RE: Powernet: Special Handling individuals with lifetime dose gre ater than age

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

The following was Linda's response to me on Powernet. To put my 
comments in proper context, Linda's comments are necessary.

Thanks...

> Hi Sandy/All,
> 
> Diablo Canyon's lifetime dose program is very simple.  We follow the
> NCRP recommendations.  If a person's lifetime dose has exceeded their
> age in years we limit that individual to 1 Rem at Diablo Canyon per
> year, with no extension process necessary.  If that limit proves too
> restrictive we can process a lifetime dose extension.  That extension
> would require the plant manager's signature.  If the individual is a
> contractor, the extension requires the signature of a high ranking
> individual within the contractors company, as well.  Our lifetime dose
> policy has never resulted in anyone being denied access to our RCA or
> to do the job for which they were assigned. 
> 
> In answer to Sandy's questions directly:
> 
> (1) In light of the fact that there are no regulatory requirements for
> lifetime dose, where is the momentum coming from for licensees to do
> anything with respect to lifetime dose?
> 
> I believe it is in Diablo Canyon's best interests to attempt to follow
> the recommendations of the major scientific governing bodies (NCRP and
> ICRP) in our industry.  Our yearly admin guideline is 2 Rem.  We also
> evaluate all dose extensions above that level against a 10 Rem in 5
> year criteria.
> 
> (2) The current NRC Form 4 Equivalent only requires that an 
> individual state what their lifetime dose is, and, unless there is a
> PSE, nothing else need be done (other than an attempt to validate the
> dose - if the licensee can do that).
> 
> Actually that's not quite true.  There is no block to list a single
> lifetime dose total on an NRC Form 4 equivalent, only an itemization
> by licensee. Many of us add that "feature" but it's not part of a true
> Form 4 equivalent.
> 
> (3) The NCRP has recommendations regarding lifetime dose. However,
> NCRP, ICRP, ICRU are not regulatory bodies, and in the past most
> licensees frowned upon regulation through guidelines, recommendations,
> etc. So again, where is the push to treat lifetime dose differently,
> coming from?
> 
> Attempting to apply and follow consensus science makes sense in
> today's litigious society.
> 
> (4) If one looks at the cumulative and individual doses at the US
> nuclear plants over the past decade, the totals have been reduced
> dramatically. Rarely is there an individual over 1 rem in an annual
> period. Therefore, those individuals with lifetime dose > age has to
> be a small population. The majority of the higher dosed individuals,
> have either retired or died. Again, what number of individuals are we
> dealing with, and why?
> 
> The population of individuals in this category is small.  Most of the
> individuals that we deal with all work for the major service vendors
> and their administrative programs tend to be more restrictive than
> ours for individuals in this category.  
> 
> If you have any questions, give me a call.


----------------------------------------------------------------------------------
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 				                           
ICN Plaza, 3300 Hyland Avenue  		E-Mail: sperle@icnpharm.com          	          
Costa Mesa, CA 92626

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