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Re: Posting and Monitoring Requirements @ DOE Facilities
This looks good on paper, but my experience at a DOE facility indicates that a
policy of badging only those who obviously need monitoring is a sure way to get
in trouble, for 2 major reasons:
1. As in most aspects of this business, the "unlikely" often happens. A
researcher in one field which does not involve radiation exposure may join some
group which is using a source, accelerator, or x-ray machine. Such ad hoc
collaboration may be good for research, but could lead to unmonitored
exposures. Unless you have physical controls, such as a control point, which
prevent unmonitored individuals from entering a restricted area, I would have
the philosophy, "If in doubt, badge."
2. In the event of future radiation injury litigation, if an unmonitored
individual states that he worked with radiation sources, you will end up relying
on his lawyer to do your dosimetry. (This was a problem with the DOE system.
I'm not sure if it's still that way, but when I was there, the contractor was
not responsible for any future injury claims; a good deal for the contractor,
but a bad deal for the taxpayers.)
The opinions expressed are strictly mine.
It's not about dose, it's about trust.
Curies forever.
Bill Lipton
liptonw@dteenergy.com
Stanford Dosimetry wrote:
> 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
> --------------------------------------------------
> Stanford Dosimetry LLC
> www.stanforddosimetry.com
> stanford@stanforddosimetry.com
> 360 293 9334
> 360 770 7778 (cell)
> -------------------------------------------------
>
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