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

[BLHamrick@AOL.COM]

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