U.S. NUCLEAR REGULATORY COMMISSION August 2010

Revision 1

REGULATORY GUIDE

OFFICE OF NUCLEAR REGULATORY RESEARCH

The NRC issues regulatory guides to describe and make available to the public methods that the NRC staff considers acceptable 

for use in implementing specific parts of the agency=s regulations, techniques that the staff uses in evaluating specific problems or 

postulated accidents, and data that the staff needs in reviewing applications for permits and licenses. Regulatory guides are not 

substitutes for regulations, and compliance with them is not required. Methods and solutions that differ from those set forth in 

regulatory guides will be deemed acceptable if they provide a basis for the findings required for the issuance or continuance of a 

permit or license by the Commission. 

This guide was issued after consideration of comments received from the public. 

Regulatory guides are issued in 10 broad divisionsC1, Power Reactors; 2, Research and Test Reactors; 3, Fuels and Materials 

Facilities; 4, Environmental and Siting; 5, Materials and Plant Protection; 6, Products; 7, Transportation; 8, Occupational Health; 

9, Antitrust and Financial Review; and 10, General. 

Electronic copies of this guide and other recently issued guides are available through the NRC=s public Web site under the 

Regulatory Guides document collection of the NRC=s Electronic Reading Room at 

http://www.nrc.gov/reading-rm/doc-collections/ and through the NRC=s Agencywide Documents Access and Management 

System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html, under Accession No. ML101370008. The regulatory analysis 

may be found in ADAMS under Accession No. ML101370119. 

REGULATORY GUIDE 8.35 

(Draft was issued as DG-8032, dated December 2009) 

PLANNED SPECIAL EXPOSURE 

A. INTRODUCTION 

This regulatory guide provides guidance on the conditions and prerequisites for permitting 

planned special exposure(s) (PSE(s)), as allowed by Title 10 of the Code of Federal Regulations

(10 CFR) Part 20, “Standards for Protection against Radiation” (Ref. 1), the associated specific 

monitoring and reporting requirements, and examples of acceptable means of satisfying these 

requirements. 

Occupational dose limits are established in 10 CFR 20.1201, “Occupational Dose Limits for 

Adults.” 10 CFR 20.1201(b), and 10 CFR 20.1206, “Planned Special Exposures,” provide the conditions 

and limits for PSEs of adult workers (i.e., radiation doses in addition to and accounted for separately from 

the doses received under the limits specified in 10 CFR 20.1201). In addition, 10 CFR 20.2104(b) and 

10 CFR 20.2104(e)(2) specify the requirements for obtaining prior occupational dose information, 

10 CFR 20.2105, “Records of Planned Special Exposures,” and 10 CFR 20.2106, “Records of Individual 

Monitoring Results,” specify the requirements for exposure and monitoring records applicable to PSEs. 

The requirements for reporting PSEs appear in 10 CFR 20.2202, “Notification of Incidents,” 

(10 CFR 20.2202(e)), and 10 CFR 20.2204, “Reports of Planned Special Exposures.” 

This regulatory guide contains information collection requirements covered by 10 CFR Part 20 

that the Office of Management and Budget (OMB) approved under OMB control number 3150-0014. 

The NRC may neither conduct nor sponsor, and a person is not required to respond to, an information 

collection request or requirement unless the requesting document displays a currently valid OMB control 

number.
Rev. 1 of RG 8.35, Page 2 

B. DISCUSSION 

The regulations restrict PSEs to those special situations that could result in a higher exposure than 

allowed by the normal limits of 10 CFR 20.1201 and that, if not provided for, could create a severe 

problem in the licensee’s operations. Problems might include unscheduled facility shutdowns or high 

radiation levels that impede operations important to safety. Accordingly, a special set of limitations and 

reporting and recordkeeping requirements apply if licensees decide to use PSEs. Approval of PSEs for an 

adult worker must be in writing before the exposure occurs and, once it occurs, the exposure cannot be 

treated as a routine occupational exposure (see 10 CFR 20.1206). Furthermore, minors are not allowed to 

participate in PSEs. 

 Efforts should be made to maintain the doses received during PSEs as low as reasonably 

achievable (ALARA). Methods for reducing the dose received by the individual authorized to perform 

the PSE should be considered while planning the activity. A more detailed discussion of reducing 

radiation doses appears in Regulatory Guide 8.8, “Information Relevant to Ensuring that Occupational 

Radiation Exposures at Nuclear Power Stations Will Be as Low as Is Reasonably Achievable” (Ref. 2). 

In determining the amount of dose to assign to the PSE in advance of the exposures, licensees 

must be aware of the individual’s current year exposure and lifetime PSE dose history to avoid 

unnecessary overexposure affecting a worker’s occupational dose (see 10 CFR 20.2104). 

C. REGULATORY POSITION 

1. Use of Planned Special Exposures 

a. The PSEs are to be used only under exceptional circumstances, not as a routine method of 

increasing dose limits applicable to routine exposures. However, licensees may consider the use 

of PSEs to permit workers who have critical skills and who are necessary for a particular job to 

receive an exposure in addition to the routine occupational exposure limit. 

b. The rule does not require that participation in PSEs be voluntary on the part of the individual 

workers. However, licensees may establish a program of voluntary PSEs. In any case, licensees 

should consider the potential benefits of involving the worker in the planning and preparation for 

the PSE. The NRC believes that the health risk from these limited exposures is small and that the 

use of PSEs may be necessary for licensees to accomplish important tasks vital to continued safe 

operations. Regulatory Guide 8.29, “Instruction Concerning Risks from Occupational Radiation 

Exposure” (Ref. 3), discusses the issue of a worker accepting the risks associated with an 

assigned task. 

c. Exposures in excess of the routine occupational dose limits received during accident or 

emergency situations that require immediate action to save human lives or to prevent the failure 

of equipment important to safety are not PSEs. However, all exposures in excess of the routine 

occupational dose limits received during accident and emergency situations must be determined 

and subtracted from the annual 50-millisievert (mSv) (5-rem)) PSE limit and the 250 mSv 

(25 rem) allowed for lifetime PSEs (see 10 CFR 20.1201(b)). A PSE can be authorized if the 

conditions associated with an accident or emergency permit complying with the conditions 

specified in 10 CFR 20.1206(a) through (e). 
Rev. 1 of RG 8.35, Page 3 

2. Conditions for Use of Planned Special Exposures 

The seven conditions listed in 10 CFR 20.1206 must be satisfied if a licensee authorizes an adult 

worker to receive a PSE. The following list summarizes these conditions: 

(1) A PSE is reserved for an exceptional situation when alternatives are unavailable or 

impractical. 

(2) The PSE is authorized in writing before the exposure occurs. 

(3) Individuals involved are informed of the purpose, the estimated doses, and the associated 

potential risks, and are instructed in the measures to take to keep the dose ALARA. 

(4) The licensee shall determine the doses from all previous PSEs and all doses in excess of 

the limits (including doses from accidents and emergencies) received during the lifetime 

of the individual. 

(5) The dose from the PSE must be under the dose limit for 1 year and 5 times annual dose 

limits for a lifetime. 

(6) Records shall be maintained of the details of the PSE and shall be submitted to the NRC. 

(7) The estimated dose from the PSE shall be recorded, and the individuals who received the 

PSE should be informed of the dose within 30 days of the PSE. 

2.1 Exceptional Situation Exists 

a. Licensees should authorize PSEs only for exceptional situations. The use of PSEs must be 

justified and well documented (see 10 CFR 20.2105). Licensees should not use PSEs as a routine 

method of increasing occupational exposure limits. The NRC staff will review the justification 

for the PSE when it examines the licensee’s records of the PSE. To request an NRC review 

before initiating a PSE, the licensee may contact the appropriate regional office directly. 

b. The following are examples of exceptional situations in which a PSE might be justified: 

(1) The work is to be performed by one individual rather than several. A source becomes 

disconnected during radiography. It may not be practical or feasible for the source to be 

recovered in two or three steps by different persons. Authorization for one person to 

receive up to 50 mSv (5 rem) total effective dose equivalent, in addition to his or her 

routine occupational exposure, may be reasonable for the recovery. The NRC regulations 

permit the licensee to use previously approved procedures in carrying out work under a 

PSE. For example, the licensee could have an approved generic procedure for source 

retrieval that, among other things, addresses all the administrative and recordkeeping 

requirements of 10 CFR 20.1206. Provided that the situation is exceptional and 

alternatives that might avoid higher exposures are unavailable or are impractical, an 

individual’s exposure received during a source retrieval may be considered a PSE. The 

licensee must meet all the conditions of 10 CFR 20.1206 and document them as required 

by 10 CFR 20.2105. 
Rev. 1 of RG 8.35, Page 4 

(2) The use of dose-averting methods is not possible. Work must be performed on 

instrumentation in a high-radiation area where space is very limited and shielding or 

other dose-averting methods are not possible. It may be necessary to authorize a PSE to 

make the necessary repairs to the instrumentation. 

(3) The collective dose to personnel may be reduced. It may be more dose-effective to keep 

certain skilled workers on a particular job because they will be able to perform the job 

more rapidly than lesser skilled workers and thus reduce the overall dose to personnel. 

For example, if two persons can weld in a high-radiation area and collectively receive 

120 mSv (12 rem) (60 mSv (6 rem) per person, 20 mSv (2 rem) under a PSE and 40 mSv 

(4 rem) of routine exposure)) while four less skilled workers would receive 160 mSv 

(16 rem) (40 mSv (4 rem) per person of routine exposure), the collective dose would be 

reduced from 160 mSv to 120 mSv (16 rem to 12 rem) by using the two skilled workers. 

The PSEs are not intended to be used only as a routine collective dose reduction 

technique. However, reducing collective dose could contribute to the justification of a 

PSE. 

2.2 Prior Written Authority Obtained 

a. The licensee (and employer if the employer is not the licensee) must specifically authorize the 

PSE in writing before the exposure occurs (see 10 CFR 20.1206(b)). A contractor employer may 

authorize the use of PSEs by a licensee in advance to accommodate any urgent circumstances that 

may arise. 

b. In planning for a PSE, the licensee is permitted to assign a portion of the dose to routine exposure 

and the rest to the PSE. This should be authorized prior to the planned activity, see 10 CFR 

2105(a)(2). When the postexposure evaluation is made, the dose amount that the licensee 

planned to assign to a PSE should be recorded as a PSE. If the total dose received for the actual 

PSE is less than the planned PSE, the actual PSE dose received must be recorded as the PSE dose 

(see 10 CFR 20.2105(a)(6)). If the total dose received is more than the planned PSE but is not an 

overexposure, the extra portion may be recorded as a PSE or as a routine dose. In other words, 

the planned PSE dose should not be reassigned, postexposure, to routine exposure if it is later 

determined that a PSE was not needed. The intent of the regulation is that a PSE would be used 

infrequently. Once a licensee decides to authorize a PSE, all the unique limitations and reporting 

and recordkeeping requirements are to apply, even if the doses actually received fall within the 

dose limits for routine operations. For example, if a job planned with a PSE of 50 mSv (5 rem) 

and a routine dose of 20 mSv (2 rem) to an individual actually results in a dose of 40 mSv 

(4 rem), the entire 40 mSv (4 rem) dose must be recorded as a PSE dose (see 

10 CFR 20.2105(a)(6)). If, before initiating a PSE, it is found that a PSE is not needed, and it is 

canceled, the resulting exposure can be recorded as routine. 

c. The procedures for the radiation protection program should specify the management level of the 

person who may authorize a PSE. The responsible person should be at a sufficiently senior level 

to ensure worker protection and to judge the appropriateness of the PSE for the exceptional 

circumstances. This person would normally be the radiation safety officer, the radiation 

protection manager, or someone in the organization with equivalent qualifications. 

2.3 Individual Informed and Instructed 

a. Before authorizing a PSE, the licensee must ensure that the individuals involved are (1) informed 

of the purpose of the planned operation, (2) informed of the expected radiation levels, estimated 
Rev. 1 of RG 8.35, Page 5 

doses, and associated risks or other conditions that may be involved in performing the task, and 

(3) instructed in measures to take to keep the dose ALARA, while considering other risks that 

may be present (see 10 CFR 20.1206(c)). 

b. To ensure that the intent of the plan is realized, the workers who are to receive a PSE should be 

fully informed and aware of the circumstances under which the PSE was authorized. These 

workers should understand the importance of keeping their exposure ALARA. They should also 

understand the procedures and controls to be used in the particular PSE to keep their exposures 

ALARA. Licensees have an obligation to inform workers (before they receive a PSE) of the 

expected radiation levels, estimated doses, associated risks, or other significant conditions that 

might be involved in performing the task so that the individuals are aware of and understand the 

health and safety significance of the PSE. The authorization for the PSE should include this 

information. 

2.4 Prior Doses Determined 

a. According to 10 CFR 20.1206(d), before authorizing the PSE, the licensee must ensure that all 

previous PSEs and all doses in excess of the routine occupational limits in effect at the time of the 

exposures (10 CFR 20.1201(a)(1) and the former 10 CFR 20.101) for the individual’s lifetime 

have been determined from records for each individual who will participate in the PSE. The 

licensee must also determine the doses received during accidents and emergencies that exceed the 

routine occupational dose limits in effect at the time of the exposures (see 10 CFR 20.1206(d)) 

and must subtract those doses from the limits for PSEs (see 10 CFR 20.1201(b)). (Accident 

doses are doses resulting from an unexpected event involving exposure to radiation or radioactive 

material. Emergency doses are doses resulting from any immediate action taken in response to a 

situation or occurrence of a serious nature that develops suddenly and unexpectedly.) 

b. If complete records (including the provisions of 10 CFR 20.2104) of the worker’s current and 

previously accumulated occupational dose history, such as a completed NRC Form 4, are not 

available, the individual cannot be authorized to receive a PSE (see 10 CFR 20.2104(e)(2)). 

Regulatory Guide 8.7, “Instructions for Recording and Reporting Occupational Radiation Dose 

Data” (Ref. 4), provides guidance on records of occupational exposure. 

2.5 Planned Special Exposures and Exposure Limits Determined 

a. Individuals receiving PSEs can receive a maximum dose in 1 year of any or all of the following: 

(1) 100 mSv (10 rem) total effective dose equivalent (50 mSv (5 rem) from routine 

operations and 50 mSv (5 rem) from PSEs), or 

(2) 1 Sv (100 rem) to any individual organ or tissue, including any deep-dose equivalent plus 

the committed dose equivalent for the organ or tissue (500 mSv (50 rem) from routine 

operations and 500 mSv (50 rem)) from PSEs, and 

(3) 300 mSv (30 rem) dose equivalent to the eye (150 mSv (15 rem) from routine operations 

and 150 mSv (15 rem) from PSEs), and 

(4) 1 Sv (100 rem) to the skin or to any extremity (500 mSv (50 rem) from routine operations 

and 500 mSv (50 rem) from PSEs). 
Rev. 1 of RG 8.35, Page 6 

b. Individuals can receive a lifetime dose from PSEs of any or all of the following: 

(1) 250 mSv (25 rem) total effective dose equivalent; or 2.5 Sv (250 rem) to any individual 

organ or tissue, and 

(2) 750 mSv (75 rem) to the eye, and 

(3) 2.5 Sv (250 rem) to the skin or to any extremity. 

2.6 Worker’s Planned Special Exposure Dose Recorded and Worker Informed 

a. The licensee must record its best estimate of the dose (dose of record) resulting from the PSE in 

each affected individual’s record and inform the individual, in writing, of the dose within 30 days 

of the PSE (10 CFR 20.1206(g)). The 30-day time period for notifying the worker of the dose 

received is to allow sufficient time for the licensee to make its best estimate of internal and 

external exposures received as part of the PSE. The best estimate is understood to mean the dose 

of record as determined by accredited dosimetry, bioassay, air sampling, or other analyses, such 

as time and motion studies. If the intake of Class Y material (i.e., materials that remain in the 

body for time periods on the order of years) is being assessed, the licensee may delay the 

recording and reporting of the results of its assessments for periods of up to 7 months to allow for 

the additional measurements necessary for the assessments (10 CFR 20.1204(d)). However, the 

internal dose reported within the 30 days may be identified as an initial best estimate pending 

completion of a final assessment, after which the actual dose assigned should be recorded and 

reported. 

b. The dose from a PSE must be tracked separately from the routine occupational dose for the 

individual (see 10 CFR 20.1206(g)). Thus, a person may have an accumulated routine 

occupational dose of 30 mSv (3 rem) total effective dose equivalent for the year, receive a dose of 

40 mSv (4 rem) total effective dose equivalent from a PSE, and still be able to receive up to an 

additional 20 mSv (2 rem) of routine occupational exposure for the year, even though the person 

has had a total dose of 70 mSv (7 rem) for the year. The dose from the PSE is not to be 

considered in controlling the future occupational dose of the individual under 10 CFR 20.1201(a) 

but is to be included in evaluations required by 10 CFR 20.1206(d) and (e). The dose resulting 

from a PSE is to be included in the total for all PSEs for the individual, and it is to be used in 

determining the dose balance remaining for future PSEs. 

2.7 Records and Written Reports Maintained 

a. The licensee must maintain records of the conduct of a PSE in accordance with 10 CFR 20.2105 

and must submit a written report in accordance with 10 CFR 20.2204. In addition, 

10 CFR 20.2106 requires that the records of doses received during PSEs be maintained for all 

individuals who participated in a PSE. These records should include all the information listed in 

10 CFR 20.2105. The NRC has included its revised Form 5, along with guidance on its use, in 

Regulatory Guide 8.7. 

b. A written report of the PSE, notifying the Administrator of the appropriate NRC regional office, 

is due within 30 days after the PSE has occurred. Any report filed under 10 CFR 20.2204 must 

contain the information in the records listed in 10 CFR 20.2105. The report allows the NRC to 

assess the actual frequency of PSEs and determine whether followup inspections may be 

warranted. 
Rev. 1 of RG 8.35, Page 7 

2.8 Internal and External Exposure Considerations 

For PSEs, as well as for routine exposures, both internal and external doses are to be summed in 

calculating the total effective dose equivalent, see 10 CFR 20.1202. This requires controlling the total 

effective dose equivalent but permits tradeoffs between internal and external exposures to be made to 

achieve ALARA doses. The sum of external and internal doses during the PSE should be maintained 

ALARA. Licensees should use the conditions specified in 10 CFR 20.1502, “Conditions Requiring 

Individual Monitoring of External and Internal Occupational Dose,” to determine when monitoring is 

required. 

2.9 Exposures of Minors and Declared Pregnant Women 

The PSE provisions of 10 CFR 20.1206 do not apply to minors (10 CFR 20.1207, “Occupational 

Dose Limits for Minors”) or to the embryo or fetus (10 CFR 20.1208, “Dose Equivalent to an 

Embryo/Fetus”). The rule permits a licensee to authorize only an adult worker to receive PSEs. In 

addition, the dose limits in 10 CFR 20.1208 would normally preclude a declared pregnant woman from 

receiving a PSE, since the 10 CFR 20.1208 limits are more restrictive than the annual dose limits in 

10 CFR 20.1201. In general, declared pregnant women should not be considered candidates for PSEs. 

However, the provisions of 10 CFR 20.1206 also apply to the dose limits for the lens of the eye, skin, and 

extremities. Therefore, in some situations, it may be possible for a declared pregnant woman to receive a 

PSE to her extremities (or skin or eyes) that would not exceed the dose limits to the embryo or fetus. 

D. IMPLEMENTATION 

The purpose of this section is to provide information to applicants and licensees regarding the 

NRC’s plans for using this regulatory guide. The NRC does not intend or approve any imposition or 

backfit in connection with its issuance. 

In some cases, applicants or licensees may propose or use a previously established acceptable 

alternative method for complying with specified portions of the NRC’s regulations. Otherwise, the 

methods described in this guide will be used in evaluating compliance with the applicable regulations for 

license applications, license amendment applications, and amendment requests. 
Rev. 1 of RG 8.35, Page 8 

REFERENCES1

1. 10 CFR Part 20, “Standards for Protection against Radiation,” U.S. Nuclear Regulatory 

Commission, Washington, DC. 

2. Regulatory Guide 8.8, “Information Relevant to Ensuring that Occupational Radiation Exposures 

at Nuclear Power Stations Will Be as Low as Is Reasonably Achievable,” U.S. Nuclear 

Regulatory Commission, Washington, DC. 

3. Regulatory Guide 8.29, “Instruction Concerning Risks from Occupational Radiation Exposure,” 

U.S. Nuclear Regulatory Commission, Washington, DC. 

4. Regulatory Guide 8.7, “Instructions for Recording and Reporting Occupational Radiation Dose 

Data,” U.S. Nuclear Regulatory Commission, Washington, DC. 

 

1

 Publicly available NRC documents are available electronically through the Electronic Reading Room on the NRC’s public Web 

site at: http://www.nrc.gov/reading-rm/doc-collections/. The documents can also be viewed on-line for free or printed for a fee in 

the NRC’s Public Document Room (PDR) at 11555 Rockville Pike, Rockville, MD; the mailing address is USNRC PDR, 

Washington, DC 20555; telephone 301-415-4737 or (800) 397-4209; fax (301) 415-3548; and e-mail PDR.Resource@nrc.gov.