United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

U.S. Nuclear Regulatory Commission

Question 413: This question refers to the answers to

Questions 66 and 31 under §20.1003 and §20.1201,

respectively, and to Question 26 (d) under §20.1003.

Simply designating an area as a restricted area so you can

control everyone at occupational dose limits is a

perversion of every radiation protection principle

published. Of course, this is just my opinion. I hope NRC

will revise its interpretation of this definition.



For example, a secretary in a nuclear medicine clinic

without any direct person-to-person contact with patients

should not be subject to occupational limits just because

she is in a restricted area. Many other examples could be

cited, and some that are more in the gray area should be

examined carefully. Clearly, there is a significant

population of exposed persons that are not being held to

the proper standard. The following statement refers to the

answer to Question 26 (d) concerning "individual E." In

spite of the definition of occupational dose, mere

geography is not justification for classifying a person as

a radiation worker.



Answer: The questioner appears to object to the

definition of "occupational dose" that states that

"occupational dose means the dose received by an individual

in a restricted area or . . . ." The NRC cannot change

this definition by revising its "interpretation of this

definition." The definition can only be changed by

rulemaking.



While there may have been a lack of clarity in the

referenced answers, our intention is that licensees should

not engage in a practice of "simply designating an area as

a restricted area so you can control everyone at

occupational dose limits." Question 66 asks if a simple

fenced area can qualify as a restricted area and the answer

is yes, provided it is the licensee's purpose to limit

access for the purpose of controlling radiation exposures.

Question 31 asks if students and volunteers (such as

nuclear medicine students and "candy stripers" who

transport nuclear medicine patients or perform volunteer

work in a nuclear medicine department) are subject to

occupational dose limits. The answer to this question is

that these individuals are subject to the occupational dose

limits because, and provided that (as the question

implies), the type of work they are assigned involves

exposure to radiation; it does not matter where (in which

area) they are working Question 26 (d) asks if the

occupational dose limits or public dose limits apply to

"Individual E," a secretary for a radiography company, who

works in a "controlled area" next to a "restricted area"

containing a hot cell. The answer is that the occupational

dose limits apply), again because the type of work assigned

presumably involves exposure to radiation since it must be

performed near the hot cell. (References: 10 CFR 20.1003,

10 CFR 20.1201).









Page Last Reviewed/Updated Thursday, March 29, 2012