Security and Control - A Regulation Change is Needed

[Bill McCarthy <wbm@MIT.EDU>]

Radsafers,

To all of you who feel the NRC enforcement Policy falls short, I agree with
you.  However, you must remember that the NRC is required to enforce all of
the regulations.  My understanding is that this includes even the
ridiculous ones. The only way around the issue of having to secure and
control every atom is to get the regulations changed.  I should note that
the enforcement Policy is a big help, but it is not the solution.  I
suggest that we put our minds together here on radsafe and determine what
needs changing (the NRC likes when you do the preliminary work).  Most of
the NRC people I know are on our side on this.  It is just that their hands
are tied to a regulation meant for things like portable radiography
devices, not check sources you could eat or put in your pocket and get no
significant dose.  

I suggest, just to get the discussion started, that 20.1801 and 20.1802 be
chanced to read: 

20.1801 "The licensee shall secure from unauthorized removal or access
licensed material, likely to result in a dose to an individual member of
the public in excess of the limit in section 20.1301, that are stored in
controlled or unrestricted areas."

20.1802 "The licensee shall control and maintain surveillance of licensed
material, likely to result in a dose to an individual member of the public
in excess of the limit in section 20.1301, that is in a controlled or
unrestricted areas and not in storage."

Regulatory guidance could easily be put together to assist in estimating
the 100 mrem to the public.  For example a lab using 120 microcuries of
P-32 in an experiment may give a dose of 100 mrem to an individual who eats
that researcher's experiment.  However, if you use the "magic number" of
1E-6 (this does not necessarily apply here, but the NRC uses it in their
patient release guidance - they use 1E-5) the quantity jumps to 120 curies.
 This is a more reasonable quantity to be concerned about.  The real number
would fall lower than 120 curies because of external exposures from
bremsstrahlung radiation, but you get the Idea.

As we all know rewriting regulations take a significant amount of time, so
the longer we put this off the longer we are stuck with the regulation as
is.  When we have come to a consensus we can send it into the NRC.

Thanks, Bill


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William B. McCarthy, Ph.D.
Assistant Radiation Protection Officer
Massachusetts Institute of Tecnology
Building 16-268
77 Massachusetts Avenue
Cambridge, MA 02139

e-mail: wbm@mit.edu
voice: (617) 253-0346
fax: (617) 258-6831
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