ML20033D832
| ML20033D832 | |
| Person / Time | |
|---|---|
| Site: | 05000054, 07000687 |
| Issue date: | 09/15/1984 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20033D833 | List: |
| References | |
| NUDOCS 8410230384 | |
| Download: ML20033D832 (12) | |
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4-V ENCLOSURE'2 r
1 GUIDANCE AND DISCUSSION OF-REQUIREMENTS FOR AN APPLICATON TO TERMI'NATE A~
NON-POWER REACTOR FACILITY' OPERATING LICENSE-Revision 1-i
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Prepared by i
Standardization and Special Projects Branch j
Division of Licensing 1
Office of Nuclear Reactor Regulation d
U. S. Nuclear Regulatory Commission j
September 15, 1984 j
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GUIDANCE AND' DISCUSSION OF REQUIREMENTS FOR AN APPL 1CATON TO TERMINATE A 1
NON-POWER REACTOR FACILITY OPERATING LICENSE' The following guidene.e and discussion of requirements for requesting authority to decommission and terminate a non-power reactor facility operating license is en update and adaptation of and supplements NRC Regulatory Guide 1.86, "Termi-nation of Operating License for Nuclear Reactors," a copy of which is attached.
Although Regulatory Guide 1.86 pertains specifically to power reactors, rest of it is applicable to non-power reactors as well.
The_ guidance contained herein is interim, pending issuance and implementation of new regulations on decommis-l sioning.
I.
GENERAL-INFORMATION 1., _Aoplication An application for authority to initiate decommissioning should.be filed under 10 CFR 50.82.
It is recommended that the fuel be removed from the core as-soon as practicable and shipped off-site in accordance with DOE, NRC and DOT require-ments under the existing facility operating license,. which permits all' activities associated with those tasks.
The application should be an inclusive document that.contains all of the necessary information to enable staff. review without extensive reference to other documents.
-Three signed and notarized originals and 19 copies.cf the application should be submitted in accordance with 10 CFR 50.30 and Generic Letter No. 84-18 from-l Darrell Eisenhut to all non-power reactor licensees, dated Jtily 6,1984. - Refer to 10 CFR 170 for information on licensing amendment fees, if(applicable.
2.
The Decem5issionino Plan (DP)
The DP describes an organized means-for removing' all. ' radioactive components and l
essentially all radioactivity within the reactor facility that was covered by the facility operating license The request for dismantling of the reactor and -
termination of the fac.ility operating' license should include a_ detailed plan t
describing the organization and program that will'be used during the decommis-sioning of the facility.
The plan should accomp1.ish the required tasks with the least possible exposure to radioactive and non-radioactive contaminants.
It-also must describe clearly how the licensee will-continue to, protect.the health :
l and safety of the public and the environment during the dismantling activities.
Termination of the license by_the NRC. requires that the decommissioned facility be suitable for unrestricted use.
At this time, the acceptance criteria being l
used by the staff for unrestr.icted use are either Sj. Roentgen /hr above background I
et 1 meter from the surface or 10 mrem /yr above background, considering reason-able proximity and occupancy, and the permissible surface. contamination levels
.c given in Table 1 of Regulatory Guide 1.86.
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- A DP submitted to NRC is reviewed in the above context.
Following approval of the DP by the NRC, the NRC will issue an Order authorizing imple, mentation.
This Order supersedes and replaces the operating license.
The plan may then be imple-mented by the licensee.
Following notification by the-licensee.of completion of the decontamination and disposal of components and materials from the facility,.
NRC Regional staff will conduct an on-site survey to verify that the acceptable I
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activity and contamination levels are satisfied. - When the requirements are i
satisfied, NRC will issue an Order that terminates the license and any further NRC jurisdiction over the facility.
Should the DP include fuel removal and partial decontamination, followed by a relatively long delay before the remaining radioactive components are removed, NRC.may amend the license to permit " Possession Only".
This would pertain until l
the Order authorizing dismantling is issued.
I The' " Possession Only" license permits the ownership and possession of fuel, by-1 product material and reactor components,-but does not permit operation of the reector.
This license status, though permitting significant relief from the technicalz specifications, still requires edequate surveillance, monitoring and reporting.
3.
Technical Soecifications The technical specifications that are part of the operating license assure.the safe operation of the reactor.
Most of these specifications 'wguld not be appli-
- Ole to those, operations essociated with a DP.
The DP should therefore include l
relevant technical specifications or controls.
Since the plan becomes part of the license, it completely replaces the technical specifications which were l
Appendix A to the operating license.
4 Environmental Report When requesting authorization for decommissioning and termination, the licensee rust also submit an Environmental Report (ER). 'To the extent practicable, the ER should be written usine the guidelines in 10' CFR 51.45.
The ER should address:
(1) the collective dose equivalent to workers for the entire dismantling and-decommissioning project; (2) exposure of the general public ;to radioactive effluents released during the proposed activities; and (3) anticipeted exposure levels of the general public following license termination.
The NRC must deter-mine if an Environmental 1mpact Statement (E]S) is necessary.
To make this cetermination, the staff r:vst prepare an Environmental-Assessment (EA) based on the licensee's ER.,
if it is deterrined that an EIS is not 6eeded, the staff l '
pre;eres and publishes a finding of no sicnificant environmer.tal impact (i.e.,
ceclares that an E]S is not required).
The EA, which forms the basis for this l
c: ster-ination, is made publicly available.
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II. -LICENSEE'S DECOMMISSIONING PLAN OUILJNE AND CONTENTS 1,0. Plan Background and Management v
The DP should, include, as a minimum, the information discussed below'and be in general accordance with the following recor:rnended format and outline.
Paragraph numbers correspond to' suggested section numbers in the DP,
]l 1.1 Summary Descript %n This section should contain a brief description of the reactor facility, the,
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duration of the license, the approximate usage during:the licensed period and.
a synopsis of the DP.
A discussion of-alternativesL to the: selected decommis-sionino approach (if any), cost estimates for each alternative, availabilityf of.
funds (includingsourcesofoutsidefinancing,ifappropriate),majortasksand schedules- (in particular, the estimated date for completion of decommissioning),
items subject to quality assurance, tasks:that may be performed by_a contractor, and the final radiation survey plan all should be included..,The collective dose-equivalent (person-rem) for the selected approach, asicompared to~ each alterna -
H tive' considered, also should be included.
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1.2 Facility Operating History i
i This section-should describe historical information.on operational occurrences that could impact decommissioning safety.
Such things :as-radioactivity spills i
or releases that resulted in significant contamination,. specific ~ location of-
_i systems and equipment that may contain high. levels of radiation, and' areas of-
.the site that may contain radioactive hot-spots should be described, ~This type of information should be obtained from facility records and personnel familiar with the facility, 1,3 Current Radiolooical Status of Facility t
Padiation levels for systems, structures, 'and components should be established '
at the time the DP is submitted.
It is recognized that, at the ' time of the DP submittal, complete information might not be available for p.lanning' of: activities.
However, to the extent practicable, sources of radiation that are the basestfor
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radiation protection should be described.
Information in this section should be updated as additional radiation surveysL are made.
The description should tabu-late sources by isotopic compositon and gamma ray energy groups,-strength (curie-content), and geometry.
Sources of radioactivity should be' located on reactor core and plant layout drawings,. For all sources, including activation product' I
sources, the rodel(s) and parameters for calculating.the source magnitudes should-be provided.
Exposure pathways to the public also should be analyzed.
t 14 De ommissionino Alternative This section should describe the decommissioning alternative selects.d (eig, safe entonbr.ent (ENTOMB), partial dismantling folbwed by safe storege and eventual completion of the dismantlino of the facility.(SAFSTOR), or continuous dismant-
-ling and decontamination of the facility (DECON).
It should also describe:the 1
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measures proposed to reduce radiation to levels that permit-unrestricted use o" the area, if that is the ultimate goal, or other alternatives to ensure that the utilizing personnel and the public will not be unduly exposed to radiation.
1.5 Decommissioning Organization and Resoonsibilities This section should identify key positions in the decommissioning organization and describe their functions.
The lines of authority up to upper _ management-
-levels should be indicated.
The person with onsite management authority should-be designated by position, along with a description of duties and responsibili-
-ties.
The education', training and experience requirements should be described-for. positions - that are important to safety.
The management policy and organizational structure related to ensuring that occupational radiation exposures are As Low As Reasonable Achievable- (ALARA)-
should be described along with the responsibilities and the activities of management and health physics personnel having responsibility for radiation
_prote tion and maintaining exposures ALARA.
1.6 Regulations, Regulatory Guides and Standards This section should identify and discuss the various' health physics and indus--
trial health criteria and' standards which will guide the actiyities described in the DP; for example, Regulatory Guide 1.86, ANSI /ANS-15.10-1981 and OSHA require-ments.
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1.7 Training end Qualifications-This section should contain a description of the proposed training program and personnel qualifications, including contractor personnel'as well_as licensee employees.
The description should include the scope of training-in decontami-
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nation, other decommissioning activities, industrial-hygiene, health, physics, and use and maintenance of monitoring and safety equipment.
The duties and responsibilities of persons responsible for'all training activi-l.
ties should be desianated and discussed.
The types of records that will be
. maintained for all training activities (e.g., status of trained-personnel, l
training of new employees, refresher or upgrading) should be~-described in this section.
2.0 Occurational and Radiation Protection Procrams 2.1 Eadiation Protection Procram This section should contain a description of methods for occupational radiation protection.
It should provide information on survey and personnel monitoring ecuipment, redia tion protcc;Un..Cai,;ues, and practices tha t will be employed by the licensee in 'meeti'ng the 10 CFR 20 requirements for protection.agai~nst and the ALARA commitment, o
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The health physics program during decommissioning should be described in detail.
The authority and responsibility of each position should also be identified. The criteria for selection of equipment and instrumentation for performing radiation 1
monitoring and personnel monitoring should also be provided in this section. The use, storage, calibration, testing, and maintenance of these instruments should be described,. The policy, methods, frequency, and procedures for conducting radiation surveys and personnel monitoring should also be described.
2.2 Industrial Safety end Hyoiene Program This section is concerned with the protection of personnel from detrimental non-i i
radioective exposures such as would be associated with controlled demolitions, I
airborne debris, and the use of various solvents to reduce or eliminate. removable radioactive contamination.
The industrial (other than radiation) safety program should be described in i
detail and should conform with all appli:able OSHA and industrial safety require--
rents.
The authority and responsibility of each position should.be included.- In l
addition, this section should include tN criteria for. selecting equipment and l
methods for controlling non-radioactiv0 exposures.
Accident prevention and response should be included.
2.3 Contractor Assistance The licensee may choose to use contractors to accomplish some.or all of the decommissioning activities and tasks.
However, the responsibility for health and safety during all aspects of decommissioning' rests with the licensee, For each contract, the plan should describe the scope. of work to be accomplished, the administrative control system used to ensure adequate health and safety pro-i tection, and the relationship of the contracted work to the schedule for the
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2.4 Cost Estimate and Funding 4
This section should present a cost estimated, by task, for accomplishing the decommissioning.
This estimate should be based on conditions at the facility at estimated costs of the termination radiation survey (see Section 3)y include the time the DP is submitted.
The cost estimate should specificall The licen-see should also show how sufficient funds will be made available to accomplish decommissioning.
If a-delayed decommissioning alternative is selected,.-include plans for periodic reevaluation during the safe-storage period.
3.
Dismantlino and Decontamination Tasks and Schedules 3.1 Tesks This section should descrive ne U m and activities that will be utilized to' prepare the site and facility and for' tne actual dismantling and decontamination operations.
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For major activities, the relationship between activities and tasks should be shown. Where pertinent, the schedules for accomplishing interrelated activities and tasks should be delineated.
Schedules and/or critical path-type diagrams should clearly indicate the estimated time for completion of_ major activities
.and for completely decommissioning the facility.
L 3.3 Task Analyses Descriptions and procedures for accomplishing major activities should be pro-vided.
Any special health and safety considerations should_be addressed for each task, as appropriate.
3.4-Safe Storace i
Activities related to. preparing and maintaining the facility and site for safe.
storage of any remaining radioactive components unti1 their removal is accom '
plished should be described to the extent they are known.
4.0 Safecuards and Physical Security l
A description and schedule of any proposed changes' to the NRC-approved physical security plan and, when a'pplicable, the' NRC-approved material, control _ and 'accoun-tability plan should be submitted in this section.
If this section -contains information which must be protected from public disclosure in'accordance with 10 CFR 73.21 or 10 CFR 2.790, it should be submitted under separate: cover.
5.0 Radiolooical Accident Analyses A discussion of radiological accidents related to fuel handling during 'decommis-sioning should be presented in this section if the. fuel has not been removed-pre-viously under the operating license.
Sufficient _ detail _should be included so that the consequences of any significant -potential accidents are cle'arly defined and 4talyzed.
If no fuel is present on-site, radiological accidents need not be considered except for those that would fall within the general categories included in Section 3.
6.0 Radioactive Materials and Waste Manaaement 6.3 Fuel Disposal New fuel should be shipped off-site as soon as practicable.
Irradiated. fuel
'i also should be removed from the' core as soon as practicable and shipped off-site to f acilitate the remaining dismantling tasks.. Irradiated fuel may be removed frcm the reactor and shipped under the existing operating license and technical specifications, prior to approval of the DP.
Disposal of fuelimust be accom-plished in_accordance with the requjrex nts >f tne Uu W ar Maste Policy Act of 19E.2 and applicable NRC and DOT regulations.
Also, if the fuel is owned by the DOE, DOE will decide its destination and disposition.
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6.2 Radioactive llaste Processino This'section should describe the gaseous, liquid, and solid radioactive wastes that will be generated during decontamination and other decommissioning activi-ties and the systems used for their detection, control, storage, treatment and:
disposal.
The discussion should be related to radioactivity levels, volumes of radioactive w'este, existing systems that will be retained in an operational status, and redwaste management systems that have to be implemented to meet the L
various safety and ALARA requirements.
7.0 Technical and Envircnmental Specifications After the nuclear fuel js removed from the reactor and shipped off-site, most of th'e'cperating license technical specifications are no longer applicable, if the license has been amended or superseded by an Order, as discussed in Section 1,3, above.
Technical specifications during the decommissioning. phase should be derived from an analysis of the health and safety and environmental assessment of decommission-ing the. facility. -The analysis should lead to the conclusion that industrial and radiation exposures of decommissioning personnel and the public are ALARA and are small fractions of respective limits and guidelines (10 CFR 20, NIOSH, OSHA, et.c.).
The technical specifications or controls that are developed should reflect the i
safety precautions necessary during the various decommissioning phases.
8.0 Proposed Termination P.ediation Survey-Plan l
The purpose nf a termination radiation survey plan-is to provide the bases for verifying that the facility and site meet prescribed radioactivity levels that permit their unrestricted pse.
This section'should describe the survey plan that will provide the data necessary to demnnstrate that the facility and site meet criteria for release for unrestricted use, if that is the ultimate goal.
The description should include such things as (,1) the: proposed method for assuring that sufficient radiological data'for all pertinent structures, sur-faces, systems, components, and site are included in the survey-(diagrams and plant layout drawings may be used to facilitate presentation), (2) the type I
and number of radiation readings, for both internal and external surfaces, (3)
L the type and operating condition of instruments to be used, including their l
- ower limit of detection, (4) procedures used to obtain and analyze date, and (5) procedures used for auditing and verificatfori of data.
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INTERIM REPORT TO NRC l!bere a facility is to be only partially dismantled and will remain in safe i
storage for more than one year, an interim report should be submitted to the NRC-at the conclusion of the partial dismentling phase describing the interim status-and delineating the various safety, health physks, safeguards and environmental measures that will be taken to ensure the safety of operating pedonnel,. the public and tne facility and to minimize environmental impacts.
Thifinterim report also should include an update of plans'and schedules for the remaining l
dismantlino activities.
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-8 IV.
FINAL REPORT TO NRC This report should be submitted at the time the licensee requests the'NRC termi-nation survey and should summarize the activities' that were conducted at the facility in preparation for receipt of the NRC Order for. license termination.
The report shpuid present the results of the final radiation and environmental' surveys, the respective analyses and their relation to guidelines and limits for unrestricted use of.the facility.
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June 1974 U.S. ATOMIC ENERGY COMMISSION r REGULATOR:Y GUIDE g!
DIRECTORATE OF RESULATORY STANDARDS og REGULATORY GUIDE 1.88 TERMINATION OF OPERATING LICENSES FOR NUCLEAR REACTORS A. INTRODUCTION A licensee _having a possession.only license must retain, with the Part 50 liceme, authorization for special:
Section 50.51, " Duration of liceme, renewal," of 10 nuclear material (10 CFR Part 70, "Special Nuclear CFR Part 50, " Licensing of Production and Utilization Material"), byproduct material (10 CFR Part 30," Rules
' Facilities," requires that each license to operate a of General-Applicability to Licensing of Byproduct production and utilization facility be issued for a Material"), and source material (10 CFR-Part 40, specified duration. Upon expiration of the specified
" Licensing of Source Material"), until the fuel, radio.
period, the license may be either renewed or terminated.
active components, and sources are removed from the by the Commission. Section 50.82, " Applications for -
facility. Appropriate administrative controls and facility -
termination of licenses," specifies the requirements that requirements are imposed by the Part 50 license and the must be satisfied to terminate an operating license, technical specifications to assure that proper surveillance -
including the requirement that the dismantlement of the is performed and that the reactor facility is maintained facility and disposal of the component parts not be i in a safe condition and not operated, inimical to the common defense and security or to the health and safety of the public. This guide describes A possession only liceme permits various options and methods and procedures considered acceptable by the procedures for decommissioning, such as mothballing, Regulatory staff for the termination of operating entombment, or dismantling. The requirements imposed licenses for nuclear reactors. The Advisory Committee depend on the option selected.
on Reactor Safeguards has been consulted concerning -
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this guide and has concurred in the regulatory position.
Section 50.82 provides that the-licemee 'may dis.
mantle and dispose of the component parts of a nuclear B. DISCUSSION reactor in accordance with existing regulations. For research reactors and critical facilities, this has usually -
When a licensee decides to terminate his nuclear meant the disassembly of a reactor and its shipment reactor operating license, he may, as a first step in the offsite, sometimes to. another appropriately' licensed process, request that his operating license be amended to organization for further use. The site from which a restrict him to possess but not operate the facility. The reactor has been removed must be decontaminated, as advantage to the licensee of converting to such a necessary, and inspected by the Commission to deter.
possession only license is reduced surveillance require.
mine whether unrestricted access can be approved, in ments in that periodic surveillance of equipment im.
the case of nuclear power reactors, dismantling has portant to the safety of reactor operation is nolonger usually been accomplished by shipping fuel offsite, required. Once this possession.only license is issued, making the reactor inoperable, and disposing of some of reactor operation is not permitted. Other activities the radioactive components.-
related to cessation of operations such as unloading fuel y
from the reactor and placing it in storage (either onsite Radioactive components may be either shipped off.
of offsite) may be continued.
site for burial at an authorized burial, ground or secured usAEC REGULATORY GUIDES copin o bigevesmov
.eigned by, gi ny inogeig "0"50'.00. i7od"nc E,*I.'Sf*n.*Ie oe*imEO@iE. Ep.Ts N7S..f.U.a.# ",oD'."Mo',%71.4 iiTS Ui ZO,'.i7, d
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and/'or-shielding material. Means such as a remote.
(1) Environmental surveys, 4
readout intrusion alarm system should be provided to indicate to designated personnel when a physical banier (2) Facility radiation surveys,.
is penetrated. Security personnel that provide access control to the facility may be used instead of the (3) Irispections of the physical barriers, and physical barriers and the intrusion alarm systems.
(4) Abnormaloccurrences.
- b. The physical barriers to unauthorized entrance into the facility, e.g., fences, buildings, welded doors.
and access openings, should = be inspected at least
- 4. DECONTAMINATION FOR RELEASE FOR UN.
quarterly to assure that these barriers have not deterior.
RESTRICTED USE ated and that locks and locking apparatus are intact.
If it is desired to terminate a license and to eliminate c, A facility radiation survey should be performed at any further surveillance requirements, the facility should least quarterly to verify that no radioactive materialis be sufficiently decontaminated to prevent 'rfsk to the escaping or being transported through the containment public health and safety. After the decontamination is barriers in the facility. Sampling should be done along satisfactorily accomplished-and the site inspected by the most probable path by which radioactive material the Commission, the Commission may authorize the-such as that stored in the inner containment regions license to be terminated and the facility abandoned or -
could be transported to the outer regions of the facility:
released' for unrestricted use. The licensee should per.
and ultimately to the environs.
form the decontamination using the following guide.
lines:
- d. An environmental radiation survey should be performed at least semiannually to verify that no
- a. The licensee should make a reasonable effort to signficant amounts of radiation have been released to the climinate residual contamination.
environment from the facility. Samples such as soil, vegetation, and water should be taken at locations for
- b. No covering should be applied to radioactive which statistical data has been established during reactor surfaces of equipment or structures by paint, plating,or e
operations, ether covering material untilit is known that contamina-(i
' tion levels (determined by a survey and documented) are
- e. A site representative should be designated to be below the limits specified in Table 1. In addition, a
-responsible for controlling authorized access into and reasonable effort should be inade (and documented) to movement within the facility, further minimize contamination prior to any-such covering.
- f. Administrative procedures should be established for the notification and reporting of abnormal occur.
- c. The radioactivity of the interior surfaces of pipes, rences such as (1) the entrance of an unauthorized drain ' lines,~ or ductwork should be determined by person or persons into the facility and (2) a significant making measurements at all traps and other appropriate change in the radiation or contamination levels in the access points, provided contamination at these locations facility or the offsite environment.
is likelytto be representative of contamination on the interior of the pipes, drain lines, or ductwork. Surfaces I
- g. The following reports should be made:
of premises, equipment, or scrap which are likely to be contaminated but' arc of ~such size, construction, or (1) An annual report to the Director of Licensing, location as to make the surface inaccessible for purposes U.S. Atomic Energy Commission, Washington, D.C.
of measurement should be assumed to be contaminated 20545, describing the results of the environmental and in excess of the permissable radiation limits.
facility radiation surveys, the status of the facility, and 1
an evaluation of the performance of security and
- d. Upon request, _the Commission may authorize a surveillance measures.
licensee to relinquish possession or control of premises, l
equipment, or scrap having surfaces contaminated in (2) An abnormal occurrence report to the Regula-excess of the limits specified. This may include, but is L
tory Operations Regional Office by telephone within 24 not limited to, special circumstances such as the transfer l
hours of discovery of an abnormal occurrence.- The of premises to another licensed organization that will abnormal occurrence will also be reported in the annual continue to work with radioactive materials. Requests report described in the preceding item.
for such authorization should provide:
- h. Records or logs relative to the following items (1) Detailed, spm'le infutu.. L.u.U.ng, the
-should be kept and retained until the license is termi' premises, equipment, scrap, and t'adioactin contami-nated, after which they may be stored with other plant nants and the nature, extent, and degree of residual records:
surface contamination.-
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TABLEI ACCEPTABLE SURFACE CONTAMINATION LEVELS b
b NUCLIDE:
AVERAGE c max]Muyb d REMOVABLE e U-nat, U-235, U 238, and 5,000 dpm a/100 cm2 -
15,000 dpm a/100 cm2 1,000 dpm a/100 cm2 -
associated decay products Transuranics, Ra 226 Ra 228, 100 dpm/100 cm2 300 dpmn00 cm2 20 dpm/100 cm2 Th-230, Th 228, Pa 231,
. Ac 227,1125,1129 Th nat, Th 232, St.90, 1000 dpm/100 cm2 3000 dpm/100 cm2 200 dpm/100 cm2 Ra 223, Ra 224, U.232, -
I126,1131,Il33 Beta gamma emitter (nuclides.
5000 dpm M/100 cm2 15,000 dpm M/100'em2 1000 dpm h/100 cm2 with decay modes other than alpha emission or spontaneous fission) except Sr.90 and others noted above, nWhere surface contamination by both alpha and beta gammaomitting nuchdes exists, the limits established for alpha and.
beta gamma emitting nuchdes should apply independently.
bAs used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as determined by correcting -
the counts per minute observed by an appropriate detector for background, ef!1ciency, and geometric factors associated with the instrumentation.
' Measurements'of aveiage contaminant should not be averaged over more than I square meter. For objects ofless surface area, the I
average should be derived (n; each such object.
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The maximum contamination level applies to an area of not more than 100 hm.
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'The amount of removable radioactive material per 100 cm of surface area should be determined by wiping that area with dry illter or soft absorbent paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency. When removable contamination on objects of less surface area is determined, the pettinent levels.
should be reduced proportionally and the entire surface should be wiped. -
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