U.S. Nuclear Regulatory Commission

Blind Spiking of Personnel Dosimeters and the Inspection Program

HPPOS-224 PDR-9111220133

Title: 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

8.4.4.3): "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

Applicability: Reactors