ML20148G080

Requests Variance to 10CFR20 Regulation Re Processing of Radiation Monitoring Dosimeters by Accredited Personnel to Allow Continued Use of in-house Thermoluminescent Dosimeter Program

ML20148G080
Person / Time
Site:	07000920
Issue date:	02/22/1988
From:	Ryan R RENSSELAER POLYTECHNIC INSTITUTE, TROY, NY
To:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
29084, NUDOCS 8803290031
Download: ML20148G080 (3)

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Under the above referenced license the Rensselaer Polytechnic Institute is obligated to abide by the regulations set forth in 10CFR20.

The recent rule change requiring that whenever raiiation monitoring dosimeters are provided to personnel in order to meet the requirements, licensees must have the dosimeters processed by personnel who have been accredited under the National

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Voluntary Laboratory Accreditation Program operated by the National Bareau of Standards.

Rensselaer Polytechnic Institute would like a variance to this requirement and continue to use our in-house TLD dosimetry program.

Investigation of the cost of NVLAP accreditation is in the order of $15,000 which equals the approximate 5-year cost of our in-house program.

Also, the total man-rems estimated on a yearly basis for those persons operating under all above referenced licenses is less than 0.5 man rem per year.

Rensselaer Polytechnic Institute has utilized a computerized TLD program for more than 10 years. A change was nade f rom the vendor supplied service at that time because of

1) Erroneous reporting of neutron exposures,

2) tardiness of badge return f rom the vendor to RPI,

3) and lack of day-to-day operational knowledge of Rensselaer's radiation program that is useful in interpreting reported exposures.

Rensselaer's TLD program utilizes a 4 element TLD badge that can mesure beta exposure under a thin mylar window, a deep dose under a 1 graa/cm2 absorber area, and neutron exposure using the differential of TLD 600 and 700 readings.

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R.M. Ryan February 23, 1988 Page 2 The badges are quality controlled, as are the readouts.

Logbooks are used to record all TLD readings prior to entry into the computer.

The calibration sources used in our program are NBS traceable.

In any case, the NVLAP certificate (which has the "Voluntary" designation) does not appear to be cost effective, nor does it appear that it will result in any reduction of radiation exposures to Rensselaer faculty, staff, or students.

We therefore request a variance to this regulation as it appears in 10CFR20, responsive to our in-house program.

Sincerely,

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R.M. Ryan, Director Office of Radiation & Nuclear Safety RMR/es

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