Re: Personnel Contamination Events

["x" <netngatr@magnolia.net>]

In response to Jack Bell and Dan Doggett,

The term 'risk based' raises some apprehension for me also.  Considering the
effect that the 'risk based' draft NUREG 1640
http://www.nrc.gov/NRC/NUREGS/SR1640/V1&2/index.html could have for release
of material and exit monitor setpoints,  I personally would support tight
contamination controls facilitated by a low threshold for PCE
documentations.  Any opinions on NUREG 1640 effects?

While contamination events are typically logged, there is a good deal of
difference in the threshold for logging.  Some track anything over 100 ccpm,
some log only those over 1000 ccpm, some track if it's on the skin, but not
on the scrubs, etc.

Normally, for what I've seen anyway, the PCE is logged as the ccpm
(corrected counts per minute, observed counts minus background counts)
direct reading from the meter, so the default area would be ~15-20 cm2 for
the typical 'pancake' probe.  In any case, I agree with Jack that area
should be defined in some manner.

If the data is collected but not used, sure, it is a bean count.  But if the
data is used, it is useful data.  I also consider it lawsuit insurance to
document a reason for no action taken.  Does anyone know of a documented NRC
requirement to do this tracking?

One hidden benefit of logging even 'nuisance contaminations' is that it is a
significant data source to be used when negotiating PC laundry contracts or
purchasing different types of PCs.   The data can be used to justify to
management and purchasing agents a higher cost laundry service or better
performing PCs.

I agree that evaluation of the dose associatied with the event is paramount.
But what the PCE tracking criteria would allow is a pre-defined industry
standard for performing dose calculations.  If an event is less than the
criteria determined, no further dose calculations are required.  If it is
higher than the criteria, further evaluations are warranted.  Isn't this
what the Below Regulatory Concern, LNT debate, and .002 uCi in 49CFR172 are
about, having a predefined limit below which no action is required?

Several institutions are working toward a standardized qualification process
for HP/RP techs.  This is just one more area to standardize that would allow
economies of scale for training road techs.


Richard Sumrall, BS, NRRPT
HP Instructor
Grand Gulf Nuclear Station
rsumral@entergy.com
My own opinion, not reviewed or endorsed by my employer.  He'd probably
disagree as a standard operating procedure anyway.


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