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

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

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

> 

> 

> 

> 

> 

> 

> 

> 

> 

> 

> "Redmond, Randy (RXQ)" wrote:

> 

> > Tom,

> >

> > I refer to statistics as "sadistics" and I'm certainly not an expert at

> any

> > this.  I'll tell you what we do (DOE facility, NRC agreement state).

> >

> > 1.  We use the DOE 5400.5 surface contamination values (uranium 5000

> dpm/100

> > cm2 total and 1000 dpm/100 cm2 removable); at times we also use the

> 15000

> > dpm/100 cm2 maximum depending on the value of the object.  Items are

> subject

> > to at least one decon to get the levels down - the ALARA statement in

> > 5400.5.  The state accepts these values for free release.  Of course if

> its

> > metal, then we have to abide by the Richardson memo - no metal released

> if

> > its been in a contaminated area.  The 5400.5 values are consistent with

> Reg

> > Guide 1.86 values (even though some folks claim the 1.86 values are not

> for

> > free release).

> >

> > 2.  I'm not familiar with any reference or regulatory standard on

> whether to

> > use MDA or Lc; however, the EM-30 Performance Objective issued by DOE in

> the

> > early 90's basically said to pick one and justify it (for volumetric

> > release).  In my opinion (sadistically speaking) Lc is the correct value

> if

> > your objective is not to release any radioactive material (at whatever

> > confidence you choose).  Using Lc is impossible in the field due to

> varying

> > backgrounds, each instrument has a different efficiency, each tech uses

> a

> > different distance to the surface .. . .).

> >

> > 3.  See number 2.  The MDA value is what the instrument will detect with

> XX

> > % confidence (most people use 95%).  If you have an MDA of 100 dpm and a

> > sample is 100 dpm, then you'll have a distribution around your MDA -

> count

> > the sample with exactly 100 dpm in it twenty times and statistically 50%

> of

> > the time the value will be less than 100 dpm and 50% of the time the

> number

> > will be more than 100 dpm 50% of the time (sometimes you'll get exactly

> 100

> > dpm; sometimes, about 5% of the time using 95% confidence you'll get a

> value

> > less than the Lc).  Anyway, using the MDA to state that nothing is there

> is

> > not correct, that's where Lc comes in.  Check some of Brodsky's work and

> > NUREG 1400 contains some good info on MDAs and Lc.

> >

> > Like I said, don't base anything on what I wrote - "sadistics."

> >

> > Randy Redmond (32458)

> > Radiological Control Organization

> > BWXT Y-12 L.L.C.

> > Oak Ridge, TN

> > 865-574-5640

> >

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

> > > From: Goff, Tom [SMTP:Tom.Goff@wipp.ws]

> > > Sent: Tuesday, October 28, 2003 2:27 PM

> > > To:   ''RadSafe Send Message'

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

> > >

> > > >     Title:

> > > >

> > > >     We are discussing using a critical level for free release

> surveys.

> > > > Please provide answers to the following:

> > > >

> > > >     Are you using critical value or MDA for free release surveys of

> > > > materials from your site?

> > > >

> > > >     Does anyone have a reference/regulatory standard on whether to

> use

> > > > MDA or critical value for free release surveys?

> > > >

> > > >     Given that an MDA results in a 95% confidence in detecting

> > > > contamination at the MDA value, what is the corresponding confidence

> if

> > > > using the critical level?

> > > >

> > > >     I would welcome any other comments or thoughts on this.

> > > >

> > > >     Tom Goff

> > > >

> > > >

> > >

> --------------------------------------------------------------------------

> > > > ----------------------------------------------------------------

> > > >     Let me know if you're ok with this.

> > > >

> > > >

> > > >

> > > >     Tom Goff

> > > >     WIPP ALARA Coordinator

> > > >     WIPP Integrated Waste Operations

> > > >     (505) 234-8861

> > > >     (fax)  234-8963

> > > >     e-mail  Tom.Goff@WIPP.ws

> > > >     page (505) 234-8850  (pager 479)

> > > >     P.O. Box 2078

> > > >     Carlsbad, NM 88221

> > > >     Radiological Engineering: Anticipating Problems.....providing

> > > > solutions!!!

> > > >

> > >

> > >

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