De-Minimis (the age determination thread)

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

> Therefore, I would say that applying
> ALARA to radiation levels that are already below the variations in natural
> background is not "reasonable" and should not be done where avoidable.

If only the NRC implicitly included the De-Minimis philosophy and 
limits. When they tried, they were accosted by many group. When a 
value was put forth, it was too ridiculous to even be considered, in 
that it was essentially meaningless, and impossible to even measure, 
for documentation purposes.

It's ironic that the NRC and other regulatory bodies already have a 
significant number of "De-Minimis" values in current regulations. 
Consider that personnel monitoring is not even required for 
individuals who will receive less that 500 mrem (5.0 mSv) in a year. 
Take this one step further. Prior to the January 1, 1994 
implementation of the revised 10CFR20, a facility was required to 
maintain the doses per the specific time frame taking into account 
all doses received from all facilities (licensees) etc. Now, a 
facility only needs to address monitoring requirements, training 
requirements, based on what the individual will receive in the 
"current" facility only. If an individual comes into a new work 
facility, and brings along an annual dose of 2 rem (20.0 mSv), that 
need not be taken into account. The current facility simply states 
that the individual will not exceed the threshold for monitoring, and 
need not provide it.

In conclusion, we deal with De-Minimis all the time. It's now the 
right moment to insist that realistic De-Minimis values be included 
in the regulatory process.

------------------------------------------------------------------------
Sandy Perle					Tel:(714) 545-0100 / (800) 548-5100   				    	
Director, Technical				Extension 2306 				     	
ICN Worldwide Dosimetry Service		Fax:(714) 668-3149 	                   		    
ICN Pharmaceuticals, Inc.			E-Mail: sandyfl@earthlink.net 				                           
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Personal Website: http://sandyfl.nukeworker.net
ICN Worldwide Dosimetry Website: http://www.dosimetry.com

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