Re: Personnel exposure records

[LIPTONW@detroitedison.com]

A "planned special exposure" requires the licensee to assess the lifetime 
exposure histories of those involved - no dose records = no planned special 
exposure. 
 
The opinions expressed are strictly mine. 
It's not about dose it's about trust. 
 
Bill Lipton 
liptonw@detroitedison.com 
 
You wrote: 
 
Is there any reason, other than for litigation, to retain exposure records 
many years after the persons exployment or exposure? 
I discount epidemiology since current practices and regulatory requirements 
(i.e., point of highest exposure) bias the data upwards by significant and 
unknown and undocumented factors.  And the demise of 5(N-18) has removed 
the rad.protection programmatic reason. 
 
If in fact litigation is the only reason then perhaps HP staffs should have 
a legal tech for maintaining such records.  And if so perhaps NRC should 
make the record retention requirements optional beyond some minimal period. 
 
This question is prompted by a proposed HPSSC std for rad.prot records, 
which includes as part of its purpose litigation protection. 
 
Please send responses directly to me for summary unless you desire to stir 
up the troops. 
 
Disclaimer:  the above are the personal musings of the author, and do not 
represent any past, present, or future position of NIST, the U.S.
government, 
or anyone else who might think that they are in a position of authority.  
Lester Slaback, Jr.  [Lester.Slaback@NIST.GOV]  
NBSR Health Physics  
Center for Neutron Research  
NIST  
Gaithersburg, MD  20899  
301 975-5810
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