Bill Lipton submiital to Petition for Rulemaking PRM-20-25

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

With Bill's permission, I am providing Bill's recent submittal with 

respect to Petition for Rulemaking, PRM-20-25:



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

http://ruleforum.llnl.gov/cgi-bin/downloader/ICN_PRM_public/1274-

0004.msw



June 14, 2003



Secretary

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

ATTN:  Rulemakings and Adjudications Staff



Subject: Comments on Petition for Rulemaking, Docket No. PRM-20-25



I support the intent of  this petition, which will assure that 

dosimetry used to assign dose to individuals who are monitored for 

occupational radiation exposure are monitored with dosimetry that is 

required to meet applicable quality standards.  However, I believe 

that the proposed regulatory wording needs clarification.  I have two 

concerns:



(a) Most nuclear power reactors assign secondary dosimetry, in 

addition to the primary dosimetry, to individuals who are monitored 

for occupational radiation exposure.  The primary dosimetry is the 

dose of record.  The secondary dosimetry is used to provide an 

instantaneous indication of dose rate and accumulated dose.  In the 

event that a person’s primary dosimetry is lost or unreadable, the 

secondary dosimetry is used as part of an investigation to assign 

dose.  The proposed wording could be interpreted as requiring NVLAP 

accreditation for secondary dosimetry, because of its contingency use 

to assign dose.  Since this is not the intent of this petition for 

rulemaking, the wording should be clarified to avoid the need for 

secondary dosimetry NVLAP accreditation.



(b) The proposed wording defines a personal (lapel) air sampler as an 

“individual monitoring device.”  This may be interpreted as requiring 

NVLAP accreditation for lapel samplers, since they may be used to 

assign CEDE.  The wording should be clarified to remove the need for 

NVLAP accreditation of lapel samplers. 



My proposed wording is:



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  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 dosimetry 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]



Submitted by  William V. Lipton  ScD, CHP, CHMM









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

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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