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Assuming you're in a decommissioning mode (i.e.,
license termination is your objective) and the installation does not have a
license condition requiring UFC standard demonstrations for effluents and direct
radiation, the UFC standard would not apply via a separate compliance
demonstration. The UFC standard was considered by the NRC when
establishing site release criteria under the license termination rule (LTR; see
SECY-97-046A).
Note also that the LTR encompasses residual
activity only: "radioactivity in structures, materials, soils,
groundwater, and other media at a site resulting from activities under the
licensee's control. This includes radioactivity from all licensed and unlicensed
sources used by the licensee, but excludes background radiation. It also
includes radioactive materials remaining at the site as a result of routine or
accidental releases of radioactive material at the site and previous burials at
the site, even if those burials were made in accordance with the provisions of 10 CFR Part 20."
Rick Orthen
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