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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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