[Date Prev][Date Next][Thread Prev][Thread Next][Date Index][Thread Index]
Re: I submitted the "primary" versus "secondary" dosimeterclarification
I appreciate your clarification. Nevertheless, with rulemaking, "The devil's
in the details." Too often, well-intentioned rules are misinterpreted. Since
there are no definitions for "primary dosimetry" and "secondary dosimetry" in
10 CFR 20, your proposed revision to this regulation has to be written so that
the requirements are clear and meet your intent.
You also have to address the issue of, "...personnel dosimeters used to comply
... with other applicable provisions of this chapter or with conditions
specified in a license..." ED's that are not used to determine the personnel
dose of record, but are used for these purposes (e.g., ALARA or access control
to hi rad areas) should not require NVLAP evaluation.
Regarding the issue of extremity dosimetry, what is the rationale for the
original exclusion of extremity dosimetry from NVLAP? If this rationale is
still valid, the exclusion should remain.
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:
> I submitted the following comment back to the NRC, per the recent
> dialogue, to categorically clarify my position regarding secondary
> dosimetry not coming under the auspices of the proposed rulemaking:
>
> Clarification to my proposed revision to 10 CFR 20.1501[c], as
> published May 5, 2003
>
> 1. The intent is that only dosimetry used as a primary dosimeter
> shall require accreditation per the proposed rulemaking.
>
> 2. The intent is not for secondary dosimetry, that is dosimetry used
> in the event the primary dosimeter is lost, the calculated dose is
> questioned due to anomalies, the dosimetry is improperly worn, or
> other investigated reason, the primary dosimeter can not be used to
> assign the final dose of record.
>
> 3. Item 2 is currently the accepted method by the NRC and state
> regulatory agencies, and my proposed rulemaking does not intend to
> modify this practice. The intent is only for primary dosimetry to be
> accredited.
>
> -------------------------------------------------
> 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/
>
> ************************************************************************
> You are currently subscribed to the Radsafe mailing list. To unsubscribe,
> send an e-mail to Majordomo@list.vanderbilt.edu Put the text "unsubscribe
> radsafe" (no quote marks) in the body of the e-mail, with no subject line.
> You can view the Radsafe archives at http://www.vanderbilt.edu/radsafe/
************************************************************************
You are currently subscribed to the Radsafe mailing list. To unsubscribe,
send an e-mail to Majordomo@list.vanderbilt.edu Put the text "unsubscribe
radsafe" (no quote marks) in the body of the e-mail, with no subject line.
You can view the Radsafe archives at http://www.vanderbilt.edu/radsafe/