U.S. Nuclear Regulatory Commission

IE Position - Unduly Restricted Access of Female NRC Inspectors to Radiation Areas

HPPOS-055 PDR-9111210231

Title: IE Position - Unduly Restricted Access of Female

NRC Inspectors to Radiation Areas

See the memorandum from J. H. Sniezek to B. H. Grier (and

others) dated October 2, 1980. It is an IE position that

states each female NRC inspector has to read and be

familiar with Regulatory Guide (RG) 8.13. Therefore,

licensees shall not restrict access of an NRC inspector

because of requirements considered to be imposed by 10 CFR

19.12 regarding instructions to workers on prenatal

exposure.

During NRC onsite inspections, several licensees imposed

additional restrictions on the access of female NRC

inspectors to radiation areas. These restrictions appeared

to be honest attempts on the part of the licensees to

comply with the requirements of 10 CFR 19.12 and the

guidance of RG 8.13, "Instructions Concerning Prenatal

Radiation Exposure." It is not believed that the licensees

were attempting to impede or hinder the inspection effort

but rather were being overly cautious in their

interpretation of the requirements.

RG 8.13 sets forth information to be presented by NRC

licensees to female employees and to their supervisors and

coworkers. This information is part of the instruction

that should be provided pursuant to 10 CFR 19.12. The

intent of RG 8.13 is not only to assure that employees are

aware of the risk associated with radiation exposure of an

embryo or fetus but also to permit women to make an

informed decision when considering employment in situations

involving their potential exposure to radiation. The dose

limits in 10 CFR 20 do not differentiate between females

and males. Licensees should not interpret the requirements

of 10 CFR 19.12 and the guidance of RG 8.13 as imposing any

additional radiation dose limits or restrictions on females.

Each female NRC inspector has to read and be familiar with

RG 8.13. Therefore, licensees shall not restrict the access

of an NRC inspector to any part of a facility because of

requirements that are considered to be imposed by 10 CFR

19.12 as related to instructions of workers on the risks of

prenatal radiation exposure.

Regulatory references: 10 CFR 19.12, Regulatory Guide

8.13, Regulatory Guide 8.36

Subject codes: 8.11, 12.9, 12.18

Applicability: All