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RE: Surface Contaminated Objects and release limits
Randy and all,
You raise a good point: Under certain circumstances, unconditionally
released and unregulated radioactive material (Under NRC regulations) must
be shipped as radioactive material (under DOT regulations.)
A similar "conflict" existed some years ago. "Deregulated" materials under
NRC regulation 10 CFR 20.2005 were still radioactive for shipping purposes.
As a result of this "conflict", the DOT exempted from its regulations all
material meeting the requirements of 10 CFR 20.2005. Perhaps DOT would be
willing to do this again for a broader class of unconditionally released and
unregulated radioactive material.
Regards,
Wes
Wesley R. Van Pelt, PhD, CIH, CHP
Wesley R. Van Pelt Associates, Inc.
Consulting in Radiation Safety and Environmental Radioactivity.
http://home.att.net/~wesvanpelt/Radiation.html
mailto:wesvanpelt@att.net
-----Original Message-----
From: owner-radsafe@list.vanderbilt.edu
[mailto:owner-radsafe@list.vanderbilt.edu]On Behalf Of Redmond, Randy (RXQ)
Sent: Thursday, January 23, 2003 8:49 AM
To: 'radsafe@list.vanderbilt.edu'
Cc: Wical, Scott Andrew (S3W); Oliver, Bobby (OLV); Barker, James H. (X6B);
'mark.richards@rfets.gov'
Subject: RE: Surface Contaminated Objects and release limits
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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