[ RadSafe ] Neutron Source Licensing Requirements

[Syd H. Levine]

Zaid:

Nice to see you here in RadSafe.  It is not difficult to write the license 
application, just mind numbing with respect to the hoops they will make you 
jump through.

I believe Ohio is an agreement state, so contact the regulators there and 
ask for the forms you will need.  Also ask for any guidance documents or 
instructions they may have available.

An old trick is to do a FOIA request (or whatever the equivalent state open 
records law is called there in Ohio) for an exemplary permit application 
done by some other licensee (I used to actually say in the request that I 
wanted the one or two they considered the best they ever received) and use 
that as a template.  Back before computers, that is how lawyers built their 
"form files", the forms they copied when doing documents for clients.  The 
only hitch here is that your request may be denied on a homeland security 
rationale; it just depends on how much they have calmed down recently.

Your real problem is acquiring an AmBe neutron source.  There is presently a 
critical shortage of Americium-241.  There are a couple of members here on 
the list who can better address that situation if they are watching.

Good luck.

Syd H. Levine
AnaLog Services, Inc.
Phone:  (270) 276-5671
Telefax:  (270) 276-5588
E-mail:  analog at logwell.com
Web URL:  www.logwell.com


----- Original Message ----- 
From: "Zaid Farukhi" <zfrexon at yahoo.com>
To: <radsafe at radlab.nl>
Sent: Thursday, February 08, 2007 5:24 PM
Subject: [ RadSafe ] Neutron Source Licensing Requirements


> What are the sequence of steps to get a neutron source license?
>  The usage is for a new homeland security detector.
>
>  If you like, please respond to zfrexon at yahoo.com.
>
>
>  Zaid Farukhi
>  Rexon TLD Systems, Inc.
>  Rexon Components, Inc.
>  24500 Highpoint Rd
>  Beachwood, OH 44122
>
> Tel: 216-292-7373  24x7: 440-585-7086
>  Fax: 216-292-7714
>  URL: www.rexon.com
>  Email: sales at rexon.com, zfrexon at yahoo.com
>
>
>
>
> radsafe-request at radlab.nl wrote:
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> _______________________________________________
>
>
> Today's Topics:
>
> 1. Re: RADSAFE Message - Number of Atoms of Uranium Ingested
> (Bernard L. Cohen)
> 2. RE: ANSI/HPS N13.12-1978 (Sandy Perle)
> 3. Re: Stack Emission Limits (dckosloff at firstenergycorp.com)
> 4. Stack Emission Limits (Eric.Goldin at sce.com)
> 5. Re: Stack Emission Limits (Otto Raabe)
> 6. Re: AW: AW: [ RadSafe ] Re: Exposed "had lower incidences of
> all cancers - "Environmental - (John Jacobus)
> 7. Re: IAEA Proceedings (Cehn at aol.com)
> 8. Re: Incidence vs death question, was: Exposed " -had lower
> incidences of all cancers - " (John Jacobus)
> 9. Ecological Dose-Response Studies (Otto Raabe)
> 10. The hot and cold of history & journalistic credibility
> (Harold Careway)
> 11. Re: Shipyard worker study (Keith Welch)
> 12. Mobile phone controversy (Bjorn Cedervall)
> 13. Exposed " -had lower incidences of all cancers - " NO
> selection of healthy workers (howard long)
>
>
> ----------------------------------------------------------------------
>
> Message: 1
> Date: Thu, 08 Feb 2007 10:32:37 -0500
> From: "Bernard L. Cohen"
> Subject: [ RadSafe ] Re: RADSAFE Message - Number of Atoms of Uranium
> Ingested
> To: "Leo M. Lowe" , RadiatSafety
> Message-ID: <45CB4295.1000603 at pitt.edu>
> Content-Type: text/plain; charset=ISO-8859-1; format=flowed
>
> My error. I took the 5 Bq intake in the UNSCEAR Table as Bq/day,
> whereas it was Bq/year. There were slight differences in the numbers we
> used, so my result should have been a million trillion (1 E18) atoms per
> year, not per day.
>
> Leo M. Lowe wrote:
>
>> Dear Dr. Cohen,
>>
>> Your response on RADSAFE to the claim that even one atom of depleted
>> uranium was a threat (Dr. Durakovic) was bang on - this is a direct
>> way to show the nonsense of such a claim.
>>
>> However, I estimate a lower number (by roughly a factor of 1000) than
>> your value of a million trillion (1E18). According to UNSCEAR (2000,
>> Annex B, Table 16), the reference annual intake of U-238 in the diet
>> is 5.7 Bq. Using a specific activity of 1.235E04 Bq U-238/g of
>> uranium, this converts to a daily intake of roughly 1 microgram of
>> uranium, which is roughly about a million billion atoms (1E15). I am
>> presuming that water intake and inhalation are relatively minor
>> sources of U in most cases.
>>
>> All academic, and no effect on your main point, but I was wondering
>> how you derived your number.
>>
>> Regards,
>>
>>
>> Leo M. Lowe, Ph.D., P.Phys.
>
>
> -- 
> ÐÏࡱá
>
>
>
> ------------------------------
>
> Message: 2
> Date: Thu, 8 Feb 2007 07:11:35 -0800
> From: "Sandy Perle"
> Subject: RE: [ RadSafe ] ANSI/HPS N13.12-1978
> To: "'Dustin G Miller'" ,
> Cc: 'David Drupa'
>
> Message-ID:
> <2099866F46DCA04E83F1600E6274AA2C0239D328 at gdses.corp.gds.com>
> Content-Type: text/plain; charset="US-ASCII"
>
> Dustin,,
>
> I am Chair of the Health Physics Society Standards Committee. Many of the
> old standards are capable of being put into a PDF file format. The 
> question
> is whether the 1978 version was an HPS standard or another Accreditted
> Standards Coordinator If that is the case, then there would be a copyright
> and HPS can not make a copy.
>
> Please contact David Drupa, HPS Secretariat's Office who can provide you
> with the requirements to receive this standard, if it is available, at
>
> David Drupa
> HPSSC Secretariat
> 1313 Dolley Madison Blvd.
> Suite 402
> McLean, VA 22101
> 703-790-1745 ext. 30
>
> ddrupa at burkinc.com
>
> Regards,
>
> Sandy
> ----------------------------------------------------------------
> Sandy Perle
> Senior Vice President, Technical Operations
> Global Dosimetry Solutions, Inc.
> 2652 McGaw Avenue
> Irvine, CA 92614
>
> Tel: (949) 296-2306 / (888) 437-1714 Extension 2306
> Tel: (949) 419-1000 Extension 2306
> Fax:(949) 296-1144
>
> Global Dosimetry Website: http://www.dosimetry.com/
> Personal Website: http://sandy-travels.com/
>
>
> -----Original Message-----
> From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On 
> Behalf
> Of Dustin G Miller
> Sent: Thursday, February 08, 2007 6:34 AM
> To: 'RADSAFE'
> Subject: [ RadSafe ] ANSI/HPS N13.12-1978
>
> Does anyone have a copy of the 1978 version of the ANSI/HPS N13.12 
> standard?
> The title is Surface and Volume Radioactivity Standards for Clearance. I
> know it has been superseded by a 1999 version, which is available on the 
> HPS
> member website, but the 1978 version has some information that was not
> included on subsequent versions.
>
> Please respond outside of radsafe. Thank you.
>
>
>
>
>
>
> ------------------------------
>
> Message: 3
> Date: Thu, 8 Feb 2007 10:09:09 -0500
> From: dckosloff at firstenergycorp.com
> Subject: Re: [ RadSafe ] Stack Emission Limits
> To: BLHamrick at aol.com
> Cc: radsafe-bounces at radlab.nl, radsafe at radlab.nl, RADCH-L at in2p3.fr
> Message-ID:
>
>
> Content-Type: text/plain; charset="US-ASCII"
>
> Ah yes, the member of the public who continuously moves around the plant
> perimeter to maintain his position at the highest dose rate location at 
> all
> times. I was just watching a sequel to "The X-Men" (and Women, how did
> they get away with that title?) and they had two mutants who would 
> actually
> be able to do that if they also had good detection equipment and 
> predictive
> tools. Well, okay, also a good catering service and a rapid response
> porta-potty service (or astronaut diapers).
>
> Don Kosloff,
> Beaver PA and Bedford OH
>
>
>
>
> BLHamrick at aol.com
> Sent by:
> radsafe-bounces at r To
> adlab.nl ograabe at ucdavis.edu,
> franz.schoenhofer at chello.at,
> RADCH-L at in2p3.fr, radsafe at radlab.nl
> 02/07/2007 11:53 cc
> PM
> Subject
> Re: [ RadSafe ] Stack Emission
> Limits
>
>
>
>
>
>
>
>
>
>
>
> 10 CFR 20.1101 imposes an additional
> constraint on the effluents such that the individual member of the public
> likely to
> receive the highest dose will not receive more than 10 millirem.
>
>
>
> -----------------------------------------
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>
> ------------------------------
>
> Message: 4
> Date: Thu, 8 Feb 2007 08:01:42 -0800
> From: Eric.Goldin at sce.com
> Subject: [ RadSafe ] Stack Emission Limits
> To: radsafe at radlab.nl
> Message-ID:
>
> Content-Type: text/plain; charset=US-ASCII
>
>
> Otto, If I understood your question below, you're asking about the
> demonstration of compliance with the 10CFR20.1101(d) dose constraint from
> air emissions. It's been a few years since I've used it, but the COMPLY
> code endorsed by EPA presents a fairly simple progressive plan to
> demonstrate compliance. The simplest level is based on possession limits,
> the second level on concentration limits at the stack, the third is a
> screening model based on NCRP Commentary 3 that makes conservative
> assumptions about releases, and finally the fourth level is a more 
> detailed
> modeling that requires information about your facility, stack volume 
> rates,
> distances to receptors, etc. Without knowing any more about what you're
> doing, the screening model of Level 3 appears to allow for averaging of
> releases over the year. Therefore, it doesn't matter under what "profile"
> the emissions occur - short bursts followed by long periods of no release.
>
> There may be newer versions of the code and guide (what I used was 
> Revision
> 2 dated October 1989) documented in EPA 520/1-89-002. And I if I recall
> the code was available on the EPA website. I'd have to do some serious
> digging but I'm pretty sure that there was guidance from the NRC that
> permitted the use of the COMPLY code for demonstrating compliance with
> those relatively new Clean Air Act standards. Let me know if you have any
> questions. Eric
>
> Eric Goldin, CHP
> Southern California Edison
> eric.goldin at sce.com
>
> ++++++++++++++
>
> February 7, 2007
>
> 10 CFR Part 20 sets annual average limitation for stack emissions in the
> United States. For example, for carbon-11 monoxide, the annual average
> concentration is given as 2E-6 microcuries per milliliter of air. [Sorry
> about the American units.] .
>
> My question concerns a brief ultra-high concentration emission that may
> occur only occasionally and last only a few seconds. Is there a peak limit
> for such an emission? I can always run my exhaust fans for a year to get
> the average down to the allowed annual average, but even if the exhaust
> fans were turned off after an emission event there is no real difference 
> in
>
> potential exposure risk. But it seems that I can meet the release limit by
>
> simply running my fans while there are no emissions.
>
> Comments please.
>
> Otto
>
> +++++++++++++++++++++
>
>
>
> ------------------------------
>
> Message: 5
> Date: Thu, 08 Feb 2007 08:11:15 -0800
> From: Otto Raabe
> Subject: Re: [ RadSafe ] Stack Emission Limits
> To: "Bryan Bagg" , "Wesley"
> , "'Franz Sch?nhofer'"
> , "'RADCHEM-LIST \(RADCHEM-LIST\)'"
> , "'RADSAFE'"
> Message-ID: <6.0.1.1.2.20070208080959.02c28ac8 at mailbox.ucdavis.edu>
> Content-Type: text/plain; charset="us-ascii"; format=flowed
>
> At 08:42 PM 2/7/2007, Bryan Bagg wrote:
>>Note also that a licensee must demonstrate that air emissions of
>>radioactive material (excluding Rn-222 and its daughters) to the
>>environment will not exceed a TEDE of 0.1 mSv to the individual member of
>>the public likely to receive the highest dose. This is found in 10 CFR
>>20.1101 (d), Radiation Protection Programs, and most if not all equivalent
>>Agreement State regulations.
> ************************************************************
> February 8, 2007
>
> Thanks Bryan and Barbara and Wes for your useful comments.
>
> Sincerely,
>
> Otto
>
>
> **********************************************
> Prof. Otto G. Raabe, Ph.D., CHP
> Center for Health & the Environment
> University of California
> One Shields Avenue
> Davis, CA 95616
> E-Mail: ograabe at ucdavis.edu
> Phone: (530) 752-7754 FAX: (530) 758-6140
> ***********************************************
>
> ------------------------------
>
> Message: 6
> Date: Thu, 8 Feb 2007 09:23:26 -0800 (PST)
> From: John Jacobus
> Subject: Re: AW: AW: [ RadSafe ] Re: Exposed "had lower incidences of
> all cancers - "Environmental -
> To: Rainer.Facius at dlr.de, radsafe at radlab.nl
> Cc: rad-sci-l at WPI.EDU
> Message-ID: <951676.63944.qm at web54303.mail.yahoo.com>
> Content-Type: text/plain; charset=iso-8859-1
>
> Rainer,
> I guess if you only look at the data selectively, you
> will find what you want. You just choose to ignore
> the leukemia values and the age based incident rates.
> Maybe I am just more critical than you since you did
> not see the rest of the table.
>
> As the RERF data demonstrated, you need to follow this
> population for many years. In 10 years, the incident
> values will be different. Of course, if you like what
> you have now, why waste the money looking for more
> information.
>
>>From what I have read, it is clear that radiation
> exposures do not present risk below 100 mSv acute
> dose. No harmful risks have also been demonstrate for
> fractionated and low dose rates 2 or 3 times
> background. I think that low dose experiments are
> interesting, but do not contribute much to the
> epidemiological data. Your bet (prejudice) may be
> realized, but I doubt it.
>
>
> --- Rainer.Facius at dlr.de wrote:
>
>> John,
>>
>> regarding the "reduced cancer incidences" the
>> message of table III is equally clear. Concentrating
>> on the pooled incidences for men and women the data
>> say:
>> all cancers: 95/114.9 -> SIR95%=(0.67, 0.83,
>> 1.01) : non-significant
>>
>> all w/o leukaemia: 88/111.6 -> SIR95%=(0.63, 0.79,
>> 0.97) : formally significant
>>
>> all solid cancers: 82/109.5 -> SIR95%=(0.60, 0.75,
>> 0.93) : formally significant
>>
>> In my view, for the purely statistical evaluation of
>> a putative beneficial association the same criteria
>> should be applied as for the appraisal of a putative
>> detrimental association, i. e., these data at best
>> can serve as a justification to continue such
>> epidemiological investigations. Hence, I would
>> hesitate to claim the above 'positive' associations
>> as proof for a beneficial action of those exposures.
>>
>>
>> However, such - by controlled, truly low dose and
>> dose-rate laboratory work - well established
>> phenomena like induced radiation resistance,
>> adaptive response, non-monotonous dose response
>> functions for several cancer related radiobiological
>> endpoints at all levels of biological organization
>> yield some plausibility to the assumption that
>> biological mechanisms do exist which indeed might
>> CAUSE the above association. My present bet
>> (prejudice) is that eventually the mechanisms behind
>> these laboratory observations will be sufficiently
>> elucidated so that the inference of a causation of
>> the statistical observations will be justified.
>>
>> Regarding the "consideration of all studies and not
>> just one report" I would urgently invite you to
>> quote the one or two studies which you consider as
>> presenting the most compelling evidence that low
>> dose and dose-rate exposure to low LET ionizing
>> radiation below say 500 mSv causes cancer.
>>
>> Kind regards, Rainer
>>
>> Dr. Rainer Facius
>> German Aerospace Center
>> Institute of Aerospace Medicine
>> Linder Hoehe
>> 51147 Koeln
>> GERMANY
>> Voice: +49 2203 601 3147 or 3150
>> FAX: +49 2203 61970
>>
>> -----Ursprüngliche Nachricht-----
>> Von: John Jacobus [mailto:crispy_bird at yahoo.com]
>> Gesendet: Samstag, 20. Januar 2007 17:05
>> An: Facius, Rainer; radsafe at radlab.nl
>> Cc: rad-sci-l at WPI.EDU
>> Betreff: Re: AW: [ RadSafe ] Re: Exposed "had lower
>> incidences of all cancers - "Environmental -
>>
>> Rainer,
>> I am aware of that interpretation about the
>> significans of the of SIR values. That being said,
>> are the values for reduced cancer incidents also
>> insignificant? Or does the relevance of the numbers
>> not important if you have a political view the
>> radiation is good?
>>
>> Cherry-picking data is common. It is used by those
>> who are anti-radiation and who are looking for a
>> hormetic effect. Nevertheless, one needs to
>> consider all of the studies, and not just one
>> report.
>>
>> --- Rainer.Facius at dlr.de wrote:
>>
>> > John,
>> >
>> > if you were able to properly interpret the numbers
>> given by you, you
>> > would not claim that they prove an increased
>> incidence, not to speak
>> > of a causal relation.
>> >
>> > The 95% SIR confidence interval for leukaemia (all
>> > types) is (0.85, 2.12, 4.37), i.e., utterly
>> insignificant.
>> > For malignant lymphoma it is (1.01, 3.13, 7.29),
>> i.e., essentially
>> > insignificant again.
>> >
>> > If you ask professional epidemiologists, you will
>> find a consensus
>> > that in order for an association to be considered
>> established by such
>> > studies, the confidence interval for standard
>> mortality or incidence
>> > ratios should exclude the value of three or at
>> least two, i.e., the
>> > _lower_ confidence limit should be above that
>> value. Findings below
>> > that value at best can serve as a rationale to
>> spend money on a
>> > repetition of a study.
>> >
>> > Kind regards, Rainer
>> >
>> > Dr. Rainer Facius
>> > German Aerospace Center
>> > Institute of Aerospace Medicine
>> > Linder Hoehe
>> > 51147 Koeln
>> > GERMANY
>> > Voice: +49 2203 601 3147 or 3150
>> > FAX: +49 2203 61970
>> >
>> > -----Ursprüngliche Nachricht-----
>> > Von: radsafe-bounces at radlab.nl
>> > [mailto:radsafe-bounces at radlab.nl] Im Auftrag von
>> John Jacobus
>> > Gesendet: Freitag, 12. Januar 2007 16:16
>> > An: radsafe
>> > Cc: Rad Science List
>> > Betreff: [ RadSafe ] Re: Exposed "had lower
>> incidences of all cancers
>> > - "Environmental -
>> >
>> > Dr. Long,
>> > Again, another typical example of cherry-picking
>> data.
>> >
>> > As noted in Table III
>> > Leukemia (all-types) Observed 7; Expected 3.3
>> > Malignant Lymphoma Observed 5; Expected 1.6
>> >
>> > If you are unable to read the article, how can one
>> expect to have an
>> > intelligent discussion with you?
>> >
>> > Why do you constantly quote the incomplete data of
>> Chen, et.al. of
>> > 2004?
>> >
>> > --- howard long wrote:
>> >
>> > > John Jacobus, the paper you refer to did,
>> indeed,
>> > mislead in its
>> > > "Conclusion", comparing its tables and
>> discussion.
>> > > HPs can judge for themselves:
>> > > "Correspndence: Dr W Peter Chang, Inst. of
>> > Environmental Health
>> > > Sciences, National Y U Med School 155, sec2
>> Linong
>> > St. Taipei112,
>> > > Taiwan"
>> > >
>> > > Int.J. Radiat. Biol, Vol82, No.12, Dec. 2006
>> pp
>> > > 849-858
>> > > (The Environmental Health Sciences review by
>> > Chang et al of cancer
>> > > risks in 7,271 persons exposed to 1 to 2,363 mSv
>> > gamma over 23 years),
>> > > "ABSTRACT
>> > > Conclusion [ in entirety],
>> > > The results suggest that prolonged low dose
>> > radiation exposure
>> > > appeared to increase risks of developing certain
>> > cancers in specific
>> > > subgroups of this population in Taiwan."
>> > >
>> > > "Received 12 May 2005; revised 11 Sept. 2006;
>> > accepted 18 Oct.
>> > > 2006".
>> > >
>> > > The opposite impression, much cancer was
>> > prevented by the radiation,
>> > > is clear from its
>> > >
>> > > Table III "All cancers - Observed 95 Expected
>> > > 114.9 "
>> > > "Solid cancers - Observed 82
>> > Expected 109.5" and
>> > > "Discussion: - Compared to the reference
>> > population, the study
>> > > population had lower incidences of all cancers
>> > combined, all cancers
>> > > combined except leukemia and all solid cancers
>> > combined (Table III)."
>> > >
>> > >
>>
>> +++++++++++++++++++
>> "We must face the fact that the United States is
>> neither
> === message truncated ===
>
>
> +++++++++++++++++++
> "We must face the fact that the United States is neither omnipotent or 
> omniscient - that we are only 6 percent of the world's population; that we 
> cannot impose our will upon the other 94 percent of mankind; that we 
> cannot right every wrong or reverse each adversity; and therefore there 
> cannot be an American solution to every world problem."
>
> === message truncated ===
>
>
> ---------------------------------
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