ML20198A309
| ML20198A309 | |
| Person / Time | |
|---|---|
| Site: | University of California-Davis |
| Issue date: | 12/11/1998 |
| From: | Alexander Adams NRC |
| To: | |
| Shared Package | |
| ML20198A287 | List: |
| References | |
| NUDOCS 9812160224 | |
| Download: ML20198A309 (2) | |
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a BALLOT' FOR
!. ANS 15.12
" Radiation Protection at Research Reactor Facilities (1993)"
-l APPROVED l
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l- I x DISAPPROVED WITH COMMENTS l
COMMENTS i
I See next page. !
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Alexnnder Adnms ir. INNRC f$dr&02A 7 ee - iMu/ 8 Print Name Signature / Date U return NLT 13 Dec 98
- 9812160224 981211 1 PDR ADOCK 05000607
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Non-Power Reactors and Decommissioning Project Directorate Comments l
ANSI /ANS-15.12, " Radiation Protection at Research Reactor Facilities"
- 1. Definitions. Definitions that are unique to the standard and not based on 10 CFR Part 20 should be identified.
- 2. Definitions, Accessible Area and Significant Portion of the Body. These definitions do not have a basis in the regulations. These definitions could be used to bypass the l requirements for Control of Access to High Radiation Areas (20.1601) and Control of '
Access to Very High Radiation Areas (20.1602). For instance, if a beam occupies less j than 900 cm 2of the body, it is not a significant portion of the body, and, therefore, it l could not be considered an accessible area. If it is not considered an accessible area, l then irrespective of the intensity of the beam, even if it meets the definition of a high or a very high radiation area, the access controls would not necessarily have to meet l 20.1601 and 20.1602. If the beam came under the definition of a high or very high radiation area, access controls would have to come under 20.1601 and 20.1602. The above definitions should be deleted from the standard.
- 3. Definitions, NVLAP. Modify the definition to describe what the program accomplishes.
- 4. Definitions, occupational dose. The definition differs from that in 10 CFR Part 20 in that exposure from persons that have been administered radioactive materialis not included in the list of exposures that do not constitute occupational dose.
- 5. Definitions, soluble material. This is not a 10 CFR Part 20 definition. What is the basis of the definition used in the standard?
l l 6. Definitions. It is not clear what definitions Note 1 applies to.
- 7. Section 5.4. In order for material to be released for unrestricted use it should fall under l this criterion. " Equipment and material will only be released for unrestricted use if it contains no detectable licensed radioactive materials when surveyed with appropriate equipment and instrumentation." Comment also applies to Section 6.2.3(4), third sentence. See 10 CFR 20, Subpart K.
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