Re: Emergency Doses Allowed

[ALOIS.SINGER@hq.doe.gov]

Based on some of the replies I have seen to this question regarding
DOE requirements, I would offer some facts from 10 CFR 835.  The
requirements for Planned Special Exposures are contained in Subpart C,
835.204, while the requirements and/or guidelines are contained in
Subpart N, 835.1302.  these are separate and distinct requirements and
exposure in the one case is not intended to be counted in the other.

As to questions of how either Planned Special Exposure or Emergency
exposure affect future occupational dose, 835.204(f) states that the
dose from planned special exposures is not to be considered in
controlling future occupational dose of the individual under 835.202,
but is to be included in records and reports required under this part.
Subpart N-Accidents and Emergencies states that any employee who has
exceeded occupational exposure limits specified in 835.202 and 835.205
(skin dose) may be permitted to return to work in radiological areas
during the current year provided that all of the following conditions
are met: approvals from the contractor organization and the DOE field
organization, counseling of the individual by Radiation Protection and
medical personnel on the consequences of receiving additional
exposure, and the employee agrees to return to radiological work.
Subpart N likewise requires that all emergency exposures be recorded
and reported.

On the questions regarding whether you should use external exposure,
CEDE or TEDE when determining exposure for planned special exposures
and emergencies, all exposure within DOE is required to be reported in
accordance with 835.203 which says that the TEDE during the year shall
be determined by summing the effective dose equivalent from external
exposures and the committed effective dose equivalent from intakes
during the year.  Since both 835.204 and 835.1302 require recording
and reporting of the individuals dose (to be entered into the
individuals exposure records) and DOE uses TEDE to determine
individual dose, the limits associated with these two sections of 10
CFR 835 should be TEDE doses.

Joyce Davis has a point since it won't take much of a plutonium uptake
to exceed 25 rem TEDE.

These are my thoughts on this question.

Thanks for listening,

Skip
Alois.Singer @hq.doe.gov