Accidents and Dose Limits

[William McCabe <WMCCABE@tnrcc.state.tx.us>]

I am having a discussion with our legel staff regarding accidents and
dose limits.  Our legal people are telling me that the regulatory dose
limits (100 mrem/yr as well as the 25 mrem whole body, 75 mrem thyroid,
and 25 mrem other organ to any member of the public) and effluent
concentration limits (i.e. 10CFR20, App B) and other such limits, as
applicable, apply.  Their opinion is based on how they are reading our
state equivalent of 10CFR (essentially the same as 10 CFR).   (It seems to
me that this is like saying it is agtainst the law to receive anything more
than minor cuts and bruises ANY traffic accident.)

It has always been my understanding that you cannot apply a regulatory
dose limit or effluent concentration limit to a radiological  accident.  All you
can do is plan and prepare for any reasonable or credible accident
situation and do everything you can to prevent the accident from
occurring and take action to mitigate the consequences of the accident if
it should occur.  (To continue my earlier analogy... install automobile
safety devices, design vehicle to absorb and distribute impact energy
away from passenger, require seat belt use, etc.  This will not prevent
exceeding minor cut and bruide injuries, but will (should) help minimize
more serious injuries and death).

I'd appreciate any comments and especially references and other state
and federal regulatory positions or guidance on this subject from the
RADSAFE community to help clear up either my or my legal people's (or
both our) misconceptions.

Thanks in advance.

Will McCabe
wmccabe@tnrcc.state.tx.us