United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

Question 137: At a nuclear power plant, the individual

asked to approve a planned special exposure (PSE) will need

to believe that the alternatives are impractical or

unavailable before doing so. But he or she must recognize

that the NRC inspector who later reviews the PSE report may

not agree, possibly leading to a notice of violation for an

overexposure. If the individual at the nuclear power plant

chooses to request it from the Region, can a decision be

obtained in advance regarding the acceptability of the

licensee's alternatives analysis?

Answer: Yes. Any licensee may contact the appropriate

supervisor or manager (e.g., a Branch Chief in the Division

of Radiation Safety and Safeguards in an NRC regional

office) to determine whether or not the NRC staff agrees

that the circumstances in an actual situation meet the

requirement for an "exceptional situation when alternatives

that might avoid the higher exposure are unavailable or

impractical." A written description of the circumstances

of the exceptional situation should be provided to the NRC

regional office when requesting NRC review in advance of a

PSE. However, an NRC decision in advance of a PSE, based

on the information submitted by the licensee, that the

circumstances appear to meet the regulatory requirements

does not preclude a subsequent NRC finding, based on

additional information obtained during an inspection, that

the circumstances were not as originally described and,

therefore, that the PSE was not in accordance with the

regulatory requirements concerning PSEs. (Reference: 10

CFR 20.1206).

Page Last Reviewed/Updated Thursday, March 29, 2012