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RE: 10CFR35.315 + comments



Carol and group:

You wrote:

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.

You are very nearly successful.  And on behalf of all beleaguered medical
HPs THANK YOU!  You are certainly correct it is a time intensive hassle of
dubious benefit.

The revision of 10 CFR 35 due for final review by the NRC commissioners
drops that requirement.  The latest on the schedule is that the
commissioners have all agreed in principal to the new reg but now like
Congress must reconcile their differences over this and that.  They are
expected to issue a SRM, staff requirements memorandum to deal with the
final few issues and it will spell out a schedule for final approval,
publication in the FR, and effective date.  We are probably looking at 2001
for effective date.  THAT IS THE GOOD NEWS.

THE BAD NEWS

The draft of NUREG-1556, "Consolidated Guidance...Medical Licenses" retains
that level as official guidance.

Now I have to respectfully disagree with you Carol.  I think many of us do
need a number  and or guidance.  When looking at such a situation as
decontamination of a hospital room, we first go to requirements, then
guidance, then common sense.  While you might answer, common sense tells
us...  Existing guidance both the NCR's and NCRP is similarly restrictive.
It is hard to counter "authoritative guidance" with common sense and not
feel you are sticking your neck WAY OUT!

I have actually made an attempt to answer that lack.  I did some
calculations based on using the same ratio as that between the maximum
occupational dose [NCRP recommendation & 10 CFR 20] and the NCRP 116,
negligible individual dose, that ratio being 1/5000 and using that with an
annual limit on intake and considering uptake fractions of 10^-5 to 10^-3.
Another VA HP, Dan Miron helped me turn that into an article.  The
decontamination action levels that come out, I will warn you, are quite
high.  That's partly why I considered a range of ingestion fractions.   We
had intended to submit the article to RSO or ORS sometime between the FR
publication date and effective date feeling that it shouldn't be published
too far in advance of the effective date. 

I would like to ask a favor.  I have been told that ICRP 57 has some decon
guidance that is also quite high.  I don't have a copy of that.  It is
supposed to be on page 37.  I would appreciate knowing what it is and
greater, appreciate getting a fax of the page or  couple of pages if that is
reasonable.

So anyway, help is on the way.


Any opinions expressed are mine alone and do not necessarily represent those
of the Denver VA Medical Center, The Department of Veterans Affairs, or the
U.S. Government.

Peter G. Vernig                
Radiation Safety Officer, VA Medical Center, 1055 Clermont St. Denver, CO
80220, ATTN; RSO MS 115
303-399-8020 ext. 2447, peter.vernig@med.va.gov [alternate
vernig.peter@forum.va.gov] Fax 303-393-5026 [8 - 4:30 MT service] Alternate
Fax 303-377-5686

"...whatever is true, whatever is noble, whatever is right,, whatever is
pure, whatever is lovely, whatever is admirable, if anything is found to be
excellent or praiseworthy, let your mind dwell on these things."    Paul

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