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. 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. 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 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. 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.