RE: 10 CFR 20

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

> previous regulations (10 CFR 20.408)

10CFR20.408 basically required a licensee to break down the dose into 
a histogram. Numbers of individuals who were within specific dose 
ranges. While this makes for interesting statistics, it may be a 
potential use for epidemiologists, but other than that .. just 
statistics. There was no correlation to total dose for the licensee. 
The RG 1.16 Report was a second attempt to obtain some dose data. The 
problem with that report was that by breaking dose down into work 
categories, the use of secondary dosimetry was often the source. In 
addition, dose below a specific threshold need not be accounted for. 
The bottom line, if the cumulative dose for all categories was within 
I believe 25% of the actual dose, the RG 1.16 report was considered 
acceptable.

The 10CFR20.2206 requirement does make more sense. This is actual 
dose received by each individual (a copy of what is sent to the 
individual - per the requirement of the annual report). In this case, 
the NRC can by use of the SSN determine total dose for each 
individual. While the requirement may stem fro  the previous 408 
report, the result is totally different as to what is actually 
provided, and how it is used.

Probably doesn't answer the source of the 408 report, but does 
provide insight to how the various reports were generated and 
ultimately used, or abused!

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

Personal Website: http://sandyfl.nukeworker.net
ICN Worldwide Dosimetry Website: http://www.dosimetry.com

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