqa.zip |
186K |
02/09/95 |
Archive of the Questions and Answers Based on 10 CFR Part 20 Database. |
qa1.html |
1.1K |
02/07/95 |
Question 1: If a licensee decides to implement Part 20 in mid-year,
how does the licensee treat the annual dose limits? Prorated? Add
contributions from beginning of year before the revised Part 20 was
adopted? |
qa10.html |
971 |
02/07/95 |
Question 10: Why does the revised Part 20 still require Form 4?
10 CFR 20.2104 |
qa100.html |
925 |
02/07/95 |
Question 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 |
qa101.html |
1.0K |
02/07/95 |
Question 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 |
qa102.html |
1.4K |
02/07/95 |
Question 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? |
qa103.html |
406 |
02/07/95 |
Question 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?
|
qa104.html |
913 |
02/07/95 |
Question 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 |
qa105.html |
1.3K |
02/07/95 |
Question 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? |
qa106.html |
1.4K |
02/07/95 |
Question 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 |
qa108.html |
792 |
02/07/95 |
Question 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 |
qa109.html |
1.6K |
02/07/95 |
Question 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 |
qa11.html |
438 |
02/07/95 |
Question 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)? |
qa110.html |
512 |
02/07/95 |
Question 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. |
qa111.html |
999 |
02/07/95 |
Question 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 |
qa112.html |
649 |
02/07/95 |
Question 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 |
qa113.html |
715 |
02/07/95 |
Question 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
|
qa114.html |
1.3K |
02/07/95 |
Question 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 |
qa115.html |
389 |
02/07/95 |
Question 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? |
qa116.html |
815 |
02/07/95 |
Question 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 |
qa117.html |
910 |
02/07/95 |
Question 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? |
qa118.html |
1.8K |
02/07/95 |
Question 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? |
qa119.html |
749 |
02/07/95 |
Question 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? |
qa12.html |
959 |
02/07/95 |
Question 12: How will the revised Regulatory Guides be used in determining
acceptability of a licensee's implementation of the revised Part 20?
|
qa120.html |
720 |
02/07/95 |
Question 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. |
qa121.html |
1.0K |
02/07/95 |
Question 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? |
qa122.html |
1.2K |
02/07/95 |
Question 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 |
qa123.html |
228 |
02/07/95 |
Question 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 |
qa124.html |
276 |
02/07/95 |
Question 124: Do the requirements of 10 CFR 20.1703(a) apply to
respiratory protection equipment that is to be used only in emergencies?
|
qa125.html |
504 |
02/07/95 |
Question 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 |
qa126.html |
1.7K |
02/07/95 |
Question 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 |
qa127.html |
1.5K |
02/07/95 |
Question 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 |
qa128.html |
831 |
02/07/95 |
Question 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 |
qa13.html |
2.5K |
02/07/95 |
Question 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? |
qa130.html |
914 |
02/07/95 |
Question 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? |
qa131.html |
530 |
02/07/95 |
Question 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? |
qa132.html |
1.3K |
02/07/95 |
Question 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). |
qa133.html |
1.6K |
02/07/95 |
Question 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 |
qa134.html |
1.1K |
02/07/95 |
Question 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 |
qa135.html |
857 |
02/07/95 |
Question 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 |
qa136.html |
1.4K |
02/07/95 |
Question 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 |
qa137.html |
1.5K |
02/07/95 |
Question 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 |
qa138.html |
1.7K |
02/07/95 |
Question 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 |
qa139.html |
451 |
02/07/95 |
Question 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 |
qa14.html |
454 |
02/07/95 |
Question 14: Are Design Basis Accident criteria (doses) changed
by the revised Part 20? 10 CFR 50 Appendix A |
qa141.html |
1.0K |
02/07/95 |
Question 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? |
qa142.html |
1.6K |
02/07/95 |
Question 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? |
qa143.html |
590 |
02/07/95 |
Question 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 |
qa144.html |
816 |
02/07/95 |
Question 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? |
qa145.html |
2.0K |
02/07/95 |
Question 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 |
qa146.html |
894 |
02/07/95 |
Question 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 |
qa147.html |
626 |
02/07/95 |
Question 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? |
qa148.html |
605 |
02/07/95 |
Question 148: What is the dose limit for a member of the public
in a restricted area? |
qa15.html |
384 |
02/07/95 |
Question 15: Will the reporting criteria of 10 CFR 50.72 and 50.73
have to be changed? 10 CFR 50.72 |
qa150.html |
840 |
02/07/95 |
Question 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? |
qa16.html |
1.1K |
02/07/95 |
Question 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 |
qa17.html |
423 |
02/07/95 |
Question 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? |
qa172.html |
1.3K |
02/07/95 |
Question 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? |
qa175.html |
1.6K |
02/07/95 |
Question 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 |
qa176.html |
1.4K |
02/07/95 |
Question 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 |
qa177.html |
635 |
02/07/95 |
Question 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? |
qa179.html |
950 |
02/07/95 |
Question 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 |
qa18.html |
864 |
02/07/95 |
Question 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? |
qa180.html |
628 |
02/07/95 |
Question 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 |
qa183.html |
519 |
02/07/95 |
Question 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? |
qa19.html |
631 |
02/07/95 |
Question 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? |
qa191.html |
569 |
02/07/95 |
Question 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 |
qa192.html |
1.6K |
02/07/95 |
Question 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 |
qa2.html |
868 |
02/07/95 |
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 |
qa20.html |
515 |
02/07/95 |
Question 20: Pertaining to Question 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 |
qa201.html |
1.2K |
02/07/95 |
Question 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? |
qa203.html |
739 |
02/07/95 |
Question 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? |
qa204.html |
1008 |
02/07/95 |
Question 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? |
qa205.html |
1.0K |
02/07/95 |
Question 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 |
qa206.html |
352 |
02/07/95 |
Question 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 |
qa207.html |
706 |
02/07/95 |
Question 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 |
qa208.html |
464 |
02/07/95 |
Question 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)? |
qa209.html |
586 |
02/07/95 |
Question 209: (a) Does the revised Part 20 require that meters be
calibrated? (b) If so, is the calibration frequency specified? |
qa21.html |
471 |
02/07/95 |
Question 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? |
qa210.html |
268 |
02/07/95 |
Question 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)? |
qa211.html |
1.7K |
02/07/95 |
Question 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 |
qa212.html |
1.2K |
02/07/95 |
Question 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 |
qa213.html |
633 |
02/07/95 |
Question 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 |
qa214.html |
1010 |
02/07/95 |
Question 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 |
qa215.html |
363 |
02/07/95 |
Question 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? |
qa216.html |
702 |
02/07/95 |
Question 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] |
qa217.html |
984 |
02/07/95 |
Question 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
|
qa218.html |
976 |
02/07/95 |
Question 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? |
qa219.html |
963 |
02/07/95 |
Question 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 |
qa22.html |
2.9K |
02/07/95 |
Question 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 |
qa220.html |
663 |
02/07/95 |
Question 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 |
qa221.html |
718 |
02/07/95 |
Question 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 |
qa223.html |
746 |
02/07/95 |
Question 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 |
qa224.html |
765 |
02/07/95 |
Question 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 |
qa226.html |
1.1K |
02/07/95 |
Question 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 |
qa227.html |
1.2K |
02/07/95 |
Question 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 |
qa228.html |
1.6K |
02/07/95 |
Question 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 |
qa229.html |
776 |
02/07/95 |
Question 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 |
qa23.html |
246 |
02/07/95 |
Question 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? |
qa230.html |
937 |
02/07/95 |
Question 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 |
qa24.html |
465 |
02/07/95 |
Question 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 |
qa25.html |
505 |
02/07/95 |
Question 25: Does the definition of a "member of the public" mean
"all" individuals? If so why is the exception statement added to the
definition? |
qa26.html |
13K |
02/07/95 |
Question 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 questions
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 |
qa27.html |
776 |
02/07/95 |
Question 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 |
qa28.html |
1.3K |
02/07/95 |
Question 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? |
qa29.html |
671 |
02/07/95 |
Question 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? |
qa3.html |
591 |
02/07/95 |
Question 3: What do you do about hot particles? 10 CFR 20.1201 |
qa30.html |
572 |
02/07/95 |
Question 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. |
qa31.html |
756 |
02/07/95 |
Question 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 |
qa33.html |
600 |
02/07/95 |
Question 33: What is the dose limit for visitors entering a restricted
area (e.g., visitors to a hospital, patients' relatives, escorted
tourists)? |
qa34.html |
412 |
02/07/95 |
Question 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 |
qa35.html |
493 |
02/07/95 |
Question 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?
|
qa36.html |
498 |
02/07/95 |
Question 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? |
qa37.html |
537 |
02/07/95 |
Question 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? |
qa371.html |
1.5K |
02/07/95 |
Question 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? |
qa372.html |
1003 |
02/07/95 |
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? 10 CFR 20.1204 |
qa373.html |
1.6K |
02/07/95 |
Question 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 |
qa374.html |
1.4K |
02/07/95 |
Question 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 |
qa375.html |
2.6K |
02/07/95 |
Question 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 |
qa376.html |
2.1K |
02/07/95 |
Question 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? |
qa377.html |
820 |
02/07/95 |
Question 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 |
qa378.html |
709 |
02/07/95 |
Question 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 |
qa379.html |
2.5K |
02/07/95 |
Question 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 |
qa38.html |
1.2K |
02/07/95 |
Question 38: Can the results of bioassays alone be used to determine
if the licensee must sum internal and external doses under Part 20?
|
qa380.html |
2.1K |
02/07/95 |
Question 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 |
qa381.html |
1.3K |
02/07/95 |
Question 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?
|
qa382.html |
1.1K |
02/07/95 |
Question 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? |
qa383.html |
1.4K |
02/07/95 |
Question 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 |
qa384.html |
1.8K |
02/07/95 |
Question 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 |
qa385.html |
2.5K |
02/07/95 |
Question 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 |
qa386.html |
2.1K |
02/07/95 |
Question 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 |
qa387.html |
1.3K |
02/07/95 |
Question 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 |
qa388.html |
794 |
02/07/95 |
Question 388: In regard to Question 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 |
qa389.html |
1.5K |
02/07/95 |
Question 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"? |
qa39.html |
545 |
02/07/95 |
Question 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? |
qa390.html |
2.8K |
02/07/95 |
Question 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 |
qa391.html |
572 |
02/07/95 |
Question 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?
|
qa392.html |
1.0K |
02/07/95 |
Question 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, |
qa393.html |
2.9K |
02/07/95 |
Question 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 |
qa394.html |
1.1K |
02/07/95 |
Question 394: (a) 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 |
qa395.html |
1.9K |
02/07/95 |
Question 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 |
qa396.html |
2.5K |
02/07/95 |
Question 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? |
qa397.html |
437 |
02/07/95 |
Question 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 |
qa398.html |
1.5K |
02/07/95 |
Question 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 |
qa399.html |
1014 |
02/07/95 |
Question 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 |
qa4.html |
1.4K |
02/07/95 |
Question 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 |
qa40.html |
1.2K |
02/07/95 |
Question 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? |
qa400.html |
943 |
02/07/95 |
Question 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 |
qa401.html |
1.3K |
02/07/95 |
Question 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 |
qa402.html |
2.0K |
02/07/95 |
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, 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 |
qa403.html |
2.0K |
02/07/95 |
Question 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 |
qa404.html |
2.7K |
02/07/95 |
Question 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 |
qa405.html |
918 |
02/07/95 |
Question 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 |
qa406.html |
1.3K |
02/07/95 |
Question 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 |
qa407.html |
1.5K |
02/07/95 |
Question 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? |
qa408.html |
1.7K |
02/07/95 |
Question 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 |
qa409.html |
702 |
02/07/95 |
Question 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? |
qa41.html |
2.3K |
02/07/95 |
Question 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). Will |
qa411.html |
1.2K |
02/07/95 |
Question 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)? |
qa412.html |
1.7K |
02/07/95 |
Question 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. |
qa413.html |
2.8K |
02/07/95 |
Question 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 |
qa414.html |
1.9K |
02/07/95 |
Question 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 |
qa415.html |
830 |
02/07/95 |
Question 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. |
qa416.html |
1.0K |
02/07/95 |
Question 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 |
qa417.html |
1.4K |
02/07/95 |
Question 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 |
qa418.html |
2.3K |
02/07/95 |
Question 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? |
qa42.html |
1.0K |
02/07/95 |
Question 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 |
qa420.html |
2.9K |
02/07/95 |
Question 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 |
qa421.html |
685 |
02/07/95 |
Question 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.
|
qa422.html |
1.4K |
02/07/95 |
Question 422: This question refers to Question 95 under 10 CFR Part
19 and Question 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 |
qa423.html |
1.5K |
02/07/95 |
Question 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 |
qa425.html |
561 |
02/07/95 |
Question 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? |
qa426.html |
2.2K |
02/07/95 |
Question 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? |
qa427.html |
1.7K |
02/07/95 |
Question 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 |
qa428.html |
5.4K |
02/07/95 |
Question 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 |
qa429.html |
946 |
02/07/95 |
Question 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? |
qa43.html |
1.3K |
02/07/95 |
Question 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? |
qa430.html |
837 |
02/07/95 |
Question 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 |
qa431.html |
626 |
02/07/95 |
Question 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? |
qa432.html |
1.0K |
02/07/95 |
Question 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? |
qa433.html |
612 |
02/07/95 |
Question 433: Question 397 concerns a reporting requirement in "reactor
technical specifications." Does this question, and the answer provided,
apply to non-power reactors? |
qa434.html |
1.6K |
02/07/95 |
Question 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 |
qa435.html |
1.0K |
02/07/95 |
Question 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 |
qa436.html |
1.5K |
02/07/95 |
Question 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 |
qa437.html |
1.0K |
02/07/95 |
Question 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; |
qa438.html |
1.4K |
02/07/95 |
Question 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 |
qa439.html |
685 |
02/07/95 |
Question 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
|
qa44.html |
842 |
02/07/95 |
Question 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 |
qa440.html |
511 |
02/07/95 |
Question 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
|
qa441.html |
2.1K |
02/07/95 |
Question 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
|
qa442.html |
512 |
02/07/95 |
Question 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? |
qa443.html |
272 |
02/07/95 |
Question 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)? |
qa444.html |
2.6K |
02/07/95 |
Question 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 |
qa445.html |
1.1K |
02/07/95 |
Question 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 |
qa446.html |
1.2K |
02/07/95 |
Question 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
|
qa447.html |
1.8K |
02/07/95 |
Question 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 |
qa448.html |
1.7K |
02/07/95 |
Question 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 |
qa449.html |
1.2K |
02/07/95 |
Question 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 |
qa45.html |
200 |
02/07/95 |
Question 45: In determining the "eye dose equivalent," can credit
be taken for shielding provided by eyeglasses/safety glasses? |
qa450.html |
2.9K |
02/07/95 |
Question 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 |
qa451.html |
1.8K |
02/07/95 |
Question 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
|
qa452.html |
2.5K |
02/07/95 |
Question 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 |
qa453.html |
2.1K |
02/07/95 |
Question 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 |
qa454.html |
3.9K |
02/07/95 |
Question 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 |
qa455.html |
1.5K |
02/07/95 |
Question 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, |
qa456.html |
2.2K |
02/07/95 |
Question 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 |
qa457.html |
1.5K |
02/07/95 |
Question 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 |
qa458.html |
1.8K |
02/07/95 |
Question 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 |
qa459.html |
2.1K |
02/07/95 |
Question 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 question 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 |
qa46.html |
650 |
02/07/95 |
Question 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? |
qa460.html |
3.1K |
02/07/95 |
Question 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
|
qa461.html |
1.5K |
02/07/95 |
Question 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)? |
qa47.html |
1K |
02/07/95 |
Question 47 and anwser. |
qa48.html |
571 |
02/07/95 |
Question 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. |
qa49.html |
228 |
02/07/95 |
Question 49: For control of access to very high radiation areas,
will physical barriers be needed to preclude unauthorized access?
|
qa5.html |
844 |
02/07/95 |
Question 5: Who is responsible for regulating radium - the State
or NRC? 10 CFR 20.1001 10 CFR 20.1002 |
qa50.html |
786 |
02/07/95 |
Question 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? |
qa51.html |
561 |
02/07/95 |
Question 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 |
qa52.html |
1.6K |
02/07/95 |
Question 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 |
qa53.html |
1.3K |
02/07/95 |
Question 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 |
qa54.html |
2.6K |
02/07/95 |
Question 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 |
qa55.html |
644 |
02/07/95 |
Question 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 |
qa56.html |
878 |
02/07/95 |
Question 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 |
qa57.html |
431 |
02/07/95 |
Question 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 |
qa58.html |
646 |
02/07/95 |
Question 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 |
qa59.html |
1.3K |
02/07/95 |
Question 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 |
qa6.html |
571 |
02/07/95 |
Question 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 |
qa60.html |
2.7K |
02/07/95 |
Question 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 |
qa61.html |
791 |
02/07/95 |
Question 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 |
qa62.html |
1.2K |
02/07/95 |
Question 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?
|
qa63.html |
3.0K |
02/07/95 |
Question 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 |
qa64.html |
1.5K |
02/07/95 |
Question 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) |
qa65.html |
1.0K |
02/07/95 |
Question 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 |
qa66.html |
2.4K |
02/07/95 |
Question 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 |
qa67.html |
889 |
02/07/95 |
Question 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? |
qa68.html |
2.3K |
02/07/95 |
Question 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 |
qa69.html |
1.9K |
02/07/95 |
Question 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 |
qa7.html |
509 |
02/07/95 |
Question 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? |
qa71.html |
2.4K |
02/07/95 |
Question 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 |
qa72.html |
709 |
02/07/95 |
Question 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
|
qa73.html |
469 |
02/07/95 |
Question 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? |
qa74.html |
862 |
02/07/95 |
Question 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 |
qa75.html |
2.4K |
02/07/95 |
Question 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 |
qa76.html |
1.2K |
02/07/95 |
Question 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 |
qa77.html |
1.7K |
02/07/95 |
Question 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
|
qa78.html |
600 |
02/07/95 |
Question 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? |
qa79.html |
1.4K |
02/07/95 |
Question 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 |
qa8.html |
462 |
02/07/95 |
Question 8: Under what circumstances are planned special exposures
permitted? |
qa80.html |
1.6K |
02/07/95 |
Question 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 |
qa81.html |
1.0K |
02/07/95 |
Question 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? |
qa82.html |
347 |
02/07/95 |
Question 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
|
qa83.html |
822 |
02/07/95 |
Question 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 |
qa84.html |
314 |
02/07/95 |
Question 84: Can a female worker legally declare pregnancy if she
does not yet have documented medical proof? 10 CFR 20.1003 |
qa85.html |
496 |
02/07/95 |
Question 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 |
qa86.html |
456 |
02/07/95 |
Question 86: Does the term "per unit intake" in Footnote 1 to 20.1202
refer to one event or to the entire monitoring period? |
qa87.html |
160 |
02/07/95 |
Question 87: Will the numbering sequence of the revised regulation
be changed once the "old" Part 20 expires? |
qa88.html |
598 |
02/07/95 |
Question 88: Will each NRC region hold orientation meetings for
licensees on the revised regulation? When and where might these occur?
|
qa89.html |
543 |
02/07/95 |
Question 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? |
qa9.html |
535 |
02/07/95 |
Question 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 |
qa90.html |
1.6K |
02/07/95 |
Question 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? |
qa91.html |
767 |
02/07/95 |
Question 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? |
qa92.html |
1.4K |
02/07/95 |
Question 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 |
qa93.html |
316 |
02/07/95 |
Question 93: In the definition of individual monitoring devices,
is there any reason electronic monitoring devices are not mentioned?
|
qa94.html |
1022 |
02/07/95 |
Question 94: Why was the "controlled area" defined? |
qa95.html |
794 |
02/07/95 |
Question 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? |
qa96.html |
939 |
02/07/95 |
Question 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 |
qa97.html |
782 |
02/07/95 |
Question 97: 10 CFR 20.1201(b) refers to "doses received during
accidents, emergencies, and . . . ." Is there any difference between
an "accident" and an "emergency"? |
qa98.html |
2.0K |
02/07/95 |
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 |
qa99.html |
3.1K |
02/07/95 |
Question 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. |
qaindex.html |
12K |
01/05/95 |
Index of all Regulatory References cited in HPQA |