Re: Part 20 revision

[Sandy_Perle_at_USFPL201@email.fpl.com]

     >>I am amazed that NRC received only 23 comments on a proposal of
     such fundamental interest to the health physics community.  Part
     of the reason might have been the lack of a forum such as this to
     stir up interest.  NRC has formed some specific BB's to encourage
     such comments in the future, but I suspect that common interest
     forums like this will be more successful.<<

Actually, this issued had been discussed extensively within the health ohysics 
community .. power plant health physics. The issue had to do with whether or not
all persons accessing a site, not necessarily entering the radiation controlled 
area, had to have rad control area training. The following is a summary of what 
I recently provided our management. Hope this format doesn't get screwed up in 
pasting:


What The Rulemaking Change Says:

1. Clarifies the definition of an occupationally exposed worker as an individual
whose assigned duties involve exposure to radiation, and, that they are likely 
to receive a dose in excess of 100 mrem in a year. 
2. A member of the public is defined based on not where they work, but with 
respect to the dose they are likely to receive.
3. Plant workers who do not meet the criteria stated above will be considered as
members of the general public, as stated below in item 4.
4. Clerical workers or other individuals similar in nature, who access the 
radiation controlled areas, but are not exposed to levels whereby they are 
likely to exceed 100 mrem in a year, are not required to be trained.
5. The rule allows individuals (members of the general public - such as truck 
drivers and repair service employees) who occasionally enter a restricted area 
to not be required to receive occupational training, merely because they entered
a restricted area when the potential to exceed 100 mrem in a year does not 
exist.
6. 10 CFR 20.1101(b) requires that licensees adopt procedures and engineering 
controls to achieve occupational doses and doses to members of the public that 
are as low as reasonably achievable (ALARA). Radiation protection training 
programs continue to be an important element of an ALARA program.
7. The NRC expects that individuals who do not require training under this rule,
since their normal job does not require them to work in areas where they are 
likely to exceed 100 mrem in a year, but are classified as an emergency worker 
according to the plant emergency plan, that they would still be required to 
receive regulatory required training.

What does the Rulemaking mean:

1. This rule change is analogous to the requirement when to monitor an 
individual for exposure to radiation. The current requirement states that 
monitoring is required for an individual if they are likely to receive in excess
of 500 mrem in a year.
2. The issue evolves around "regulatory required training" versus "common sense 
training."
3. The plants can determine who will and who will not be trained.
4. Common sense dictates that while training is not required per the 
regulations, some scaled down training might be prudent to inform individuals 
who access the radiation controlled areas that they are in fact being exposed to
levels of radiation, and what impact that might have on them. More than anything
else, it should allay any fears that they might have, and, mitigate a future 
litigation issue whereby the individual states that they were not informed by 
the utility that they were in an area where they could be exposed to radiation.


Issues:

1. Potential litigation if certain work groups are determined to be "members of 
the general public" and not as "occupationally exposed workers" per the criteria
that the individual is not likely to receive in excess of 100 mrem in a year.
2. This issue, one that workers, even those deemed to be occupationally exposed 
workers, state later that they were not informed of all the hazards, risks or 
requirements for working in an environment whereby they were exposed to 
radiation. 

Sandy Perle
Supervisor Health Physics