[Date Prev][Date Next][Thread Prev][Thread Next][Date Index][Thread Index]
RE: Contaminated Scaffold Knuckles
Well, although Reg Guide 1.86 only applies to the termination of operating
licenses for nuclear reactors (in theory), HPPOS-072 and for that matter,
HPPOS-071 and IE Circular 81-07 apply only to operating nuclear power
reactor facilities.
A large segment of this industry (for one, most if not all DOE sites) have
the "luxury" of free-releasing items to numerical guidelines, i.e., DOE
Order 5400.5 Table IV-1 values. These values are essentially equivalent to
the acceptable surface contamination levels in Reg Guide 1.86. I've also
known some "non-power reactor licensees" to utilize numerical surface
contamination guidelines. Personally, I'm not a big fan of the power
reactor's philosophy of, "How Low Can You Go?" It can lend to some wasteful
conflicts between licensees - which only lessens the industry's credibility.
So, in essence, it is possible for a segment of this industry to release
materials with known average surface contamination levels of, say, 4,000
dpm/100 cm2 b/g activity. And, if someone wanted to literally comply with
NUREG-1608, then an SCO-I shipment would be required for this material.
??????
Obviously, there are discrepancies among the plethora of regulations
applicable to our industry. Sometimes it's hard to remain logical.
Rodney Bauman, CHP, RRPT
Bechtel Jacobs Company, LLC
Project Health Physicist
ETTP and Y-12 Waste Operations
Y-12 Plant Bldg. 9624, MS 8222
Voice: 865.241.5344
Pager: 865.417.0561
Fax: 865.576.3946
84u@bechteljacobs.org
> -----Original Message-----
> From: William V Lipton [SMTP:liptonw@DTEENERGY.COM]
> Sent: Thursday, September 20, 2001 12:28 PM
> To: Redmond, Randy R. (RXQ)
> Cc: Joe Heckman; radsafe@list.vanderbilt.edu
> Subject: Re: Contaminated Scaffold Knuckles - Turkey Point
>
> 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
> >
>
> ************************************************************************
> You are currently subscribed to the Radsafe mailing list. To unsubscribe,
> send an e-mail to Majordomo@list.vanderbilt.edu Put the text "unsubscribe
> radsafe" (no quote marks) in the body of the e-mail, with no subject line.
************************************************************************
You are currently subscribed to the Radsafe mailing list. To unsubscribe,
send an e-mail to Majordomo@list.vanderbilt.edu Put the text "unsubscribe
radsafe" (no quote marks) in the body of the e-mail, with no subject line.