Re: You can't have too much NVLAP.

["Sandy Perle" <sandyfl@EARTHLINK.NET>]

First, let me state that the proposed rulemaking does not imply in 

any form that secondary dosimetry require NVLAP accreditation. That 

is currently true today, in that a facility may use a secondary 

dosimeter; i.e., electronic, SRPD or a calculation to report "dose of 

record" when the primary dosimeter is not a viable dosimeter due to 

anomaly, damage or loss.



Secondly, the purpose of this proposed rulemaking is simply common 

sense. If one is to record "official dose of record", then it is my 

opinion that to provide for a credible result, that the reading shall 

come from a dosimeter that is accredited by NVLAP, meeting ISO 17025. 

This is currently required for whole body dosimeters. Why not 

extremity dosimeters, or, any other dosimeter used for recording 

"official dose of record."



This rulemaking was not proposed blindly. I consulted with industry, 

as well as NRC individuals, at the highest levels.



As far as ICN benefiting .. that is furthest from the truth. We 

already provide extremity monitoring for our power reactor clients, 

and, we would not benefit from accrediting electronic dosimeters.



I ask anyone to argue the need for a dosimeter to meet standards. In 

fact, the rulemaking proposal includes the NRC documents that state 

categorically the EDs, should be accredited, and should meet industry 

standards.



On 5 May 2003 at 12:53, William V Lipton wrote:



> 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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-------------------------------------------------

Sandy Perle

Director, Technical

ICN Worldwide Dosimetry Service

ICN Plaza, 3300 Hyland Avenue

Costa Mesa, CA 92626



Tel:(714) 545-0100 / (800) 548-5100  Extension 2306

Fax:(714) 668-3149



E-Mail: sandyfl@earthlink.net

E-Mail: sperle@icnpharm.com



Personal Website: http://sandy-travels.com/

ICN Worldwide Dosimetry Website: http://www.dosimetry.com/



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