RE: Contaminated Scaffold Knuckles - Turkey Point

["Redmond, Randy R. (RXQ) " <RXQ@Y12.doe.gov>]

If I release something at the DOE 5400.5 limits (say 4000 dpm/100 cm2

total), then I'm in violation of DOT regulations?



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





> -----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

> >

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