You can't have too much NVLAP.

[William V Lipton <liptonw@DTEENERGY.COM>]

I recommend that Radsafer's review today's (May 5, 2003) Federal

Register Notice, "Sander C. Perle, ICN Worldwide Dosimetry Service,

Receipt of Petition for Rulemaking".



Sandy's intent seems to be to revise 10 CFR 20.1501(c) to:  (1) remove

the current exemption from NVLAP accreditation requirements for extemity

dosimetry, and (2) require NVLAP accreditation of electronic dosimeters.



While some of these proposed requirements may be worthwhile, I am

concerned about the wording of the proposed new 20.1501(c):  "All

personnel dosimeters used to determine the radiation dose and that are

used by licensees to comply with 10 CFR 20.1201, with other applicable

provisions of this chapter, or with conditions specified in a license

must be processed and/or evaluated by a dosimetery processor - (1)

Holding current personnel dosimetry accreditation from the ...

NVLAP..."  As written this seems to apply to electronic dosimetry that

is used as secondary dosimetry, since:  (1) this secondary dosimetry may

be used for the dose of record in the event that primary dosimetry is

lost or unreadable, (2) this secondary dosimetry is used to support the

ALARA provisions of 10 CFR 20, and, for power reactors, electronic

dosimeters may be used to fulfill the high radiation areas < 1000

mrem/hr entry provisions in our licenses.



I think that, if this petition is accepted, the language in the

resulting rulemaking should be clarified to limit its applicability to

primary personnel dosimetry.  Dosimetry that is used as secondary

dosimetry and that is used as the dose of record only on a contingency

basis should be specifically excluded from this requirement.  In

addition, I do not see the need for this to apply to extremity

dosimetry.



Perhaps, a dialogue on Radsafe could help resolve potential concerns

among licensees.



I also want to emphasize that, even though ICN may significantly benefit

from such rulemaking, I am NOT implying any ulterior motives for this

petition.



The opinions expressed are strictly mine.

It's not about dose, it's about trust.

Curies forever.



Bill Lipton

liptonw@dteenergy.com





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