ML20209E534
| ML20209E534 | |
| Person / Time | |
|---|---|
| Issue date: | 06/12/1985 |
| From: | Minogue R NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20209A892 | List:
|
| References | |
| FRN-49FR1205, RULE-PR-20 AA39-2-032, AA39-2-32, NUDOCS 8506260456 | |
| Download: ML20209E534 (5) | |
Text
Distributirm?
DRPES NK PD ORPB RD/SUH7 PHinoque DIbss g,
KGoller m onti JUN 121985 mlexander j Etiellis.s(=
millespie MEMORANDUM FOR: William J. Dircks Executive Director for Operations FROM:
Robert B. Minogue, Director Office of Nuclear Regulatory Research
SUBJECT:
CONTROL OF NRC RULEMAKING: RES REVIEW OF ONG0ING RES SPONSORED RULEMAKING, " IMPROVED PERSONNEL DOSIMETRY PROCESSING -- 10 CFR PART 20" Based on our review of ongoing RES sponsored rulemaking, " Improved Personnel Dosimetry Processing -- 10 CFR Part 20," RES recommends that the NRC should proceed with this rulemaking. This recommendation, in draft form, has been coordinated with the user offices (NMSS, NRR, SP and IE).
The basis for our recomendations is as follows:
Accreditation and standardization are needed because most dosimetry processors are known to have difficulty in the measurement of radiation doses in the occupational range.
~
Inaccuracies in personnel dosimetry processing could lead to overexposures, including the embryo / fetus in the case of pregnant radiation workers.
A recent (1984) personnel dosimetry intercomparison study at ORNL showed that only slightly more than half of all dosimeters tested met the guidelines for accuracy, and further, some of the reported results differed from the reference value by more than a factor of 20.
The intercomparison study just cited reported that the 1984 results are i
even less accurate than those of a similar ORNL study reported in 1982.
Many of the discrepancies and differences occurring in dosimetry processing studies are the result of non-standard procedures such as in the choice and use of calibration sources, exposure phantoms, exposure geometries, and dosimetry readout procedures.
The Interagency Policy Committee on Personnel Dosimetry Processing, which consists of seven Federal agencies and the Conference of Radiation 3
0FC:
NAME:
N 1
DATE:
Q l
.O
~
9@
1
T 9
9 JUN 121985 1 : Control Program Directors (representing the States), have endorsed the program and plan to reconnend its adoption by their agencies.
Accreditation of dosimetry processors will improve the public perception of dosimetry services and will lead to increased credibility of dosimetry records in lawsuits involving radiation exposure.
Of the comments received on the proposed rule 70% were in favor 21% were against, and 9% were uncommitted.
An accreditation program, requested by and initiated with funds provided by the NRC is now being conducted by NBS, using ANSI N13.11 as the performance standard.
In addition, interagency cooperation and coordination has been solicited throughout the development of the rule f rom the Interagency Policy Connittee on Personnel Dosimetry (IPCPD).
The complete RES review package has been sent to OEDO (Attention: DEDROGR)and to the directors of NMSS, NRR, SP and IE.
Orisinal signed W4 usammMDBM Robert B. Minogue, Director Office of Nuclear Regulatory Research ct 6/6/85
- See previous concurrence, m
0FC: RES:0RPB
- R S B : RES;
- CHMN
- RE
- F 0
)
nogue NAME: DNellis*
- Rdo nder*: KGo11er*
- FGillespie*: DR
%------------------------------------'----------f/85 DATE: 3/27/85
- 3/17/,85/
6/l
- 3/28/85
- 5/23/85
- 6/
/85 h ra r
t) U t /1/91 yo
/
u "j '
/
,Qi W
OFFICE REVIEW PACKAGE ENCLOSURE ITEM A
Federal Register Notice B
Draft Regulatory Analysis C
Draft Res Recommendations D
Regulatory Agenda Entry E
Assessment of Compliance with Rulemaking Pr-ocedures and Guidance F
Initial Regulatory Flexibility Analysis G
User Office Memoranda
- *=
e
, den 6 m
_L n
1 Draft RES Recommendations to EDO Concerning Ongoing Rulemaking for Improved Personnel Dosimetry Processing Past studies of dosimetry processor perfomance, discussed in the proposed rule and draft regulatory analysis, showed that the need exists for a comon performance standard for both film and thermoluminescent dosimetry processors.
In a series of tests of dosimetry processors undertaken between 1978 and 1982, improvements in the passing scores increased dramatically as a result of using standard sources and procedures. The passing scores on three tests' conducted during thi.s period were 48s, 62% and 75% of all dosimeters tested.
RES recommends that efforts continue with this' rulemaking to require certification of dosimetry pr.ocessors for the following reasons:
Certification or standardization is needed because most dosimetry processors have difficulty in the measurement of gamma doses of less than 20 mr and neutron doses of less than 50 mr, a problem that is intensified by the presence of mixed radiations.
Inaccuracies in persofinel dosimetry processing could result in overexposures, particularly to the fetus in the case of pregnant radiation workers.
A recent (1984) personnel dosimetry intercomparison study at ORNL showed that only slightly more than half of all dosimeters tested met the regulatory guidelines for accuracy, and further, some of the reported results differed from the reference value by more than a factor of 20.
The intercomparison study just cited reported that the 1984 results are even less accurate than those of a similar study reported in 1982.
Many of the discrepancies and differences occuring in dosimetry processing studies are the result of non-standard procedures in choice of calibration sources, exposure phantoms, exposure geometries, and dosimetry recdout procedures.
The' Interagency Policy C~ mmitt'ee on Personnel' Dosimetry Processing, which o
consists of seven Federal agencies and the Conference of Radiation Control Program Directors (representing the States), have endorsed the l
program and plan to recommend its adoption by their agencies.
ENCLOSURE C
-~..-.
i'
..A t
e s
Accreditation of dosimetry processors will improve the public perception of dosimetry services and will lead to increased credibility of dosimetry records in lawsuits involving radiation exposure.
Of the comments received on the proposed rule 70% were in favor 21% were against and 9% were uncommitted.
Tl ? proposed rule was published for comment in January 1984, and 96 comment letters were received, the majority of which were in favor of the rule.
RES recommends that the analysis of comments be completed without delay and that work on the final rule begin promptly thereafter.
.s.
I l
i I
l i
ENCLOSURE C yr--
yv-,
y--
-emm9-ye---m#r 9+g-+-6m---
---w
+--v 3-r------
,i.
-q=+--- - ---.---- - -, -, -,
-v
., = - - - -
-,t