Health Physics Questions and Answers - Question 457

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)