RE: Surface Contaminated Objects and release limits

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

I wanted to say thanks for the replies and phone calls I've received.  I'm

afraid that my post was a little long - my main question/concern was not

about wipe efficiency or how to determine it and I agree that the SCO

designation is very useful.



DOE Order 5400.5 and (the following can be argued, but in my opinion it is

release criteria) Reg. Guide 1.86 establish release limits of 5000 dpm/100

cm2 total and 1000 dpm/100 cm2 removable for uranium.  



I can legally release an item that is  5000 dpm/100 cm2 total to the public.

However, according to some shipping personnel, regulators, and their

interpretation of NUREG 1608,  if the same item enters into domestic

transportation, then it has to be categorized as SCO-I.  Why? Because it

exceeds 220  dpm/100 cm2  (see NUREG 1608, section 3.2.1 below).  



In my opinion, if the "guidance" in NUREG 1608 becomes a regulatory

requirement the cost $$ and the pain will be enormous.  Will any risk be

avoided - absolutely not. I'll have to replace my instruments, train

technicians, change the way I document surveys, take more time to perform

surveys, count smears using laboratory low background counters instead of in

the field using hand-held instruments, ship legally clean material as SCO-I,

will be unable to release the material - who will want something that I

released as clean, but shows up identified as a Surface Contaminated Object?

If I understand all of this, I'll have to package an otherwise "clean" item.

Can't you envision responders backing off from a desk that has 300 dpm/100

cm2 fixed uranium alpha on it (probably a little exaggerated for impact)?

This is insane.  



Regulators - establish SCO criteria that is reasonable and does not conflict

with other established criteria (Reg. Guide 1.86 is reasonable).

NUREG 1608, section 3.1.2 - "an object with external contamination may be

considered to be excepted from classification as Class 7 (radioactive)

material if:  (1) contamination when averaged over each 300 cm2 (46.5 in 2 )

of all surfaces is less than 0.4 Bq/cm2 (2200 dpm/100 cm2) for beta-gamma

emitters and low toxicity alpha emitters, and is also less than 0.04 Bq/cm2

(220 dpm/100 cm2) for all other alpha emitters; and (2) the object itself

has an average specific activity less than 70 Bq/g (2 nCi/g)."

NUREG 1608, section 3.2.1 - "For the purpose of complying with the SCO

definitions in the domestic transportation regulations only (DOT, 1996; NRC,

1996a): Contamination is the presence of a radioactive substance on a

surface in quantities in excess of 0.4 Bq/cm2 (2200 dpm/100 cm2) for

beta-gamma emitters and low toxicity alpha emitters or 0.04 Bq/cm2 (220

dpm/100 cm2) for all other alpha emitters."  

     

The opinions and concerns expressed above are my own.



Randy Redmond

Radiological Control Organization

BWXT Y-12 L.L.C.

Oak Ridge, TN

865-574-5640





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