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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 catheterization 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)