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RE: Application of 40 CFR 190



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