United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

U.S. Nuclear Regulatory Commission

Question 414: This question refers to the answer to

Question 6 §20.1201. This answer does not directly answer

the implied question, which is, "if a person is assessed a

history of 5 rem or more for the current year, is that

person permitted to receive any occupational dose?"



Implied in the answer is that if monitoring is not

required, that person can receive an occupational dose,

presumably up to 500 mrem for an adult. Conceptually, this

is not consistent with normal protection standards, i.e.,

"if you don't measure it, it is not there" is not a

normally accepted practice. The Commission allowance for

an explicit 100 mrem (SECY-90-387, November 26, 1990) would

seem a much more reasonable approach. Both of these

positions appear to conflict with the answer to Question

113 in the third set. Hopefully, a position similar to that

taken for the declared pregnant woman with a pre-existing

dose history will be taken. That is, an additional small

increment of exposure is not biologically significant.



Answer: "If a person is assessed a history of 5 rem or

more for the current year", that individual is not

permitted to receive any additional occupational dose

during that year (except a planned special exposure). The

answer to Question 6 does not imply that the individual can

receive any additional occupational dose (except in a

planned special exposure). As noted in the preamble to

revised Part 20 (56 FR 23369, second column), "the

allowance of an additional 1 rem per quarter following an

exposure in excess of the limits has been deleted" from the

final rule published on May 21, 1991. The answer to

Question 6 is consistent with the rule and the answer to

Question 113, which states that "...if the 5 rem CEDE was

received during the current year, this individual would not

be allowed any further exposure for the balance of the

year." (Reference: 10 CFR 20.1201, 10 CFR 20.2104).









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