Technical Assistance Request, Walter Reed Army Hospital, Washington, D.C., Guidance on Setting Action Levels for Exemption from Requirement to Decontaminate Therapy Room for Unrestricted Use

HPPOS-321 PDR-9307060029

See the memorandum from J. E. Glenn to R. R. Bellamy dated September 24, 1992.

The memorandum responds to a TAR dated June 10, 1992, regarding an amendment request from Walter Reed Army Medical Center. In a letter dated April 8, 1992, the licensee requested an exception to 10 CFR 35.315 (a) (7) to allow dedication of a single patient room for radiopharmaceutical therapies without being required to decontaminate to the levels required for unrestricted occupancy and assignment to a non-therapy patient. Enclosed with the memorandum was NUREG-1388, a report written by E. Y. Shum, R. J. Starmer, and M. H. Young entitled Environmental Monitoring of Low-Level Radioactive Waste Disposal Facility and published in December 1989. This branch technical position (BTP) paper on the environmental monitoring program for a low-level waste disposal facility provides general guidance on what is required by 10 CFR 61.53 of applicants submitting a license application for such a facility. Guidance is also provided in the BTP on the choice of which constituents to measure, setting action levels, relating measurements to appropriate actions in a corrective action plan, and quality assurance. HPPOS-316 contains a related topic.

In the above TAR, it was NRC's understanding that the licensee restricted the patient room to iodine-therapy patients and surveyed and decontaminated the room after release of each therapy patient. The licensee requested relief from the requirement of decontaminating the room to the level required for release as an unrestricted area. If granted, an exemption from the requirements of 10 CFR 35.315 (a) (7) would be required since the regulation does not anticipate subsequent use of the room by therapy patients. The required decontamination level of 200 dpm/100 cm2 is for the release of the room as an unrestricted area.

In its April 8, 1992, letter, the licensee submitted procedures to ensure the safety of facility personnel who frequent the vicinity of a dedicated therapy patient room.

1. The licensee stated that the door to the contaminated therapy room would remain closed and locked when the room was unoccupied.

2. The licensee stated that access to the unoccupied and locked room would be under the control of the Health Physics Office (HPO) at all times and could only be opened by HPO personnel.

The licensees request should be approved provided the following conditions are met, in addition to those specified in items 1 and 2 above. The licensee should be required to decontaminate the dedicated therapy room before use by any other therapy patient to the restricted area action level for removable surface contamination of 2200 dpm/100 cm2 as described in Regulatory Guide 8.23, "Radiation Safety Surveys at Medical Institutions," or the licensee may be approved to decontaminate based upon action levels determined to meet the following criteria:

1. No primary radiation protection standards will be exceeded (personal dose, member of the public dose, or environmental release limits); and

2. The action levels are determined to be ALARA based upon a consideration of worker, environmental, and public exposures.

The licensee must describe the procedures to be followed to determine these criteria are met.

Regulatory references: 10 CFR 35.315 (a) (7), 10 CFR 61

Subject codes: 4.3, 4.4, 5.0, 11.1

Applicability: Byproduct, Source, and Special Nuclear Materials