RE: [Fwd: Re: You can't have too much NVLAP.]

["Perrero, Daren" <Perrero@IDNS.STATE.IL.US>]

As a regulator, anything used as a primary means to determine exposure must

have a means of verification.  Calibration is one method the other is

processing by an accredited lab.  Self reading dosimeters, film badges, ion

chambers etc. all have their inherent limitations in use, but they should

not be unreliable due to their operation or performance.  That's one reason

why ANSI/NVLAP exists.  Any other secondary means or method to used to

determine exposure is exactly that, secondary and they have their place in

the scheme of things.  A secondary method should be used when primary

methods fail or if the primary is shown to be inadequate under the

circumstances under investigation and the secondary justified as a better

measurement.   



At the same time, if someone is using an EPD as the primary means to report

permanent exposure results, why wouldn't you be calibrating/processing it?

Cost alone, doesn't appear to be an adequate justification.  If you aren't,

how do you know that the result it gives you means anything at all and why

should I as a regulator accept the value when better methods of

determination exist?



As an individual with no endorsement of my employer......



The opinions expressed are mine all mine...

I'm with the government, I'm here to help

Daren Perrero

perrero@idns.state.il.us





-----Original Message-----

From: Sandy Perle [mailto:sandyfl@EARTHLINK.NET]

Sent: Monday, May 05, 2003 2:53 PM

To: William V Lipton; radsafe@list.vanderbilt.edu

Subject: Re: [Fwd: Re: You can't have too much NVLAP.]





On 5 May 2003 at 15:16, William V Lipton wrote:



> "Secondary" dosimetry is usually not required to be in compliance but

> is often placed on workers to back up primary dosimetry and get more

> info.  If NVLAP is required, then secondary dosimetry will be used less

> often and more sparingly due to the increased cost and availability of

> NVLAP dosimetry and the decreased usability of non-NVLAP dose info.  The

> end result - in my opinion - will be workers with less dosimetry - and

> thus - less information for dose reconstruction about an event if

> something goes wrong.  



I agree completely with the above, as stated previously.



I support a comment to my proposals stating the above. The above is 

my intent, and, I don't want that to be misinterpreted by anyone, 

including the NRC in their review of the proposal.



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

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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