Re: Surface Contaminated Objects

Group,

I've actually found that the Reg Guides essentially provide the

interpretation of how to implement the code. A Reg Guide is considered guidance necessary

for a "good" program. If you don't follow the reg guide, you can find

yourself to be interpreted to be outside of the reg real quick when an event occurs.

If you make no attempt to follow a Reg Guide, then how can you ask for

leniency from the NRC. In general a good program will comply with most aspects of a

Reg Guide and have written documentation why a particular aspect of a Reg

Guide doesn't apply to your type of license.

With respect to the contamination limits in Reg Guide 1.86, they seem to very

clearly apply to decommisioning and not to operating power reactors. In the

power world, there are no release limits, but sensitivity requirements of 5000

dpm/100 cm^2 fixed+removable and 1000 dpm/100 cm^2 removable. We generally

look for 100 net cpm above background for a smear.

The actual end result meter reading on a frisker for a DOT shipment won't

change on October 1, 2004. The table values for wipe limits are 10 times higher,

but the 10% smear removal efficiency is also codified. So the net difference

is "0". Take a look to see if you think you need to modify your smear MDA to

account for smear collection efficiency...

Make sure you chat with burial sites and processors to see if they are also

going to apply the smear removal efficiency to the contamination limits on

disposal containers. I don't believe they are looking to modify their site

acceptance criteria, which means your acceptable disposal container contamination

limits just got reduced by a factor of 10 or they'll say the value is the same

and not to apply the smear removal efficiency to the disposal container. This

is where good procedures come in....

Glen