re: Re: Supplemental Radiological Criteria

["Dr. Feinhals" <feinhals@tuev-nord.de>]

Dear Bill Lipton

I agree with you that the release of radioactive material from regulatory 
control should not be mixed with the authorized discharge of liquids or 
gases, which is regulated in the license. For more details see "Safety Guide 
on Application of the Concepts of Exclusion of Exposure, and Exemption and 
Clearance fron Regulatory Control" IAEA,2.-4.March 1998.

 But I don't agree, that the amount of material that can be released to the 
general public is strictly nothing. The principle of de minimis non curat lex 
means, that you can release material from regulatory control, if the 
exposition for the public is less than 0.01 mSv/a per practice. For example, 
you will derive values of a few Bq/g (Co-60) for the recycling of scrap or 
debris (under real conditions). This is something you can measure and you can 
release!
 If we accept the doctrin "detectable is not neglictable!", we have to 
consider more practices with every improvement of the measurement device.
Therefore, German licensees have values for clearance and authorized use in 
their license, if you have not- perhaps you should implement this in your 
next application.

Advice: International Symposium for Release of Radioactive Material from 
Regulatory Control, 8-10 Nov 1999 in Hamburg, Germany. More Information by 
feinhals@tuev-nord.de

J. Feinhals
TUEV Nord
Decommissioning and radwaste management

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