Health Physics Questions and Answers - Question 98
Question 98: The following questions concern the requirements of 10 CFR 20.1502 as applied to nuclear power plants.
(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" intakes?
(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)?
(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).