This impacts Administrative Control Limits. Gene Runkle agreed with Mike on this issue. A 5 Rem Dose Committment is now triggering accident investigations, which previously were triggered by 5 Rem in a single year. There was much discussion on this topic. Mike felt that it is okay to keep doses on records but it should be taken out of regulatory space, with the associated enforcement actions, which are expensive and time consuming.
Investigations do find unauthorized work, however.
But penalties and mistrust are a downside. Gene stated that it is a dose rate issue. There was no real closure on this, with lots of issues around the table. Gene will try to get Charlie Mienhold to give the RCCC the ICRP perspective on this issue. Michael Tester raised these issues, which result from digging operations at Fernald.