Re: re: Re: Supplemental Radiological Criteria

[LIPTONW@dteenergy.com]

Your statements make sense, but, unfortunately are not the law in the U.S.
If
the projected dose is less than 1 mrem/year, the licensee can petition the
NRC
for authorization to release the material.  I've done this.  However, NRC
approval is required before release.  The NRC proposed the "deminimis"
concept
approximately 10 years, ago, but withdraw it after public protest.

More philosophically, HP's have themselves to blame for this.  When we
preach
the linear, no threshold model, we're saying that any amount of radiation
exposure is potentially fatal.  If you accept that, how can you justify
deminimis?

Many thanx for your response.

Bill Lipton

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• To: Multiple recipients of list <radsafe>
• Subject: re: Re: Supplemental Radiological Criteria
• From: "Dr. Feinhals" <feinhals@tuev-nord.de>
• Date: 22 Dec 98 05:10:52
• Reply-to: UNIX2.DECO.COM:radsafe@romulus.ehs.uiuc.edu
• Sender: radsafe@romulus.ehs.uiuc.edu

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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