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Re: Veterinary Nuclear Medicine -Reply
I am not sure what the final criterion for release of patients
will be as the paper is with the Commission for review right
now and it is not my rulemaking. However, it really is not
relevant. The patient release criteria are based upon
retention and excretion in humans (not dogs and cats) and
on the assumption that the exposed individual is an informed
family member that derives a benefit from reduced hospital
stays. In the case of Part 35, it is reasonable to assume
that family members will keep some distance and that
sanitary precautions will be taken. The referenced cost
benefit analysis looks at hospital costs on the order of
$1000's/day. None of these are applicable to veterinary
medicine.
There are no current regulations that define quantities
permissible in a released animal (of which I am aware). The
disposal regulations are specific to the disposal (i.e.,
sanitary sewer, effluents, etc.).
So the bottom line is, it has to be proposed, negotiated, and
incorporated into your license to possess and use the
material. Then you will need to come up with a model to
calculate human doses from reasonably expected exposure
scenarios yielding doses of no more than 100 mrem/yr.
Charleen Raddatz
ctr@nrc.gov