NRC - security of RAM -April 24th Memorandum

["Joseph P. Ring" <joseph_ring@harvard.edu>]

Some how the email systems are not with me this week, the listserver can not accept paragraphs that begin with 'From'.  Aggie got a complete copy of the response but the listserver did not; she was a cc.  Here it is again.

Not being from NRC but understanding the process I would like to take a shot at responding to Aggie's questions.

In the (this is where the from was) early discussions with NRC and others, I understand the aggregate quantity means what is unsecured in laboratory space.  They were very concerned about looking at security on an individual item basis.    Even this many of us working on this considered marked improvement because their interpretation was every radioactive atom was a severity  level 3 violation.   It was the original intention, at least,  to provide some leeway on classifying  security violations for waste since  locking waste is very problematic in laboratories.   The original discussion with NRC included means to support the licensee's internal audit program.  This meant if a licensee had a program to control security, credit would be applied to support it.

During the last two years,  NRC has indicated its intention to retract the 'answers to questions 129 & 419 in ORNL/TM-12690' which one could have interpreted as less stringent security requirements in a laboratory. In fact, if one was unfortunate enough to visit with NRC over the issue of security they made it very clear that was not the intention.  The  quote I remember is: " every radioactive atom requires direct eye-contact supervision or a lock."

The way I understand minor violations is the NRC will keep track of them for a time to monitor resolution  and they will be removed with NOV.  

Aggie Barlow Wrote:


After reading the Guidance Memo, I guess I have a few  questions:

I am not absolutely clear to what an "aggregate quantity" refers - I assume 
this is any one container in a given lab.  What if there is more than one 
unsecured container in that one lab? [a liquid and a solid waste container 
for example]  Each is a separate "aggregate quantity", right? [Or if a waste 
container measures more than 2mrem/hr at 30 cm. is it only then an 
"aggregate quantity"?- see minor violation section.]

"Minor violations" - I assume these would be less than Severity Level IV, 
and there would be no NOV?

The next to the last paragraph says no enforcement should be taken...for 
quantities less than Appendix C.
So these are not violations, no NOV.    I was not clear that [according to 
NUREG/CR 6204]   "at the present time"    20.1801 and 1802   "do not apply 
to amounts less "   than Appendix C.     "When the guidance is withdrawn, 
this EGM will be modified to include security issues involving quantities 
less than Appendix C as minor violations."  I'm confused.  Maybe I just need 
to read this a few more times. 

Any thoughts or clarification would be helpful, using Radsafe or privately.

THANKS
Aggie
Agnes.Barlow@Yale.edu 203 737-2142
Standard disclaimer



Joseph P. Ring, Ph.D. CHP
Harvard University
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