Re: Free release of Volume and Bulk Waste

[jgbarnes@ix.netcom.com (JAMES BARNES)]

Hi Pat,

You might want to take a look at the following NRC I&E Notices:

81-07:  Control of Radioactively Contaminated Material
83-33:  Nonrepresentative Sampling of Contaminated Oil
85-92:  Surveys of Wastes Before Disposal from Nuclear Reactor 
Facilities

Also look at 10 CFR 20.2002, "Method for obtaining approval of proposed 
disposal procedures," and IEN 83-05:  "Obtaining Approval for Disposing 
of Very-Low-Level Radioactive Waste - 10 CFR Section 20.302."

The issues generally are:

    1)  Homogeneity of the materials:  What do you do to ensure that 
the media is uniformly mixed and presents a uniform consistency when 
being sampled (i.e., removal of "big chunks," mixing of media, etc.)

    2)  Methodology for the determination of the LLD of a detection 
system:

        How are you going to sample and count the media.  What 
assurance do you have that your sampling scheme is representative of 
the overall bulk of materials to be released?  If it's a pile of dirt, 
how do you obtain a sample from the center of the pile, and not just 
the top?

        What steps have you taken to prepare a source and a calibration 
scheme that matches the configuration and mixture presented by your 
sampling program (i.e., do you have "validated" spiked samples that you 
can use to calibrate your counting system--although arguably fun to do, 
"counter geometry correction" calculations are too "iffy" and don't buy 
you anything; you need to count something in the same configuration as 
your sample sets).

We have been through this in some of our decontamination and 
decommissioning work.  If you would like further information, please 
feel free to call, and I'll hook you up with our gurus.

Jim Barnes, CHP
Radiation Safety Officer
Rockwell Aerospace, Rocketdyne Division
(818)-586-5766

-------------------------------------------
You wrote: 
>
>I've been tasked to develop a procedure to "free release" volume and 
bulk
>waste for Los Alamos National Laboratory. Because of a DOE moritorium 
we are
>currently unable to free release to any offsite sanitary landfill any 
waste
>that is above "background" (no added radioactivity). Does anyone have 
or
>know of any guidance documents, references, reg guides, etc. (DOE or 
any
>other) or have themselves developed such a procedure? I would greatly
>appreciate any help on this matter.
>Patrick J. LaFrate
>ESH-1 Health Physics Operations
>Los Alamos National Laboratory
>P.O. Box 1663  MS K487
>Los Alamos, NM  87545
>
>Tele: 505-667-7137
>Fax:  505-667-6116
>email: lafrate@lanl.gov
>
>