United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

Question 98: The following questions concern the

requirements of 10 CFR 20.1502 as applied to nuclear power


(a) Since the nuclear power industry has had few intakes

approaching the 10% criteria for adding internal and

external doses, is the historical record of intakes plus

the establishment of a corporate (licensee) policy to limit

intakes to less than 10% of an ALI sufficient to exclude a

nuclear power licensee from the requirements for

"monitoring" intakes (10 CFR 20.1502) and adding internal

and external (except for specific intake instances)?

(b) Will the apparent new practice of minimizing TEDE and

allowing some intakes invalidate this historical basis and

essentially require nuclear power licensees to "monitor"


(c) In determining whether a worker is likely to exceed

the 10% criteria, on what basis are projections to be made

of the future intake of contract workers (for the remainder

of the year after they leave our site)?

Answer: (a) Yes, assuming that the conditions of exposure

are not expected to change to the extent that they are

outside the bounds of that historical record and that

procedures will be put into effect to implement the policy.

However, "surveys", in accordance with 10 CFR 20.1501 (a),

would still be needed.)

(b) Not likely. However, the resulting potential increase

in intakes will need to be considered in determining

whether or not workers are likely to receive intakes in

excess of 10% of an ALI. The historical record should be

useful in evaluating this potential increase.

(c) Such projections are not required. As indicated in

draft Regulatory Guide DG-8010 ("Criteria for Monitoring

and Methods for Summation of Internal and External

Occupational Doses"), each licensee makes the determination

independently; doses that may have been received, or that

may be received in the future, at another licensee's

facility are not included in the determination of the

monitoring requirement. (Reference: 10 CFR 20.1502).

Page Last Reviewed/Updated Thursday, March 29, 2012