RE: 10CFR35.315 + comments

[carol marcus <csmarcus@ucla.edu>]

>Date: Thu, 13 Jan 2000 13:08:23 -0600 (CST)
>From: "Vernig, Peter G." <Peter.Vernig@med.va.gov>
>Subject: RE:  10CFR35.315 + comments
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>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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Dear Peter and Group:

First, I don't have ICRP 57; can't help you there.  

Second, for those who want to look up the I-125 standard in the NUREG, it is
NUREG-1556, Vol. 9, p. R-4, Aug., 1998.  Although SNM and ACNP took NRC to
issue on this, as usual, we have heard nothing that suggests intelligent
reconsideration.

Peter, I agree that INTELLIGENT, SCIENTIFICALLY BASED guidance is a
generally good idea, but it should be INTELLIGENT AND SCIENTIFICALLY BASED,
and it should be GUIDANCE, and not a regulation, license requirement, or
anything else the NRC or an Agreement State can "get" you with.

Ciao, Carol

Carol S. Marcus, Ph.D., M.D.
<csmarcus@ucla.edu>  

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