[ RadSafe ] Action Levels
sfisher373 at aol.com
sfisher373 at aol.com
Fri Aug 16 12:30:19 CDT 2019
Under the CNSC Radiation Protection Regulations, an action level is defined to be "a specific dose of radiation or other parameter that, if reached, may indicate a loss of control of part of the licensee's radiation protection program*, and triggers a requirement for specific action to be taken."
*The definition under the Uranium Mines and Mills Regulations is identical with the addition of "or environmental protection program" at this *
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Subject: RadSafe Digest, Vol 2510, Issue 1
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Today's Topics:
1. Question for Legal Eagles + Associates (Chris Alston)
2. Re: Question for Legal Eagles + Associates
(dkjordan2001 at yahoo.com)
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Message: 1
Date: Thu, 15 Aug 2019 15:51:48 -0400
From: Chris Alston <achris1999 at gmail.com>
To: AMRSO List <AMRSO-L at list.iupui.edu>
Cc: Radsafe List <radsafe at health.phys.iit.edu>,
medphysusa at lists.wayne.edu
Subject: [ RadSafe ] Question for Legal Eagles + Associates
Message-ID: <55E41032-8F95-47A6-9E61-78B48A7BE0F6 at gmail.com>
Content-Type: text/plain; charset=utf-8
Folks
Can you elucidate for us the philosophy of regulation underlying the distinction between “limits” and “action levels”? Does it have anything to do with which entities have the primary responsibilities for enforcement, that is, those on the regulatory end of the arena or those on the regulated end?
TIA.
ca
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Message: 2
Date: Thu, 15 Aug 2019 17:02:02 -0500
From: <dkjordan2001 at yahoo.com>
To: "'The International Radiation Protection \(Health Physics\)
Mailing List'" <radsafe at health.phys.iit.edu>
Subject: Re: [ RadSafe ] Question for Legal Eagles + Associates
Message-ID: <010101d553b5$1251bbb0$36f53310$@yahoo.com>
Content-Type: text/plain; charset="utf-8"
Good Day Mr. Alston,
It was my understanding that action levels were established by regulated entities to ensure they stayed well below regulatory limits.
We dealt with a lot of companies that employed large, portable sealed sources. Most of these were Special Form to avoid needing a Type B container to transport. If one of these sources failed a leak test it was no longer Special Form and could not be moved without expensive re-packaging. Several customers established action levels at a fraction of the leak test pass/fail limit so they could move theses sources to their final resting place before they failed the test.
Several years ago I heard of a case where an inspector cited a licensee for exceeding their internal action levels in some area, even though they were well within regulatory limits. I do not know how this was resolved but you could check the radsafe archives.
-----Original Message-----
From: RadSafe <radsafe-bounces at health.phys.iit.edu> On Behalf Of Chris Alston
Sent: Thursday, August 15, 2019 2:52 PM
To: AMRSO List <AMRSO-L at list.iupui.edu>
Cc: medphysusa at lists.wayne.edu; Radsafe List <radsafe at health.phys.iit.edu>
Subject: [ RadSafe ] Question for Legal Eagles + Associates
Folks
Can you elucidate for us the philosophy of regulation underlying the distinction between “limits” and “action levels”? Does it have anything to do with which entities have the primary responsibilities for enforcement, that is, those on the regulatory end of the arena or those on the regulated end?
TIA.
ca
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