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Re: Powernet: clarification to petition posted NRC site



Many thanx for this clarification.  I support your petition, as

clarified, as long as the actual rulemaking meets this intent.  At this

time, "primary dosimetry" and "secondary dosimetry" are not defined in

10 CFR 20.  Perhaps the best way to tackle this is by adding the needed

definitions.



Here's my attempt.  I welcome your comments:



20.1003 Definitions



"Personnel Dosimeter" means a monitoring device worn by a single

individual for the assessment of deep dose equivalent, lens dose

equivalent, and/or shallow dose equivalent; and used for the purpose of

demonstrating compliance with the applicable Occupational Dose Limits of

Subpart C and providing data used to prepare records required by

paragraph 20.2106.



"Secondary Personnel Dosimeter"  means a monitoring device worn by a

single individual for the purpose of providing an immediate indication

of ambient external dose equivalent rate or accumulated dose

equivalent,  for the purpose of providing an assessment of deep dose

equivalent, lens dose equivalent, and/or shallow dose equivalent in the

event of personnel dosimetry failure, or for both purposes.  A Secondary

Personnel Dosimeter is not considered a Personnel Dosimeter if  an

individual wearing a Secondary Personnel Dosimeter is also wearing a

Personnel Dosimeter.



20.1501  General

...

(c) All Personnel Dosimeters must be processed and/or evaluated by a

dosimetry processor -

(1) Holding current personnel dosiemtry accreditation from the National

Voluntary Laboratory Accreditation Program (NVLAP) of the National

Institute of Standards and Technology; and

(2) Approved in this accreditation process for the type of radiation or

radiations...[same as existing wording]"



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:



> In response to the ongoing dialogue with Bill, regarding my petition

> to the NRC to revise 10 CFR 20.1501(c), I submitted a clarification

> (to ensure that there was no misunderstanding as to what my intent

> is). The clarification can be seen at:

>

> http://ruleforum.llnl.gov/cgi-

> bin/library?source=*&library=ICN_PRM_public&file=*&st=petitions-a

>

> -------------------------------------------------

> 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





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