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Re: You can't have too much NVLAP.
Many thanx for your prompt response. I still have the same concerns, however.
(1) ED's currently do not require NVLAP processing or evaluation because they
are not "processed" to obtain the dose. If 10 CFR 20.1501 revised to include
the proposed wording, ED's may be included since: the wording is not limited to
primary dosimetry, ED's may be used as the "dose of record" on a contingency
basis ( In this case, the dose is assigned based on an investigation which would
generally include the ED reading, area radiation surveys, time motion studies,
and coworker doses, so I don't see the need for NVLAP, here.), and ED's may be
used for other provisions of 10 CFR 20, e.g., ALARA and access control.
(2) I am not arguing that dosimetry should not meet standards. However, for
dosimeters which are are active instruments rather than passive devices, NVLAP
may not be the best standard.
(3) I reiterate, just in case my previous statement wasn't clear enough, that I
am NOT implying any ulterior motives.
The opinions expressed are strictly mine.
It's not about dose, it's about trust.
Curies forever.
Bill Lipton
liptonw@dteenergy.com
Sandy Perle wrote:
> 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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