RE: EPDs for personnel monitoring and surveys

["Sandy Perle" <sandyfl@earthlink.net>]

> The greatest decrease in reported overexposures I have observed in 
> Texas came when NRC and agreement states adopted the annual exposure 
> limits in 10CFRPart 20.   Just another example of rulemaking 
> demonstrating  a positive effect.   

This is nothing more than a "smoke and mirrors" decrease. 
Revising the regulation on the period to be monitored does not 
positively impact, or negate, the causes of unnecessary 
exposures, some that may exceed regulatory limits. This refects 
simply a the "time slice" in which a dose is accumulated. Granted, 
there are no additional quarterly limit exceedances, when an 
annual limit is imposed. One could eliminate all exposures that 
exceed a limit by simply having a 5 year limit, and no requirements 
in-between. No credit in reducing "over-exposures" should be 
provided to the monitoring period in which a dose must be 
maintained 

To address real issues real countermeasures must be 
implemented. The TLD or film dosimeter is simply the outcome 
indicator. The real countermeasure has to do with the process 
indicators, i.e.,  continuous area survey (primary) and secondary 
dosimetry.

Sandy Perle
E-Mail: sandyfl@earthlink.net 
Personal Website: http://www.geocities.com/capecanaveral/1205

"The object of opening the mind, as of opening 
the mouth, is to close it again on something solid"
              - G. K. Chesterton -
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