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[Fwd: Re: You can't have too much NVLAP.]
The following is posted with the permission of the author.
-------- Original Message --------
From: James Blute <James.Blute@aeat-qsa.com>
Subject: Re: You can't have too much NVLAP.
To: liptonw@dteenergy.com
Mr. Lipton,
Although I don't know all the ins and outs of this proposal, I tend to
agree with your position - mainly for the following reason...
"Secondary" dosimetry is usually not required to be in compliance but
is often placed on workers to back up primary dosimetry and get more
info. If NVLAP is required, then secondary dosimetry will be used less
often and more sparingly due to the increased cost and availability of
NVLAP dosimetry and the decreased usability of non-NVLAP dose info. The
end result - in my opinion - will be workers with less dosimetry - and
thus - less information for dose reconstruction about an event if
something goes wrong.
I for one would prefer additional info that is questionable (more
difficult to defend than NVLAP dosimetry) over no additional data.
I am having trouble posting to RADSAFE right now so if you get this
maybe you can post it for me.
Jim Blute, CHP
>>> William V Lipton <liptonw@DTEENERGY.COM> 05/05/03 12:53PM >>>
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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