Re: Occupational and Public Dose

[Kent Lambert <lambert@hal.hahnemann.edu>]

In response to my original post, REHA@ccmail.ceco.com wrote:
> 
>      NUREG/CR-6204 "Questions and Answers Based on Revised 10 CFR Part 20"
>      may give some insight here.

The Preface to Questions and Answers ... on the New Part 20 states:

"The answers to questions do not constitute offical legal interpretation, which can only 
be provided by the General Counsel, and they do not reflect official NRC policy as 
approved by the Commission."

This is true even though, "Answers to these questions have been prepared by, and 
reviewed by NRC staff members in the NRC Offices of Nuclear Reactor Regulation, Nuclear 
Material Safety and Safeguards, Nuclear Regulatory Research, Office of State Programs, 
and the five NRC Regional Offices.  The questions and answers also have been reviewed by 
attorneys in the NRC Office of the General Counsel"

So what use are these?  I think that the Q & A was a good thing and the NRC is to be 
commended for publishing these; however, after all of these reviews to say that these 
are not necessarily their view makes the documents virtually worthless.

I have been told that if a person is likely to receive a dose in excess of 100 mrem in a 
year then they must be classified as an occupational worker.  So a student in an 
undergraduate class which performs one experiment with a RIA kit is a member of the 
public, but a graduate student that does research with P-32 may be occupationally 
exposed.  This is like:  If I am driving down the road at 55 mph, I am an operator of a 
motor vehicle, but if I am driving down the road at 90 mph, I am an operator of an 
emergency response vehicle!  Shouldn't we be categorizing the person and then limiting 
the dose as appropriate rather than determining the doses and then categorizing the 
person?  

BTW, the rule is much improved over the previous definition.  The sticky points are 
"course of employment" and "duties involve exposure to radiation."