Health Physics Questions and Answers - Question 102

Question 102: Under 10 CFR 20.1302 (b) (2) (ii),

(a) do the words, "If an individual were continually present in an unrestricted area," mean that nder these provisions it should be assumed a hypothetical individual is there, or

(b) should occupancy studies be made in applying this section?

Answer:

(a) Yes.

(b) No. Supplemental response: Although this question came from a nuclear power plant, it seems unlikely that a nuclear power plant would choose to use this option [10 CFR 20.1302 (b) (2)], with its conservative assumptions, to demonstrate compliance with the annual dose limit in 10 CFR 20.1301 (a) (1). It seems more likely that a nuclear power plant would prefer to use the option of 10 CFR 20.1302 (b) (1) which does not involve the conservative assumptions (effluent concentrations "at the boundary of the unrestricted area" and an "individual...continuously present in an unrestricted area"). Nuclear power plants and other uranium fuel cycle facilities must meet the more restrictive public dose limits of 40 CFR 190. As noted in the statement of considerations (56 FR 23374, third column), demonstration of compliance with the limits of 40 CFR 190 will be considered to demonstrate compliance with the 0.1-rem annual limit of 10 CFR 20.1301 (a) (1) for most facilities. This demonstration of compliance would be consistent with the option of 10 CFR 20.1302 (b) (1). See the answer to the related Question 68.

(Reference: 10 CFR 20.1302).