Re: I submitted the "primary" versus "secondary" dosimeter (follow-up)

["Sandy Perle" <sandyfl@EARTHLINK.NET>]

On 6 May 2003, William V Lipton wrote:



>  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.  



Bill .. the above is true today as well. The NRC has not defined 

primary dosimetry. It is implied though in my submittal, for in it I 

state that the dosimetry that is used to meet the requirements in 

section 1201 shall be accredited. A licensee that reports dose under 

1201 is using a primary dosimeter. Of course a comment can be 

submitted to the NRC for this proposed rulemaking to detail that. As 

stated many times, and throughout the proposed submittal, I emphasize 

that official dose of record reporting requires a NVLAP accredited 

dosimeter, whatever it is. If the dosimeter is  not worn to meet 

1201, then it is not covered in my proposal. Again, this is already 

the case under the current Part 20. I am not advocating changing this 

in any way.



> 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.  



I address this comment in the above statement. I am only addressing 

dosimeters that are used to report official dose of record to meet 

1201.



> 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 current Part 20 was never revised to include extremity 

performance testing when ANSI N13.32 was published in 1995. This 

should have been done, but was not. 



With respect to accrediting EDs, ANSI N13.27 (still in DRAFT state) 

was written to include performance testing, similar to ANSI N13.11. 

Due to the fact that N13.37 included type testing requirements, which 

contradicted N42.20, the standard has been in limbo for almost 10 

years. ANSI N13.11 was revised to incorporate ED testing, and this 

has been in effect for years. The current ANSI N13.11-2001 version 

has an Appendix for ED testing, in detail.



Hope this answers some of your issues.



-------------------------------------------------

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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