Re: MDA vs. Critical level for DOE Free Release surveys

[William V Lipton <liptonw@DTEENERGY.COM>]

I can't figure out why materials licensees have it easier than power

plants, but I stand corrected; thanx.



The opinions expressed are strictly mine.

It's not about dose, it's about trust.

Curies forever.



Bill Lipton

liptonw@dteenergy.com





BLHamrick@AOL.COM wrote:



>  In a message dated 10/29/2003 7:02:02 AM Pacific Standard Time,

> liptonw@DTEENERGY.COM writes:

>

>      NRC licensees, especially power reactor licensees are not

>      allowed to free

>      release any licensed material.

>

> Ooo, not exactly true.  NRC materials licensees, licensed for the use

> of unsealed materials generally commit to unrestricted area limits

> pursuant to procedures contained in the NUREG 1556 series.  These

> limits are used for the release of surface-contaminated objects from

> the restricted area to unrestricted use.  These limits are similar to

> the old Reg. Guide 1.86 values that were adopted for use by materials

> licensees in “Guidelines for Decontamination of Facilities and

> Equipment Prior to Release for Unrestricted Use or Termination of

> Licenses for Byproduct, Source, and Special Nuclear Material, Policy

> and Guidance Directive� (FC 83-23, November 4, 1983). A direct

> quote from the current guidance (NUREG 1556) says: "When equipment or

> facilities that are potentially contaminated are to be released for

> unrestricted use, the above table provides the maximum acceptable

> residual levels.   To the extent practicable, it is appropriate to

> decontaminate to below these levels.   Surface contamination surveys

> should be conducted for both removable and fixed contamination before

> these facilities or equipment are released from restricted to

> unrestricted use, to ensure that they meet these limits." In addition,

> volumetrically contaminated materials are routinely released from NRC

> licensees, after a case-by-case approval.  See, e.g., STP 03-003,

> available at:  http://www.hsrd.ornl.gov/nrc/home.html, which

> states: "For prospective cases or cases that are not grand-fathered -

> where proposed offsite concrete releases are not covered under an

> existing decommissioning plan, 20.2002 disposal, license termination

> plan, or other specific license condition, controlled release of

> concrete with volumetric sources of contamination may be approved

> under a criterion of a "few mrem" (pursuant to a 20.2002 procedure,

> decommissioning plan, license termination plan, or other specific

> license amendment) rather than use of license termination criteria

> either in Subpart E of 10 CFR Part 20 or in the SDMP Action

> Plan." Thus, BRC failed only as a GENERIC policy.  It has been

> implemented in one form or another continuously since the AEA was

> enacted in 1946. Barbara