Blind Spiking of Personnel Dosimeters and the Inspection Program
See the memorandum from J. E. Wigginton to L. R. Greger dated June 27, 1989.
Blind spiking of personnel dosimeter has never been included explicitly in an inspection procedure for reactors. However, there may be reason to cover this topic on a case-by-case basis. Under the NVLAP program and the ANI / MAELU inspection of personnel dosimeters, nuclear power plants are expected to do blind spiking. The health physics position was written in the context of 10 CFR 20.202, but it also applies to "new" 10 CFR 20.1501.
It was asked whether, considering that 10 CFR 20.202 (c) [or 10 CFR 20.1501 (c)] requires NVLAP accreditation for personnel dosimeters, inspectors should continue to inspect for blind spiking of personnel dosimeters by nuclear power reactor licensees. The answer is that given the coverage of personnel dosimetry QA / QC in the NVLAP program and in the ANI / MAELU inspections, there is no need for all NRC inspections of personnel dosimetry to cover blind spiking of dosimeters. However, there may be reasons to cover this topic on a case-by-case basis. The answer is based in part on the following information.
Blind spiking of personnel dosimeters has never been included explicitly in an inspection procedure for power reactors; however, such spiking falls within the more general item of "quality assurance for dosimeter processing" (Inspection Procedure 83524, Section 3.03 a) and "quality assurance of personal dosimetry measurements" (Core Inspection Procedure No. 83750, Section 3.05 a.7). Apparently inspectors in Region III, and possibly other regions, have looked to see if licensees are spiking badges. At least one region (Region I) has done NRC spiking of licensee personnel dosimeters using the Radiological and Environmental Research Laboratory to do the spiking.
To be accredited by NVLAP, a dosimetry processor must pass the proficiency test (s) and must satisfy documented NVLAP criteria. The NVLAP criteria for accreditation include general requirements for a quality assurance program but no specific requirement for dosimeter spiking. However, conformance to the NVLAP criteria is checked during onsite assessments by NVLAP assessors and the quality assurance checklist provided to the assessor (to "guide" the assessor) includes "#107. The processor's quality assurance program includes processing checks such as ... blind audit dosimeters unknown to the technician ...."
The ANI / MAELU inspection procedure on personnel dosimetry (dated October 1986) includes the requirement (Number 184.108.40.206): "There should be a continuing program of blind spiking TLD's or film badges. 1. Spiked badges should be included in each processing cycle. 2. A reasonable range of exposures for gamma and beta radiation energies should be included in the spiking program." Thus, ANI / MAELU clearly expects nuclear power plants to do blind spiking.
Regulatory references: 10 CFR 20.202, 10 CFR 20.1501
Subject codes: 8.1, 12.7, 12.15