New NRC Reg Guide for patient release

[ehsnet!hps (HPS)]

Reply-to: Wes.Dunn@p2.f13.n233.z1.fidonet.org (Wes Dunn)
Fido-To: dale boyce

Dale,

I reviewed the Proposed Rule (and R.G.) and note that the instructions
must be written (not documented, as I had earlier indicated).  You should
also note that the RG gives the user quite a bit of leeway on your 
calculations, if you wish to use them.  For instance, the NRC assumes 
(for isotopes with half-life > 1 day) the maximally exposed person is
at 1 meter for 25% of the decay time.  Also, biological 1/2 life is not
used in their calcs.  While this puts a documentation burden on the licensee 
if you wish to use different assumptions, it is certainly doable.  Also
note that the release criteria is quite a bit lower for almost all other
commonly used isotopes.  

NRC estimates 50,000/yr cases requiring instructions.  From a Health &
Safety standpoint, can one justify NOT requiring written instructions
for potentially exposing individuals to > 100 mrem in an uncontrolled
setting?

Wes Dunn
Token Revenuer




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