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?
Answer: (a) Yes. (b) No. Supplemental response:
Although this question came from a nuclear power plant, it
seems unlikely that a nuclear power plant would choose to
use this option [10 CFR 20.1302 (b) (2)], with its
conservative assumptions, to demonstrate compliance with
the annual dose limit in 10 CFR 20.1301 (a) (1). It seems
more likely that a nuclear power plant would prefer to use
the option of 10 CFR 20.1302 (b) (1) which does not involve
the conservative assumptions (effluent concentrations "at
the boundary of the unrestricted area" and an
"individual...continuously present in an unrestricted
area"). Nuclear power plants and other uranium fuel cycle
facilities must meet the more restrictive public dose
limits of 40 CFR 190. As noted in the statement of
considerations (56 FR 23374, third column), demonstration
of compliance with the limits of 40 CFR 190 will be
considered to demonstrate compliance with the 0.1-rem
annual limit of 10 CFR 20.1301 (a) (1) for most facilities.
This demonstration of compliance would be consistent with
the option of 10 CFR 20.1302 (b) (1). See the answer to
the related Question 68. (Reference: 10 CFR 20.1302).