U.S. Nuclear Regulatory Commission
Technical Assistance Request, Walter Reed Army Hospital, Washington, D.C., Guidance on Setting Action Levels for Exemption from Requirement to Decontaminate Therapy Room for Unrestricted Use
HPPOS-321 PDR-9307060029
Title: Technical Assistance Request, Walter Reed Army
Hospital, Washington,DC, Guidance on Setting Action Levels
for Exemption from Requirement to Decontaminate Therapy
Room for Unrestricted Use
See the memorandum from J. E. Glenn to R. R. Bellamy dated
September 24, 1992. The memorandum responds to a TAR dated
June 10, 1992, regarding an amendment request from Walter
Reed Army Medical Center. In a letter dated April 8, 1992,
the licensee requested an exception to 10 CFR 35.315 (a)
(7) to allow dedication of a single patient room for
radiopharmaceutical therapies without being required to
decontaminate to the levels required for unrestricted
occupancy and assignment to a non-therapy patient.
Enclosed with the memorandum was NUREG-1388, a report
written by E. Y. Shum, R. J. Starmer, and M. H. Young
entitled Environmental Monitoring of Low-Level Radioactive
Waste Disposal Facility and published in December 1989.
This branch technical position (BTP) paper on the
environmental monitoring program for a low-level waste
disposal facility provides general guidance on what is
required by 10 CFR 61.53 of applicants submitting a license
application for such a facility. Guidance is also provided
in the BTP on the choice of which constituents to measure,
setting action levels, relating measurements to appropriate
actions in a corrective action plan, and quality assurance.
HPPOS-316 contains a related topic.
In the above TAR, it was NRC's understanding that the
licensee restricted the patient room to iodine-therapy
patients and surveyed and decontaminated the room after
release of each therapy patient. The licensee requested
relief from the requirement of decontaminating the room to
the level required for release as an unrestricted area. If
granted, an exemption from the requirements of 10 CFR
35.315 (a) (7) would be required since the regulation does
not anticipate subsequent use of the room by therapy
patients. The required decontamination level of 200
dpm/100 cm2 is for the release of the room as an
unrestricted area.
In its April 8, 1992, letter, the licensee submitted
procedures to ensure the safety of facility personnel who
frequent the vicinity of a dedicated therapy patient room.
1. The licensee stated that the door to the
contaminated therapy room would remain closed and locked
when the room was unoccupied.
2. The licensee stated that access to the unoccupied
and locked room would be under the control of the Health
Physics Office (HPO) at all times and could only be opened
by HPO personnel.
The licensees request should be approved provided the
following conditions are met, in addition to those
specified in items 1 and 2 above. The licensee should be
required to decontaminate the dedicated therapy room before
use by any other therapy patient to the restricted area
action level for removable surface contamination of 2200
dpm/100 cm2 as described in Regulatory Guide 8.23,
"Radiation Safety Surveys at Medical Institutions," or the
licensee may be approved to decontaminate based upon action
levels determined to meet the following criteria:
a. No primary radiation protection standards will be
exceeded (personal dose, member of the public dose, or
environmental release limits); and
b. The action levels are determined to be ALARA based
upon a consideration of worker, environmental, and public
exposures.
The licensee must describe the procedures to be followed to
determine these criteria are met.
Regulatory references: 10 CFR 35.315 (a) (7), 10 CFR 61
Subject codes: 4.3, 4.4, 5.0, 11.1
Applicability: Byproduct, Source, and Special Nuclear
Materials

