ANI Section 8.4 Rev. 5, 5/25/00

["Sandy Perle" <sandyfl@earthlink.net>]

I was provided a copy of the above referenced document this morning 
by Jerre Forbes. The following is of interest, and addresses Mike's 
original concerns and questions:

(1) The primary reason for a secondary dosimeter, as implemented over 
the past 30 years or so, was solely done because it was "good health 
physics" practice. The 2nd dosimeter, especially if a different 
configuration, provided credibility that the reported doses were in 
the "ballpark" and therefore an accurate assessment.

(2) The reason for a secondary dosimeter was not necessarily for 
immediate readout, although that was a direct result .. a passive and 
a non-passive dosimeter.

(3) Rev. 5 provides for better dentitions.

(4) The DLR is now defined as "Dosimeter of Legal Record" as defined 
by the NRC. For now, it's primarily film and TLD. EPD could become 
one in the future.

(5) As I stated previously, the 100 mrem annual limit is the 
threshold whereby when exceeded, a secondary dosimeter must be worn 
when in the Radiation Controlled Area. This has ALWAYS been the 
criteria.

(6) The previous revisions stated that the 100 mrem was a prospective 
assessment. Rev. 5 allows for "whether initially projected or as 100 
mrem is approached, a backup dosimeter of any type should also be 
used." The projection is now not the only criteria, but a facility 
could, if they so chose, wait until the 100 mrem annual dose is 
approached. I believe this approach to be unacceptable.

(7) Radiation tort cases generally don't occur when high doses are 
received. The average litigation occurs around a dose of 250 mrem.

(8) Jerre also stated that there is no correlation between dose and 
litigation filed. Therefore, if the litigations filed are for small 
dose, it seems to me that a facility would be prudent to always 
require a backup dosimeter. I suppose it all comes down to how much 
documentation do you want to support you in the event you enter 
litigation. How much is it worth to you.

In conclusion, Rev. 5 of Section 8.4 changes little, and the rules 
for monitoring have for all practical purposes, not changed at all.

Jerre reads Radsafe, so, if you have questions, refer them to Jerre, 
and perhaps he will respond directly, or, to the forum for all to 
see.

------------------------------------------------------------------------
Sandy Perle					Tel:(714) 545-0100 / (800) 548-5100   				    	
Director, Technical				Extension 2306 				     	
ICN Worldwide Dosimetry Division		Fax:(714) 668-3149 	                   		    
ICN Biomedicals, Inc.				E-Mail: sandyfl@earthlink.net 				                           
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Costa Mesa, CA 92626                                      

Personal Website:  http://www.geocities.com/capecanaveral/1205
ICN Worldwide Dosimetry Website: http://www.dosimetry.com

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