Re:

[sandy_perle@email.fpl.com]

     Jeanne:
     
     While our workers are not exposed to P-32, we are looking at reducing 
     badging the numbers of workers we currently do. Some factors to be 
     considered when determining at what levels a dosimeter is not needed, 
     even though regulatory limits are being met:
     
     1. Consider the legal ramifications. Litigation is always at hand, 
     and, it is easier to provide justification that a dose reported is 
     more likely to be correct than to prove that the individual DID NOT 
     receive an exposure, even if it were deemed to be below regulatory 
     limits.
     
     2. In the Nuclear Utility Industry we are focused to provide a minimum 
     of 1 dosimeter to an individual who is determined that they will not 
     receive more than 100 mrem in a year. This is not based on past 
     information, but looking ahead as to what their job accountabilities 
     are. Two dosimeters are required if they are to receive more than 100 
     mrem in the year.
     
     This is different than NOT badging them at all, from the 10 CFR 20 10% 
     regulatory requirement. While a dosimeter is worn, the utility can 
     still determine that the dose received, from the dosimeter, is not 
     required, although monitoring was provided, and handle it as such.
     
     3. I would assume that for P-32 the most effective dosimeter is going 
     to be the finger ring. A wrist badge might be appropriate if a 
     distance factor is applied (this is out of my expertise - and am only 
     making an observation)
     
     Anyway, I will be interested in seeing the responses you receive to 
     this question. It is a good one, and affects many different work 
     environments.
     
     My own personal opinion is that we should not be over-conservative in 
     the way we monitor the workforce, but also not be so naive to think 
     that because we have received regulatory relief that we should pull 
     all badges off of every worker. Let's face it - the reality is that we 
     have ALWAYS been allowed to "not monitor" an individual (old 10 CFR 20 
     was 25%). Now that it is 10% everyone is running to pull badges off of 
     workers. I believe that the industry is making another MAJOR mistake, 
     and we will all be paying for it in the years to come. Why? Because 
     most workers don't trust or believe us now, and their interpretation 
     is, and will continue to be, we're hiding dose from them. They are 
     going to be our future headaches, our long-term law suits, and an 
     unhappy worker will sue... in a heart beat.
     
     Sandy Perle
     Supervisor Health Physics


______________________________ Reply Separator _________________________________
Subject: 
Author:  radsafe@romulus.ehs.uiuc.edu at Internet-Mail
Date:    8/15/95 12:09 PM


I am in the process of reducing the number of film and ring badges our
office issues.  Currently we issue over 2,500/month.  A large chunk of the
monitored individuals use P-32, and receive considerably less thatn 10% of
their annual dose limits. 

I would appreciate any input from those institutions that do not routinely
badge all P-32 users.  How do you decide which P-32 users receive a badge
and which do not?  We are attempting to develope a mCi*hr yearly threshold,
above which users must have film and ring badges.  It is not working out as
"cleanly" as we had hoped.

Thanks,

Jeanne McGuire
e-mail jmcguire@magnus.acs.ohio-state.edu