10CFR20 Skin Dose Limit Proposed Rule

The NRC has placed a proposed rule for revision of the skin dose limit in

the Federal Register ... the associated NRC press release states, in part:

"Under the proposal, the dose to the skin would be averaged over the most

highly exposed 10 square centimeters instead of being averaged over one

square centimeter. This change is based on scientific studies that

demonstrate that risks from doses to small areas of the skin are less than

risks to larger areas from the same dose.

Current rules require frequent monitoring of workers to detect hot

particles and small area exposures that have insignificant health

implications. These conservative efforts to prevent small, insignificant

skin doses result in higher whole-body doses with a higher risk than the

avoided skin doses.

The health effects from small-area skin doses, such as reddening of the

skin, that might occur from a hot particle exposure are considered by the

NCRP to be very small as compared to the increased whole-body deep doses

from monitoring and work inefficiencies. To avoid exceeding the current

dose limit, protective clothing and cumbersome gloves may be used that

result in workers being subjected to non-radiological hazards, such as heat

stress and other injury consequences. Workers are also hampered by the

excessive use of protective equipment and clothing, requiring them to spend

more time completing a job in radiation areas. Additionally, small-area

overexposures can result in licensee citations and the possibility that a

worker might not be permitted to work in a radiation area for the balance

of the year.

The rulemaking is designed to establish a uniform, risk-informed skin dose

limit for all sources of shallow radiation exposures, including hot

particles and small area skin contaminations. The rule would also lessen

physical stress and reduce whole-body doses to workers by reducing the

frequency of monitoring for hot particles. The net result is a substantial

increase in worker safety and a cost-effective reduction in unnecessary

regulatory burden with little to no impact on worker safety. "

The HTML version of the proposed rule can be found at:

http://frwebgate6.access.gpo.gov/cgi-bin/waisgate.cgi?WAISdocID=43514173303+0+0+0&WAISaction=retrieve

Brent Robinson

blrobinson@aep.com

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