ML20205Q873
| ML20205Q873 | |
| Person / Time | |
|---|---|
| Site: | 07000920 |
| Issue date: | 10/10/1988 |
| From: | Ryan R RENSSELAER POLYTECHNIC INSTITUTE, TROY, NY |
| To: | Pennington W NRC |
| References | |
| 24843, NUDOCS 8811090385 | |
| Download: ML20205Q873 (2) | |
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Mr. W. Scott Pennington Uranium Fuel Seetion qf4%
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Ref:
70 920 SNM 910 Gentlemen.
The purpose of this letter is to withdraw Rensselaer Polytochnic Institute's request for a variance to section 20-202 of 100FR20 (c) requiring that personnel dosimetry be processed and evaluated by a dosimetry processor holding a current NVLAP accreditation. The petition was forwarded to the USNRC on February 22,1988 (attachment 1) and responded to on June 24, 1988 (attachment 2).
The reason for this withdmwal is that it appears unnecessaiy to requent a variance !!:
(1) An individual 18 years of age or older entering a restricted area does not receive nor is hkely to receive a whole body radation dose equivalent in excess of 312 SmRems per calendar quarter or 1250mRems per year.
(2) An indsidual under 18 years and entenng a restricted area does not receive nor is hkely to receive whole body radiation does equivalence in eacess of 62.5mRems per calendar quarter or 250mRems per year.
However Rensselaer Pot)1echnic Institute wi:1 continue to provide personnel monitoring, as desenbod in Attachment 1, for Faculty. Statt, and Students.
I rio hope the Misdom* of the USNRC does allow for variances tri the future where there appears to be no cost effectiveness or where there appears to be ()Q reduction in radiation exposure to persons.
Sincerely.
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Robert M. Ryan. Dinx:tu Of fice of Radation and Nuclear Safety RMR'c0
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R.M. Ryan, Diredor OR&NS 10/10/88 I
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February 22. 1988 U.S. Nuclear Regulatory Commission Uranium Tuel Licensing Branch Division of Fuel Cycle and Nuclear Safety Washington, D.C.
20555 Refereneet SHi-910 Centlement 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 radiation nonitoring 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 Voluntary Laboratory Accreditation Program operated by the National Bureau of Standards.
Rensselaer Polytechnic Institute would Itke a variance to this requirement and continue to use our in-house TLD dosinetry 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-rens estimated on a yearly basis for those persons operating under all above referenced licenses is less than 0.5 man rem per yea r.
Rensselaer Polytechnic Institute has utilized a computerized TLD program for more than 10 years.
A change was made frnn the vendor supp1ted service at that time because of 1)
Erroneous reporting of ne u t r o n exp m res.
- 2) t a rdines s of hidge-return fro, the vendor to RPI.
3) and lack of d.ny-to-day operational knowledge of Rensselaer's radiation program that is useful in interpreting reported exposures.
R3nsselaer's TLD program utilizes a 4 ele ent TLD badge that can resure beta exposure under a thin nylar window.
deep dose under a L gram /cm2 absorber 4
and neutron exposure using the dif ferential of TLD 600 and 700 readings.
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R.H. Ryan February 23, 1988 Page 2 l
The badges are quality controlled, na are the readouts.
Logbooks are used to t
record all TLD readings prior to ent ry into the computer.
t The calibration sources used in our program are NBS trac 3able.
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in any case, the NVLAP certificate (which has the "Voluntary" designation) l does not appear to be cost effectice, nor does it appear that it will result in any reduction of radiation exposures to Rensselaer faculty, staff, or j
students.
k'e therefore request a variance to this regulation as it appears in 10CTR20, l
responsive to our in-house program.
i Sincerely.
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R.M. Ryan, irector Of fice of Radiation & Nuclear Saf ety I
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R.M. Ryan, Director OR&NS 10/10/88 I
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION r.
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Rensselaer Polytechnic Institute ATTN: Mr. Robert M. Ryan. Director Office of Radiation and Nuclear Safety l
Troy. New York 12181 l
s Gentlemen:
l We have completed the initial review of your application dated February 22, 1988, and find that additional information is needed to complete our evaluation.
You are requested to pmvide the basis for the proposed exemption from the provisient cf 10 CFR 20.202(c).
If it is determined, howehr. that all monitored individuals fall outside the population defined by 10 CFR 20.202(a), no such i
exemption is required or necessary.
If monitoring is not required to satisfy 10 CFR 20,202(a), the license application should be revised accordingly.
Please sub it the information as a supplement to your application within 60 days of this request.
If I can be of assistance please call me nt (301) 492-0693.
Sincerely.
%K.h8 b&
k W. Scott Pennington Uranium Fuel Section Fuel Cycle Safety Branch Ditision of Industrial and i
Medical Nuclear Safety. WSS j
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