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

HPPOS-055 PDR-9111210231

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