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RE: [Fwd: Re: You can't have too much NVLAP.]
Extremity dosimetry - I would find it difficult to justify to a jury why I
accredited my whole body dosimeter system but not the extremity dosimeter
system. It's a primary dosimeter for demonstrating compliance with
extremity dose limits, and any organization with an accredited whole body
dosimeter clearly possesses the resources and expertise to obtain
accreditation of an extremity dosimeter, so how could one justify NOT
accrediting an in-house program?
EDs: obviously an ED is not processed in the same sense as a TLD, but the
device has a detector and that detector and its signal processing system
must be calibrated and operated correctly, just like a film or TLD system.
The dose rate and alarm functions would not be subject to performance
testing under NVLAP, but the accuracy of dose measurements certainly would
be. As has been stated here, some already have accreditation for their ED
systems.
But an interesting point has been raised: how much cost must a licensee
bear? Just because something CAN be doesn't always mean it SHOULD be done.
NVLAP adopted the ISO 9000 approach a number of years ago, a system that is
undoubtedly beneficial if you plan to market you dosimetry capability,
especially internationally. But for an in-house program that will not be
offered as a customer service, it is serious overkill, raising costs out of
proportion with benefits. This will undoubtedly lead some to question the
continued use of secondary dosimetry, a highly undesirable result. Power
reactor programs will probably incur the wrath of ANI if they try to
discontinue secondary dosimetry. But if ANI goes so far as to raise
premiums for a utility that abandons secondary dosimetry, but by less than
the cost of accreditation, how many will continue to use two dosimeter
systems?
Juries: another interesting idea is which would be harder to justify to a
jury - using an unaccredited secondary dosimeter or having no secondary
dosimeter? I would prefer the former, since I'd be able to present data
demonstrating measurement quality to bolster the validity of an assigned
dose of record.
Bob Flood
Nevada Test Site
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