ML18052B409

From kanterella
Jump to navigation Jump to search
Requests Interpretation as to Whether Doses Obtained from Nonaccredited Dosimeters,When Used in Addition to Accredited Dosimeter for Purposes Listed,Can Be Used in Whole or Part in Determination of Legal Record Dose
ML18052B409
Person / Time
Site: Palisades Entergy icon.png
Issue date: 12/10/1987
From: Kuemin J
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8712150261
Download: ML18052B409 (2)


Text

  • -- -- *.,!,-

consumers Power POWERiNii NllCHlliAN'S PROliRESS General Offices: 1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-0550 December 10, 1987 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

REQUEST FOR INTERPRETATION OF 10CFR20.202(c)

.WITH POTENTIAL REQUIREMENT FOR EXEMPTION Effective February 12, 1988, all dosimetry, except direct-reading dosimeters (DRDs) and extremity dosimeters, must be accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) if used to implement the requirements of 10CFR20.202(a).

At Palisades Plant, our practice is to use an accredited thermoluminescent dosimetry (TLD) badge in each case that dosimetry is required to meet the requirements of 10CFR20.202(a). In addition, the dosimeter may be accompanied by a direct reading dosimeter for short interval dose tracking, and by one or more non-accredited redundant TLDs (we refer to these as "Secondary TLDs"),

used for the following purposes:

1. To provide a backup in the event of loss, damage or other problem with the accredited dosimeter.
2. To provide additional radiation spectral or depth-dose data for the worker's exposure position(s) and exposure fields.
3. To obtain additional information on dose distribution in non-uniform radiation fields (multiple wholebody badging).

The uses described above for our "SecondaryTLDs" appear to be permitted for this type of redundant non-accredited dosimeters, based on Statements of Consideration appearing in the Federal Register, 52FR4601, dated February 13, 1987.

8712150261 871210 '.Ii P DR ADOCK 05000.255 \*

p . * *

OC1287-0230-NL04

e Ndclear Regulatory Commission 2 Palisades Plant Request for Interpretation 10CFR20.202(c)

December 10, 1987 "Turning to the major comment from medical and hospital licensees, it is not the intent of the NRC to discourage voluntary dosimetry or redundant dosimetry that is provided in addition to the required dosimetry. The subject regulation will not require the services of an accredited personnel dosimetry processor for such voluntary or redundant dosimeters."

However, should one or more of the redundant dosimeters result in dose of record (or contribute substantially to the dose of record), it is unclear whether accreditation is then necessary. Certainly, if all doses of record were obtained from non-accredited redundant dosimeters, the intent of the regulation would be violated. In our case, normally less than 10% of doses to badged personnel would contain a component originating from redundant non-accredited dosimetry.

We would appreciate a formal interpretation as to whether doses obtained from non-accredited dosimeters (our "Secondary TLDs"), when used in addition to an accredited dosimeter for the purposes stated in (1) through (3) above, may be used in whole or part in determination of legal record dose.

Your reply is requested prior to the implementation date for 10CFR20.202(c) on February 12, 1988. In the absence of such reply, we intend to continue our practice of utilizing non-accredited redundant dosimetry, as necessary, to maintain our current high standards for accurate determination of radiation doses to exposed workers.

If you interpret the rule as prohibiting the use of non-accredited dosimetry (Secondary TLDs) as is currently practiced, we request an exemption from the rule for such dosimetry when used in accompaniment of accredited dosimetry as described herein. An application fee, in accordance with 10CFR170.12(c), will be provided upon notification that an exemption will be required. Approval of the exemption, if necessary, is also requested by February 12, 1988.

~Kuemin Staff Licensing Engineer CC Administrator, Region III, NRC NRC Resident Inspector - Palisades OC1287-0230-NL04