Badge Exposure Data for General Public Compliance

[10525kfb@ibm.cl.msu.edu (Kristin Erickson)]

Hi, Ed:

In response to:
Kristin:
   We just lost this ability to use badge data to justify expected exposure
to the public.  We are being asked to show, through calculated dose estimates
in each lab, that the dose rates are below 2mrem/hr.  We were told that having
a dose <10% does not demonstrate a dose rate below 2 mrem/hr.  Any ideas on
how we can get this written back into our license like it was for the previous
10 years?

   It must be nice to be outside Region I.


We are showing that data by documenting survey results in our surveys and
in the documented surveys conducted by the laboratories.  We also calibrate
all their survey instruments with NIST traceable sources, so the data is
valid and stands up to inspection.  I should think that your data would
serve the same purpose.   You have the information available to demonstrate
compliance if the labs are similar to ours as far as the uses. 

As for as calculating doses for each lab, that is a mountain of work; I
have sympathy!  Perhaps you should try to use the survey data, and if they
need them, several "worst case" calculations which could provide
representative data for situations found throughout your facility.

As for how nice it is to be outside your region, alas, I think we are all
in the same "raft"!  I say that to licensees in other regions, too.  Region
III is getting very tough; the Cleveland Plain Dealer articles "fallout"
and Senator Glenn have had a major impact on our region, along with the
EPA's complaints that the NRC is not tough enough.

Hope some of this helps.

Kristin

All comments herein contained are my own opinions and/or experiences and
are not necessarily those of my employer or institution.

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Kristin Erickson, Radiation Safety Officer
Office of Radiation, Chemical and Biological Safety
C124 Research Complex-Eng.
Michigan State University
East Lansing, Michigan 48824
Telephone: (517) 355-5008   Fax: (517)353-4871   Email: 10525kfb@msu.edu
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