My comments on the DOE Order 5400.5 Revision

[Rodney Bauman <RBauman@wssrap.com>]

RadSafers:

Attached is a copy of my first comments sent to the DOE regarding the
proposed 5400.5 changes.  I do not like the thought of having to demonstrate
compliance with vague statements such as "measurements using appropriate
commercially available technology."  Just exactly what does that mean?
____________________________

Dear Sir:

Please consider the following comment on the proposed revision to DOE Order
5400.5, dated 10/3, draft Chg 5.

With regard to Chapter 5, Section 4.a.(2), the term "appropriate
commercially available technology" should be clarified.  Or, will additional
guidance (e.g., a standard) be established to more specifically address this
statement?

My concern is that survey protocol varies among the DOE sites and what is
considered "appropriate" is subject to broad interpretation.  For example, a
scan survey will result in less material indicating contamination
distinguishable from background, while static counts of the same material
may indicate detectable contamination.  In addition, the ability to
distinguish contamination from background is highly dependent upon static
count times.  Will scanning still be allowed?  For static counts, how long
of a count time will be considered "appropriate?"

If no specific guidance is provided, then I contemplate that such
determinations will be made at each individual DOE site.  Subsequently,
complex-wide inconsistencies will develop which will ultimately undermine
public confidence in the Department's ability to control radioactive
material.

Thank you for your time and consideration,

Rodney Bauman, CHP, RRPT
Weldon Spring Site Remedial Action Project
St. Charles, Missouri
rbauman@wssrap.com

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