Lauren Giesking

§ 20.1101 Radiation Protection Programs (subpart B)

The excerpt delineates requirements for licensees concerning radiation protection programs.
Firstly, licensees are mandated to develop, document, and implement a radiation protection
program tailored to the scale and nature of their licensed activities, ensuring compliance with
regulatory provisions.

Secondly, licensees are instructed to utilize, to the extent feasible, procedures and engineering
controls founded on sound radiation protection principles. The objective is to minimize both
occupational doses and doses to members of the public, striving for levels as low as reasonably
achievable (ALARA).

Thirdly, licensees are obligated to conduct periodic reviews of the content and implementation of
their radiation protection programs, with such reviews occurring at least annually.

Lastly, licensees must establish constraints on air emissions of radioactive material, excluding
Radon-222 and its daughters. These constraints are set to ensure that individual members of the
public are not expected to receive a total effective dose equivalent exceeding 10 mrem (0.1 mSv)
per year from such emissions. In the event of exceeding this dose constraint, licensees must
report the exceedance as per § 20.2203 and promptly undertake appropriate corrective measures
to prevent recurrence.

Katie Quindlen
§ 20.1201 Occupational Dose Limits for Adults
The annual occupational dose of radiation to individuals should not exceed a total effective dose
equivalent of 5 rems (0.05 Sv) to the whole body or the deep dose equivalent and committed
dose equivalent sum of 50 rems (0.5 Sv) to an individual organ or tissue excluding the eye lens.
The annual limit for the eye lens is the dose equivalent of 15 rems (0.15 Sv) and shallow dose
equivalent 50 rem (0.5 Sv) to the whole-body skin or skin of an extremity. Soluble uranium
should be limited to an intake of no more than 10 mg a week

When an exposure is measured by an external personal monitoring device, the deep dose
equivalent should be used unless an effective dose equivalent can be calculated by an NRC
approved dosimetry method. The deep dose equivalent should be calculated according to the
body part receiving the highest exposure and the shallow dose equivalent of 10 cm of
contiguous skin that received the highest exposure. If the monitoring device was not in the
highest exposure region or the results are unavailable, other surveys and devices may be used
to measure deep, lens and shallow dose equivalents.

Any additional dose received must be deducted from an individual’s annual and lifetime limit,
including planned special exposures. If an individual was employed elsewhere and has
documented radiation exposure within the same year, their occupational dose limit should be
adjusted.
These limits are critical to our roles in fulfilling our work in a safe manner. For brachytherapy,
these limits are critical in case an exposure should occur and can affect workflow and staffing
when handling sources.

Shelby Wingold
§ 20.1202 Compliance with requirements for summation of external and internal doses.
a. If required to monitor both external and internal doses (§§ 20.1502(a) and (b)), the
licensee must sum these doses to demonstrate compliance.
If monitoring is required only under § 20.1502(a) or (b), summation is not necessary.
b. Intake by Inhalation (§ 20.1502(b)): Total effective dose equivalent limit is met if the
sum of deep-dose equivalent divided by the total effective dose equivalent limit and one
of the following does not exceed:
1. Sum of fractions of inhalation ALI (Annual Limit on Intake) for each radionuclide.
2. Total DAC-hours (Derived Air Concentration-hours) divided by 2,000.
3. The sum of the calculated committed effective dose equivalents to all
significantly irradiated organs or tissues and expressed as a fraction of the annual
limit.
c. Intake by Oral Ingestion (§ 20.1502(c)): If radionuclides are also ingested orally and
exceed 10% of the applicable oral ALI, it must be included in dose calculations.
d. Intake through Wounds or Skin Absorption (§ 20.1502(d)): Evaluate and account for
these intakes where practical.
Note:
 The intake through intact skin has been included in the calculation of DAC for hydrogen-
3 and does not need to be further evaluated.

Peyton Head
Subpart C - § 20.1203 Determination of external dose from airborne radioactive material
This subpart ensures that licensees include the contribution of the deep-dose equivalent, lens
dose equivalent, and shallow-dose equivalent from external exposure to the radioactive cloud
when determining dose from airborne radioactive material. It also notes that airborne
radioactivity measurements and DAC values should not be used as the primary means to assess
the deep-dose equivalent when the airborne radioactive material includes radionuclides other
than noble gases or if the cloud of airborne radioactive material is not relatively uniform. The
determination of the deep-dose equivalent to an individual should be based upon
measurements using instruments or individual monitoring devices

Aubrey Buskerud
Subpart C - § 20.1204 Determination of internal exposure
Subpart C 20.104 summarizes determination of internal exposure. It is the licensee’s
duty to measure concentrations of radioactive materials in air in work areas, quantities of
radionuclides in the body, quantities of radionuclides excreted from the body, or combinations
of these measurements. Without respiratory equipment it is assumed that the individual
inhales the radioactive material at its present concentrations. Calculations such as effective dose
may be performed if radionuclide is ingested. With Commision approval, the values should be
adjusted to be accurately reflected. Class Y material calculations can be allowed up to 7 months
to ensure accurate calculations and measurements. Either the sum of the ratios of the
concentration to the appropriate DAC value or the ratio of the total concentration for all
radionuclides in the mixture to the most restrictive DAC value equals the fraction of the DAC
applicable to the mixture. If concentrations are low (<10%) or meet specific numeric criteria,
their values can be disregarded. The committed effective dose equivalent is calculated assuming
the inhalation of one ALI, or an exposure of 2,000 DAC-hours and results in 0.5 rems. Stochastic
and Non-stochastic ALI’s are used to determine effective dose equivalent values based on
numeric criteria found in the other subparts of section C.

Caitlin Evans
Subpart C - § 20.1206 Planned Special Exposures
The licensee can allow an adult worker to receive additional dose separate from doses
received under the limits under § 20.1201. Certain conditions must be satisfied to authorize
additional dose. The planned special exposure is allowed only if there are no other alternatives.
The licensee must submit approval for the planned special exposure in writing before the event
occurs. The individuals involved in the planned special exposure must be informed of the
purpose, the estimated doses, possible risks, specific radiation levels, and ALARA principles. The
licensee must collect prior doses received by the individuals during their lifetime who are
involved with the planned special exposure before the event occurs. A planned special exposure
will not be authorized if it will cause an individual’s dose to exceed the limits outlined in section
§ 20.1201(a). The licensee must maintain a record of the planned special exposure in
accordance with section § 20.2105 and submit a written report as outlined in section § 20.2204.
The licensee must record the dose received by the individual and notify the individual of their
dose within 30 days of the planned special exposure.

Marissa Martin
Subpart C - § 20.1207 Occupational Dose Limits for Minors
The dose received during an individual’s employment in which they are involved with
radioactive material or are exposed to radiation is termed an occupational dose. The radiation
material can be from either a licensed or unlicensed source. The cumulative dose does not
include background radiation, personal medical procedures, exposures from administered
radioactive sources, participation in research programs, or from the general public. For adults,
occupational dose limits are defined in § 20.1201. Comparatively, anyone under 18 years of age
is considered a minor and holds annual occupational dose limits of 10 percent of the annual
limits specified for adults. This computes a total effective dose equivalent of 0.5 rems (0.005 Sv)
to the whole body or a deep dose equivalent and committed dose equivalent sum of 5 rems
(0.05 Sv) to tissue excluding the lens of the eye. Annual dose limits to the eye lens for minors
are 1.5 rems (0.015 Sv) and 5 rem (0.05 Sv) for shallow-dose equivalent to the whole body skin
or skin of extremities.
Marissa Pringle
§ 20.1208 Dose equivalent to an embryo/fetus
Dose to the embryo/fetus should not exceed .5rem (5mSv). The dose is calculated as the
sum of the deep-dose equivalent of the declared pregnant person, and the dose equivalent of
the embryo/fetus. The person should make efforts to avoid any large variation in regular
monthly exposure. If the dose exceeds .5rem (5mSv) or is within .05rem (.5mSv) when the
person declares themselves pregnant, they are still within compliance if the dose equivalent of
the embryo/fetus doesn’t exceed .05rem (.5mSv) during the remainder of their pregnancy.

Sara Kempton
Subpart D
Subpart D summarizes radiation dose limits for members of the public. It lists that the
total effective dose equivalent to individual members of the public does not exceed 0.1 rem a
year. It notes that that dose is exclusive of outside contributions like from medical research
programs and administration or disposal of radioactive materials.
The dose in an unrestricted area should not exceed 0.002 rem in one hour. This is also
exclusive of the dose from patients that have been administered radioactive material. A licensee
may permit an individual to receive a radiation dose greater than 0.1 rem if the dose does not
exceed 0.5 rem and the user has determined that it is appropriate. A licensee can apply for NRC
authorization to operate up to an annual dose limit for an individual member of the public of
0.5 rem.

Subpart D § 20.1302
Subpart D 20.1302 summarizes compliance with dose limits for individual members of
the public. It states that a licensee can take or cause surveys of radiation levels in unrestricted
and controlled areas to demonstrate compliance with dose limits. They can show this by
demonstrating the measurement or calculation that the total effective dose equivalent to the
individual likely to receive the highest dose from the operation does not exceed the annual dose
limit. This can also be demonstrated by showing the annual average concentrations of
radioactive material do not exceed the dose limit values. Lastly, it can be demonstrated by
showing the dose from external sources in an unrestricted area do not exceed 0.002 rem in an
hour and 0.05 rem in a year.

Muna Ahmed
Subpart F
Subpart F is broken into two main components. Subpart F § 20.1501 is a general highlight
surveys and monitoring and § 20.1502 conditions requiring monitoring. Subpart F § 20.1501
states that in order to comply with regulations that areas and subsurface areas must be
surveyed to assess radiation level, residual radioactivity, and protentional radiological hazards.
Records of subsurface residual radioactivity must be kept with decommissioning records and
retained. Final Personal Dosimeters that must be processed to determine radiation dose must
be processed by a dosimetry processor accredited by the National Voluntary Laboratory
Accreditation Program (NVLAP) and dosimeter must be approved for the specific type of
radiation it will monitor.

The subpart F § 20.1502 highlights the conditions that require individual monitoring of external
and internal occupational dose. Occupational exposure must be monitored and individual
monitors devices for : adults likely to receive over 10% of the dose limits from external sources
in one year, minors likely to exceed specific dose limits in one year: deep dose equivalent over
0.1 rem, lens dose equivalent over 0.15 rem, or shallow dose equivalent over 0.5 rem, declared
pregnant women likely to receive over 0.1 rem during the entire pregnancy, and Individuals
entering high or very high radiation areas For radioactive material monitoring and assessing
must be done for: adults likely to receive an intake over 10% of the applicable Annual Limits on
Intake , minors likely to receive a committed effective dose equivalent over 0.1 rem, and
declared pregnant women likely to receive a committed effective dose equivalent over 0.1 rem
during the entire pregnancy.

Mark Brennan
Subpart G - § 20.1601 Control of high radiation areas

This subpart details the necessary restrictions in areas of high radiation. Entry into these areas
must have continuous surveillance to prevent unauthorized access, or have at least one of these
surveillance methods:
-a device which reduces the radiation to a level below 0.1 rem (1mSv) per hour at 0.3m from
the source
-a visual or audible alarm that ensures that people are aware of the high radiation area
-locked entryways, except when required
The NRC may accept an application for approval of an alternate method. These controls cannot
prevent a person from leaving the area.
Packaged and properly labeled radioactive materials alone do not require control for each
entrance to a room, as long as they do not remain there for more than 3 days, and 0.01 rem (0.1
mSv) is not exceeded at 1 meter from the package. A room containing a patient implanted with
radioactive material does not require control if there are workers present to enforce ALARA
upon others.

Jenna Lombardo
Subpart G - § 20.1602 Control of access to very high radiation areas
Accompanying the previous component of subpart G (§ 20.1601, control of access to high
radiation areas) is another controlled or restricted area with regulations established by the
United States Nuclear Regulatory Commission (USNRC) to protect human health and safety.
These additional regulations specifically address the control of access to ‘very’ high radiation
areas, which are defined as places where radiation levels meet or could exceed 500 rads (5
grays) in 1 hour at 1 meter from the radiation source or from any surface it penetrates. Facilities
with such high radiation areas, called licensees, must implement stringent measures to prevent
unauthorized or accidental access. These measures include continuous monitoring and
surveillance, additional procedures and comprehensive training, robust physical barriers, and
clear signage. Warning signs for these areas, while similar in appearance to those for other
controlled areas, will specifically state “Caution: Very High Radiation Area” to indicate the
heightened level of risk.