RE: Posting and Monitoring Requirements @ DOE Facilities

["Allen, David" <dka6@cdc.gov>]

I have to agree with this especially the second point.  A TLD is cheap

insurance against litigation.  The point that most people tend to miss

is that the TLD results are filed in a persons dosimetry record and tend

to be retrievable while the evaluation of whom needs to be monitored is

often hard to recover years later. 



David Allen



-----Original Message-----

From: owner-radsafe@list.vanderbilt.edu

[mailto:owner-radsafe@list.vanderbilt.edu] On Behalf Of William V Lipton

Sent: Thursday, November 20, 2003 7:22 AM

To: Stanford Dosimetry

Cc: Radsafe list; Tom.Goff@wipp.ws

Subject: 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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