My personal $0.02 only and a not reflection of my current affiliations
As Creamer points out - see EPRI guide page 3-1 to find the clear answer. 
Reproduced for your convenience:

2) Non-skin contamination at 100 ncpm or greater on any item or clothing worn 
by a worker that is not protective clothing should be counted as a PCE.

From: JAMIESON, THOMAS W [mailto:[email protected]]
Sent: Tuesday, February 28, 2012 06:21 AM
To: '[email protected]' <[email protected]>
Subject: RE: Powernet: PCE Question

At Fort Calhoun it would depend on the situation. If laid it down while undress 
and found on frisking I would consider no it is not a PCE, But if it was worn 
in clean controlled area and found on PCM then yes it would be.

From: [email protected] [mailto:[email protected]] On Behalf Of 
[email protected]
Sent: Monday, February 27, 2012 6:06 PM
To: [email protected]
Subject: Powernet: PCE Question

Quick Benchmark Qs.

Does your plant count contamination on an electronic dosimeter as a PCE?

Thanks.
Mike
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