Re: Posting and Monitoring Requirements @ DOE Facilities

["Stanford Dosimetry" <stanford@stanforddosimetry.com>]

It may seem picky, but the monitoring requirement in 835.402 is based on

likelihood rather than possibility. It states:



"Radiological workers who, under typical conditions, are likely to receive .

. . 0.1 rem or more in a year;"  

Which is different than your interpretation "people who could exceed 100

mrem/year." 



The External Dosimetry Program Guide, DOE G 441.1-4 (1999), has guidance on

issuance in section 4.3.1 Establishing the Need for Monitoring. It comes out

clearly against issuing dosimeters to workers indiscriminately:



	Unnecessary issuance of dosimeters should be avoided. If an

individual does not enter areas where there is a

	likelihood of external exposure resulting in a dose near or in

excess of the regulatory monitoring thresholds,

	issuance of a dosimeter to that individual is discouraged. For

reasons of practicality and uniformity, decisions

	regarding those individuals to whom dosimeters are issued should be

made on the basis of work group affiliation,

	type of work to be performed, and/or areas to be entered. There is

generally no need to perform calculations

	regarding individual dose expectations to support decisions

regarding the provision of individual dosimeters. The

	issuance of dosimeters to concerned individuals should not be a

substitute for providing information, training,

	access controls, and a comprehensive area monitoring program. The

criteria for the selection of individuals to be

	monitored should be documented in the technical basis document.



It goes on to list specific considerations that should be included in your

"professional judgment" of the requirement for issuance, and also contains a

section on area monitoring.



Hope this helps.





Neill Stanford, CHP

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Stanford Dosimetry LLC

www.stanforddosimetry.com

stanford@stanforddosimetry.com

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