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Re: You can't have too much NVLAP.
On 5 May 2003 at 14:07, William V Lipton wrote:
> (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.
I stated all dosimeters used for dose (primary is the intent) to
include EDs since they in fact do have parameters set, and are in
fact, "processed". Even if they aren't processed, the proposal takes
out the exception.
In the current wording of 10 CFR 20.1501(c), the use of a secondary
dosimeter for dose of record, when the primary fails, is already
allowed. My proposal does not change that. I agree that wording can
be changed to ensure that my intent is not misinterpreted.
The proposal is for personnel dosimetry and not for any other intent.
This can be seen in the entire document I submitted. NVLAP does not
apply to anything other than personnel monitoring, and ANSI N13.11 is
very precise in this.
> (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.
NVLAP has been testing EDs for accreditation since 1995 without any
problems. SEveral utilities have tested under the voluntary program.
I am only asking that if the dosimeter (any dosimeter is used for
"dose of record", that it meet the standard. That should be easy
enough.
> (3) I reiterate, just in case my previous statement wasn't clear enough, that I
> am NOT implying any ulterior motives.
I have no problem with your posts. A dialogue is good, and, if the
NRC accepts my proposed rulemaking, the wording should be porecise.
Thanks,
Sandy
-------------------------------------------------
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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