United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

U.S. Nuclear Regulatory Commission

Question 402: NRC Form 5 (Item No. 21, "Comments") implies

that dose from a "hot particle" should be added to the

shallow dose equivalent, maximum extremity (SDE, ME - Block

14). However, I&E Notice 90-48 states that "hot particle

exposure will not be added to skin doses from sources other

than hot particles." (a) Should hot particle doses be

added to the shallow dose equivalent as implied? (b) If

so, should this dose be subtracted from the applicable dose

category with regard to remaining available shallow dose

equivalent (skin or extremity) for the year? Based on our

understanding of the intent of I&E Notice 90-48, we believe

that "hot particle" doses should not be subtracted from the

remaining available shallow dose equivalent (skin or

extremity) for the year.



Answer: The intent of the "hot particle" example in the

instructions for Item 21 on Form 5 is simply to give one an

example of how this space on the form might be used. There

is no intention to imply that hot particle doses should be

added to other doses. The question of adding hot particle

skin doses to other skin doses was addressed in IE

Information Notice 90-48, "Enforcement policy for Hot

Particle Exposures," and the enforcement policy enclosed

with that notice, and in Health Physics Position (HPPOS)

246 (in NUREG / CR-5569). The NRC policy and staff positions

in these documents have not been changed by revised Part 20

or the instructions for Form 5 in Regulatory Guide.

Answers to the specific questions are as follows: (a) As

indicated in HPPOS-246, licensees may choose whether or not

to add a hot particle dose to other skin or extremity

doses. However, in either case, the record should be clear

as to the amount of the hot particle dose. In determining

whether or not an overexposure has occurred, the NRC will

consider the hot particle dose alone, without adding it to

other doses.



(b) The hot particle dose should not be subtracted from the

remaining available shallow dose equivalent (skin or

extremity) for the year. (References: 10 CFR 20.2106, 10

CFR 20.2206, Regulatory Guide 8.7).









Page Last Reviewed/Updated Thursday, March 29, 2012