Re: MIT and NIH Incidents produce NRC Information Notice

["Wesley M. Dunn" <WDUNN@brc1.tdh.state.tx.us>]

> Date:          Wed, 1 Nov 95 13:21:45 -0600
> Reply-to:      radsafe@romulus.ehs.uiuc.edu
> From:          tdc@ehssun.lbl.gov (Ted M. de Castro)
> To:            Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
> Subject:       Re: MIT and NIH Incidents produce NRC Information Notice

> >>I am skeptical that any licensee can " ensure that they have a
> >>radiation safety program in place that will prevent deliberate
> >>misuse of radioactive materials in all licensee areas."

> BUT my reaction was the same as yours!  That is NOT a minor detail but a
> whole new level of protection - equivalent to protection for significant
> amounts of special nuclear material!
>
> Heretofor the standard of protection was to prevent reasonably predictable
> accidents - but it has always been conceded that you cannot protect against
> a deliberate act.

I certainly hope the NRC "mistyped" their response.  It is obviously
impossible and impractical to require such a standard.  Indeed, the
standard I used in the filed was more along the lines: "Does it
require a significant amount of intentional effort" to cause a
problem.  What is and is not significant is obviously in relation to
the possible consequences.

> There was also a clause in the about surveys and with the word "calibrated"
> appended is such a way as to give it considerable emphasis.
>
> I submit that the usual standard for a contamination survey is to keep
> things below detection and the most typical detector a GM.  I submit that if
> it responds to its check source calibration is irrelevant to detection and
> elimination/control of contamination!

So what about when the "usual standard" isn't appropriate?  And how
do you demonstrate that the usual standard IS adequate, if you
don't have calibration documention?   I think the question is "what
does calibrate mean in each of these cases"?

The survey meter must be capable of distinguishing a significant
amount of loose contamination.  Yes, a thin-window GM that
demonstratably responds to a check source is usually adequate for
general contamination surveys.  But many people still use a side-
window GM that is worthless for almost any type of contamination
incident.

Also keep in mind that most users of radioactive material are not
HPs, nor are they supervised an HP.  So who is going to make these
value judgements (e.g., when the "usual standard" is appropriate) in
the field?

Side item:  10CFR20 requires several surveys that are not easily met
with a standard GM (receipt surveys for non-exclusive use shipments
and release surveys, particularly).  Items leaving a restricted area
have to meet the release survey criteria.

(hmmm...apparently, I like "obvious" and "significant" a lot today)

Wes
*********************************************************************
Wesley M. Dunn, C.H.P., Administrator      512-834-6688
Licensing Branch                           512-834-6690 (fax)
(Texas) Bureau of Radiation Control        wdunn@brc1.tdh.state.tx.us
*********************************************************************