Department of EnergyOffice of Worker Protection Programs and Hazards ManagementRadiological Control Technical PositionRCTP 95-03Operability of Radiological Monitoring InstrumentsIssue:Title 10, Code of Federal Regulations, Part 835 (10 CFR 835), "Occupational Radiation Protection," section 401(c), establishes requirements for the appropriateness of radiological monitoring instruments. Efforts to develop documented radiation protection programs in accordance with section 835.101 have resulted in questions regarding the level of effort necessary to demonstrate compliance with this provision.Introduction:10 CFR 835.401(c) requires that instruments used for monitoring and contamination control be appropriate for the types, levels, and energies of the radiation(s) encountered and also appropriate for existing environmental conditions.Discussion:The Department of Energy's (DOE) intent in promulgating instrument performance requirements in 10 CFR 835 was to assure the reliability of workplace radiological monitoring data collected during the conduct of DOE activities. One of the basic tenets in the design and operation of any instrumentation system is that the instrument(s) be appropriate for both the parameter being measured and the conditions under which the measurement will be performed.In order to comply with the requirements of 10 CFR 835.401(c), some facilities have indicated a need for additional funding in order to perform instrument testing in accordance with ANSI N42.17A, "Performance Specifications for Health Physics Instrumentation - Portable Instruments for Use in Normal Environmental Conditions." The Department recognizes that hundreds of different types of instruments are used throughout the complex, including both commercially available and unique instruments. Some individual sites have well over one hundred different instruments in use. Testing of these instruments at each DOE site to the standards established in ANSI N42.17A would not be cost effective. Guidance related to instrument testing and calibration can be found in G-10 CFR 835/E1, "Instrument Calibration for Portable Survey Instruments Implementation Guide" (IG). Section IV.A of the IG indicates that, while testing of instrument types in accordance with ANSI N42.17A is encouraged, such testing is not required. This position is supported by DOE Order 5480.4, "Environmental Protection, Safety, and Health Protection Standards," which does not list ANSI N42.17 as a mandatory standard, indicating that compliance with this standard is not required. DOE Order 5480.4 does list ANSI N323, "Radiation Protection Instrumentation Test and Calibration," as a mandatory standard. This standard includes environmental testing requirements for use of instruments outside the manufacturers' recommended temperature range or for cases where the manufacturer has not stated operating limits for humidity or pressure. Technical Position:Based upon the information cited above and the requirements of 10 CFR 835, institution of a formal instrument type testing program in accordance with ANSI N42.17 is not required to demonstrate compliance with 10 CFR 835.401(c). 10 CFR 835 only specifies that instruments used for monitoring and contamination control be appropriate for the type, levels and energies of the radiations encountered, and appropriate for the existing environmental conditions.However, further documentation or testing may be required to meet the requirements of DOE Order 5480.4. Each facility should have a documented basis for making the determination that each applicable instrument type has been appropriately tested in accordance with ANSI N323. Keep in mind that testing, by either the instrument manufacturer or by DOE facilities to meet the requirements of ANSI N323 has already been conducted for many radiation protection instruments commonly used at DOE facilities. Retesting of these instruments need not be performed. In addition, appropriate administrative controls (such as procedures) should be established to preclude use of any instrument in conditions beyond its design basis or known operational capabilities. Where evidence exists indicating that the documented data are not reliable, such as may be provided by technicians using the instruments, efforts should be made to determine the actual operational limitations of the instrument(s). Such evidence should be documented (such as in a letter to file) when used as a basis for development of instrument operating guidelines. Departmental contractors are encouraged to share any information that may be pertinent to this subject with other contractors using similar instruments. References:
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