No Subject

[besta@tis.inel.gov (Bates Estabrooks -WIPP Site - N.M.)]

December 12, 1995

Several days ago I posted a requested for guidance on DOE release limits for
items such as labware contaminated with small amounts of Pu, i.e. internal
alpha contamin., not readily quantified to dpm/sq. cm..  The various (and
varied) responses, with their source, that I received, may be of interest to
RADSAFE subscribers, to wit:

	1. "I think you will find out there are none."- University

	2."Wouldn't these qualify as clean under the definition of TRU waste?"-
University 
		
		(Note: This is true, per DOE 5820.2A, i.e. <100 nCi/g of TRU, but then
they become LLW, and still no useable release limits.)

	3. "I believe free release is out of the question."- University

	4. "There is no way you can release this to the environment." -DOE Site

	5. "I would just use the contamination release limits and try to smear...
the surfaces." or "you can do (don't laugh) (sic) gamma spec on the items,
quantify it in dpm per item (assuming the items are less than 100 sq cm),
and then release it if it's less than the contamination limit??" - DOE Site

			(Note: the gamma/photon spec idea is not far fetched.  This is how the
ARG/RAP guys find Pu and Am in the event of a "Broken Arrow.")

	6. "Look at DOE 5400.5, Chapter II, 5.c."- DOE Site
			
			(Note: 5400.5; II, 5.c.(6); Volume Contamination states: "no guidance is
currently available for release of material that has been contaminated in
depth... (e.g., radioactivity per unit volume or per unit mass.)...  Such
materials may be released if criteria and survey techniques are approved by
EH-1."
	
	7. "if it's a piece of equipment or property then there are specified
limits (check 10 CFR 834, 10 CFR 835, or the Rad Con Manual."- University

	8. "See NRC Reg. Guide 8.21, NRC I.E. Circular 81-07."- ???

	9. "Just as you cannot have someone who is 'a little bit pregnant',...
there is no such thing as 'just a little Special Nuclear Material'."-  ???


On the basis of this input, and some additional discussions/reading, it
appears that this issue is still unsettled, but will move closer to an
answer if and when 10 CFR 834 is issued.  Thank you all for your responses/help.

Bates Estabrooks