RE: 10CFR35.315 + your comment

[carol marcus <csmarcus@ucla.edu>]

At 09:04 AM 1/13/00 -0600, you wrote:
>I was just cited for that.  Although the inspectors indicated that they
>didn't see a problem with simply removing the linen from the bed, wrap from
>the toilet seat, and trash between iodine patients, they cited me because
>the reg doesn't make that distinction.  You can verbally request a waiver or
>exception.  The inspectors indicated they thought it highly likely that one
>would get the run around before getting an OK.  But you can request an
>exception to the rule as clearly it was meant for non-therapy patients.
>
>Peter G. Vernig,
>VA Medical Center, Denver
>peter.vernig@med.va.gov
>
>-----Original Message-----
>From: Malek Chatila [mailto:mc02@aub.edu.lb]
>Sent: Thursday, January 13, 2000 6:14 AM
>To: Multiple recipients of list
>Subject: 10CFR35.315 + your comment
>
>
>Dear Radsafers,
>
>I have a question concerning the release of hospital rooms that have been
>used by Iodine-131 patients (for therapeutic treatment) that I hope you can
>help me with.
>
>10 CFR 35.315, paragraph (7) states "Survey the patient's or the human
>research subject's room and private sanitary facility for removable
>contamination with a radiation detection survey instrument before assigning
>another patient or human research subject to the room.  The room must not
>be reassigned until removable contamination is less than 200
>disintegrations per minute per 100 square centimeter". 
>
>My interpretation of the above is that the limit of the removable
>contamination must be met even thus if the next patient who will be
>assigned the room is also an iodine patient undergoing therapeutic
>treatment.  Is this correct?
>
>I also would like to get your comment on the following:
>
>The hospital administration is thinking of dedicating a hospital room for
>only iodine patient.  Moreover, this room is in the middle of the hallway.
>I guess their thinking is that if the room is dedicated only to iodine
>patients, than they do not have to worry much about contamination levels
>and any special preparation for the room such as using absorbent papers to
>cover ....
>Do you think this is appropriate?  
>
>As always, thanks in advance for your assistance.
>
>Sincerely,
>
>Malek Chatila
>Health Physicist,
>Assistant RSO
>Environmental Health & Safety Center
>American University of Beirut
>Email: mc02@aub.edu.lb
>Fax: 961-1-749-198
>
>
>
>
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Dear Radsafers:

The 200 dpm per 100 cm squared regulation is a scientifically unfounded,
arbitrary and capricious number.  I got this information from the NRC
individual who created this rule.  I have spent 13 years trying to get it
removed because it is senseless and work intensive, but there is no will to
do so at the staff, management, or Commission level at NRC.  It is more fun
for NRC to give violations for nonsense than to be respected for scientific
intelligence.

We need no number at all.  As long as no subsequent patient receives more
than 500mrem, the regulatory standard would be satisfied.  For a patient who
is to receive very large purposeful doses of radioiodine, I don't think that
this standard should even apply, because it's silly.  However, it's not hard
to meet a 500 mrem standard in almost any case, even with two patients
together in the same room.

The way to get around this unsubstantiated NRC regulatory requirement is to
do some simple math and physics, and determine that the patient who is to
receive I-131 is not likely to impart more than 500 mrem to anyone.  The
patient may be hospitalized for medical reasons unrelated to being a public
health and safety hazard, and when that occurs, you don't have to monitor
the room or keep any records at all, any more than you would if the patient
was released and went home. The patient's room only has to be monitored if
the 500 mrem level is not met, and the patient is being held as a dangerous
radiation source.  I can think of only one or two cases in the past 5 years
or so in which I actually hospitalized a patient because of the possibility
of going over 500 mrem to a member of the household.  Old habits die slowly,
and my RSO still has his people lay paper and monitor the room, but we both
understand that strictly speaking, it isn't necessary.  When your Authorized
User writes the admitting orders, just ask him/her to write that this
patient is not being held as a radiation hazard, and would not reasonably be
expected to impart more than 500 mrem to anyone.  That gets the RSO off the
hook and the NRC inspector will have nothing to inspect and screw you with.

Even more important, I'd like to see the health physics and medical physics
communities push to remove the requirement for limited removable
contamination levels for all radionuclides.  We have the Part 20 standard,
and if a licensee is so dumb that they can't figure out from the
contamination level what the likely radiation absorbed dose is to various
people in the vicinity, then that licensee shouldn't have been licensed in
the first place, and the regulator should remove his/her license.

Ciao, Carol


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