Re: Emergency Doses Allowed

[David W Lee <lee_david_w@lanl.gov>]

Steve: 

	Please reread 10 CFR 835.1302 (the facts as you call them) and elucidate
as to whether, as written, you think HQ DOE meant the various stated
whole-body dose limits ranging from 5 rem to greater than 25 rem as true
legal LIMITS or just dose guidelines.

	Title 10 CFR 835.1302(d) states "the dose limits for individual performing
these operations are as follows."  This statement semantically implies to
me that the 10 rem limit stated in the table for protection of major
property is a true LIMIT, i.e., if a DOE general employee tried to save
major property and sustained a WB dose say of 13 rem, the DOE could in
theory ping the DOE contractor for having exceeded the legally specified
limit; violation of 10 CFR 835; potential Price Anderson Amendments Act
(PAAA) violation, etc.

	On the other hand, the TITLE of the Table contained in 10 CFR 835.1302
includes the word "Guidelines."  Thus, my request for your DOE elucidation:
 The dose limits specified in the Table presumably are merely "guidelines"
per the title of the Table, yet the statement of 10 CFR 835.1302(d) seems
to state that the dose numbers in the Table are legal LIMITS, not mere
guidelines.  What do you think?
 


At 04:15 PM 6/3/1998 -0500, you wrote:
>Steve, et. al.
>
>The U.S. Department of Energy currently has dose guidelines for 
>accidents and emergencies in the regulations (10 CFR 835.1302)  The dose 
>limits run from 5 rem for all emergencies to >25 rem for lifesaving of 
>large populations.  25 rem is the dose limit for "lifesaving or 
>protection of large populations."  There are other caveates too numerous 
>to mention here.
>
>58 FR 65483 makes it very clear that these values are only guidelines 
>and they have been removed from the proposed revision to 10 CFR 835 --- 
>I'm not exactly sure why.
>
>
>Rey Bocanegra
>Sr Tech Advisor on Rad protection
>DOE
>
>Don't usually add disclaimers to what I say, but .....
>The facts I mentioned above are not mine ... just the facts.
>
>>From server@romulus.ehs.uiuc.edu Wed Jun  3 12:34:31 1998
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>>Date: Wed, 3 Jun 1998 14:35:25 -0500 (CDT)
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>>From: steve hand <hand@wam.umd.edu>
>>To: Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
>>Subject: Emergency Doses Allowed
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>>Dear Radsafers:
>>
>>    Please advise on the limits allowed in an emergency with references
>>to literature if possible.  I have NCRP REPORT No. 91 and 116.  In 116
>>chapter 14 page 44 says
>>"for life saving or equivalent purposes the equivalent dose may 
>approach
>>or exceed 0.5 Sv to a large portion of the body in a short time.."  The
>>highest limit I can find in 10 CFR 20 for allowed doses is .25 Sv or 5
>>times the annual for a planned special exposure.
>>
>>1.    In the case of an emergency that is life threatening to an
>>individual, can someone get up to .5 Sv to try and save them, or up to
>>.25 Sv to try and save them ?
>>
>>2.   Rather than use one person in question 1 above, should several
>>people be used for a total of .5 or .25 Sv for life saving?  I seem to
>>remember reading something about not spreading the dose out anymore to
>>several individuals.
>>
>> Thanks
>>
>>
>>steve hand
>>university of maryland
>>radiation safety
>>hand@wam.umd.edu
>>
>>
>>
>
>
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DAVID W. LEE
Los Alamos National Laboratory
PO Box 1663, MS K483
Los Alamos, NM  87545
PH:  (505) 667-8085
FAX: (505) 667-9726
lee_david_w@lanl.gov