ML20040F510
| ML20040F510 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle, 05000000 |
| Issue date: | 02/04/1982 |
| From: | Swartz E COMMONWEALTH EDISON CO. |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| IEC-81-07, IEC-81-7, NUDOCS 8202090281 | |
| Download: ML20040F510 (3) | |
Text
7
[N Commonwealth Edison
[
) one First National Pla22. Chic 1go, lihnois
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O ~J Address R; ply to: P:st Offics Box 767
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/ Chicago, Illinois 60690 Februa ry 4, 1982 g
Mr. Richard C. DeYoung, Director S V Office of Inspection and Enforcement CSg 4
U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 k
Subject:
Dresden Station Units 1, 2 and 3 8
Quad Cities Station Units 1 and 2 g
Zion Station Units 1 and 2 g
LaSalle County Station Units 1 ano 2 g1 Byron Station Units 1 and 2 1
Braidwood Station Units 1 and 2 I.E. Circular No. 81-07 " Control o f Radioactively Contaminated Material" NRC Docket Nos. 50-10/237/249, 50-254/265, 50-295/304, 50-373/374, 50-454/455 ano 50-456/457 Reference (a):
J.
G. Keppler letter to Cordell Reed dated May 14, 1981.
i
Dear Mr. DeYoung:
Reference (a) transmitted I.E. Circular No. 81-07 to the Commonwealth Edison Company for our information and use.
Howeve r,
the NRC intent of this Circular is not clear to us for the following reasons.
Under the Discussion section on page one, there is a lengthy commentary on the need for guidanc'e "....which will provide reasonable assurance that contaminated materials are properly controlled and disposed of while at the same time providing a practical method for the uncontrolled release of materials from the restricted area...."
The discussion establishes the philosophy that there should be " operational detection levels below which the proba-bility of any remaining, undetected contamination is negligible and can be disregarded when considering the practicality of detecting and controlling such potential contamination and the associated negligible radiation doses to the public....."
While we agree that the need for guidance exists, I.E. Circular 81-07 does not provide such guidance in an unambiguaus way.
The Guidance section of the Circular states:
" Items and 60/
material should not be removed from the restricted area until they 3
have been surveyed or evaluated for potential radioactive contami-nation by a qualified individual."
Later in the same section, the j f-statement is made:
"The contamination monitoring using portable survey instruments or laboratory measurements should be performed with instrumentation and techniques (survey scanning speed, counting times, background radiation levels) necessary to detect 5000 dpm/100 cm2 total and 1000 dpm/100 cm2 removable beta / gamma contamination.
Instruments should be calibrated with radiation sources having
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r202090281 B20204 PDR ADDCK 05000010 0
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n Mr. R. ; C. DeYoung Februa ry 4, 1982 consistent energy spectrum and instrument response with the radionuclides being measured.
If alpha contamination is suspected, appropriate surveys and/or laboratory measurements capable of detecting 100 dpm/100 cm2 fixad and 20 dpm/100 cm2 removable alpha activity should be performed."
The ambiquity exists because the Guidance makes two independent statements.
First, that contaminated items should not be released, and second, that monitoring instruments should have a minimum sensitivity.
The Guidance does not specifically stateithat the minimum sensitivity and contamination limits are identical, 'or should be.
The philosophical statement made in the Discussion could imply that the lower level of instrument sensitivity should be used as the guidance for defining contamination levels.
The Commonwealth Edison Company " Radiation Protection Standards" include contamination and radioactivity limits (release criteria) for the unconditional release of materials from controlled areas to unrestricted areas.
Based upon our interpretation of the intent of Circular 81-07, the release criteria o f our " Radiation Protection Standards" have been changed to conform with the numeri-cal guidance for contamination limits given in the Circular.
See Attachment "A".
Because the Commonwealth Edison Company is actively utilizing release criteria based upon the ambiguous guidance given in Circular 81-07, we request that the NRC provide-us with a statement of concurrence with our interpretation of Circular 81-07, or provide the Commonwealth Edison Company with a definitive:
statement of release criteria for contaminated materials released to-unrestricted areas.
Due to our current decontamination schedules, your immediate attention to this matter is requested.
Please address any questions that you or your staff may have concerning this matter to this of fice.
Very truly yours, f-l,nm $ / i.
~
E. Douglas Swart Nuclear Licensing Administrator 1m cc:
H.
R. Denton (NRR),
J. G.
Keppler (RIII)
Region III Inspector - Dresden Region III Inspector - Quad Cities Region III Inspector - Zion Region III Inspector - LaSalle Region III Inspector - Braidwood Region III Inspector - Byron 3402.
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ATTACHMENT A 7
'The'fo'110wikh i$ an excerpt from the Commonwealth Edison Company
' Radiation Protection' Standards".
The Release Criteria have 2
been established ' based upon NRC guidance given in I.E. Circula r -
. No. 81-07 for the junconditional release o f materials from x
c5ntrolled areas? to unrestricted areas:
~
I
" Release Criteria Radiation-Chemk'stry will determine that all surf aces of the l'.
material are~ free of detectable contamination (less than 5000 dpm/100 cm2 beta-gamma) before an_ unconditional release is_issded.
Surveys must be made for all emitters unless it is known that a given type of radiation is not present~.
Material and equipment will be given an unconditional release by. Radiation-Chemistry providing:
a.
The contamination levels (above the background) do not exceed 1000 dpm/100 cm2 removable for beta and gamma emitters, 100 dpm/100 cm2 fixed for alpha emitters, and 20 dpm/1~00 cm2 removable for alpha emitters as measured with approved instruments; and.
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