Tamara Eng, Sharan Swenski, Shands James, Kristine Phillips, Kevin Dwyer & Glenda Longoria

Subpart B 20.1101
Subpart B is concerned with radiation protection and the conduct required of a license holder.
There are 4 conditions of 20.1101; to have a protection program, practice ALARA, maintain
testing, and minimize airborne radiation.
Protection program: the licensee will be required to compose and maintain a radiation protection
program. All radiation activity that the licensee undertakes must be able to adhere to the radiation
protection measures. To me this would mean, if linear accelerators are in the department then
staff would be aware of dose to them or their workplace through the use of dosimeters or area
monitoring devices and would include ring badges if isotopes were handled.
Practice Alara: licensee will use procedures, controls, and good practice to ensure radiation
protection principles are applied to personnel and the public. This could be to image only what is
a necessary, no unnecessary persons near high radiation areas or only essential staff in the
brachytherapy suite.
Testing: perform an annual test to ensure compliance of the radiation protection program. This
may include reviewing documentation of the protection program and annual education of
personnel on the program.
Minimize airborne radiation emissions: from Radon-222 and its decaying products to be under a
total effective dose equivalent of 10 mrem. Total effective dose equivalent is the biological dose
the person is exposed to plus any ionization that takes place within the body, which is why it is
the total dose.
Subpart C 12.1201
This section delineates dose limitations for personnel and public. Personnel should adhere to the
following exposures except for a special procedure. The following annual limits are for adults
only: whole body not to exceed 5 rems, deep dose to organs or tissue 50 rems, lens 15 rems, skin
dose 50 rems. Any emergency exposure or special exposure must be subtracted from this limit.

Tamara Eng, Sharan Swenski, Shands James, Kristine Phillips, Kevin Dwyer & Glenda Longoria
When an external exposure is measured by an external personal monitoring device the highest
exposure effect is taken into account. The deep dose measurement must be for the part of the
body receiving the highest exposure. The shallow dose should be one 10 centimeter square of
tissue that received the highest dose. All these doses must be gathered by a NRC approved
survey device.
Derived air concentrations (DAC) and annual limit on intake (ALI) relate to the possible
carcinogenic air a worker could be exposed to. Given that a person at work would breathe 2x104
ml volume of air per minute, the exposure of certain nuclides needs to be limited, certain
radioactive materials have a designated ALI and that is used to derive the DAC. DAC is a way to
quantify the parts of a nuclide in air, and this value would be the max amount of air a person
should be exposed to. In addition to the above limitations on inhalants the carcinogenic effect of
Uranium has been an added caution and constraint for personnel that work around it, because it
is soluble in the lungs and should be avoided if possible.
The licensee will be responsible for reduction of personnel dose annually regardless of where the
person was employed. This is why our dosimeter records are linked to each person and not
institute and are followed for our whole career.
Subpart C 20.1202-20.1204
There are some terms used in Part 20, subpart C, that require some defining/explaining before
moving forward with breaking down the subparts. ALI stands for annual limit on intake and it
is the limit of radioactive materials taken into the body of an adult worker by inhalation or
ingestion in a single year. Dose equivalent is the product of absorbed dose in tissue and that
tissues quality factory; effective dose equivalent is the sum of the products of the dose equivalent
to the organ or tissue and the weighting factor applicable to each body organ/tissue. DAC stands
for derived air concentration and it is simply the concentration of a radioactive material in the
air; inhalation rate of 1.2 cubic meters of air per hour results in an intake of one ALI.
20.1202 - Compliance with requirements for summation of external and internal doses:

Tamara Eng, Sharan Swenski, Shands James, Kristine Phillips, Kevin Dwyer & Glenda Longoria
Checking compliance of yearly dose limits requires the summing of external and internal source
material. 20.1202 Part B discusses radiation intake by inhalation; dose limits are not exceeded by
way in inhalation if: 1. The whole body dose equivalent plus total effective dose equivalent does
not equal unity, 2. The sum of all inhalations does not equal the annual limit (ALI), and 3. Total
number of derived air concentration (DAC) hours for all radionuclides do not reach unity when
divided by the annual limit of 2000 hours. 20.1202 Part C discusses radiation intake by oral
ingestion; this value should be accounted for if ingestion is greater than 10% of the applicable
ALI. 20.1202 Part D discusses radiation intake through wounds or absorption through skin. The
licensee must meet the requirements/dose limits of at least one of these subsections (b, c, or d) in
order to comply with the allowed dose limits of external and internal source exposure combined.
Any exposure that exceeds the set occupational limits set forth by the NRC, needs to be
accounted for and included in demonstrating compliance with the limits.
20.1203 Determination of external dose from airborne radioactive material:
Airborne radioactivity that is found in the air exits in the form of dusts, fumes, particulates,
mists, vapors, or gases. Any detection of airborne radioactive material exposure needs to be
accounted for in conjunction with any external exposure that includes the deep-dose equivalent
(whole body/deep organ dose equivalent), lens of the eyes dose equivalent, and shallow-dose
equivalent (skin dose equivalent). The determination of body/organ dose equivalent should be
based upon measurements using instruments or monitoring devices and not just solely on
airborne radioactivity measurements.
20.1204 Determination of internal exposure:
When assessing the dose to determine compliance with occupational dose equivalent limits, from
the monitoring of internal and external radiation source intake, the licensee should take
measurements of the concentration of the radioactive materials in the work areas, quantities of
the radionuclide in the body, quantities of the radionuclide excreted from the body, and/or a
combination of these measurements. When the physical or biochemical properties of a
radionuclide is known, and such nuclide is taken up into the body, the licensee can use such
information to calculate the committed effective dose equivalent (sum of the products of the

Tamara Eng, Sharan Swenski, Shands James, Kristine Phillips, Kevin Dwyer & Glenda Longoria
weighting factors applicable to each of the body organs/tissues that are irradiated) or adjust the
DAC and ALI values to reflect such physical and chemical characteristics of known airborne
radioactive material. Now, when a mixture of airborne radioactive materials exist in the air, one
may disregard certain radionuclides in the mixture only if total activity of the mixture is used to
demonstrate compliance, the concentration of that nuclide is less than 10% of its DAC, or the
sum percentage of the discarded nuclides does not exceed 30%.
Subpart C 20.1206
Subpart C 20.1206 allows for adult workers to be exposed to radiation in addition to the annual
limits and is separately tracked. This allowance is considered a planned special exposure that
must meet certain criteria to qualify as such. For a planned special exposure to be allowed the
resources for an exposure that would not exceed limits must be unavailable or impractical, the
licensee must authorize the exposure in writing prior to its occurrence, and the individuals must
be informed of the purpose and plan, estimated amount of exposure, and the measures to achieve
ALARA. A prerequisite to these criteria is determining the dose that the individual has received
previously. However, a special planned exposure cannot be authorized if the total exposure the
individual receives exceeds the numerical values of the dose limits in 20.1201 in any year and is
five times the annual dose limits in 20.1201 during the individuals lifetime. A written report
must be made of the special planned exposure and submitted in accordance with 20.2204 and the
individual must be informed of the dose received within 30 days.
Subpart C 20.1207
Subpart C 20.1207 covers the annual occupational dose limits for minors. It states that the dose
limits for minors are 10% of the annual occupational dose limits for adult workers in 20.1201.
Subpart C 20.1208
Subpart C 20.1208 establishes exposure limits to embryos and fetuses. The dose limit to the
embryo/fetus cannot exceed 0.5 rem over the course of the entire pregnancy. The licensee must
take precautions to prevent the pregnant woman from receiving above a uniform monthly
exposure. The dose equivalent for the embryo/fetus is defined as the deep-dose equivalent to the

Tamara Eng, Sharan Swenski, Shands James, Kristine Phillips, Kevin Dwyer & Glenda Longoria
declared woman and the dose equivalent to the embryo/fetus resulting from radionuclides in the
embryo/fetus and pregnant woman. If the embryo/fetus has received within .05 rem of the
established exposure limit at the time the pregnancy is declared then the licensee is in
compliance of maintain the exposure limit for an embryo or fetus.
Subparts 20.1206-1208 would probably limit who can work on brachytherapy procedures.
Specifically a minor may not be allowed to work with brachytherapy (though a minor would
probably not be employed at a radiation oncology center). Also, someone who is pregnant and
the embryo/fetus is approaching the exposure limit should not allowed to participate in a
brachytherapy procedure. Planned special exposures may allow someone who is close to their
limit to participate in place of a pregnant woman or minor as they would no longer be available
for the procedure.
Subpart D
Subpart D outlines the regulations set to protect the dose limits for individual members of the
public. In radiation oncology departments it is not uncommon to have radioactive sources
housed in certain areas or that pass through the halls on a daily basis. It is also important to note
that there is a lot of traffic that walk the halls in these facilities, passing radioactive sources
without even knowing it. Without the stringent regulations put in place by the NRC radiation
exposure could be devastating to the innocent public and employees who do not know the
dangers of radiation exposure. These regulations set by the NRC keep the employees and the
public safe from unnecessary exposure.
20.1301 - Dose limits for individual members of the public
The determined total effective dose equivalent for members of the public should not exceed 0.1
rem.1 Controlled and unrestricted areas with external sources available are also monitored and
should not exceed 0.002 rem per hour. If there is ever an instance where a patient is receiving
treatment with a radioactive source and they have a visitor, the dose to the visitor in this case
may exceed 0.1 rem, but should not exceed 0.5 rem, and it must be approved by an authorized
user. Additionally, in special cases the dose limit may be increased for a member of the public to
0.5 rem, but must come with documentation from the facility for such a need, the duration of

Tamara Eng, Sharan Swenski, Shands James, Kristine Phillips, Kevin Dwyer & Glenda Longoria
time needed for the increase, and the facility needs to identify their means of assessing and
controlling the dose.
20.1302 - Compliance with dose limits for individual members of the public
To ensure safety, the facility is responsible for performing surveys to monitor radiation levels in
unrestricted areas, controlled areas, as well as for the radioactive materials in effluents to
demonstrate that the dose limits are in compliance. 1 In addition, the facility should comply with
the dose limits in 20.1301 and submit documentation that the total effective dose equivalent
was not surpassed for the individual who received the maximum dose from any operation, or
prove that the yearly average concentration of radioactive material not go beyond the appointed
values in table 2 of appendix B to part 20. If deemed necessary, the facility may also change the
effluent concentration values in appendix B to part 20 table 2, to account for the physical and
chemical characteristics of the effluents, however it is subject to approval from the Commission.
Subpart F
Subpart F of 10 CFR part 20 addresses radiation surveys and monitoring. Subpart F is divided
into two sections, 20.1501 general section and 20.1502 conditions requiring individual
monitoring of external and internal occupational dose.
Subpart F 20.1501
The general section discusses the responsibility of every licensee to survey all areas, including
the subsurface, which may be required for the licensee to follow the regulations in this section, as
well as, areas which are reasonable given the circumstances to assess 3 aspects. First the
magnitude and extent of the radiation levels. Second the concentrations or quantities of the
remaining radioactivity. The last aspect is the potential radiological hazards of the given
radiation levels and residual radioactivity detected.1 For example, when a shipment of 125I or
198

AU arrives, all seeds must be counted to verify that none were lost during their transport.

After a procedure, all seeds must be accounted for including the information of the 3
aforementioned aspects. Every seed that is inserted into the patient is accounted for and if they
are temporary seeds, they are all accounted for upon removal as well. After removal, the patient

Tamara Eng, Sharan Swenski, Shands James, Kristine Phillips, Kevin Dwyer & Glenda Longoria
must be surveyed via a sensitive survey meter to demonstrate that no radioactivity remains.1 The
room is also surveyed both after the insertion procedure and removal procedure to ensure no
seeds were dropped. Another example, involves wipe tests to verify that no leakage has
occurred. The licensee must maintain records of all surveys delineating the location and quantity
of subsurface residual radioactivity found at the site. These records should be kept along with
records pertaining to decommissioning. The licensee must periodically calibrate both the
instruments and equipment utilized for quantitative radiation measurements, such as dose rate for
the radiation measured. Personnel dosimeters, excluding direct and indirect reading pocket
ionization chambers and dosimeters, used to measure the dose to the extremities, which need to
be processed to obtain a radiation dose reading, must follow all guidelines as stated in section
20.1201 or with conditions outlined in a license are required to be processed, as well as,
evaluated by a dosimetry processor who is currently accredited from the National Voluntary
Laboratory Accreditation Program (NVLAP) of the National Institute of Standards and
Technology. Furthermore, said dosimetry processor must be approved in the accreditation
process for the kind of radiation included in the NVLAP program which is most similar to the
given radiation for which the person is being monitored by the dosimeter.1
Subpart F 20.1502
The second section of subpart F of 10 CFR part 20, 20.1502, outlines conditions which require
individual monitoring of external, as well as, internal occupational dose. This sections states the
minimum monitoring requirements that licensees must adhere to regarding exposure to radiation,
as well as, radioactive material at levels adequate enough to show compliance with the
occupational dose limits described in this sections. Licensees must monitor occupational
exposure to both radiation from licensed, as well as, unlicensed radiation sources, which the
licensee controls.1 For example, licensees must monitor exposure to all personnel who are
involved in any part of the brachytherapy program. This includes personnel who handle
radioactive sources, as well as, individuals who transport sources from the storage area to the
operating room. It also includes the physician performing the brachytherapy procedure and
personnel present in the room in which radioactive sources are loaded or removed from
afterloading carriers or the patient.2 The licensee must supply and require the following

Tamara Eng, Sharan Swenski, Shands James, Kristine Phillips, Kevin Dwyer & Glenda Longoria
individuals to wear monitoring devices: adults who have a high probability to receive a dose
greater than 10% of the limits outlined in 20.1201(a) within a 1-year time period from sources
external to the body, minors with a high probability to receive a deep dose equivalent greater
than 0.1 rem or 1mSv, a lens dose equivalent greater than 0.15 rem or 1.5 mSV, or a shallow dose
equivalent to the skin or extremities greater than 0.5 rem or 5 mSv from radiation sources
external to the body within a 1-year time period, women who have declared they are pregnant
who have a high chance of receiving a deep dose equivalent greater than 0.1 rem or 1 mSv
during the length of their pregnancy from a source external to their bodies, and people who enter
a high or very high radiation area. Furthermore, this section states that a licensee must monitor
the occupational intake of radioactive material by and assess the committed effective dose
equivalent to: adults with a high probability to receive a committed effective dose equivalent
above 10% of the applicable annual limit on intake (ALI) within 1-year time period, minors who
have a high chance to receive a committed effective dose equivalent above 0.1 rem or 1 mSv, and
women who have declared their pregnancy to receive a committed effective dose equivalent
greater than 0.1 rem or 1 mSv during the full length of their pregnancy.1
Subpart G
Access to a high radiation areas is regulated by features of the room. Entryways are
required to be locked at all times, except when access is required. When access is required then
there must be control over each individual entry. The room should have one or more control
features for safety. The first is a control device that halts the production of radiation upon entry
to the room. The control must be able to reduce the radiation 30 centimeters from any point
below 1 rem in 1 hour. The second control device is a visible and audible alarm bright/loud
enough for the individual and supervisor to know an unintentional entry has occurred. The
entryway controls may be substituted by a continuous electronic or direct entry preventive
surveillance system. These controls must not prevent an individual from leaving a high radiation
area. Very high radiation areas (5Gy or more at 1 meter from a source) are further specified by
requiring extra cautious measures to ensure no unauthorized or accidental entry.

References

Tamara Eng, Sharan Swenski, Shands James, Kristine Phillips, Kevin Dwyer & Glenda Longoria
1. U.S. Nuclear Regulatory Commission. NRC Regulations Title 10, Code of Federal Regulation
Part 20 Surveys and Monitoring. 20.1203. http://www.nrc.gov/reading-rm/doccollections/cfr/part020/ Published May 21, 1991. Updated December 02, 2015. Accessed April
11, 2016.
2. Bentel GC. Radiation Therapy Planning. 2nd ed. New York; NY: McGraw-Hill; 1995.