Re: D&D of Buildings using Volumetric Criteria

["Leon E Brown" <lebrown@cmsenergy.com>]

On 6/30/99 Jim Blute wrote:  "The traditional method of decommissioning a
building is to use surface contamination limits (e.g., NUREG 1.86 limits or dose
based derived values using dose modeling codes such as RESBUILD or DandD) before
the building is demolished or released.  An emerging option being investigated
in the industry is the use of volumetric release criteria (e.g. pCi/g) for the
"free release" or on-site disposal of concrete rubble and/or building debris
following demolition of the building/structure."

The Big Rock Point (BRP) Restoration Project is planning to use a variation of
the emerging option referenced.  BRP plans to complete all site demolition
activities prior to performing the license termination survey.  The site will
then be released as a "greenfield" in accordance with dose based derived
concentration guideline levels (DCGLs) based on RESRAD and/or DandD pathway
analyses for soil.

To allow the disposal of debris during demolition, BRP is planing to establish a
volumetric sampling/assay "free release" program to use in returning the site to
a "greenfield" condition.  BRP already has a contract with GTS Duratek to
perform this function.

BRP plans to establish criteria for the volumetric sampling/assay program based
on detectable levels of radionuclides.  An NRC license amendment request is
being prepared to establish a solid effluent pathway similar to the currently
authorized liquid and gaseous effluent pathways.  The solid effluent pathway
will contain limitations which result in ALARA environmental impacts similar to
the ALARA environmental impacts of the liquid and gaseous effluent pathways
obtained by imposing limitations based on 10 CFR 50, Appendix I guidelines.

The solid effluent pathway limitations will be dose based volumetric release
criteria developed using BRP site specific parameters rather than the default
parameters of draft NRC guidance (Draft NRC NUREG-1640) being used for the
proposed NRC "clearance" rulemaking.  Using this approach is intended to provide
BRP the capability to release solid demolition debris prior to completion of the
NRC "clearance" rulemaking process.

Leon E. Brown
Sr. Consultant
Big Rock Point Restoration Project
(231) 587-8419
lebrown@cmsenergy.com


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