Health Physics Questions and Answers - Question 109

Question 109:

(a) Can a cardiologist who performs both nuclear cardiology and cardiac catheterization use a planned special exposure (PSE) to perform an emergency cardiac catheterization on the last day of the licensee's monitoring year if his annual exposure as of December 30 is 4.9 rem? It is expected that he will receive greater than 100 mrem during the procedure.

(b) Could the same cardiologist perform multiple cardiac atheterization as PSEs routinely during November and December if his annual exposure as of October 31 is 4.9 rem?

Answer:

(a) Yes, provided all administrative requirements of 10 CFR 20.1206 are met. (Note, although NRC is not regulating non-byproduct material, NRC still has regulatory authority since the occupational dose has been defined to include exposure from "licensed and unlicensed sources of radiation.")

(Reference: 20.1003 and 20.1206)

(b) No. 10 CFR 20.1206 (a) requires that a PSE be authorized ". . . only in an exceptional situation when alternatives that might avoid the higher exposure are unavailable or impractical." Performing routine occupational tasks for two months is not an exceptional situation, so the condition in 10 CFR 20.1206 (a) is not met. In short, PSEs cannot be used as a general mechanism to increase the annual dose limit from 5 rem to 10 rem TEDE, for normal situations. Note: The regulations do not prohibit the cardiologist from performing the procedures. If the cardiologist's exposure exceeds the annual limit, it should be treated as an overexposure rather than a PSE.

(Reference: 10 CFR 20.1003 and 20.1206)