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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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