United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

Question 457: Some licensees have established

administrative dose control levels or guidelines, below

regulatory dose limits, as a tool to support supervisory

and management involvement in dose minimization.

Procedures commonly describe certain review actions to be

taken at successive dose levels, with a higher level of

management involvement at higher dose levels. If an

administrative dose control level or guideline is exceeded

without all of the described actions being taken, but no

regulatory limit is exceeded, is the fact of exceeding the

control level or guideline a violation of NRC regulations?

Answer: Exceeding an administrative dose control level or

guideline that is below the limits of 10 CFR Part 20 is not

a violation of 10 CFR Part 20. This is generally true with

respect to other parts of the NRC regulations, although it

is subject to exceptions; for example, for medical

licensees, 10 CFR 35.25 (a) (2) specifies requirements for

a "supervised individual" including following "the written

radiation safety and quality management procedures

established by the licensee". Such procedures might

include administrative dose control levels or guidelines

and failure to follow such procedures could be a violation

of 10 CFR 35.25 (a) (2). Furthermore, exceeding an

administrative dose control level or guideline could be a

violation of procedural requirements in the plant technical

specifications at a nuclear power plant or a violation of

specific license conditions in a material license.

(Reference: Other)

Page Last Reviewed/Updated Thursday, March 29, 2012