United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

Question 101: 10 CFR 20.1202 (d) requires licensees to

evaluate and, to the extent practical, account for intakes

through wounds or skin absorption. What type of

"evaluation" is appropriate for determining absorption

through the skin from skin contamination, and at what

"practical level" should it be accounted for? For what

nuclides, using what criteria can absorption be neglected

under a certain threshold, such as less than 10K, 100K of

skin contamination?

Answer: The requirement to evaluate and account for

intakes through wounds or skin absorption is not new. The

old Part 20 has similar requirements [10 CFR 20.103 (a)

(1)]. Therefore, the "type of evaluation" that has been

used before, if adequate, can continue to be used. The

statement in the old Part 20 (10 CFR 20.103, Footnote 4)

that such intakes should "be evaluated and accounted for by

techniques and procedures as may be appropriate to the

circumstances" continues to be appropriate guidance for the

revised Part 20. Reference: 10 CFR 20.1202 (d)).

Page Last Reviewed/Updated Thursday, March 29, 2012