Re: Medical examination for a radiation worker

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

> We are not quibbling over semantics.  We are in significant disagreement
> on the meaning of a key section of the NRC regs.

John, 

You're interpreting what you believe the intent to be. You are 
ignoring what the reg says.

(a) identifies WHO must be trained and on what topics

(b) says that there must be an assessment made, for those who 
exceed the threshold, and for those who don't.

I was involved in the discussions that led to this revision while at 
the utility, and I know what the intent was, and what the resultant 
rule says. It's stated above. Alan Rocklein of the NRC stated it, 
and Les Slaback also stated the intent and what it does do, very 
concisely. I also stated that any facility can provide any training 
they so desire. Neither I, nor the NRC or any other regulatory body 
is demanding that no training be provided. The rule only says WHO 
must be trained (which implies who need not be).

I believe that there is nothing to be gained by discussing this 
further.

§19.12 Instructions to workers.

(a) All individuals who in the course of employment are likely to 
receive in a year an occupational dose in excess of 100 mrem (1 
mSv) shall be—

(b) In determining those individuals subject to the requirements of 
paragraph (a) of this section, licensees must take into 
consideration assigned activities during normal and abnormal 
situations involving exposure to radiation and/or radioactive material 
which can reasonably be expected to occur during the life of a 
licensed facility. The extent of these instructions must be 
commensurate with potential radiological health protection 
problems present in the work place.  


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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