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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
> >
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