Re: Contaminated Scaffold Knuckles - Turkey Point

[William V Lipton <liptonw@DTEENERGY.COM>]

I see the irony, here, but you may be taking statements out of context.



(1) Table 1 of RG 1.86 applies to final surveys for releasing a premises, i.e.,

terminating a license.  It does NOT apply to releasing material from a

licensee's restricted area.  The NRC provides interpretations of free release

criteria in HPPOS-072, "Guide on 'How Hard You Have to Look' as Part of

Radioactive Contamination Control Program."  This states, "The regulations

applicable to nuclear power reactor licensees do not provide for release of

materials for unrestricted use that are known to be radioactively contaminated

at any level..."  It's subtle and sometimes confusing, but there's a difference

between releasing items from a licensed facility and releasing a facility from

the requirements of a license.



Regardless of the required sensitivity, if any contamination due to licensed

material is detected, an item cannot be free released.  However, an item with

detectable radioactivity below the NUREG-1608 thresholds can be shipped to an

authorized receiver without regard to its radioactivity.  This is why it's

important to document these "nonradioactive shipments."  Each such shipment must

meet 2 fundamental requirements:  (1) activity, both distributed and surface

contamination, below applicable thresholds (may include IATA limits), and (2)

shipment must be to an authorized recipient.  I've shipped radioactive waste as

nonradioactive material.



As a practical matter, if you are free releasing material to an unlicensed

landfill or scrapyard, keep in mind that many of these facilities now have

portal radiation monitors.  These are often set as close to background levels as

the operator can get the setpoint.  (The usual technique is to bring the

setpoint down to where the monitor alarms and then gradually raise it until the

alarm stops.)  Thus, even if you have legitimately free released material, the

shipment may still alarm the monitor, and will be rejected.  You are especiallly

vulnerable to this if you release materials in small batches, which are then

combined in a bulk container.  Although the individual batches do not alarm your

monitors, the aggregate may have enough ram to alarm the monitor at the

receiving facility.



The NRC has been trying to establish free release levels, but has been meeting

fanatical public opposition.  The scrap metal industry also tends to oppose

release limits, since they may get stuck with unmarketable material.  Good or

bad, this is something we have to live with.



Just keep in mind that any screwup by any licensee hurts all of us.



The opinions expressed are strictly mine.

It's not about dose, it's about trust.



Bill Lipton

liptonw@dteenergy.com





"Redmond, Randy R. (RXQ)" wrote:



> "NUREG-1608 provides a threshold value for surface contamination, below

> which an

> object may be shipped as nonradioactive.  This was apparently inadvertently

> omitted from the regulations.  (see section 3.1.2):  The threshold is:  2200

> dpm/100 cm2 beta-gamma and 220 dpm/100 cm2 alpha, averaged over 300 cm2.  (I

> assume this limit applies to the total of removable and fixed

> contamination.)"

>

> Interesting.  Reg Guide 1.86 permits me to free release items in certain

> radionuclide categories if they are less than 5000 dpm/100 cm2 total and

> less than 1000 dpm/100 cm2 removable.

> Randy Redmond

> BWXT Y-12 L.L.C.

> Y-12 National Security Complex

> Radiological Control Organization

> Email:  rxq@Y12.doe.gov

> Phone:  865-574-5640

> Fax:  865-574-0117

>



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