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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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