[Date Prev][Date Next][Thread Prev][Thread Next][Date Index][Thread Index]
Re: Powernet: Re: I submitted the "primary" versus "secondary"dosimeter(follow-up)
Thanx for your response. I appreciate your intentions, but am still concerned
about the wording of the proposed regulations.
Also, I missed this on the first review, but I noticed that the proposed
definition of "individual monitoring devices" includes "...person ('label')
[sic] air sampling devices." I assume you mean "lapel" samplers. Since lapel
samplers may be used to determine CEDE and CDE, would they be covered by
20.1501(c)? If so, does ANSI N13.11 cover this?
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:
> 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/
>
> -----------------------------------
> Reply to: powernet@hps1.org
> If Questions, contact Mike Russell, CHP at russelmj@songs.sce.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/