Re: Emergency Doses Allowed

[ALOIS.SINGER@hq.doe.gov]

David Lee wrote: "Thank-you for your rapid reply.  But now that you
have clarified that the dose limits/guidelines for emergency exposure
conditions in 10 CFR 835.1302 are TEDE doses, not merely whole-body
external doses, what do you propose be done to address Joyce's
original point?  Since the amount of a long-lived alpha emitter
required to impart a CEDE of 25 or 50 rem is minuscule and such an
amount can on rare occasion be intaken in a Pu nuclear facility as
part of routine operations, not "emergency exposure conditions," is it
not then appropriate to consider revising the limits of 10 CFR
835.1302 upward in a manner that would somehow permit or recommend a
CEDE for Plutonium that is appropriate for an "emergency exposure
condition" rather than the present set of dose limit numbers, which
since they are as you say CEDE limits as well as external DE limits,
appear to be truly inappropriate in the case of long-lived alpha
emitters?...."

Your response to my posting raises some very good points which I
cannot resolve.  My statement that the limits/guidelines associated
with 835.204 and 835.1302 should be TEDE doses is my interpretation of
the rule because to me it does not make sense to set limits or
guidelines in terms of whole body external dose but require monitoring
and tracking and setting of legal occupational dose limits in terms of
CEDE.  However, I can't presume to know what was in the minds of those
who wrote the rule.  I agree that this looks like a good issue for DOE
to resolve.  Considering that this may take a very long time, the
approach that I would take is that the table for emergency exposures
contains guidelines.  Therefore, there appears to be room to
accomodate situations such as dealing with an emergency that will
result in a significant plutonium uptake and a resulting large
internal exposure.  your questions would best be posed to EH-3 and
EH-5 who have responsibility for setting and interpreting the DOE
radiation protection requirements.

Not trying to be evasive, but I can only speak for myself, and not for
DOE.

Skip Singer
Alois.Singer@hq.doe.gov