Re: Personnel Contamination Events

["Leon E Brown" <lebrown@cmsenergy.com>]

Phil Budnik from the Big Rock Point Restoration Project asked that I post the
following comments related to personnel contamination events (PCEs) to RADSAFE
for him.

In response to PCEs, it appears the issue is one of inconsistency and of
risk/reward evaluation.

First, an inconsistency.  Why would a program document a PCE for 100 ccpm on the
skin of a worker, yet allow the same worker to wear PCs that are 500 ccpm?  It
can't be to protect the worker.

On the risk/reward evaluation, if the program spends too much time following up
on PCEs and is not able to find the cause of the PCE(s), then perhaps the ratio
at "that" program is out of balance.  In other words, if 20 hours are spent on
interviews, survey documentation and the lost time of a worker in the field,
then perhaps the threshold for documenting a PCE is too low.

A PCE in some instances is an indicator of something going on and/or a precursor
that radiological controls are ineffective.  In my experience there were other
indicators to management that radiological controls are inadequate (e.g., higher
than expected exposure, hot air samples, surveys, etc.).

It seems that PCEs are one method of evaluating the effectiveness of the
Radiation Protection Department - not a very good one, but one that is easy to
look at instead of using other methods to evaluate the program.

Just my own thoughts.

Philip R. Budnik

Submitted by:

Leon E. Brown, CHP
Sr. Consultant
Big Rock Point Restoration Project
(231) 547-8419
lebrown@cmsenergy.com


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