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Re: NRC PROPOSES $6,000 FINE AGAINST ST. JOSEPH MERCY HOSPITAL IN MICHIGAN FOR OVEREXPOSURE TO A MEMBER OF THE PUBLIC



For clarification, the report can be found at http://www.nrc.gov/reading-rm/doc-collections/enforcement/actions/materials/ea02248.html
 
With regard to exposure rate values, these are in the report:0
B.   10 CFR 20.1301(a)(2) requires that each licensee conduct operations so that the dose in any unrestricted area from external sources, with exceptions not applicable here, does not exceed 2 millirem in any one hour.

Contrary to the above, the licensee conducted operations so that the dose in unrestricted areas exceeded 2 millirem in any one hour. Specifically, licensee operations on July 1, 2002, resulted in a dose of 10 millirem in one hour in an emergency exit stairway, and a dose of 17millirem in one hour outside the ground floor window of a patient's room. Licensee operations continued through July 7, 2002, when the resultant doses were 4 millirem in one hour and 8 millirem in one hour, respectively.

It should be noted that these values are outside of the patents room.  I assume next to the bed the dose rates would be significantly higher. 

Also, NCRP 37 provides recommendations.  The NRC grants a license under which the  licensee agrees to operate.  You cannot pick the regulations you like to follow.


Carol Marcus <csmarcus@ucla.edu> wrote:

. . .

So, where does 3 to 15 rem come from? Nowhere credible.  As I see it, the member of the family elected to get a radiation dose that is judged safe for radiation workers, in order to be with a dying relative.  Seems reasonable to me.

It may be reasonable to point out that 10 CFR Part 20 includes the last sentence of 20.1001:  "However, nothing in this part shall be construed as limiting actions that may be necessary to protect health and safety."  I would sincerely argue that the mental health of the member of the family comes under this clause, and that the standards need not apply.  The care and peace of mind of the dying patient should be considered as well.  While I would go to great lengths to prevent a member of the family from receiving a dose that I know to be harmful, I don't see any reason to become hysterical about a dose that is a! bout what a radiation worker may receive in a year, or significantly less.  In NCRP no. 37, it is recommended that family members over 45 not receive more than 5 rads from the patient.  I don't know how old the family member in question was, but clearly there are standards that would support much higher radiation doses than the NRC seems prepared to permit in extreme circumstances.





-- John
John Jacobus, MS
Certified Health Physicist
e-mail: crispy_bird@yahoo.com


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