Surface Contaminated Objects

["Redmond, Randy (RXQ)" <redmondrr@Y12.doe.gov>]

Amendment to 49 CFR goes into effect October, 2004.  Maybe some of you will

remember my tirade January 2003 over the definition of contamination that is

being included (see January 2003 Archives).  The DOT definition of

contamination is:



"Contamination means the presence of a radioactive substance on a surface in

quantities in excess of 0.4 Bq/cm 2 for beta and gamma emitters and low

toxicity alpha emitters or 0.04 Bq/cm 2  for all other alpha emitters.

Contamination exists in two phases.

(1) Fixed radioactive contamination means radioactive contamination that

cannot be removed from a surface during  normal conditions of transport.

(2) Non-fixed radioactive contamination means radioactive contamination that

can be removed from a surface during  normal conditions of transport."



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.  DOT has established

what appears to be a new limit for determining is an item is "contaminated"

of 2200 dpm for beta-gamma and low toxicity alpha emitters.  Don't know

about your GM pancakes, but by all "calculations" I have a hard time

detecting 2200 dpm total beta-gamma and as far as detecting 220 dpm

beta-gamma on smear with a field instrument - oh well . . . ..



Anyone else dealing with this?





Randy Redmond (32458)

Radiological Control Organization

BWXT Y-12 L.L.C.

Oak Ridge, TN

865-574-5640





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