Re: Occupational Dose Limits

[Regis_A._Greenwood@FirstEnergyCorp.com]

Ladies and Gentlemen,

Reading 10CFR20.1003 one comes across definitions of both occupational dose
and of member of the public. Further reading of 10CFR20.1301 yields dose
limits for members of the public. No where in Part 20 does it say that a
person becomes an occupationally exposed individual merely by entering a
restricted area. The reference to being occupationally exposed soley by
virtue of location was deleted by final rule making (60FR36038 dated
7/13/95 and effective 8/14/95).

In the "Statements of Consideration" for this final rule, the commission
makes it very plain " and makes it clear that that a member of the public
does not become a worker just by entering a restricted area"  and "
changing the definition of 'Public Dose' so that it is not dependant on
where an individual is..."  and "this change is consistent with the changes
to 'Occupational dose' and is considered clarifying"..

This may be found, along with other explanations of who needs training etc,
in 10CFR20 Statements of Consideration, pages 20-SC-76 through 20-SC-81.

Thank You for Your Attention.

Regis A. Greenwood, C H P
ragreenwood@FirstEnergycorp.com
                      OR
greenwood@physicist.net