ML20056C449

Final Response to FOIA Request for Documents.App C Records Already Available in Pdr.Forwards Documents Listed in App D, Which Are Being Made Available in Pdr.App E Records Partially Withheld (Ref FOIA Exemption 5)

ML20056C449
Person / Time
Site:	Dresden, Duane Arnold, Zion, LaSalle, 05000107
Issue date:	03/10/1993
From:	Grimsley D NRC OFFICE OF ADMINISTRATION (ADM)
To:	Darrin J ALNOR NUCLEAR CORP.
Shared Package
ML20056C450	List: ML20056C449 ML20056C462
References
FOIA-92-565 NUDOCS 9306240118
Download: ML20056C449 (17)

Text

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U S. NUCLEAR REGULATORY COMMISSION tmc F usa htuvE SI Nuvet swi FOIA -

92-s6s

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b3 RE sroNsE iveE E 4 'j RESPONSE TO FREEDOM OF XX I "Na' l Iraat'A' h '

INFORMATION ACT (FOIA) REQUEST DATE s%...../

NAR 101993 DOCKt i NUMBE R(Si //r apphcstw/

REQUES1FH Mr. John C. Darrin PART l.-AGENCY RECORDS RELE ASED OR NOT LOCATED (See ther4cd bones /

No agency records subject to the request have been focated No additional agenc y records subject to the request have been located.

Requested records are avadable through another pubhc di;tribution program. See Comments section.

C are aheady available for pubhc inspection and copying at the Agency records subject to the request that are identified in Append.desi X

NRC Pubbe Document Room. 2120 L Street, N.W., Washington, DC, U

are being made available for public inspection and copying Agency records subject to the request that are identified in Appendides)

X at the NRC Pubhc Document Room,2120 L Street, N W., Washington, DC. in a folder under this FO! A number.

i The nonproprietary version of he proposalls) that yru agreed to accept in a telephone conversation mth a member of my staf f is now being made avadable t

for pubhc inspection and copying at the N RC Pubhc Document Room,2120 L Street, N.W., Washington, DC,in a folder undes this FOIA number Agency recurds subject to the request that are ictentified in AppendMest may be inspected and copied at the NRC Local Public Document Room identified in the Comments section.

E nclosed is information on how yod may obta:n access to and the charg% for copying records located at the NRC Public Document Room,2120 L Street, N W. Washington, DC.

Agency records subject to the request are enclosec'.

Records subject to the request have been referred to another f ederal aynty(ies) for review and direct response to you.

y Fees You wol be billed by the NRC for fees totaling $

You ml: receive a refund from the NRC in the amount of $ 415.03 In view of N RC's response to this request, no further action is being taken on appeal letter dated

, No PART II. A-INFORMATION WITHHELD FROM PUBLIC DISCLOSURE Certain information in the requested records is being withheld from public disclosure pursuant to the exemptions described in enn for the reasons stated in Part II, B, C. and D. Any released portions of the documents or which only part of the record is being withheld are being made available for pubhc d

X inspectica and copying in the NRC Public Document Room,2120 L Street, N.W., Washington, DC in a folder under this FOIA number, COMME NTS

• The records identified on enclosed Appendices C, D,

and E are the remaining records responsive to your request.

Copies of Appendix C,

D, and the releasable portions of the record on Appendix E are enclosed.

The actual fees for the processing of your request are noted below Clerical Search

- 7.5 bra. clerical cearch G $12.18 = $ 91. 35 Clerical Review 2 hrs. clerical review 0 $12.18 =

24.36 Professional Search -

5 hrs. prof. search 9 $29.10

=

145.50 Professional Review - 2.5 hrs, prof, review 0 $29.10

=

72.75

=

69.80 Duplication - 349 pgs. 0 $0.20 per pg.

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Total

$403.76 t-l This cqmoletes NRC'g_ action on va r reauest.

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SsGN UR E, DIR E C T OR, DIVISIC ' F F RE E DOY OF INF ORMATION AND PUBLICATIONS SE RVICES

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9306240118 930310 PDR FOIA

- DARRIN92-565 PDR!

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f o8A WMBER(si DAtt RESPONSE TO FREEDOM OF INFORMATION ACT (FOIA) REQUEST FOIA 565 MAR 101993' (CONTINUATION)

PART ll B-APPLICABLE EXEMPTIONS E

are being withheld in their entirety or in part under the f

Records subject to the request that are described in the enclosed Appendix (es)

Exernption No.(s) and for the reason (s) given below pursuant to 5 U.S.C. 552(b) and 10 CF R 9.17(a) of NRC regulations.

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1. The witnheid mformation is properly classif.ed pursuant to Executive O* der. IExernption 1) t 2 c. The withheld snformataon relates bole'y to the entemal personnel rules and mocedures of NRC { Exemption 2)

3. The withheld erfoimation is sDec>ficah enempted from public disclosure by statute ind6cated. (Exempt.on 3)

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Secteoris 141145 of the Atomic Energy Act, which prohibits the disclosure of Restnctec Data or Formerly Restneted Data (42 UIC. 21612165).

Section 147 of the Atomic Energy Act, which p ohibits the d6 closure of Unciasof,ed Safeguards Information (42 USC. 2167L r

4 The withheld information is a trade secet or commerc4st or Imancial mf ormation that is being withbeid f or the reasontsi indicated. (Exemption 4)

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The snformation is considered to be coni.dential busineits tpropnetaryl vrforrtsat.un The inf ormatron is considered to be propnetry intorniation pursi ant to 10 CF R 2 7904dlill The information was submitted and rNewed 'r1 conf ertenc e pursuant to 10 CF R 2 790 ldh 21

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(Evernption SL Apptecable Ptmtege-X 5 The withheid mformate consists of,eteragency or etiaarncy recoros that ce net a# irr woe ga onco.e, aug lei,gation Dehberadve Process Dislosure of vedecmonal mto manon would send ta irih4te een and tea % enhange of iocas essent.ai to the dehbe ative process Where records are withheid in their entset y, the lac ts are avint abi, ciert e med -

ih( peedecemon# udormanon There aise 1,re no reasonably sepegable f actuar X

porttons because the release of the f acts wou3d permit an mmrett mover, into _t.= aedecesionaf p'or ess_of the. agency Attorneg wwk prodott pnvdege iDm ument s prer.a+d t', e atmme, o r, onn.nc.s# r.f ht #tir.n

- Attorney client pnvHnge. (Conht at commumcations between an attorney and h:s'her clie.

The withheld m'ormat on is e=empted from pubac d sciove t etavse 4ts oeosse could resst m a cleviv unwarranted masiori of personal pen,acy. (Exemption 6) 6

- - - - - ~ - -. - ~

7. The withheld mtortnation consrsta v records compded f os laa enf orc emect purposes anti es t eeng *.thbeid for the reasonm end+ared (Enemption 7)

Desclosurs could rea>or' ably be enpected to eterfere with an enforcement proceedmg because it could reveal Ibe scope, direction, and focus of

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7 enforcement efforts. and thus could possibly allow bripients to take action to shee!d potential wrontyforng or a vsolation of NRC requirements

.from investigators. [ Exempt *on 7 ( A))

Disclosure would constetute an unearranted mvas.on of persona # prwacy. (Ememption 71CH i

T he info mation c ons sis v names of mdvdsr. and uhe mierwbnr rhe em hvm et ah,:hr wt >casonx>iv t.e c aoected to re= eat identmes nf confident ai sources (Exemption 7 (OH

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PART R C-DENYlNG OFFICIALS Pursuant to 10 Cf R 9 ? Fbi and er 0 25g! v the U S Nacka bgoWo'y Cmmon Wahom it h.n be n dele'mmed Ifiat t e efematron

• thhe'd a esernpr ham pro h

The nemm remo,s tde 4r the ceaw a e thow chc a.: centet.ed below as denyme duct +on or d@mwe, aN t* at its p odutw ar dociove $ contw w the pA c mtnest ef hcrals and the D.rettor. 0+s.on of Freede of tr'tormadon am Putmet om Se, m Off me of Ad%n+t, anon for any den 44 that may be appsed to the E necutive Dacctor b

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for Domavons iEDOI

,.-HICORDS DENIED APPELL ATE Of FICI AL.

j DINYING Of flCIAL T! T L E 'OF F ICf EDO T d RETARY iG i

i Thomas T. Martin

.i_R_e.gional A_dmi_ni strato. _r _RI 4J,R, E i X a

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PART 11. D-APPEAL FilGHTS Ay such appeal must be rnade in wrrtmg within 30 days of receipt r

The denial by each orny4ng omcial identifre1 ;n Pa*t it.C may be appeated to the Appellate Officist identified the e Appeals must be andrelied, as appropriate, to the f secuinre Director lof Operations, to the Sechttary of the Comm:ssion, or to the inspector General,(LS Regotatory Commasion, Washmston, DC 20555, and should clearly stsie on the erivelope and in the letter that it es an " Appeal from an tmtta! FOI A Dec Of this responSS.

U.S. NUCLEAR REGULATORY COMMISSION (

. OlRC FORM 464 (Part 2) (191)

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APPENDIX C i

DOCUMENTS MAINTAINED AT THE PDR HUMBER DATE DESCRIPTION 1.

8/81 USNRC Regulatory Guide, 8.28,

" Audible Alarm Dosimeters," Acc. No. 8110050032, (5 pgs.).

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FOIA-92-565 i

APPENDIX D i

RECORDS MAINTAINED IN THE PDR UNDER THE ABOVE REQUEST NUMBER HUMBER DATE DESCRIPTION i

1.

6/30/92 Memo for Those on Attached List from D.

'I A.

Cool, subject:

" Health Physics Position on the Use of Electronic Dosimeters to Measure Dose of Record,"

(3 pgs.).

2.

Undated Note to Roger P.,

unsigned, re:

DAD's, (2 pgs.).

3.

Undated Paper re:

Electronic Dosimetry

Problems, (3.pgs.).

4.

Undated Paper re:

Summary of Public Comments on Draft Regulatory Guide, " Audible Alarm Dosimeters," (7 pgs.).

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Re:

FOIA-92-565 APPENDIX E DOCUMENTS DEING RELEASED IN PART i

i itUMBER DATE DESCRIPTION 1,

7/28/92 Memo for Cunningham from Cooper, subject:

" Health-Physics Position on the Use of Electronic Dosimeters to Measure Dose of Record," (2 pgs.) -

EXEMPTION 5.

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WASHINGTON. D.C. 20665

• g JUN 3 01992 MEMORANDUM FOR:

Those on Attached List FROM:

Donald A. Cool, Chief Radiation Protection and Health Effects Branch Division of Regulatory Applications Office of Nuclear Regulatory Research

SUBJECT:

HEALTH PHYSICS POSITION ON THE USE OF ELECTRONIC 00SIMETERS TO MEASURE DOSE OF RECORD In a letter from Siemens Gammasonics, dated May 28, 1992, the Associate Director of Health Physics Services, expressed concern that the Siemens Electronic Personal Dosimeter (EPDS) would not be acceptable to NRC for use by licensees. This concern seems to stem from the requirement that only NVLAP accredited processors process TLD's and Film.

10 CFR Part 20.202(c) states that:

"All personnel dosimeters (except for direct and indirect reading pocket ionization chambers and those dosimeters used to measure the dose to hands and forearms, feet and ankles) that require processing to determine the radiation dose and that are utilized by' licensees to comply with ' paragraph (a) of this section, with other applicable provisions of 10 CFR Chapter 1, or with conditions specified in a -

licensee's license must be processed and evaluated by a' dosimetry processor:

(1) Holding current personnel dosimetry accreditation from the National Voluntary Laboratory Accreditation Program (NVLAP) of the National

'i Institute of Standards and Technology, and (2) Approved in this accreditation process for the type of radiation or radiations included in the NVLAP program that most closely approximate the type of radiation or radiations for which the individual wearing the dosimeter is monitored."

For the revised 10 CFR Part 20, i 20.1502 contains similar language. The rule clearly states that "all personnel dosimeters...that require processing...be processed" by a NVLAP processor. Since the EPDS requires no processing, it does not require a NVLAP processor.

So the issue is not whether the EPDS can be used, but rather, is the EPDS an appropriate substitute for TLD or film. The staff believes that an electronic dosimeter, which has proven itself reliable in field use trials (as the Siemc.ns electronic dosimeter appears to have done) and is on a par with current i

dosimetry used for permanent records in terms of precision, accuracy and j

reliability, would be an acceptable alternative to TLD or film.

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Addressees Memorandum dated:

James H. Joyner, Chief Facilities Radiological Safety & Safeguards Branch Division of Radiation Safety and Safeguards Region I r

Ronald R. Bellamy, Chief Nuclear Materials Safety Branch Division of Radiation Safety and Safeguards Region I William E. Cline, Chief Radiological Protection & Emergency Preparedness Branch Division of Radiation Safety and Safeguards Region II Douglas M. Collins, Chief Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards Region II L. Robert Greger, Chief Emergency Preparedness & Radiological Protection Branch Division of Radiation Safety and Safeguards Region III John A..Grobe, Chief Nuclear Material Safety & Safeguards Branch i

Division of Radiation Safety and Safeguards Region III William L. Fisher, Chief Nuclear Materials Licensing Section Division of Radiation Safety and Safeguards Region IV 1

Charles L. Cain, Chief Nuclear Materials Inspection Section Division of Radiation Safety and Safeguards Region IV t

Gregory Yuhas, Chief Emergency Preparedness & Radiological Protection Bran:h Division of Radiation Safety & Safeguards Region V i

Robert J. Pate, Chief Nuclear. Materials Safety & Safeguards Branch Division of Radiation Safety & Safeguards Region V

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I hope you issue the IN for problems relating to the use of DAD's.

I believe it's overdue and will help licensee's.

The follewing are problems I have observed or heard of during the use of DADS.

Many of these problems occurred because some think DADS are the total answer to dose /?xposure control.

Design Problems Some designs don't provide good, easy to read, data. Somatimes ALARMS are not l

loud enough.

Some ALARMS are similar in sound - Dose Rate vs. Occu. Dose.

i liard to tell which data is in the window, Dose Rate vs. Occ. Dose.

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Exposure Control Problems Workers sent into area without a dose rate meter (with DAD) and are not l

knowledgeable of dose rates in the area (TS vio).

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HP doesn't always record individuals ALARA, setpoints (no record).

(results inconsistent alarm set points).

HP does not alwa>I use dose rate alarm setpoint in an ALARA manner. Dose rate set too high.

Sometimes only I crew member wears DAD and all workers in that crew are in a dose intense area - 1 DAD not always representative of crew dose rate.

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2 Worker's less attentive of ambient dose, rely totally on DAD.

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Training Problems Workers don't always know which alarm is sounding, workers don't always respond as required when DAD alams.

Licensee instruction on DADS both GET and job site is poor.

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i ELECTRONIC DDSIMETRY FROBLEM9 Region III licepsses have owperienced soveral problems with electronic dosimitors.

Included in those problema han been.an inability to-hea the alarms, inadequate training on the use of the donimeters a,d human factors problems with the design and use of the dosimeters, including: difficulties in reading accumulated dome values, mas,k i n g of dose alarms by dose rate alarms, and inattentivenous and poor Job coverage by technicians.

There appears to be an over. reliance on the dosimeters and their-alarm functions to controb' work activities and does to workers.

The following list describes spacific problems found at hegion III facilities.

DUANE ARNOLD Mpreb, 19??. (fR 331/92007)

The licensen did not p ovide adequate training on electronic donimotors.

i n that alarms for dono and done rate were not-d,emonstrated to workors and the policy for responen to alarms was not clearly doncribod.

Tbchnicians relied on workers'to-exit their work ahea on a high done alarm and did not. control tho' I

J b based on an allowable job,dpse limit.

Dous.

a arms were basically masked by dosn rato al arms apd the accumul ato dama road out wan hard to read apcurately because of the design.

These probinma with the electronic' dosimatne along with an ipadequata survey led to a substantial potential for an overexposure.

i DREGDEN Chtobor, 1991.

(NOV and Proposed Imposition. of C[vil

Penalty, IR 249/91033)

Rolying on electronic dosimninen to signal problema may have contributed to complacency in technician coverago of recirc system dirscharge valve ISI work.

Workorn were instructed to work through dous rate alarms which was contrary to station policy.

Tho dpnimetry was located in the wrong place which led tb significant administrativo overaxposures, i

LASALLE

Jpnuary, 1992.

(Enf.

Conf.

Roport 374/92004)

Discussed additional administrative overexponures which occurred an a result of workorn being unable to hear dosimotse alarms while hanging uhielding in the drywell.

December, 1991.

(IR 374/91029)

Inadequate training on the responen to ED alarms and what the alarma indicated contributed to an administrative oyoraxposure while a worker was cleaning a fuel I

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A worker heard 'his ED alarming; however, he continued to perform.his dhties inutnad of notifying RP.

He wont no f ar au-t'a relocate his dosimoter to an arum ho thought bhdahigher domo rate which was obviously a poor rpsponse to the alarm.

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Oftober, 1991.

(IR 373/91022)

Dua to high.

a bient noian levels, worksrs could not' hear ED a arms while thuy were cleaning sludge in a

redwaste tank room resulting in administrative okereuposureu (50 per cent more doso than allowed).

T1e EDu were baggod and the wor kers could not rwad the accumulatud dann valups' but decided to koop wprking becaune they did not haar any alarms.

Technicians saw the workers look at the dosimatarc ahd.ausumed that they knew what their dose was and that everything was ok.

• li on April, 1992 (No report yet)

A worker incorrectly placed his ED inside his plastic PCs.

Technicians relied-on the ED to provi de indications-of pr obl ems.

Thu worker was supposud to be' in tho wpek area'for only 10 minutos'but~ remained.for i hour plus.

The ED's accumulated done alarm could nht be heard'by the worker and was not' discovered uptil he exited the area and undrussed, resu2 ting in an administrativo overexposure.

l The problems listad above are the more recent ones.

.Thore havo been other probi lms over the years that could be easily dug up.

An informal po1 3 of Region III liennsens revealed that training on the use of efectrcnic-dosimeters varied from none at all to actually demonstrating the alarms and the proper response to them.

Two distinct policies on roepenno' to alarms was also Somejlicenseen allow work to continue through high rovenled.,

- dose rate alarmsi while othurn. expect workers to exit the area on ahighdonoratel alarm.

A11 licenunca expected workers to exit.

on a high dosn al arm.

However,-the dosa-alarm can be mankod by the dose rato al arm on both A1nor and Merlin Gerin EDs.

We feel it in important to emphasize the need;for proper instructions on i

the liconece's pglicy for response to the alarms and-that there should be a demonstration of the al' arms.

This is especially important when t

comes to contract worker * ~ who travel -from m

outage t~o outagie because different dowimators with different.

sounding alarma-ars used : and policies dif f er f rom place to place.

It is clear' thai problems ' associated with EDs will continue to occur without those issues being addressed.

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eeu g pl-T There in at uo ani inconsistency in reactor toch specs which may be contributing to these problems.

This tech spec is the ono that allows high radiation area access as'long as one or mora of the following aru provided:

a.

A radiation monitoring device which cantinuously. indicates the radiatibn done_,r_aig in the area.

I b.

A radiation! monitoring device which continuously integratas the radiation dome rate in the arua and. alarms when a procot integratedpusgis received.

Entry into such areas with' this monitoring device may be mado aftnr the daue rate l evel has been entt311ched and pornonnel have been made knowledgeab:.s of sham.

c.

.A health phyuice qualified individual ( i. e.,, qualifind in I

radiation ~ photection proceduros) with a radiation dose rate monitoring devico who is responsible for.providing positiva control over the activitten within the area and shall perform periodic radiation surveill anew.

i Note that the control measures provided in (a) - and (c) above are based on demo rhte and require a done ratn meter.

Thu control mnasure describeci in (b) is based on an ' alarm for. accumulated dose.

Thero in'no-requirement to -have a done-rato motor in tha.

work area co, iniecuence, the ED in taking the. place of a.

docey rate motor.

However, the control moauuro is baned on.an alarm for doue, not d6sc rate.

It in recognized that dono rates are supposed to bn ostablished prior to entr.y, but this does'not hulp-you if dose rates change while the worker is in the area or if an adequate survey is not performed in the area.

Many liconseen.

have the policy' to allow work to continue through dose rate alarms.

Au sta$ed above, dous rate alarms can mask dous alarms.

In this case, control measure (b) in useless.

If the desu rate hle alarm was used as the basis J or - control, then this control measure would consistent with (a) and (c)'

and' potential q

problems. associ&ted with not recogni::ing accumulated dose alarms i

could bu avoidedl l

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Ubf SLHiARY OF PUBLIC COMMENTS ON ORAFT REGULATORY GUIDE OH-804-4 k.

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" AUDIBLE ALARM 00SIMETER5" "p[;?;

Sixteen public coments were received.

A IIst of commenters is given at

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tha end of this summary.

The most important issue was whether the guide should hans been more or less favorable about the use of audible alarm dosimeters.

Some commenters thought the cfosimeters were more reliable and useful than stated in t$e guide (1, 3, 11, 12, 15).* Other commenters saw the dosimeters as being of little value, unreliable, costly, or even dangerous (2, 6, 7, 9).

On reconsideration the guide has been revised to be more favorable to the use of audible alarm dosimeters.

It has been concluded that audible alarm dosimeters are both more reliable and mcre 'aseful than assumed in the draft guide, )ut there is to intent to make alarm dosimeters mandatory in any situa-tion.

1he issues are discussed in more detail below.

1.

Relfibility Two commenters stated that audible alarm dosimeters were much more rell-able than the guide stated (1, 11).

Two other commenters said that the dosim-eters were anreliaule (6, 7).

Tech / Ops (1) said their dosimeters (Prima iia) experienced a failure rate of 7% over two years and that the devices had recently been improved by better bonding of the transducer to the case to prevent mechanical failure.

These

" Numbers in parentheses refer to the commenters listed at the end of this sumary of corcents.

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statements are not inconsistent with the test results for this model reported i

9 in HURE0/CR-0554,* Those test results showed the Prima iia having low j.f -

resistance to accidental change of the on-off switch and failing the water l

Iy innersion and salt water. corrosion-resistance tests (as did all other models.

h tested.) The Prima lla performed well on mechanical shock tests, and battery Iffe was pod, Xetex (11) claimed that audible alarm dosimeters were reliable and faulted the NUREG/CR-0554 report for its unfavorable conclusions, five Xetex models were tested for that report.

Four of 25 uaits had weak mounting clips, one of 25 failed a temperature shock test (declining temperature), all failed a water fomersion test and a salt water corrosion resistance test.

The units survived 4

mechanical shock tests fairly well, had adequate battery life, and measured radiation dose quite accurately.

In reviewing NUREG/CR 0554 and NUREG/CR-1452," it appears that the test results do not fully suDstantiate the conclusion made that "the dosimeters tested are not capable of surviving repeated severe punishment such as that which might be encountered in a harsh industrial or outdoor environment." Many units failed the mounting clip strength test and the test of the on-off switch for resistance to accidental change.

Only 5 models uniformly passed these tests (Xetex Accuchirp 416A, Reactor Experiments Dig 10ose, Technical Associates POR 10, Xetex 409A1, and Dosimeter Corporation RAW-II).

The Eberline Rad Tad would have passed completely except that the switch on a singic unit could be changed.

Likewise the Xetex 412A and Xetex 415A failed only because of a singic clip strength failure.

' Oscar R. FiuThern, W. T. Bartlett, and C. O. Hooker, " Pocket-Sized Electronic Dosimeter Testing." NUREG/CR-055; January 1979.

• • Robert A. Fox, C. D. Hooker, and B. i. Hogan, "further Testing of Pocket-Q Sized Electronic Doslecters," NUREG/CR-1452, April 1980.

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in rapidly falling or rising temperatures, except for an occasional failure.

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No units of any model continued operating af ter being immersed in water

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for 1 minute. All models seemed to suffer serious corrosion af ter immersion p

in salt water. All units operated at high humidity and high or low temperature, X<.

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These tests were done in response to comments that audible alarm y

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dosimeters had failed under these circumstances.

Indeed they would.

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a more reasonable response than discouraging the use of the dosimeters every-where would be to only discourage their use where water or salt are problems, for example, working in heavy rain, swamps, or where ocean spray is present.

Several of the models were fairly successful in mechanical shock tests (Eberline Rad Tad, Atomic Products Corp Prima Ila, Oosimeter Corporation RAW-1, RAW-11, and DAD-1885, Nuclear Associates Prima II, Victoreen VIP 885, Xetex

C 412A and 4J5A, and Technical Associates POR 18).

Others did not perfcrm as well (Technical Associato FH-1, ICN PPai 2, Reactor Experiments Digiuose, xetex 406A-1 and 409A-1 and Nuclear Enterprises Model 95/0023).

(There were insuffici-ent data for judgment about some others (Xetex Accuchirp 416A).

The criteria were that at least 2 units had to be tested and that no more than one could faie af ter both a 4 foot drop and a 5 foot drop.) This would seem to indicate that many models are adequately protected from mechanical shock.

Battery life also seemed generally adequate.

All units exceeded 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> at 2.5 mR/hr. All units except the Dosimeter Corporation RAW-I and Reactor Experiment DigiDose exceeded 250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br /> of operation at 2.5 mR/hr.

The radiological properties on the models with recdout also seemed ade-quate in all cases (accuracy for a dose of 10 mR Cs-137, energy response, accuracy at high dose rates of 1.5 to 15 R/hr, and no failure to alarm at 500 R/hr).

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dosimeters are adequately reliable for many uses as long as the limitations of

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the devices are respected.

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In reviewing the comments on the reliability of audible alarm dosimeters i

in Attachment 1 to the value/ impact statement some commenters noted that some of 5

g-the observations were very old (#1, 4) and some dealt with inappropriate use of 9

Qc the dosimeters (#8 and perhaps #2).

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Thus, the conclusion is that some audible alarm dosimeters have adequate h:,

reliability when properly used.

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Usefulness The value/ impact statement to the draft guide estimated that the reduction In dose that could result from the use of audible alarm dosimeters would be

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minimal.

Although some commenters agreed (2, 6, 7, 9), other :ommenters of fered persuasive evidence that audible alarm dosimeters had been very us'ful.

Particularly e

persuasive was a description of how audible alarm dosimeters were used to reduce exposure at the Mayo Clinic (12).

The dosimeters were very useful for training people where to stand around equipment to minimize dose, A more complete descrip-tion may be found in a published article (Joel E. Gray, " Radiation Awareness uno Exposure Reduction with Audible Monitors," American Journal of Roentgenology, 133, 1200, December 1979).

A similar statement was received about exposure at a university (15)'.

Xetex (11) claimed that in many pcwer plant situations, a small change in location can often save dose while still accomplishing the job; dosimeters provide the feedback necessary for the worker to do that.

Those quastioning the usefu!r.ess of audible alarm dosimeters sometimes cited their expense and lack of reliability (7) and sometimes claimed'that they _

O vouid repiace the inherenti, more userui survey meter (2, 6).

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the likelihood of audible alarm dosimeters reducing use of survey meters or Z

asked for documentation (1).

Support for this claim of substitution can be i

found in an August 16, 1976 from John Weller, Offshore Power Systems to Robert.

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Alexander, NRC.

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l "During three years of service as a field health physicist in a regulatory program evaluating radiography licenses, I personally discovered or observed under field conditions at least fif teen cases

. where the audible dosimeter was being suostituted for the survey instruments. During the last eight years as a consultant and manager in the commercial industrial radiography field, I have been intimately involved in the training and control of personnel relative to radio-logical safety.

My observations and experience in this realm as a health physicist has been to prohibit use of audible dosimeters based on high exposures and vy one over exposure caused by dependence on audible dosimeters in lieu of the survey instrument."

i Westinghouse said that audible alarm dosimeters would be ineffective for their fuel fabrication operation because of high noise making the alarm l

inaudible, generally low dose rates, and adequate coverage of the facility by a fixed area monitor (9).

Under such circumstances there is little doubt that audible allrm dosimeters would have little usefulness, and the guide did not recommend their use in such situations.

Audible alarm dosimeters are not particularly useful where dose rates are fairly low, fairly constant and predictable, and where an area nonitoring system is in use.

3.

Performance Specifications too Detailed for Guide The performance specifications in the guide were taken from a draft AtiSI standard.

Some people objected to that much detail in a guide (2, 3, 6, 8, 14,16).

Since the standard has now been published, the standard can now be reference'$ instead.

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Hiscellaneous comments

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Wearer should not be allowed to adjus the sound level (3).

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This would seem to be too restrf'tive considering the problems

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with inappropriate sound levels.

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b.

Supervisor should check operability of t,he dosimeter b.]ch day (3).

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This suggestion would be too restr ictive for some cscs.

For example, field radiographers often operate with nc supervisor presen't for extended periods of time.

c.

Use of fountain pen style clips should je discouraged (3).

The gripping power of the clip is insufficient; it should hol at least 2000 gm (6).

Response

The staf f prefers to use the cri[.eria in the ANSI standard; the criteria do not allow " fountain-pen style" glips.

d.

Exposure integrating dosirneters may be prevented f rom alarming in high exposure rate fleids as a result of high' detector current drawing down the supply voltage especially when the batteries are not fresh (5).

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The testing performed by Battelle fouk that all commercially

Response

available alarm dosimeters continue to alarm without faii.src at dose rates of 500 R/hr.

The ANSI standard requires alarms to operate in fields up to 1,000 times the highest alarm setpoint.

By checking with tre commenter (5),

Battelle found that the alarm dosimeters that failed to alarrn at high dose

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ratosweeacustommadeforthecommenteraccordingtohisspedifications.

It is clear that custom build devices that do not meet the specift 1tions in the ANSI standard may not be adequate.

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In C.4a, "high noise envIrore.cnt" should be defined (10).

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Response:. The casicst and most effective way to tell if the do',imeter is M$

loud enough is to IIsten to its sound in the area where it will be used.

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jk' ments of dB levels are much 1 css convenient and probably not as meaningful.

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Each Individual user must make the judgment on whether the sound level is loud 15

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enough (or sof t enough).

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f.

In C.7, "similar jobs" should be defined (10).

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Response; The paragraph was doloted because all dosimeters sold chirp at some dese increment such as 1 mR.

g.

In C.7, when can dosimeters that alarm only when a preset exposure j

has been reached be used (10)?

Response

Jobs such as reactor maintenance to Indicate that some admin-istrative Jose Ilmit has been reached.

h.

A question was raised on the appropriateness of the referenced nocicar

's power plant Standard Technical Specification 6.12.1 on use of audibic alarm dosimeters in high radiation areas (14).

Response

The Technical Specification was not given in its entirety, causing 4

some distortion in meaning.

This has been corrected by stating the Technical Spect fIcation more completely.

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November 18,1992 FREEDOM OF INFORMATION Mr. Donnie H. Grimsley ACT REW Director US Nuclear Regulatory Commission p._p _gg Washington, DC 20555

Dear Mr. Grimsley:

Rados Technology, Inc. requests, under the Freedom of Information Act, any notices, bulletins, or other documents regarding the use of electronic dosimeters for personnel dose monitoring.

More sr ecifically, we would like such documents that relate to the following manufacturers products:

Alnor Dositec Dosimeter Corporation of America Eberline Merlin-Gerin SAIC Thank you for your attention to this matter.

Sincerely, t

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. g$ (s!u..m John C. Darrin '..

I President

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. hd %ggiL'S Jvsss ys by Rados Technology. Inc, Telcphone 6460 [obbin Road (410) 740 1440 Columbia, MD 21045 Telefan (410' '40 4676

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