ML20210Q240
| ML20210Q240 | |
| Person / Time | |
|---|---|
| Issue date: | 09/28/1993 |
| From: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Bangart R NRC OFFICE OF STATE PROGRAMS (OSP) |
| References | |
| TASK-TF, TASK-URFO NUDOCS 9708280254 | |
| Download: ML20210Q240 (19) | |
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SEP 281993 MEMORANDUM FOR:
Richard L. Bangart, Director, OSP-Kenneth E. Raglin, Director, TTC James Lieberman, Director. 01 Stuart Treby, OGC Joanna M. Becker, OBC Seymour H. Weiss, Director, ONDB, NRR C. W. Hehl, Director, DRSS, Region I J. Philip Stohr, Director, DRSS, Region II William L. Axelson, Director, DRSS, Region III L. Joseph Callan, Director, DRSS, Region IV Ross A. Scarano, Director, DRSS, Region V Lemoine Cunningham, NRR Donald A. Cool, RE" FROM:
Carl J. Paperiello, Director Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
SIXTH SET OF QUESTIONS AND ANSWERS ON NEW PART 20 A sixth set of questions and answers on the major revision of 10 CFR Part 20 (new Part 20) is enclosed for your information.
A draft of these questions and answers was provided earlier for your review.
These questions and answers are being made publicly avai'.sble.
44 Carl
. Pa eriello, Director Division of Industrial and Medical Nuclear Safety, NMSS
Enclosure:
As stated CONTACT:
Joe DeCicco (301) 504-2067 g
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'i SEP 281993 MEMORANDUM FOR:
Richard L. Bangart, Director, OSP Kenneth E. Raglin, Director, TTC James Lieberman, Director, OE Stuart Treby, OGC Joanna M. Becker, 0GC Seymour H. Weiss, Director, ONDB, NRR Charles W. Hehl, Diractor, DRSS, Region 1 J. Philip Stohr, Director, DRSS, Region 11 Charles E. Herelius, Director, DRSS, Region III L. Joseph Callan, Director, DRSS, Region IV Ross A. Scarano, Director, DRSS, Region V FROM:
Carl J. Paperiello, Director Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards
SUBJECT:
SIXTH SET OF QUESTIONS AND ANSWERS ON NEW PART 20 A sixth set of questions and answers on the major revicion of 10 CFR Part 20 (new Part 20) is enclosed for your information. A draft of these questions and answers was provided earlier for your review, These questions and answers are being made publicly availab'e.
Carl J. Pa eriello, Director Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety' and Safeguards
Enclosure:
As stated CONTACT:
Joe DeCicco (301) 504-2067 D11Talg 0t (hard copy) See also next page IMNS r/f HMSS r/f NRC File Center PRPB S/F (Part 20)
FCongel, NRR LJCunningham, NRR JBuchanan, NRR.
JPartlow, NRR RAnderson, TTC BMorris, RES GGrant.
TDMurphy PDR
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SEP 281993 0FC IM0B*
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NAME JDeCicco:kr CJones FCombs LCunningham EWBrach CPaperiello DATE 9/21/93 9/16/93 9/21/93 9/22/93 9/24/93 9/24/93 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY: G: SET 6Q&A2:JED Distribution:
Central Files PRPB R/F REmch JWiggington PMcKee RErickson EButcher CWillis CRaddatz CTrottier, RES ARoccklein, RES RBellamy, RI JJoyner, RI WCline, Ril DCollins, Ril RCaniano, Rill CPederson, Rlll
'JMurray, RIV CCain, RIV WFisher, RIV Jeese, RV GYuhas, RV RPate, RV
. MEMORANDUM FOR:
Richard L. Bangart, Director, OSP Kenneth E. Raglin, Director, T,TCf l
James Lieberman, Director,,0! cA Stuart Treby, OGC Joanna M. Becker, CBCTE Seymour H. Weiss, Director, ONDB, NRR pSL ichard-1(i: Cooper,-11rDirector,, DRSS, Region 1 R
J. Philip Stohr, Director, D sV,> Region 11
' Charles-Ev-Norelius Directd(r,"DRSS, Region III g' 'ua L. Joseph Callan, Director, DRSS, Region IV Ross A. Scarano, Director, DRSS, Region V FROM:
Carl J. Paperiello, Director Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards
SUBJECT:
SIXTH SET OF QUESTIONS AND ANSWERS ON NEW PART 20 A sixth set of questions and answers on the major revision of 10 CFR Part 20 (new Part 20) is enclosed for your information. A draft of these questions and answers was provided earlier for your review. These questions and answers are being made publicly available.
Carl J. Paperiello, Director Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards
Enclosure:
As stated CONTACT:
Joe DeCicco (301) 504-2067 DISTRIBUTION: 1hard copyl IM08 r/f IMNS r/f NMSS r/f NRC File Center PRPB S/F (Part 20)
FCongel, NRRC LJCunningham, NRR JBuchanan, NRR JPartlow/0GC' (J R RAnderson, TTC BMo ris, RES GGrant TDMurphy PDR E-MAIL ONLY:
Regional Branch Chiefs and Section Leaders IMNS Branch Chiefs and Section Leaders DCool KDragonette CTrottier JRicci, TTC P
/7 NAME Nicco:kr Cd[es (Ikombs/
kCMnYngNm Ehdbch CPap llo DATE 4 /#//93 9 /lh93 0kh 9 /2 @93 6/7Al/93 7 /Je)93 C = COVER E = COVER & ENCLOSURE '
N = NO COPY
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OFFICIAL RECORD COPY:
G: SET 6Q&A2:JED
1-ENCLOSURE-SIXTH. SET OF QUESTIONS AND ANSWERS ON NEW PART 20 Following are questions and answers concerning the new 10 CFR Part 20 (10 CFR
.Part 20 Sections'20.1001 - 20.2402) and,its implementation.
These questions-and answers have been compiled arimarily for use in training NRC regional inspection staff members, but t1ey are being'made publicly available for information of interested c,*ganizations and to encourage communications between the public and the NRC staff concerning this new rule. Additional questions and answers are being compiled and will be made publicly available at a later date.
The questions included here were provided by individuals and organizations outside the NRC and by NRC staff members. Answers to these questions have been prepared by, and reviewed by NRC staff members in the NRC Offices of Nuclear Reactor Regulation, Nuclear Material Safety and Safeguards, Nuclear
' Regulatory-Research, Office of State Programs, and five' NRC Regional Offices.
The questions and answers also have been reviewed by an attorney in the NRC Offico of the General Counsel.
The answers to questions do not constitute official legal interpretations, which can only be provided by the General Counsel,.and they do not reflect official NRC policy as approved by the Commission. The answers do reflect NRC staff decisions and technical opinions on spsific aspects of regulatory requirements.
Additional information about the questions and answers follows:
o Questions and answers are arranged in the order of appearance in Part 20 of the section of Part 20 to which the question appears to be most closely related.
Questions on Part 20 itself are followed by related questions concerning 10 CFR Part 19, reactor technical specifications, and regulatory guides.
l 0
The questions are not in numerical order. The number assigned to each question is merely a unique identification number.
This identification number has no relationship to the subject of the
- question, o
Unless otherwise indicated in an answer, a reference to a Federal Reaister volume and page number (e.g., 56 FR 23377) refers.to a sage number in the May 21, 1991 edition of the Federal Reaister, whic1 contained the new Part 20 and related information, on pages 23360-
- 23474, s
I 4
l h o The first five sets of questions and answers are identified by their dates of issuance and their NRC accession numbers in the following table. The accession numbers can be used by the NRC staff to retrieve these documents from the NUDOCS system and by members of the public to obtain the documents from the NRC Public Document Room.
Egi Q11n Accession Nqi First 12/6/91 9112190258 Second 4/17/92 9205010117 Third 7/23/92 9207300261 Fourth 9/14/92 9209230012 Fifth 6/08/92 9306110303
- SIXTH SET OF QUESTIONS AND ANSWERS ON NEW PART 20 10 CFR 20J201 Occupational Dose Limits for Adults OVESTIOR 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 exceeoing the annual TEDE limit?
ANSWER:
(a) The purpose of the 15 rem non-stochastic limit to the lens of the eye is to prevent lens opacities (cataracts).
The dose limit to the head (a stochastic limit) and the dose limit to the eye (non-stochastic limit) are measured at different depths in tissue,1 cm tissue equivalent depth for deep dose and 0.3 cm for eye dose; and for low penetrating radiation (such as beta or low-energy x-rays), doses at different tissue depths can be significantly different.*
(b) The 15 rem eye dose equivalent applies to the exposure to the lens of the eye and is measured at a tissue depth of 0.3 cm. The 5 rem TEDE limit is the sum of the deep dose equivalent at a tissue depth of I cm and the committed -
effective dose equivalent, in general, a person can receive 15 rem to the eye (measured at 0.3 cm) without exceeding the 5 rem limit on deep dose equivalent when the head is exposed to beta or low-energy photon radiation, although it would be rare for an individual to receive 15 rem eye dose equivalent without exceedi.ng a deep dose equivalent of 5 rem. (
Reference:
. M H10H 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 suurce of exposure, the worker wears a lead apron that covers the waist dosimeter, but not the collar dosimetar. Over the course of a year, the worker receives a dose of 5.2 rem as measned by the collar dosimeter and 1.7 rem as measured by the waist-dosimeter.
(a) Has the individual been overexposed?
(b) Can licensees take credit for shielding while monitoring the external dose component of the TEDE?-
ANSWER:
(a) Y'es, the individual has received a dose in excess of 10 CFk 20.1201 limits. The head and neck constitute part of the "whole body", and in this case, received the highest exposure. The collar dosimeter measured a
' dose of 5.2 rem over the course of a year.
If the head and neck were not shielded, and if the collar dosimeter was a measurement of the dose to the head and neck, then the dose exceeded the limit of 5 rem TEDE.
(b) The licensee can only "take credit" for shielding if it can be shown that the doze monitored behind the shielding is an accurate measurement of the maximum deep dose equivalent to the individual. Many shields used for radiation protection do not cover all of the upper legs, upper arms, and/or neck, and few if any shields protect the head from external radiation.
I
i
. Therefore, few shields would satisfy the conditions for credit. However, licensees should use shielding as necessary to minimize the area of exposure and keep doses Al. ARA. (
Reference:
OVEST10N 176:
10 CFR 20.u01 (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 thn 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, without having an overexposure?
(c)
Cn a person receive 50 rem shallow dose equivalent to each extremity during one year?
ANSWEB (a) Yes, as long as the total shallow dose equivalent does not exceed 50 rem in either position. The skin of the extremity is not considered in the shallow-dose equivalent limit to the skin of the whole body.
The annual limits are a shallow-dose equivalent of 50 rem (0.50 Sv) to the skin at to any extremity.
(b) Again, as long as it can be shown that the total shallow dose equivalent does not exceed 50 rem at any one location on the skin of the whole body, there is no violation.
If the two different areas of the skin of the whole body each receives 50 rem total shallow dose equivalent during the year, then the limit has not been exceeded.
(c)
Yes.
The regulation states "...or to any extremity;" therefore, a worker may receive a shallow-dose equivalent of 50 rem to nch of the four extremities.
(
Reference:
10 CFR 20.1201, 20.1003, Reg Guide 8.34)
OVESTION 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 close?
ANSWER (a) Yes. The annual limit for the dose to the head is the same as the annual limit to the trunk and other portions of the whole body, which, in the absence of internal dose, is equivalent to 5 rem deep dose equivalent.
(
Reference:
OVESTIDJi217: 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).
ANSWER: Without knowing the occupational dose received by the worker at the other facility, the licensee cannot demonstrate compliance with the occupational dose limits for the worker if it permits the worker to receive concurrently an occupational dose.
The licensee cannot allow the worker to receive-any occupational exposure after the licensee becomes aware the
- worker is also receiving an occupational exposure at another facility which the worker refuses to name.
See 56 FR 23383, third column, and Question 41, first Set, for additional information concerning concurrent employment.
(
Reference:
10 CFR 20.1201, 20.2106) 10 CFR 20.1202 Comoliance with Reouirements for Summation of External and Internal Doses OVESTION 179:
If a licensee im)lements the revised Part 20 in July, 1993, is the licensee required to go bac( and evaluate internal dose for the purpose of determining total effective dose equivalent for the year?
ANSWER:
No.. The footnote to 10 CFR 20.2104(d), as amended _in 57 FR 57877, 12/8/92, states, " Licensees are not required to partition historical dose between the external dose equivalent (s) and the internal committed doso equivalent (s)." As long as all of the licensee's worker's doses are below the old limits and/or the workers will not participate in planned special exposures, the licensee need not reevaluate prior doses before implementing the revised Part 20. However, the licensee must subtract the dose already received during the year from the new annual dose limits to find the limits for the remainder of the year, as explained in Question 1, Set 1.
(
Reference:
20.1202,20.2104)
OVESTION 180: Does the word "also" as used in 20.1202(c) mean intake by oral ingestion and inhalation, or oral ingestion and external exposure?
ANSWER:
In 10 CFR 20.1202(c), the words "...also receives an intake by oral ingestion..." mean in addition to the ingestion associated with inhalation, as discussed in 10 CFR 20.1202(b). All intakes by oral ingestion in excess of 10
-percent of the applicable ALI must be accounted for, whether the dose from cral ingestion is in conjunction with-intakes by inhalation, external doses, or both.
(
Reference:
10 CFR 20.1202, Reg Guide 8.34) 10 CFR 20.1204 Determination of Internal ExD;, ore OVESTION 183:
If an individual receives an intake of Class Y material in
-September and, pursuant to 10 CFR 20.1204(d), tha licensee waits 7 months to record the dose (March), whatiyear should the dose be recorded?
ANSWER: The committed effective dose equivalent should be recorded in the year the intake was received.
If the dose exceeded the limits, then it is considered an overexposure at the time when the intake occurred, and should be reported immediately.
(
Reference:
j 10 CFR 20.1206 Planned Special Exposure OVESTION 191:
Is a licensee required to provide dosimeters to an individual during a planned.special exposure (PSE) tnat would only be worn during the PSE?
ANSEB: No, there is no requirement, but the licensee may do so.
10 CFR 20.1206 requires that the doses received during a PSE be accounted for-separately from the doses received under the limits of 20.1201, and the use of separate dosimeters that are worn only during the PSE is a practical means to account for the PSE dose.
(
Reference:
10 CFR 20.1206, 20.2105, 20.2204)
DVESTION 192:
10 CFR 20.1206(e) says that licensees may not authorize PSEs for workers whose doses from previous PSEs and all " doses in ercess 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, especially if the facility was not a licensee? (d)
It appears that overexposures will require the licensee to ba::k-calculate the dose in excess of the limits, particularly when that dose was received from an intake of radioactive material. However the footnote (#5) in 10 CFR 20.2106 says that assessments of dose equivalent and records made using units in effect before the licensee's adoption of this Part need not be changed. Will the licensee have to, in fact, convert the old doses in excess of the limits to committed effective dose equivalent?
ANSWER:
(a) The regulatory limits at the time and place of the overexposure apply.
If the individual worked for the Departrat of Energy (DOE), then the DOE limits apply.
If the individual worked in a foreign country, then that country's limits apply.
(b) The actual limit applies.
(c) Yes.
It is the purpose of the regulation to control licensed material in such a manner that the total dose to an individual, from licensed and non-licensed sources, does not exceed standards prescribed in the regulations.
(d)
Yes.
(
Reference:
10 CFR 20.1206, 20.2104, 20.1001, Reg Guide 8.35) 10 CFR 20.1301 Dose limits for Individual Members of the Public OVESTION 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?
ANSWER: The practice of having separate limits for discharge to sewers is a practice that has been in place since 10 CFR Part 20 was proposed in 1955.
If the dose limit for individual members of the public included the dose contribution of licensed material into sanitary sewerage, there would be no practical way for the licensee to determine the magnitude of that dose
7 contribution for the purpose of demonstrating compliance with the limit because of the remoteness of the individual being exposed from the point of discharge. Water released into the sanitary sewer is considered unavailable until it passes through the sewage treatment plant.
Effluent concentration limits (as in Table 2 of Appendix B) have always been calculated under the premise that a member of the public lives at the licensee's site boundary and utilizes the air and water available at that point.
Release limits are set in Table 3 so that if the releases from the sewage treatment facility were the only source of ingestitle water, the dose to the individual would be a committed effective dose equivalent of 0.5 rem per year.
(
Reference:
OVEST10N 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?
ANSWER:
If the public is not allowed to enter for reasons other than limiting radiation exposure, the answer is yes.
If the public is not allowed to enter in order to limit radiation exposure and for other reasons, the answer is no.
As indicated in the answer to Question 26(a), under the discussion of
" controlled area", when an area meets both the definition of a controlled area and the definition of a rcstricted area, the area is consitiered a restricted area for purposes of compliance with Part 20.
(
Reference:
OVESTION 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?
@JEB:
(a) The 0.5 rem per year limit is -intended to be applied primarily to temporary situations where operation of the facility, or public exposure to radiation, is not expected to result in doses above 0.1 rem over long periods of time.
20.1301(c)(1) requires that the licensee specify d r,a expected duration of operation in excess of the limit. The Commission will only approve such applications if the licensee provides all,f the information specified in 10 CFR 20.1301(c), and if the information
- acceptable.
(b)
It is unlikely that the Commission will approve a quest to operate at the higher limit indefinitely.
(
Reference:
11) 0VESTI0tl205:
(a) 10 CFR 20.1301(a)(2) requires that he 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 millirem in any one hour inspectable?
ANSWER:
General response: This requirement in 10 CFR 20.1301(a)(2) is not new.
It is essentially the same as the requirement in 10 CFR 20.105(b)(1).
Specific response: (a) Yes.
a (b) The licensee must be able to demonstrate compliance with the dose liniits of 10 CFR 20.1301 and the survey requirements of 10 CFR 20.1501.
If an inspector identifies areas where the radiation levels may be in excess of 2 millirem in any one hour and the licensee is unable to demonstrate compliance with the dose limits for an unrestricted area and with the survey requirements, the licensee may be cited.
(
Reference:
10 CFR 20.1301, 20.1501)
OVESTION 206:
Can a licensee allow radiation levels of 5 mR or more in one hour in an area without limiting access to the area?
ANSWER:
If the phrase "...without limiting access to the area?" is intended to mean an unrestricted area, the answer is no.
See Question 205, this Set.
(
Reference:
10 CFR 20.1301, 20.1003) 10 CFR 20.1302 Comoliance with Dose limits for Individual Members of the Public OVESTION 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?
ANSWER: No.
If using 10 CFR 20.1302(b)(1) to show compliance with dose limits, occupancy times (time an individual is present) may be taken into account.
If using the method in 10 CFR 20.1302(b)(2)(ii) to demonstrate compliance, dose is calculated as if an individual were continuously present, regardless of whether an individual is continuously present.
See related Questions 68, Set 2, and 102 Set 3.
(
Reference:
10 CFR 20.1302, 20.1301)
E ESTI0B 208:
Is the licensee required to use the most accurate method for determining compliance with the dose limits or is it allowable to use any one of the acceptable methods (assuming the acceptable method yields the lower dose)?
MSHff: The licensee may use any one of the acceptable methods for determining compliance with the dose limit (10 CFR 20.1301(b)(1) or (2)).
See related Question 102, Set 3.
(
Reference:
10 CFR 20.1302) 10 CFR 20.1501 General 00ESTION 209:
(a) Does the revised Part 20 require that meters be calibrated?
(b)
If so, is the calibration frequency specified?
MSE8:
(a) Yes,10 CFR 20.1501(b) requires that the licensee insure that
i y
) instruments and equipment used for quantitative radiation measitrements are calibrated periodically for the radiation measured.
(b)
Part 20 regulations do not define " periodically." However, specific NRC license conditions and other Parts of Title 10 (i.e., Parts 34 and 35) may specify the periodicity for calibration.
(
Reference:
@ESTION 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 cf 10 CFR 20.1501(c)?
ANSWER: No.
(
Reference:
10 CFR 20.1501) 10 CFR 20.1502 Conditions Reouirina Individual Monitorina of External and Internal Occunational Dog OUEST10N 211:
20.1502(a)(2) and (b)(2) say that monitoring is required for declared pregnant wamen "...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 pregnant woman (whose estimated date of delivery is in January or February) during the current calendar year.
The licensee then estimates that for the next calendar year, between the start of the year and deliverv, the declared pregnant woman's external doses will be less that 10 percent of the applicable embryo / fetus dose limits, is the licensee required to badge the woman for the new year? (d) Can licensees assume that after delivery, the " year" time period is over and that monitoring the woman (to demonstrate compliance with the embryo / fetus dose limits) is no longer required?
ANSWER:
(a) The worrt " year" is used to indicate a 12-month period starting in January. (See definition of year in 10 CFR 20.1003).
(b) This requirement is for determining whether monitoring must be provided, and the term year is used to be consistent with other monitoring criteria as specified in 10 CFR 20.1502.
(c) Once a determination is made to monitor the declared pregn ant woman, monitoring is to continue for the entire pregnancy, to determina compliance with the limit of exposure to the embryo / fetus.
(d) Yes. Once the woman is no longer a declared pregnant woman, the need to provide monitoring will be based on requirements of 10 CFR 20.1502(a)(1).
(
Reference:
10 CFR 20.1502, 20.1003)
OVESTION 212: A licensee makes a prospective determination that adult workers in Department W are D91 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 comoliance with
. the occupational dose limits of the revised Part 20.
(a)
If an inspector finds the TLD badges being worn incorrectly or misused by Department W workers, can the licensee be cited?
(b) Hust the doses be reported to the workers?
If recording is required, must it be kept on Form St MSEB:
(a) No citation against 10 CFR 20.1502 would be issued, provided the licensee can provide documentation that adequately supports the evaluation that monitoring ol' external dose is not needed. An inspector ray bring the issue of incorrect wearing of dosimeters to the attentien of the licensee, and may document this lack of good practice in the inspection report.
(b) No, reporting is not required.
If the badges are not used for compliance with the regulations, the licensee is not required to record the results on NRC Form 5 or its equivalent.
(
Reference:
10 CFR 20.1502, 20.2106)
MESTION 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?
ANSWER:
(a) The individual / organization that is licensed to possess the material used is responsible for monitoring the representative.
(b) The results of the monitoring must be maintained by the licensee as required by 10 CFR 20.2106.
(
Reference:
10 CFR 20.1502, 20.2106)
OVEST10N 214:
(a)
If the individual had agi 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 2, determines in advance that the worker's annual dose for b.0.th 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 several previous employers during the year, some who badged and some who did not, and Licensee Z makes a prospective determination that its own activities will result in a dose less than 10%, must Licensee Z monitor for external dose?
ANSWER:
(a) No. The criteria to determine whether monitoring is required is independent of exposures received at any other place of employment prior to or subsequent to employment with Licensee Z.
(b) No.
(
Reference:
10 CFR 20.1502, 20.2104, Reg Guide 8.34)
OVESTION 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?
ANSWER: No.
See previous question.
(
Reference:
I
____._______m..__
I OVESTIQH 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)
ANSWER: Appendix X to Regulatory Guide 10.8, Rev.2, was developed to provide guidance on how to implement new Part 20 at a medical facility.
This guide will be revised in its entirety in the future to address the changes in 10 CFR Part 20.
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Reference:
10 CFR 20.1502) 10 CFR 20.1601 Control of Access to Hiah Radiation Areas 00ESTION 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?
6N1MLB; (a) 10 CFR 20.1601(a) requires that entrance or access points to a high radiation area have "one or more" of the listed features to preclude excessive radiation exposure to an individual. The control device in subparagraph (1) stipulates only that it cause the radiation level to be reduced so that an individual, upon entry, could not receive 100 mrem in an hour within 30 cm of an accessible area of the source. This paragraph does not distinguish between " authorized" or "unauthe-ized."
(b) The control device must activate "unon entry into the area" at the
" entrance or access po'
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Reference:
OVESTION 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 line-of-site, satisfy the requirement?
ANSWER:
(a) Yes, provided there are personnel in attendance at all times who will take the necessary precautions to prevent the exposure of individuals to radiation or radioactive material in excess of the limits established in Part 20, and operate within the ALARA provisions of the licensee $s radiation protection program.
(b) Yes, provided the room is properly posted.
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Reference:
. _. _ _.. ~
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12 -
LAppendix X to Reg; Guide 10.8) i i
10 CFR 20.1602 Control of' Access of j
Igry Hiah Radiation-Areas r
~.
El6Ugi 220:
10 CFR=20.1602 gives requirements for control for access to' vert high radiation areas, and has no exemption clause.
_defu es 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 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 1 meter, very high, radiation areas?
(b) Do the requirements in 4
-20.1602-apply to teletherapy rooms or fixed / field radingraphy-facilities?-
i
. ANSWER: (a) Yes, i
(b) Yes.
However, this does not prohibit patients from receiving prescribed i
-medical-treatment _in a-teletherapy room '
Reference:
10 CFR 20.1602, 20.1003) 10 CFR 20.1902 Postina Reauirements OUESTION 221: Since the posting recuirements are all in terms of deep dose equivalent, what requirements shoulc be followed when posting for low energy beta radiation?
ANSWER: Unless the beta particle can deliver-a dose at a tissue. depth of 1 cm, the. area does not require postina for radiation area (20.1902(a)), high radiationarea-(20.1902(b)),orveryhighradiationarea(20.1902(c));
'however,_ posting for airborne 1 radioactivity area (20.1901(d)) and for areas or rooms inLwhich licensed material.:is used or stored (20.1901(e)) needs to be
-considered for-beta emitters. See Questions 57, Set 1, and 74 and-85, Set 2.
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Reference:
10 CFR 20.1902,_20.1901) 10 CFR'20.1903-Exceptions to Postina Reauirements 00ESTION:223: - Are 'radiographers exempt from posting-at a temporary field site, sunder 10 CFR 20.1903(a), since they perform radiography in each area less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, attend.the material to prevent: exposure of individuals in excess'of the limits (1 e., have clear sight over.the designated area and are Tin constant' attendance); and control the1 area- (i.e., tell. individuals to leave if they come too close to the source)?^
8KW1. : The new'Part 20 requirements-do'not change this exemption.
- Radiographers continue to-be-exempt.under-20.1903(a);-however, industrial
. radiographers are required under 10 CFR 34.42 to conspicuously post areas z
,where-radiography is being performed. -(
Reference:
10 CFR 20.1903, 34.42)
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, DUESTION 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?
6NSWER: No. The authorization to use only the term " danger" (vice " caution")
for a very high radiation area provides emphasis to the potential hazards.
There are no exemptions in the code for posting a very high radiation area.
Since a high radiation area does not reauire using the term " danger," the exemption would apply to this area if the conditions of 10 CFR 20.1903(a) are met.
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Reference:
10 CFR 20.1903, 20.1902) 10 CFR 20.1904 Labelina Containers DMESTION 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?
ANSWER:
(a)
In the context of 10 CFR 20.1904, and in accordance with Health Physics Position (HPPOS) 28, a container is a receptacle in which radioactive material is held or carried.
(b) There is no limit to the size of a container.
(c) Typically, a room is not ccmidored a container; it is considered an area, and should be posted as si m (d) A transportation cask or pa c.. ige in certain circue. stances could be a container.
If a container is in transport, and packaged and labeled in accordance with Department of Transportation regulations, it is exempt from the labelling requirements of 10 CFR 20.1904.
If, however, the container / cask / package is not in transport, it is subject to the labelling requirements of 10 CFR 20.1904.
(e) Under certain circumstances, the trailer of a tractor-trailer could be considered a container.
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Reference:
10 CFR 20.1904, HPPOS 28) 10 CFR 20.1906 Procedures for Receivina and Openina Packaaes OVESTION 227:
(a) Hust gauge licensees perform a survey of each gauge package (if the package is labeled with a Department of Transportation 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, thn returned to a storage location?
ANSWEB:
(a) As a result of amendments to Part 20 published on 8/31/92 [57 FR 39353], the licensee is not required to survey the gauge package for contamination if the source is in special form as defined in 10 CFR 71.4 and
I
^
. is not required to monitor radiation levels unless the package contains quantities of radioactive material that are in excess of the Type A quantity, as defined in 10 CFR 71.4 and Appendix A to Part 71, provided there is not evidence of degradation of package integrity.
(b)
If there is no evidence of degradation of package integrity, no surveys are required if the package contains less than or equal to a Type A quantity and the source is in special form.
If the source is not in special form, a contamination survey is required; if the source is greater than a Type A quantity, the external surface of the package must be monitored for radiation levels.
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Reference:
10 CFR 20.1906, 71.4)
OVESTION 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 performing 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 to the storage location at the end of the day?
(b)
Or is each transport from one temporary site to another considered a shipment, with a " receipt" at each job site?
ANSWER:
(a) The source should be surveyed at the end of the work day, just prior to or immediately after storage.
If the package contains quantities less than a Type A quantity, the licensee is not required to survey the surface of the package for radiation levels.
If the package contains quantities of radioactive material in excess of a Type A quantity, as defined in 10 CFR 71.4 and Appendix A to 10 CFR Part 71, the licensee, in accordance with 10 CFR N.1906(c), shall perform monitoring as soon as practicable but not later than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> after the package is received at the licensee's facility if it is received during the licensee's normal working hours, or not later than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> from the beginning of the next working day if it is received after working hours.
(b) No. The package "is received at the licensee facility" when it is
~
returned to the storage location at tFe end of the day.
It is not necessary to survey radiation levels at temporary job sites.
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Reference:
10 CFR r
20.1906, 71.4)
MEST10N 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?
MSEB: The requirements of 20.1906 refer to the external surface of package, not the source itself; the requirement to wipe test a source is usually a license condition.
If the source is not a gas or not in special form, the licensee is required to monitor the labeled package (White I, Yellow II or Ill) for contamination regardless of whether a leak test has been performed.
If the source is in special form as defined in 10 CFR 71.4, the external surface'of the package does not need i.o be monitored for contamination.
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Reference:
10 CFR 20.1906, 71.4)
' OVESTION 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 requirements?-
M1E8: No.
10 CFR 20.1906(b)(2) correlates radiation-level monitoring requirements with Type A quantities; however, 10-CFR 20.1906(a) and (b) are independent requirements because 20.1906(a) delineates requirements for making arrangement for receivino yadioactive material, and 10 CFR 20.1906(b) delineates the monitorino requirements once the material is received.
See Question 227.
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Reference:
10 CFR 20.1906, 71.4)
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