Re: comparing individual and collective doses

["Roger Pedersen" <RLP1@NRC.GOV>]

In the US reactor world we generally think of ALARA as reducing collective dose from various licensed activities to As Low As Reasonably Achievable.  Although, this sometimes means that an individual is allowed to receive a higher dose to reduce the collective dose for an activity, I can't agree with the statement that ALARA does not apply to individuals.  By definition, collective dose is the sum of individual doses.  You can not reduce the collective dose if you don't control the individual doses contributors.



10 CFR Part 20.1101(b) is a program requirement.  Licensees are required to have a program in place to insure doses are ALARA.  The Statements of Consideration (Federal Register, Vol. 56, No. 98, Tuesday, May 21, 1991) published when Part 20 was revised (making ALARA a requirement), provides additional guidance on the Commission's intent.  The penultimate paragraph to Subpart B (page 23367) states that "Compliance with this requirement will be judged on whether the licensee has incorporated measures to track and, if necessary, to reduce exposures and not whether exposures and doses represent an absolute minimum..."   It goes on to state that this is "admittedly subjective criteria," and "the level of effort expended on the radiation protection programs should reflect the magnitude of the potential exposures, both the magnitude of average and maximum individual doses and, in facilities with large numbers of employees, collective (population) doses."



Roger Pedersen

Sr. Health Physicist

U.S. NRC





>>> <BLHamrick@AOL.COM> 12/03/03 09:39PM >>>

In a message dated 12/3/2003 5:38:57 PM Pacific Standard Time, 

idias@interchange.ubc.ca writes:

That is, ALARA does not apply to individual dose.



What this means for regulations depends on the "regulator" :)!

I'd like to hear from other regulators on this, because I don't think the 

above is the way 10 CFR 20.1101(b) is generally applied.



Barbara



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