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Question 457: Some licensees have established
administrative dose control levels or guidelines, below
regulatory dose limits, as a tool to support supervisory
and management involvement in dose minimization.
Procedures commonly describe certain review actions to be
taken at successive dose levels, with a higher level of
management involvement at higher dose levels. If an
administrative dose control level or guideline is exceeded
without all of the described actions being taken, but no
regulatory limit is exceeded, is the fact of exceeding the
control level or guideline a violation of NRC regulations?
Answer: Exceeding an administrative dose control level or
guideline that is below the limits of 10 CFR Part 20 is not
a violation of 10 CFR Part 20. This is generally true with
respect to other parts of the NRC regulations, although it
is subject to exceptions; for example, for medical
licensees, 10 CFR 35.25 (a) (2) specifies requirements for
a "supervised individual" including following "the written
radiation safety and quality management procedures
established by the licensee". Such procedures might
include administrative dose control levels or guidelines
and failure to follow such procedures could be a violation
of 10 CFR 35.25 (a) (2). Furthermore, exceeding an
administrative dose control level or guideline could be a
violation of procedural requirements in the plant technical
specifications at a nuclear power plant or a violation of
specific license conditions in a material license.
(Reference: Other)