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Re: A Technical (Licensing) Question!
I'd try to separate the licensing and waste disposal issues:
(1) I take it that the site is no longer under DOE jurisdiction, and, hence,
requires an agreement state or NRC license. This being the case, if the presence of
SNM in any quantity is confirmed, you should have your license amended, or obtain a
new license, to allow its possession.
(2) If the presence of SNM is confirmed, you may be able to petition the NRC, under
10 CFR 20.2002, to permission to dispose of small quantities in a mill tailings
disposal cell.
Permit me one final comment. You stated: "... A strict interpretation of 10 CFR 70
would lead one to believe that one atom of Pu is subject to licensing, but as others
have pointed out, that's absurd..." And your point is?
The opinions expressed are strictly mine.
It's not about dose, it's about trust.
Bill Lipton
liptonw@dteenergy.com
Steven Rima wrote:
> Bill et al,
>
> Here's a little more information on this subject that complicates it.
> The facility in question (lab) is on a DOE site and has never been
> subject to either NRC or State licensing or regulation. Yes, there is
> some scant evidence that transuranics have been analyzed there in the
> past. However, the waste stream is (hopefully) destined for a mill
> tailings disposal cell that, when closed, will come under an NRC
> license. The NRC is telling us that *we* should determine whether the
> Pu is licensable or not, and whether it can go to the cell, and tell
> them what our answer is. I've looked at 10 CFR 40, 70, etc..... and
> found no good answer.
>
> A strict interpretation of 10 CFR 70 would lead one to believe that
> one atom of Pu is subject to licensing, but as others have pointed
> out, that's absurd. It's such fun to deal with regulatory agencies
> sometimes! :-)
>
> Steve
>
> Steven D. Rima, CHP, CSP
> Radiation Safety Officer
> MACTEC, Inc.
> 970-248-6787
> fax 248-6725
> cell 260-3848
> steven.rima@doegjpo.com
> or
> sdrima@mactec.com
>
> ______________________________ Reply Separator _________________________________
> Subject: Re: A Technical (Licensing) Question!
> Author: William V Lipton <liptonw@dteenergy.com> at Internet
> Date: 8/11/00 6:06 AM
>
> I'm not aware of any exemptions for SNM. The only relaxation of the
> regulations is provisions for a general license for calibration or reference
> sources, in 10 CFR 70.19.
>
> A few questions that you should be asking?
>
> (1)What is the history of the facility you're decommissioning? Did they use
> SNM?
> (2) If they did, then how did they terminate their license?
>
> The opinions expressed are strictly mine.
> It's not about dose, it's about trust.
>
> Bill Lipton
> liptonw@dteenergy.com
>
> Steven Rima wrote:
>
> > RADSAFERs,
> >
> > I actually have a technical question that I am hoping someone can
> > assist me with. I've been looking through 10 CFRs, becoming more
> > frustrated the more I look (Imagine that!) Here's the question: What
> > quantity of SNM (Pu 239/240) requires a license for possession, use,
> > etc.? A regulatory citation would be great.
> >
> > Here's a little background information: We have analyzed samples from
> > the ducting in a radiochemistry laboratory that is slated for
> > demolition. If we count the samples long enough, a few show extremely
> > small trace amounts of Pu 239/240. I'm not completely convinced that
> > it's really there, but I can't positively rule it out either. It seems
> > to me that a concentration and/or quantity below which licensing is
> > not required would be in the regulations somewhere, but I've not found
> > it. If I find a few atoms of SNM in an entire building, is a license
> > needed?
> >
> > Thanks in advance,
> >
> > Steve
> >
> > Steven D. Rima, CHP, CSP
> > Radiation Safety Officer
> > MACTEC, Inc.
> > 970-248-6787
> > fax 248-6725
> > cell 260-3848
> > steven.rima@doegjpo.com
> > or
> > sdrima@mactec.com
> > ************************************************************************
> > The RADSAFE Frequently Asked Questions list, archives and subscription
> > information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html
>
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