Re: Contaminated Scaffold Knuckles - Turkey Point

[Lam Hoi Ching <lamhc@HKUSUA.HKU.HK>]

At 04:27 PM 2001/9/20 +0000, William V Lipton wrote:

>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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