Re: Monitoring requirements

["Sandy Perle" <sandyfl@ix.netcom.com>]

The NRC does allow that an individual not be monitored if there is a 
prescriptive decision that the individual will not exceed 10% of any 
regulatory limit. The Annual Form 5 calls one of these as monitoring 
provided  - NOT required (as Eric Golden stated). I am also aware of 
plants, as a member on the NEI Task Force for the development and 
implementation of PADS, who stated that they would monitor 
individuals who did not need to be monitored, and NOT record the data 
NOR report the information to either the NRC or the individual. While 
this is permitted, I believe it to be a mistake, from the liability 
perspective. Providing a report for monitoring provided but not 
required is a better option to follow. IF the individual is told 
later on, when updating their Form 4, that a plant says there is no 
record for their employment period, that will cause problems, be 
assured. That is when the employee will believe there is something 
hidden regarding their exposure. Yes, the NRC permits this, but does 
it make sense for anyone to implement such a program?

------------------
Sandy Perle
Technical Director
ICN Dosimetry Division
Costa Mesa, CA 92626
Office: (800) 548-5100 x2306 
Fax:    (714) 668-3149
  
mailto:sandyfl@ix.netcom.com
mailto:sperle@icnpharm.com

ICN Dosimetry Website:
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