RE: Release Criteria for Heavy Equipment

[Craig Reed <CReed@novoste.com>]

	Elizabeth,

	Kelly's assessment is on the money.  Contamination on discrete
items is not a dose issue, it's a political issue.   Releasing surfaces
that are above consensus regulatory values is a challenge because the
technical analysis (i.e., the dose calc) to justify an excepted approach
often yields release values much much higher than the regulatory values
(with loose TRU being the normal exception).   

	Higher limits can be obtained, but you need concurrence from
Line Mgt within your organization, within DOE and likely from the State
willing to accept your released item.  You have to go to those folks (in
order) with dose and a cost estimates for the alternatives and let them
evaluate the costs and accept the risk.

	What the regulations do not address is the statistical certainty
of a release survey (i.e., one driver for MARSSIM).  Of course the media
won't care that that you met a 90/90 test when you released an item if
it was later found contaminated (above the limits), but at least you
will have the regulator concurrence on the public risk. 

	You did not say and it may not fit your situation at all, but if
you believe the items (or at least large portions of the items) are
uncontaminated then you can make an effort at cost savings with the
existing limits by implementing statistical surveys at fewer sampling
points.  You increase the statistical uncertainty of the release as a
whole but you stack the deck in your favor by biasing surveys to the
likely affected points.  HP tech's already do this on discrete items:
they just assume the risk (for you) themselves and move on.  

	Finally, when it's all said and done, you have to do as much
surveying (and spend as much money) as the HP that comes behind you.

	Craig Reed
	creed@novoste.com

	      

> --- Elizabeth Algutifan  wrote:
> > To all HPs in the DOE world:
> > 
> > We are in the process of attempting to release several pieces of
> > heavy equipment
> > for unrestricted use and are concerned with time and money factors
> > (aren't we
> > all!).  I have the following questions for you:
> > 
> > 1. Are any of you currently using surface criteria release limits
> > greater than
> > DOE Order 5400.5 Table IV-1 values for any items (not just heavy
> > equipment)? 
> > 
> > 2. If you have been approved to go above the Table IV-1 values,
> > what process did
> > you go through and what, if any, resistance did you meet from
> > regulators? 
> > 
> > Thanks in advance for your war stories,
> > 
> > Elizabeth Algutifan,
> > Health Physicist
> > Weldon Spring Site Remedial Action Project
> > St. Charles, MO 
> > Elizabeth_Algutifan@wssrap-host.wssrap.com
> > 
> >
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