So, Doc – I read an article about how the NRC is changing dose limits to let radiation workers get more dose. I’m a hospital RSO – how’s this going to affect me?
So…let’s start by noting that there haven’t been any regulatory changes yet. There are some Executive Orders (e.g. Executive Order 14300: Ordering the Reform of the Nuclear Regulatory Commission), and some proposed regulatory changes, but the thrust of most of them is to make it easier to build and license small modular nuclear reactors, not to tell you to change your medical radiation safety program. And – most importantly – the actual regulations today remain the same as they’ve been for a number of years, and will continue to be the same until the rule change is finalized and implemented. And even then implementation takes some time – anywhere from months to years. So no matter what the NRC decides (and what’s approved), you’ll have plenty of time to understand how it affects you and how you might need to change your own radiation safety program. And here’s the thing – you might not need to change a thing!
Say, for example, that public dose limits are revised upwards – from, say, 100 to 500 mrem annually for members of the public. You can revise your policy manual to increase your allowable dose limits for members of the public…but you don’t have to. You’re allowed to have your limits be more restrictive than regulatory limits – no regulator is going to give you a violation for being more protective than you’re required to be. Same thing for rad worker dose limits– you’re also allowed to have local limits that are lower than what the regs require. So – sure – if the NRC eases up on their regulatory limits you can do the same in your policy manual, or you can keep your dose limits exactly as they have been. Having said that, if you have workers (or members of the public) running close to dose limits from time to time it can be nice to have some more wiggle room. Or you might choose something in the middle – you could raise your dose limits to match the new regulations while maintaining internal limits as they have been. Or any of a number of other possibilities – whatever works best for you and your organization.
Consider, too, that there’s been talk of “eliminating ALARA” – at present, you’ve got to have an ALARA program as a part of your license application process; does this mean that you’d need to delete all references to ALARA and cancel your internal ALARA program? Well…no. Again, your regulators won’t ding you for voluntarily having a protective program, even if it’s not required by regulations. So if you’re happy with your current ALARA program you can keep it exactly as it is.
That being said, there are some sorts of regulatory changes that would cause you to make changes in your radiation safety program:
- Reducing limits (e.g. allowable dose or dose rate)
- Changing required periodicities (e.g. sealed source leak tests from semi-annual to quarterly)
- Adding required events calling for reports to regulators (e.g. loss of exempt sources)
- Revising a definition so that your facility, sources, equipment, etc. are now regulated (e.g. changing the definition of “radioactive material” to include previously exempt materials such unimportant quantities of source material)
What these have in common is that your current policies or practices are probably not in compliance with the new requirements because the new requirements are more restrictive than what they were when you were licensed.
That all being said, there’s very little in the proposed changes that will affect a medical licensee – the proposed changes (found about 2/3 of the way down this web page in Section XVII) are to 10 CFR Parts:
30—RULES OF GENERAL APPLICABILITY TO DOMESTIC LICENSING OF BYPRODUCT MATERIAL
37—PHYSICAL PROTECTION OF CATEGORY 1 AND CATEGORY 2 QUANTITIES OF RADIOACTIVE MATERIAL
40—DOMESTIC LICENSING OF SOURCE MATERIAL
51—ENVIRONMENTAL PROTECTION REGULATIONS FOR DOMESTIC LICENSING AND RELATED REGULATORY FUNCTIONS
70—DOMESTIC LICENSING OF SPECIAL NUCLEAR MATERIAL
72—LICENSING REQUIREMENTS FOR THE INDEPENDENT STORAGE OF SPENT NUCLEAR FUEL, HIGH-LEVEL RADIOACTIVE WASTE, AND REACTOR-RELATED GREATER THAN CLASS C WASTE
140—FINANCIAL PROTECTION REQUIREMENTS AND INDEMNITY AGREEMENTS
Also, remember – none of this happens instantaneously! Even if all of these proposed changes are approved the NRC will need to give everyone a chance to come into compliance – licensees, Agreement States, and others. Which means that even if your license is affected, you’ll have a year or more to update your policies, procedures, training, and (if required) license to comply. That being said, I’ve got to admit I didn’t see much – if anything – that would call for any drastic changes for a medical licensee, or for most others.
That’s about all I can see in this, to be honest. But if you go to work for a utility or someone who wants to get a license for a nuclear reactor or another fuel cycle facility, you’re going to need to take a careful look at the revised rules…or find a consultant who can help you to do so.
Good luck!