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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/

>

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