RE: Decay in Storage

[Paul Lavely <lavelyp@uclink4.berkeley.edu>]

Clayton Bradt

Thanks.

What I wanted was an answer and to get our inspector off the hook 
with the radwaste staff (who kept asking him to explain our license 
requirements). Your response may be criticized because it exemplifies 
a very cautious approach to dealing with small quantities of 
materials; however, it does give me a very good answer to the 
question that we asked. Therefore, I want to express my thanks for 
your explanation.

As to the second part

>consider the licensees for which DIS is an option: mostly small medical =
>and research facilities. Generally these licensees are  unsophisticated =
>in health physics. Most are pretty small operations with RSOs who are =
>not HPs and whose primary responsibility is not managing the radiation =
control program.=20

I agree with this concern and have seen some strange ideas of the 
requirements from non-HPs about rad issues for small programs. 
However, we are a Broadscope type "A" licensee with several 
professional HPs and years of experience. All of the licensed sites 
in the University of California system have professional HP staff. 
Since our licenses are individually written and approved, it would 
appear that some consideration of the differences between small and 
large programs could be made.  Again, I have not tried to force a 
decision on this. Nor, to my knowledge, has anyone else. I have found 
the California DHS staff to be reasonable and professional. Perhaps 
their rationale is the same as you stated for NYS Dept. of Labor.

We need to remember that the person who did the initial survey and 
decided to place this short half life material into a radwaste 
container for DIS was more than likely (in our case) a graduate 
student and not an HP.

Paul Lavely <lavelyp@uclink4.berkeley.edu> UC Berkeley

>The purpose for the DIS rules is to cut a break for licensees so that =
>they do not have to send their short-lived waste to a licensed disposal =
>facility. Its a way around the inescapable fact that there is not and =
>will likely never be a de minimus or BRC rule. (And this is the thanks =
>we get!)
>
>The requirement for both 10 half-lives decay and a survey showing it is =
>indistinguishable from background becomes more reasonable when you =
>consider the licensees for which DIS is an option: mostly small medical =
>and research facilities. Generally these licensees are  unsophisticated =
>in health physics. Most are pretty small operations with RSOs who are =
>not HPs and whose primary responsibility is not managing the radiation =
>control program.=20
>By requiring that both criteria be met, regulators have a little more =
>confidence that the facility's cold trash won't be setting off alarm =
>bells down stream.=20
>
>
>
>************************************************************************
>Clayton Bradt, CHP <raldrich@nysnet.net>        phone: 518/457-1202
>Assoc. Radiophysicist                                             fax:   =
>    518/485-7406
>NYS Dept. of Labor
>Radiological Health Unit
>Blg.12, Rm 169
>State Office Campus
>Albany, NY 12240
>***********************************************************************


Paul Lavely <lavelyp@uclink4.berkeley.edu> UC Berkeley
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