RE: MDA vs. Critical level for DOE Free Release surveys

["Redmond, Randy (RXQ)" <redmondrr@Y12.doe.gov>]

We'll let the archives speak for themselves.



Have a good day Bill.



> -----Original Message-----

> From:	William V Lipton [SMTP:liptonw@dteenergy.com]

> Sent:	Wednesday, October 29, 2003 10:14 AM

> To:	Redmond, Randy (RXQ)

> Cc:	'Goff, Tom'; ''RadSafe Send Message'; Oliver, Bobby (OLV); Wical,

> Scott Andrew (S3W)

> Subject:	Re: MDA vs. Critical level for DOE Free Release surveys

> 

> I covered:  1.  TN versus NRC release standards.  2. HPPOS-72.  3.  (The

> need

> to specify Type 1 and Type 2 errors separately.

> 

> Which of these did you cover?

> 

> The opinions expressed are strictly mine.

> It's not about dose, it's about trust.

> Curies forever.

> 

> Bill Lipton

> liptonw@dteenergy.com

> 

> "Redmond, Randy (RXQ)" wrote:

> 

> > Bill, I believe you repeated what I said.

> >

> > > -----Original Message-----

> > > From: William V Lipton [SMTP:liptonw@dteenergy.com]

> > > Sent: Wednesday, October 29, 2003 9:52 AM

> > > To:   Redmond, Randy (RXQ)

> > > Cc:   'Goff, Tom'; ''RadSafe Send Message'; Oliver, Bobby (OLV);

> Wical,

> > > Scott Andrew (S3W)

> > > Subject:      Re: MDA vs. Critical level for DOE Free Release surveys

> > >

> > > 1.  NRC licensees, especially power reactor licensees are not allowed

> to

> > > free

> > > release any licensed material.  See HPPOS 72 - I pasted in a copy,

> below.

> > > TN is

> > > known for its easygoing free release standards.  It's no coincidence

> that

> > > so

> > > many radwaste, "green is clean" processors are located, there.

> > >

> > > 2.  When you refer to, "The MDA value is what the instrument will

> detect

> > > with XX

> > > % confidence (most people use 95%)..." keep in mind that it is

> necessary

> > > to

> > > specify confidence levels, separately, for Type 1 (false positive) and

> > > Type 2

> > > (false negative) errors.  You seem to imply that the 95% level applies

> to

> > > both.

> > > Often, the levels are the same, but this is not necessarily true,

> > > especially

> > > under MARSSIM.

> > >

> > > The opinions expressed are strictly mine.

> > > It's not about dose, it's about trust.

> > > Curies forever.

> > >

> > > Bill Lipton

> > > liptonw@dteenergy.com

> > >

> > > Guide on "How Hard You Have to Look" as Part of Radioactive

> > > Contamination C ontrol Program

> > >

> > > HPPOS-072                                     PDR-9111210170

> > >

> > > Title:  Guide on "How Hard You Have to Look" as Part of

> > > Radioactive Contamination Control Program

> > >

> > > See the letter from R. C. DeYoung to E. D. Swartz

> > > (Commonwealth Edison Company) dated May 18, 1982.  The

> > > intent of IE Circular No. 81-07 (IEC-81-07) was to give

> > > guidance on "how hard you have to look" for radioactivity

> > > when the use of portable survey equipment is necessary as

> > > part of a radioactive materials control program.  The

> > > detection limits in IE Circular No. 81-07 (IEC-81-07) are

> > > not release limits.  The health physics position was

> > > written in the context of 10 CFR 20.201, 20.301, and

> > > 20.302, but it also applies to the "new" 10 CFR Part 20,

> > > Sections 20.1501, 20.2001, and 20.2002.  HPPOS-071 and

> > > HPPOS-73 contain related topics.

> > >

> > > The intent of IEC-81-07 (see HPPOS-071) was to provide

> > > guidance on acceptable limits of detection of portable

> > > survey equipment; thus, defining "how hard you have to

> > > look" for radioactivity when the use of portable survey

> > > equipment is necessitated as part of a radioactive

> > > materials control program.  Low background, fixed

> > > laboratory counting equipment can readily detect levels of

> > > radioactivity several orders of magnitude less than the

> > > detection levels discussed in the circular.  However, the

> > > use of laboratory counting equipment is not always

> > > practical for all situations and portable survey equipment

> > > may need to be employed.

> > >

> > > The circular did not establish criteria for releasing

> > > radioactivity contaminated materials from restricted areas

> > > for unrestricted use.  The regulations applicable to

> > > nuclear power reactor licensees do not provide for release

> > > of materials for unrestricted use that are known to be

> > > radioactively contaminated at any level.  Authorization for

> > > disposal of specific radioactively contaminated materials

> > > may be requested as specified in 10 CFR 20.302 [or 10 CFR

> > > 20.2002].  The Commission recognizes the need for "de

> > > minimis" classification of wastes and has initiated work to

> > > define "de minimis" levels on a specific waste basis.  This

> > > work is continuing.  [Note: The statement concerning "de

> > > minimis" classification of wastes is related to the below

> > > regulatory concern (BRC) policy, which has now been

> > > withdrawn.]

> > >

> > > With regards to your request for concurrence with release

> > > criteria in your "Radiation Protection Standards," we

> > > cannot concur since the regulations do not contain release

> > > criteria provisions as described above.  The method

> > > available to you for obtaining authorized release limits is

> > > to submit to the Office of Nuclear Reactor Regulation (NRR)

> > > a request for license amendment that addresses specific

> > > release limits.  Although we have sent a copy of your

> > > letter to NRR for information, the excerpt you provided

> > > from your "Radiation Protection Standards" lacks specifics

> > > which would support a request for specific release limits

> > > for radioactively contaminated materials.

> > >

> > > If you desire a specific authorization for disposal or a

> > > license amendment for specific release limits, please

> > > direct your request to the Office of Nuclear Reactor

> > > Regulation.

> > >

> > > Regulatory references:  10 CFR 20.201, 10 CFR 20.301, 10

> > > CFR 20.302, 10 CFR 20.1501, 10 CFR 20.2001, 10 CFR 20.2002

> > >

> > > Subject codes:  7.6, 9.7

> > >

> > > Applicability:  Reactors

> > >

> 

************************************************************************

You are currently subscribed to the Radsafe mailing list. To

unsubscribe, send an e-mail to Majordomo@list.vanderbilt.edu  Put the

text "unsubscribe radsafe" (no quote marks) in the body of the e-mail,

with no subject line. You can view the Radsafe archives at

http://www.vanderbilt.edu/radsafe/