United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

Question 109: (a) Can a cardiologist who performs both

nuclear cardiology and cardiac catheterization use a

planned special exposure (PSE) to perform an emergency

cardiac catheterization on the last day of the licensee's

monitoring year if his annual exposure as of December 30 is

4.9 rem? It is expected that he will receive greater than

100 mrem during the procedure. (b) Could the same

cardiologist perform multiple cardiac catheterization as

PSEs routinely during November and December if his annual

exposure as of October 31 is 4.9 rem?

Answer: (a) Yes, provided all administrative

requirements of 10 CFR 20.1206 are met. (Note, although

NRC is not regulating non-byproduct material, NRC still has

regulatory authority since the occupational dose has been

defined to include exposure from "licensed and unlicensed

sources of radiation.") (Reference: 20.1003 and 20.1206)

b) No. 10 CFR 20.1206 (a) requires that a PSE be

authorized ". . . only in an exceptional situation when

alternatives that might avoid the higher exposure are

unavailable or impractical." Performing routine

occupational tasks for two months is not an exceptional

situation, so the condition in 10 CFR 20.1206 (a) is not

met. In short, PSEs cannot be used as a general mechanism

to increase the annual dose limit from 5 rem to 10 rem

TEDE, for normal situations. Note: The regulations do not

prohibit the cardiologist from performing the procedures.

If the cardiologist's exposure exceeds the annual limit, it

should be treated as an overexposure rather than a PSE.

(Reference: 10 CFR 20.1003 and 20.1206)

Page Last Reviewed/Updated Thursday, March 29, 2012