Re: Security and Control - A Regulation Change is Needed

[Bill McCarthy <wbm@MIT.EDU>]

I miswrote the activity of P-23 in the example below.  It should be 12
microcuries and 12 curies of P-32, not 120 microcuries and 120 curies.

At 01:49 PM 5/18/1998 -0500, you wrote:
>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 12.0 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 12.0 curies.
> This is a more reasonable quantity to be concerned about.  The real number
>would fall lower than 12.0 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
>
>
>---------------------------------------------------------------------
>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
>---------------------------------------------------------------------
>