United States Nuclear Regulatory Commission - Protecting People and the Environment

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


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


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