ML20043B978

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Responds to 880330 Request Re Bases for De Minimis Policy Development by Other Agencies
ML20043B978
Person / Time
Issue date: 04/29/1988
From: Stello V
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To: Bernthal
NRC COMMISSION (OCM)
Shared Package
ML20042C963 List: ... further results
References
FRN-53FR49886, RULE-PR-CHP1 NUDOCS 9006010133
Download: ML20043B978 (74)


Text

{{#Wiki_filter:.. p i ~.m UNITED STATES j g NUCLEAR REGULATORY COMMi^ l0N j d l q WAestles070es. D. C. 30W6 t. APR t i 1988 3 o... MEMORANDUM FOR: Commissioner Bernthal FROM: Victor Stello, Jr. Executive Director for Operations

SUBJECT:

BASES FOR DE MINIMIS POLICY DEVELOPMENT BY OTHER AGENCIES (REF: M880314)

REFERENCE:

(1) Cancer Risk Management, C. Travis, et. al., Environmental Science and Technology Vol. 21, No. 5. May 1987 (2) Qualitative and Quantitative Carcinogenic Risk Assessment, Section 3, Dose-Response Assessment, Environmental Protection Agency, June 1987 The purpose of this memorandum is to respond to your request made in the staff requirew nts memorandum (SRM) of March 30, 1988. The SRM was issued subsequent to the staff's briefing of the Commission on the status of efforts to apply de minimis and below regulatory concern concepts to Commission policies. You specifically requested information on the bases and analytical techniques used by other agencies in developing de minimis policy / regulations on toxic waste. The following information, based on the listed references, is intended to provice an overview response.to your question. t Numerous State and Federal agencies, as well as the U.S. Environmental Protection Agency (EPA), have documented approaches for cleanup of hazardous waste sites. The common features of almost all approaches is that they are based on the assumption that allowable concentrations of hazardous materials in the environment can be defined for which no significant adverse effects on humans or the environment are expected. As indicated in the staff's March 30,,1988 presentation, the acceptability of j carcinogenic risks is frequently expressed in terms of an individual lifetime Choices for the magnitude of this individual lifetime risk cancer risk level. level are often made on a case-by-case basis and have ranged from 10 4 to 10 7 The method for determining acceptable levels of contamination in the context of l a risk assessment is referred to as the " absolute approach" to the management of cleanups at hazardous waste sites, and is used by both Federal and-State agencies. For example, in EPA's Superfund Public Health Evaluation Manual, methodologies to determine cleanup levels are identified which: (1) calculate the environmental migration of chemicals, (2) determine media-specific L concentrations, and (3) use toxicity based criteria for specific chemicals to I i L evaluate risk levels. l' For carcinogens, the projected site-specific human intake of a chemical (average over 70 years) is calculated by multiplying peak long-term concentration in an exposure medium by the human intake factor for that medium and adjusting the averaged result by a body weight factor. The resulting 9006010133 8911.30 .hh 1 bFR49886 PDC A

j y Commissioner Bernthal 2 chronic daily intake value is multiplied by a carcinogenic potency factor to calculate a lifetime risk for each chemical taken into the body through a specific intake pathway. The total lifetime risk is summed over all intake pathways and for all chemicals at a site. For potential carcinogens, cleanup levels are exEected to maintain lifetime cancer risk in the range from 10 4 to 10 7 with 10- as a desirable target level. The carcinogenic potency factor is stated as being derived from data generated from standard tests in which l 1 standardized extrapolation techniques are applied. These factors are upper J bound risk estimates or slope factors that are derived by the Environmental ProtectionAgency's(EPA) Carcinogens Assessment Group and are based, for the most part on animal experiments involving exposures at doses at and somewhat i belowmaxImumtoleratedlevels(i.e.,thehighestdosethatwouldnotalterthe 1 animals normal life from effects other than cancer). Although extrapolation to low dose can be based on several models, EPA and several other agencies (California Department of Health Services, New Jersey Department of Environmental Protection) use a multistage linearized model unless data indicate a strong preference for another model. This model reflects the favored theory that carcinogenesis is a multistage process consisting of at least three distinct stages: initiation, promotion and progression. The multistage nature of the process has been experimentally demonstrated in cells of some animal tissue. At low doses, the multistage model relates exposure to risk on a linear basis. The origin of the lifetime cancer risk goal is somewhat obscure but appears to have evolved from a Food and Drug Administration response in setting a threshold from which judgements could be made regarding a contaminant in beef. This risk goal concept was reinforced by the Supreme Court's 1980 be'nzene decision. With regard to the Food and Drug Administration (FDA) action the andCosmeticsActprohIbited 1958 Food Additives Amendment to the Food, Drug,ic. In 1962, by Congressional the use of food additives found to be carcinogen amendment, FDA was permitted to approve the use of a carcinogenic animal drug if the gency was convinced that no residue of a drug would be found in edible tissues of the treated animals. This course proved to be unworkable, for two reasons: progress in analytic chemistry was so rapid that proven methods of analysis quickly became obsolete, and improved detection methods showed that no drug administered to animals is ever entirely absent from animal tissues. The problem of enforcing the 1962 amendment was highlighted in the early 1970's when diethylstilbestrol residues were discovered in beef liver with highly sensitive analytic methods. As a result, FDA proposed sensitivity-of method guidelines; namely, that any assay approved for controlling a carcinogenic drug must be capable of measuring residues that present more than an insignificant risk of cancer, and specified 10 ' lifetime risk of cancer as a quantitative criterion of insignificance. l-In the 1980 benzene decision, the court recognized the existence of insignificant risks. In so doing, it offered quantitative bounds as follows: "If, for example, the odds are one in a billion that a person will die from cancer by taking a drink of chlorinated water, the risk clearly could not be considered significant. On the other hand, if the odds are one in a thousand that regular inhalation of gasoline vapors which are two percent benzene would be fatal, a reasonable person might well censider the risk significant and take

i 's Constissioner Ternthal 3 appropriate steps to decrease or eliminate it." In his concurring opinion; Chief Justice Burger stated: " Inherent in tt.is statutory scheme '.s authority to refrain from regulation of insignificant or de minimis risks." ' The staff believes the two references are especially relevant to your request. The first reviews risk management decisions made by regulatory apencies. The - second =1s a-section in " Qualitative and Quantitative Carcinogenic Risk ' Assessment," a document prepared for EPA in June 1987. A copy of the EPA's Superfund Public He61th Evaluation Manuel is also available. -If you are interested, any or all of these documents can be made available to you. eit t.a1 Lipd M i yiotcr Sullo," Victor Stello, Jr. Executive Director for Operations cc: Chairman Zech Commissioner Roberts Lommissioner Carr Commissioner Rogers SECY OGC GPA 115TRIBUT10N BERNTHAL MEMO I [I JTaylor TRehm-VStello HThompson, NMSS 'EBeckjord TMurley, NRR Dross JMurray OGC BMorris EDO r/f g 2Rosttocry ~ RAlexander

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/ /88 : 7/DL/BB / 88 OFFICIAL RECORD COPY 1

^ .5i..-:-; i. :. t t 9lt I PRESENTAT10N SCHEDULE l ACRS SUBCOMMITTEE ON WASTE MANAGEMENT TOPIC:plNINIM!sANDBELOWREGULATORYCONCEP.N I FOOP 1167, 1717 H STREET, N.W. WASHINGTON, D. C. tiny 4, 1988 l 8:30 --9:30 a.m. Intreductier, and Executive Session D. Moeller, Chaiman 9:30 - 9:40 s,rn. Welcone and Opening Remarks D. Moeller 9:40 - 10:30 a.rr. _BRC Policv Statement Introduction R. Bernero, NMSS

Background

K. Dragonette, NP.SS Policy Statenent Expected Petitien/ Status BREAr. -10:30 - 10:45 e.t. 10:45 II:30 a.m.. Feiease and Decomissionin:; Criteria L. Rouse, NMSS, and 4 S. Neuder, RES Pesidual Activity Standards Residuel Activity in Soils 11:30 - !?:25 Gemstones D. Cool, NL*SS LUNCH 12:;5 1:15 p.m. 1:15 1:4 5 p.rr. Lurrectf.EA/1AEAActivities R. Cunningher, NvS5 1:45 - 2:45 p.m. Intecral Aeproach to issues W. Lahs, RES Peprise of Comission Briefing Internettonal Conference Status l Initial Ideas 2: 45 - 3:00 p.m. BREAr. 3:00 - 4:00 p.m. E>.ecutive Session 4:00 p.r. ADJOURN 0

g' e H $GJ ll6 7 l P:3 0 4.m. ACNW ON EEMINIMIS AND BELOW I REGULATORY CONCERN MAY 4, 1988 '1. BRC POLICY STATEMENT (K. DRAG 0NETTE, NMSS) 45 minutes' BACKGROUND POLICY STATEMENT EXPECTED PETITION / STATUS 2. RELEASE AND DECOMMISSIONING CRITERIA 45 minutes (L. ROUSE, NMSS; S. NEUTER, RES) RESIDUAL ACTIVITY STANDARDS RESIDUAL ACTIVITY IN SOILS H 3. GEMSTONES (D. COOL, NMSS) 45 minutes ,j l 4. CURRENT NEA/IAEA ACTIVITIES (R. CUNNINGHAM, NMM ) 30 minutes 5. lNTEGRAL APPROACH TO ISSUES (W. LAHS, RES) 60 minu^.A 1 ' REPRISE OF COMMISSION BRIEFING INTERNATIONAL CONFERENCE STATUS L INITIAL IDEAS t

l l ACRS (ACNW) BRIEFING l L DE MINIMIS BELOW REGULATORY CONCERN i POLICY DEVELOPMENT I o M AY 4, 1988 4 i ~ h _____,_,,_.________,____________.__._______.___________.__.__________.____c

m s y + t t i RES " REGULATORY EX EM PTION" ACTIVITIES l PRIOR TO NOV 24, 1987 SRM o RESPOND TO COMMENYS ON AMPR & TAKE APPROPRIATE ACTION t o COMPLETE CONTRACTOR WORK ON RESIDUAL R ADICACTIVtYY RELEASE-j STANDARD - PROPOSE NRC POSITION o RESPOND TO

      • RM FOR WASTE OIL DISPOSAL o ADVISE COMMISSION 'ON CONSISTENCY. OF RELEASE STANDARDS l

5 ^ L + 1 m ) ,4 -r.w. .. m ,,7 e v. w -6 ,r,c g e.,.,,r,.. ...m ~ e, en -e -..,.

  • j h;N EXEMPTIONS FROM REGULATORY CONTROL.

-THEIR POTENTIAL USE IN THE DEVELOPMENT OF RADIATION PROTECTION POLICIES & REGULATIONS BACKGROUND RESPOND TO COMMISSION REQUESTS TO ADDRESS ISSUES SPECIFIED IN SRMe OF FEB 5 & NOV 24, 1e87 JIt. MAR 3 0,1 9 E S - 1 ADVISE ON HOW EXISTING & PROPOSED DE MINIMIS, BELOW REGULATORY CONCERN & RESIDUAL RADIOACTIVITY RELEASE STANDARDS ARE REl.ATED & HOW CONSISTENT RELEASE STANDARDS ARE ACHIEVED i DEVEI.GP COMMISSION POLICY STATEMENT TIIAT WOULD IDENTIFY A LEVEL OF RADIATION RISK DELOW WHICII GOVERNMENT REGULATION DECO 3fES l UNWARRANTED ESTABLISH A GENERIC NUMBER FOR EXPOSURE THAT IS BELOW 4 REGULATORY CONCERN RECENT a. NEAR-TERM ACTIONS f STATUS REPORT ON MARCII 14 1988 ? TECHNIQUES USED BY OTHER AGENCIES - RESPONSE ON APRTL 29. 1968 l 4 OPTIONS PAPER ESTABLISHING GENERIC NUMBER-AUGUST 1. 1988 l INTERNATIONAL WORKSHOF _ - OCTOBER 17-19. 1988

  1. t

\\ ~ -3 IMPACT OF GEMSTONE ISSUE ON PROPOSED DE MINIMIS/BRC POLICY L i i o ROLE OF JUSTIFICATION OF PRACTICE CONCEPT QUESTIONED l t t c STAFF VIEWPOINT: i o NEED FOR POLICY POSITION BASED ON NEGLIGIBLE RISK (WHAT ARE _OTHER AGENCIES DOING ?) i o NEED FOR BRC POLICY, TO ALLOW CONSIDERATION OF COST / RISK REDUCTION CONSIDERATIONS 1 I Note:f,~ order of magnitude difference In de minimIs risk l l; level definition I 2. value differences In risk coefficients i 4 i l i 3 t .w e ewa w ,'n , ~ e-s~e v~> s -v-nm .r s~ v.- ,a w-w- -e..


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r I t 'i ? 4 f MAJOR TOPICS DISCUSSED AT COMMISSION MEETING i L l RAotATION PROTECTION FRAMEWORK & THE TERMS a CONCEPTS ASS i I REOULATORY CUTOFF 9 i q t j l POLICY DEVELOPMENT CONSIDERATIONS-998 EJONT OF CURRENT MRC, EPA & t SMTER9eATIOMAL ACTsvtTtES etAwa FOn sesTEnsenTeOsent av pOssu.s 1 m .Ov.c. .v m. ro . -....etc.c.c co e - ^ 3 k l 4 f 6 e wea m eh me de

L i; l 4. ' RADIATION PROTECTION FRAMEWORK ) BASIC REGU1.ATORY 100FR20 DOSE UNIT q o I 1 ALARA Required W ) SUPPLEWENTARY STDs e.g. 40 CFR 190, CAA O U C 1 ( >POUCY STATEMENT WASTE STREAWS Z M l et Q_. ___ GENERIC BRC W l I I c UW SOURCE o D SPECIFIC ( p l - BRC De Facto BRC f o t.voi. _ NEGUGIBLE INDIV. I I RISK CURRENT -6 POTENTI AL 5 i

NATIONAL AND INTERNATIONAL P!CTURE ~ CAf1ADI AN AT0ftlC' ErlERGY C0flTROL BOARD (CAECB) ~ BRC.--5 MREMS/YR DOSE LIMIT FOR DISPOSAL OF WASTE (1985) U.K. NATIONAL RADIOLOGICAL PROTECT 10ft BOARD (NRPS) DE MilllMIS--S MPEMS/YR ALL SOURCES COMBillED,.5 MREMS/YR IfiDIVIDt'AL SOURCES ENVIR0!! MENTAL PROTECTIOtt AGEllCY (EPA) BRC--4 MREMS/YR DOSE LIMIT PER WA5TE STREAM (1988) NUCLEAR -REGULATORY COMMISS10ft (NRC) BRC--POLICY ON PETIT 10f15 FOR RULEMAKillG (1986) NUCLEAR REGULATORY COMMISSIO!! (NRC) URC--RECOMMEf1DATIONS FOR GErlERIC RULEMAKit1G Off RADIDACTIVE tlASTE (1988) NUCLEAR REGULATORY COMMISS10ft (NRC) DE Millit1IS--NEGLECT DOSES UP TO 1 MREM /YR I!? COLLECTIVE DOSE EVAltIAT10f15-(REVISED PART 20, 1988) ~ NUCLEAR REGULATORY COMMISSIOff (NRC) DE FACTO BRC LEVELS !!! THE REGULAT10flS NATIONAL COUNCIL FOR RADI ATIOff PROTECTION (NCRP) DE MINIMIS--RECOMMEf1DS 1 MREM /YR AS A " NEGLIGIBLE lilDIVIDUAL RISK LEVEL" INTERNATIONAL ATOMIC ENERGY ASSOCIATION-(IAEA) DE MINIMIS I MREM /YR (TO If4DIVIDUALS), 50 MREM /YR (SKIN DOSE), 100 MAN-REM (COLLECTIVE) 6

4 l PO LIC.Y DEVELOPMENT CONSIDERATIONS " SOURCE SPECIFIC" VS " GENERIC" BRC LEVELS l l 3 CHARACTERIZATION -OF CUTOFF LEVELS CNARACTERIZATION OF SOURCES ON A NATIONAL BASIS l e i ROLE OF COST / RISK TRADEOFFS l CONVERSION OF BRC DOSE LEVELS TO RISK j ~ i DIFFICULTIES IN ESTABLISNINO " NEGLIGIBLE RISK" LEVELS I 7 [

s i r ^ i BRC WASTE STREAMS ) I COMMENTS ON. ANPR. i I i i ta 3 LETTERS REC"D - 58 OPPOSED l j - GENERIC VS. SOURCE SPECIFIC - EVENLY SPLIT RULEMAKING DESIREABLE CRITERIA CODIFIED - NO ADDITIONAL CRITERIA NEEDED j CRITERIA FOR ANY SITE '& SPECIFIC DISPOSAL SITE I i DOSE CUTOFF - 1-10 mrosa/yr i SUGGESTIONS FOR SAFE SITE LIMIT i 5 f I i l 8 ~.

I i MAJOR AUTHORITIES REGULATIONS IMPACTING REGULATORY CUTOFF POLICIES j EPA j GENERALLY APPLICABLE ENVIRONMENTA8 RADIATION STANDARDS (AEA) - SAFE - DRINKINO WATER ACT l CLEAN iR8R ACT f i l NRC EXEMPTION AUTHOPITY (ATOaseC ENERGY ACT SECT 90985 57es, Sta S1) i LOW-LEVEL RADIOACTIVE WASTE POLICY AMENDMENTS ACT OF 1998 I I -l t i I i f 1 t 9 1 -~ -s . _ ~.... _, - - _ _ - -... _.. _ _ _ _. _.. _

.E e i i i ? i NRC/NEA WORKSHOP ON RULES FOR EXEMPTION l .$2 MOM REGULATORY CONTROL s k l l 1 i INTENT: FOCUS INTERNATIONAL REGULATORY ATTENTION & DEVELOP CONSENSUS i ON CONTENT OF EXEMPTION POLICY -l 3 i I PLACE a TIME: PAN AMERICAN NEALTN ORGANIZATION CONFERENCE FACILITIES t WASNINGTON. DC, OCT 17-19.1988 j i STRUCTURE: PARTICIPANTS-INVITED EXPERTS FROM NAYIONAL & INTERNATIONAL i i REGULATORY AUTNORITIES: PRESENTATIONS OF INVITED PAPERS i 1 i 4 I 10 ... _,. ~ .. -. ~..

4 .m l i l l i i INITIAL IDEAS ON POLICY DEVELOPMENT O O A L: RESPOND TO COMMISSION REQUEST FOR GENERIC NUMBER POR EXPOSURES BELOW REGULATORY CONCERN t } ( PROVIDE - FLEXIBILITY TO DEVELOP REASONABLE A PRUDENT [ i i EXEMPTIONS FROM REQULATORY CONTROL FOR: LOW LEVEL WASTE STREAM OfSPOSAL, DECONTAMINATED & DECOMMISSIONED STRUCTURES & SITES, CONSUMER PRODUCTS, ete APPROACH: MULTIPLE (3) INDIVIDUAL DOSE VALUES TO DEFINE GRADED DEGREE OF JUSTIFICATION FOR EXEMPTIONS i [ 11 1

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ACCEPTABLE SURFACE CONTAMINATION LEVELS NUCLIDE AVERAGE . MAXIMUM REMOVABLE U-nat, U-235, U-238, and 5,000 dpm al100 cm2 15,000 dpm a/I00 cm2 1.000 dpm al100 cm2 associated decay products Transuranics, Ra-226, Ra-228, 100 dpm/100 cm2 300 dpm/100 cm2 20 dpm/100 cm2 Th-230 Th-228, Pa-231, Ac-227. I-125,1-129 Th-nat, Th-232, Sr-90, 1000 dpm/100 cm2 3000 dpm/100 cm2 2 200 dpm/100 cm Ra-223, Ra-224, U-232, I-126,1-131,I-133 i i 2 Beta-gamma emitters (nuclides 5000 dpm #9/100 cm 15,000 dpm #9/100 cm2 1000 dpm #9/I00 cm2 j with decay modes other than alpha e emission or spontaneous fission) I except Sr-90 and others noted above. f (1) .y ,. ~. _. _.,. _... -.. _ _. .... ~..,.. _ _. -.

NEW GUIDANCE ADDRESSES External Exposure Rate Volumetric Distribution Surface Distribution (2) 9 e --y-=s- -- - r4 e,a = p p wy.-, 4, + m.c w m. y____ 2

e.. 'r m,. APPLICATION OF NEW GUIDANCE Soils and Structures (Stage 1) Equipment and Materials (Stage 2) (3)-

NEW GUIDANCE - PATHWAY CONSIDERATIONS-Direct External Exposure Resuspension-Inhalation Agriculture-Ingestion Secondary Transfer-Ingestion Groundwater-Ingestion 6 e i 1 (4) e v e-f f.e*- T Yer e e'-*w-- --w ww-* 7w wer w+---

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TABLE 1 Derived Residual Radioactivity Inventory and Surfaca Activity. Licits for Unrestricted Reiscs2 cf Licensed Facilities l (Note: Additional Radionuclides will be added later) Derived-Derived Inventory Surface Activity Limits-- Limits Radionuclide (pCi/m2) (dpm/100 cm2)' 54Mn 4.2 E40 2 E+2 55Fe 7.7 E+3 3 E+5 58Co 3.6 E40 ~ 1 E+2 i I 60Co 1.3 E+0 5 E+1 63Ni 4.6 E+5 2 E+7 1 65Zn 5.0 E40 2'E+2 i 90Sr+90Y 4.6 E+2 2 E+4 95Zr 5_'O E40 2 E+2 i 99Tc 8.4 E+4 3 E46 l 1251 2.9 E42 1 E+4 1291 5.6 E+2 1 E+4 131 1 1.2 E+1 4 E+2 l i 230Th 7.7 E+1 3 E+3 232Th 1.5 E+1 6 E+2 232U 3.6 E+1 1 E+3 234U 1.9 E+2 7 E+3 235U 4.6 E+1 -2 E+3 231Th 5.0 E+2 2 E+4 l ~ i l 231 a 1.7 E+2 6 E+3 P 238U 2.0 E+2 7 E+3 .I 234 h 1.8 E+2 7 E+3 i i T 234 a 1.8 E+0 7 E+1 (5) l P

a ~ m ...,..~- , N -~ i. i MEMORANDUM APRIL 6, 1988 f STELLO'to BECKJORD:(RES), THOMPSON (NMSS),MURLEY.(NRR) l l There is an urgent need.for' developing ~guldance to ensure consistent ' Agency. decisions regarding acceptable levels.of contamination for the release of lands and facilities for unrestricted use.... I therefore direct the.RES staff to prepare an interim policy statement a consistent with the Commission-directed below regulatory concern policies which, as a minimum,- would document -(1) the criteria attendant to existing; decommisioning practice and (2) the longer range NRC plans for follow-on: policy guidance and rulemaking..This interim policy statement should be issued in FY 1988. (6)

w =- e., ,,,, %f ' A , $~ ~ N PRIMARY DOSE LIMIT-BRC Cost-Effectiveness J I. Past Experiences Health Risk / S (7) 3 ^'JM. ,f' Y._

+ m-s 3 t' w, t _.._7 i 4 INTERIM POLICY Primary' Dose Limit Secondary Limits -External exp6sure-limit Inventory limit: -Surface (dpm) limit 6 (8). e-

TABLE 2. C arison.of.tho'A DerivedSirfaceActivityLtits ^ wi the Average Regula ory Guide 1.86 tietts; 4. Reg. Guide 1.86' ~ ' Derived Surface Surface 11 i Activlty Ligit~ Activity Limit: Radionnelide 1(dom /100 caZ) Idom/100 cm2). 54 2 2 E+2 5 E+3 55Fe 3.E+5 4 E+3 580s 1 E+2 5 (+3 1 60Co 5 E+1- & E+3 63R1-2 E+7 5 EM l 65Zn 2 E+2 5 E+3 90sr+90Y 2 E+4 1 E+3 95 r 2 E+2 5 E+3 Z 99Tc 3 E+6 5 E+3 1251 1 D4 1 E+2 l' 1291 g(+4 1 E+2 1311 4 E+P 1.E+3 230Th { E49 1 E+2 232Th & E+2-1 E+3 232U 1 (+3 1 E+3 23 % 7 E+3 5'E+3 235g 231Th 1 (44 +3 5 E+3 2E 5 E+3 1 231Pa 6 E+3 5 E+3 23 % 7 E+3 5 E+3 23#7h 7 E+3 5 E+3 ES4P4 7 E+1 5 E+3-(9)' teforence Utanius-msture 7 E+3 5 E+3 .p. ~; h.:,., -, - ,_,.._,2 . _,-.__.-,_._ J

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- 2. RELEASE AND DEC0f'MISS10NING CRITERIA .CURREfiT PRACTICES FOR RESIDUAL.-ACTIVITY . SURFACE CONTAMINATION S0ILS G a e g -V w-c w -9 , a m:2 +-- P'y 9 Meast- .-WM .y .y s,%gg-p s-m- -q v-,'+-,wge. 9 v ,%-y yyvd-+ rgmy-6Y

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..l u ,meme .FESIDUAL' ACTIVITY CRITERIA L I 'FOR SURFACE CONTAMINATION-GUIDELINES FOR DECONTAMINATION OF Ftrit ITIES' AllD' EQUIPMENT PRIOR TO RELEASE FOR' UNRESTRICTED USE OR TERMINATION OF LICEt1SES'FOR-BYPRODUCT, SOURCE, 01: SPECIAL NUCLEAR MATERIAL. REGULATORY ' GUIDE 1.86, TLRMINATIOff 0F OPERATillG LICENSES FOR NUCLEAR 0-REACTORS O IIACKGROUND AND BASIS WITH RELATIVLLY MINOR CHAR! GEL, USED SINCE-1950'S. h0T DERIVED'ON DOSE BASIS; CollSIDERED TO BE SUFFICIENTLY LOW TO BE OF fiEGLIGIBLE SIGNIFICAllCE TO HEALTil AllD SAFETY AfiD SUFFICIENTLY HIGil TG EE PRACTICAL OF ATTAlflMENT AND MEASUREMENT. p " GUIDELINES".RLFERENCED ABOVE INCORPORATED AS LICENSE CONDITION ON FUEL CYCLE LICErJSES. .e, - - ~. - _ _ _ _.

v .:= :- ' ACCEPTAliLELSURFACELCONTAMINATION LEVELS ~ -HUCLIDES -AVERAGE - MAXIMUM REMOVAL.- ASSCAEDb f^ 5,000 DPM u/100 cM 15,000 DPM a/100,cM 1,000 DPM../100 cM ~^ g PRODUCTS R 28 $0 T 28, 100-DPM/100 cM 300 DPM/100 cM 20 DPM/100 cM PA 231, AC-227, I-125, I-129 --2 1000'DPM/100 cM 3000'DPM/100 cM 200 DPM/100 cM 2 H-p I-120, I-131, I-133 BETA-GAMMA EMITTERS 2 2: f10 DES OTHER 'IllAf! f t PHA 5000-DPM 11-/100 Cn 15,000 DPM sy/100 cM 1000 DPM ey/100 cM 2 (NUCLIDES WITH DECAY EMISSIDHS OR SPOli 9 ~"?ls FISSION) EXCEPT SR-bL AND OTHERS NOTED ABOVE. 4 M. ~,, _ _

g-m RESIDUAL ACTIVITY CEITERIA FOR' SOILS 0 EPA -- INTLRIM RECOMME!!DATIONS ON DOSES TO PEP.S0ilS EXPOSED TO TRANSURAlllUM ~ ELEMENTS 1:1 THE GENERAL FNVIROilMENT O BRAf4Cil IECl1NICAL POSI110t --DISPOSAL OR OllSITE STORAGE OF Til0RIUM OR URANIUM WASTES FRUN PAST OPERATIONS 0 BACKGROUND AND BASIS DEVELOPMENT OF EPA RECOMMENDATIONS INITIATED IN EARLY 1970's, PROPOSED AS FEDERAL RADIATIOrt PROTECTIOrt GUIDANCE IN 1977, AND PRESENTLY BEING PURSUED AS FINAL GUIDELINES. i EPAGUIDAgCEFORTRA!!SURANIUMSollCONTAMINATIONREPURTEDASBASEDLON RISK (10 /YR) USIT1G 1 NHAD/YR TO LUNG, 3 MRAD /YR TO BONE.- STAFF TEClitlICAL POSIT 10I1 PUBLISilED IN 1981 (116 FR 52061) USED PROPOSED EPA GUIDAflCE.AS BASIS FOR DEALING WITil LARGE VOLUME, LOW CONCENTRATION URANIUM A14D THORIUM Soll CONTAMINATION CASES. STAFF TECliNICAL POSITION PROVIDES BASIS FOR UNPESTRICTED RELEASE AS OPTION 1 AND THREE OTHER OPTIONS WITli SPECIFIC PEOUIREMENTS FOR LICENSE TE RMIllATION. .c =,.. y. i+yw...- a. -. = g wy p +, w+- s, r ,m,% p we p v .',.n.--- .. -gam ..-4p.g.WA.,y-

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_AC_CEPTAP,LE S0IL C0HTAhlNAT10N LEVELS- - SOIL CONCENTHATloti LEVEL - FOR UtlRESTRICTED' AREA-I: 1:1IID 0F. MATERIAL (PCI/G OF SOIL) IIRANCH TEcimICAL NATURAL URANIUn (U-238+ 10L POSITION (le6 FR 52061) b-2311) -WITri DrCAY PROI;UCTS PRESENT AliD IN EoUILIBl?iUM' DEPLETED URANIUM OP NATURAL 35-UP.ANIUM THAT HAS'BEEN SEPAEATED FROM ITS DECAY PRODUCTS, SOLUBLE OR INSOLUBLE -NATURAL THORIUM (TH-232 + TH-228) 10 WITH DECAY PRODUCTS PRESENT AND IN EQUILIBRIUM-E14RICHED URAlllUM, SOLUBLE OR 30 tiiSOLUBLE DERIVED POSITIO!1S PLU10NIUH-(Y).'OP. (W) 25 AMERICIUM-214i(k) ' 30 ALL BYPRODUCT MATERIAL CASE-BY-CASE DETERMINATION BASIS LUNG DOSE, 10 MREMS/YR; BONE DOSE, 60 MREMS/YR; EXTERNAL RADIAT10tl, 10 MICR0h0ENTGENS/HR-ABOVE BACKGROUND AT ONE METER FROM SURFACE. L o .u., .g m.: 7- .mr- .g .Q w-ww #. p q 97 .~ .=,4ww - 4 e gr V W'e+aW' t . men.+++.h.p.

~ y;; -= ~Y^ ~ 011iERLOPTIONS FOR RELEASE'0F: URANIUM / THORIUM: SOIL CONTAMINATION. MAXIMUM CONCEllTRATIONS (PCI/G) ERAllCH TECHNICAL POSITIOrt DISPOSAL OPTIONS' 21 3 4 SC- .500 NATURAL TIIORIUM NATUPAL URANIUl1 (WITH DAUGHTERS i>RESE!!T) 40 200 ^ DEPLETED URANIUM ~ 100 1000-I SOLUBLE 300 3000 INSOLGBLE ENRICHED URANIUM SOLUBLE-' 100 ,1000 2500 250 ~ li: SOLUBLE BURIAL AT 4 FEET,' DEED RESTRICTIONS FOR OPTIONS 3 AND 11, ASSUMES lhTRUSIONS:- BASIS OPTION 2, DO MREMS/YF Mil 0LE BODY OR ORGAN' DOSE; OPTION 3,-0.02 WORKING LEVEL; OPTION li,'SCO MRLt-iS/YR WHOLE BODY OR' ORGAN DOSE, 0.02' WORKING-LEVEL FOR NAT: U.. c .e

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.x. x \\ .t 'i 3 GUIDELINES FOR DECONTAMINATION OF FACILITIES AND EQUIPMENT L PRIOR TO' RELEASE.FOR. UNRESTRICTED USE-t OR TERMINATION OF; LICENSES FOR BYPRODUCT, SOURCE; . OR SPECIAL NUCLEAR MATERIAL. s p e s ,k., 4 U.S. Nuclear R*;ulet: m ission. Divisien of Industris. J Medical Nuclear Safet: ~ Washington, DC 20555 August 1987 p. 9 J i s - i. -{ 4 t'- F y w

The instructions in this guide, in conjunction with Table 1, specify the radionuclides and radiation exposure rate limits which should be used in decontamination ato survey of rurfaces or premises and equipment prior to abandonment or rc' ease for unrestricted use. The limits in table 1 do not apply to premises, equipment, or scrap containing indcced radioactivity for which the radiological considerations partinent to their use may be different. The release of suth facilities or items froir regulatory control ir considered on a case-by-case bcsis. 1. The licensee shall make a reasonable effort to eliminate residual contamination. 2. Radioactivity on equipment or surfaces shall not be covered by paint, plating, or other coverisg material unless contamination levels, as determined by a survey and documenteo, are below the limits specified in Table 1 prior to the application of the covering. A reasonable effort must be made to minimize the contamination prior to use of any covering. 3. The radioactivity on the intetior surfaces of pipes, drain lines, or ductwork sheil be determined by mak ng measur nents at all traps, and other appropriate access points, provided that contamination at these locations is likely to be representative of contamination on the intt.rior of the pipes, drain lines, or ductwork. Surfaces of premises, equipment, or scrap which are likely t be contaminated but, are of such size, construction, or location as to Nke the surface inaccessible for parposes of measurement shall be presumed to be contaminated in excess of the limits. 4. Upon request, the Commission may authorize a licensee to relinquish possession or control of premises, equipment, of scrap having surfaces contaminated with materials in excess of the limits specified. This may include, but would not be limited to, special circumstances such as razing of buildings, transfer of premises to another organization continuing work with radioactive materials, or conversion of facilities to a long-term storage or stanGby status. Such requests must: a. Provide detailed, specific information describing the premises, equipment or scrap, radioactive contaminants, and the nature. *xter', and degree of residual surface contamination, b. Provide a detailed health and safety anslysis which reflects that the residual amounts of materials on surface areas, together with other consideratiors such 6: prospactive use nf the premises, equipment, or scrap, are unlikely to resu' in an unreasonable risk to tht: health and safety of tha public. ~

5. Prior to release of premises for unrestricted use, the licensee shall make a comprehensive radiation survey which establishes that contamination is within the limits specified in Table 1. A copy of the survey report shall be filed with the Division of Industrial and Medical Nuclear Safety. U. S. Nuclear Regulatory Commission, Washington, DC 20555, and also the Admirist*4 tor of the NRC Regional Office having jurisdiction. The report should be filed at least 30 days prest to the planned date of abandonment. The survey report shall: a. Identify the premises, b. Show that reasorable effort has been made to eliminate residual contamination, Describe the scope of the survey and general procedures followed. c. d. State the findings of the survey in trits specified in s'.he instruction. Followirg review of tlie report, the NRC will consider visiting the f ar.ilities to confim the survey. \\ - (M-%g ,f{f]. /Q q( Qg g. <1

A .m a TABLE 1 ACCEPTABLE SUFfACE CONTAMINAfl0N LEV [t.5 mighdf RE"4)VABtEbef 8 AW RAGEbcf NUCLIDE5 2 2 1,000 dpm a/100 cm U-mt. U-235. U-238, and 2 15,000 dpm a/100 cm associated decay products 5,000 dpm a/100 cm 2 20 dpm/100 cm2 Transuranics Ra-226. Ra-228 2 300 dpm/100 ce Th-230, Th-278 Pa-231, 100 dpm/100 cm Ac-??/, I-125, I-129 2 Th-aat, in-212, Sr-90, 2 3000 dpm/100 cm2 200 dpe/100 cm Ra-77), Ra-274. U-232, 1-176, 1000 dpm/iOO cm 1-11!, 1-33 Be t a-garwa emi t ters (nuclides 2 1000 dpm sy/100 c.2 w sh decay rodes other thar. 2 15,000 dpm By/100 cm 5000 dee: sy/100 cm alpha emission or spontaneous fission) except Sr-90 and others noted above. lh d beta-gamma-emitting aubere surface contamination by both a:pha-ar.d beta-gamma-emitting nuclides exists, the limits estabitshed for a p a-an nuclides should apply independently. I the ) means the rate of emission by radioactive cater s1 es determined by corre J ti factors associated with the instrww. cation. b s used in.his table, dpm (disintegrations per minute counts per minute observed by an appropriate detector for background, es ;iciency, and geome r c A d over more than I square meter. For objects of less surface area the average (14easurements of average contae:insnt should not be average should be derived for each such object. 2 ihe maximum contaminatica level applies to an area of not more than 100 cm. d of st rface area should be determined by wiping that area with dry filter or sof t 2 l t on the wipe with an appropriate instrtment of eihe amount of removable radioactive material per 100 cm absorbent paper, applyf og moderate pressure, and assessing the amount of radioactive mater aEen removab l h id be reduced knovra efficiency. proportsenolly and t.92 entire surface should be wiped. h ld not exceed 'the averane and niemimum radiation levels associated with surface contamination resulting from beta-gamma emitters s e timeter of 0.2 erad/t:r et I cm ar.d 1.0 mrad /hr at I cm, respectively, measured through not more than 7 milligrams per square c n total absorber. -e&

m y l } [ $. Jame 1974 / d kiUU[.a YbRY GUIDE . DIRECTORATE OF REGULATORY STANDARDS ,' n s o' l REGULATORY OUlDE 1.86 1 TERMINATION OF OPERATING LICENSES FOR NUCLEAR REACTORS A. INTRODUCTION A licensee having a possession.only license must retain, with the Part 50 license, authonr.ation for special Section 10.51, " Duration of heense, renewal," of 10 nuclear material (10 CFR Part 70, "Special Nuclear CFR Part D, "Licensms of Production and Utihration Matena'"), byproduct rnatenal (10 CFR Part 30," Rules. ' Facihties," requires that each bcense to operate a of General Appbcabihty to Licensing of Byproduct production ' and utilization facibty be issued for a Matenal"), and source matenal (10 CFR Part 40, specified duration. Upon expiranon of the specified " Licensing of Source Matenal"), until the fuel, radio-penod, the license may be either renewed e termmated active components, and sources are removed from the by the Commission, Section 50.80, " Applications for facihty. Appropnate admmistrative controls and facihty termmation of heenses," specifies the requirements that requirements are imposed by the Pan 50 heense and the i must' be satisfied to termmate an operating beense, technical specifications to assure that proper surveillance including the requirement that the hsmantlement of the is performed and that the reactor facihty is maintamed facility and disposal of the component pans not be m a safe condition and not opetited. y L immical to the common defense and secunty or to the health and safety of the pubhc. This ir.ide desenbes A possession enly license permits vanous options and L methods and procedures considered acceptable by the procedures for decommissionmg, such as mothballing. Regulatory staff for the termmation of operatmg entombment. m dismantling. The requirements imposed bcenses for nuclear reactors. The Adusory Committee depend on the option selected. on Reactor Safeguards has been consuhed concermng (", ttus guide and has concurred m the regulato:y position. Section 50.82 provides that the licensee may dis. L mantle and dispose of the component parts of a nuclear l B. DISCUSSION reactor in accordance with existing regulations. For L' research reactors and entical facihties this has usually i When a-heensee dreides to ternunate his n'iclear meant the disassembly of a reactor and its stupment l, ~ - reactor operatmg hcense he mab as a first step m.the offsite. sometimes to another appropnatel) heen ed li process, request that f.is operstmg bcense be amended to organaation for further use. The site from whi.3 a . restrict him to possess but not operate the facihty. The reactor has-been removed must be decontammatec. as advantage to the beensee of convenmg to such a necessary, and mspected by the Commission to deter. possession only bcense is reduced surveillance requir,- mme whether unrestncted access can be approved. In ' {, pg. ments m that permdie sarveillance of equipment n> the case of nuclear power reactors, dismanthn3 has - Rq portant to the safety of reaetor operation ts no longer usually been accomphshed by shippmg fuci offsite, L required. Once this possess:on onJy license is issued, makmg the reactor moperable, and disposing of some r>f f reactor operation is not permitted. Other activities the radioactive components. L' related to cessati. t of operations such as unloadmg fuel from the reactor and placing it m storaFe (e ther onsite Radioactive components may be either shipped off: of offsite) may be contmued. site for bunsi at an authorized burial ground or secured' D, N' . i = ~ ~~ y=y r gi, ; c.o,c,. oua wi. .m e e. en ao.m, e m.s usaseaecu m onyouiets ..neee m - ~,.e a.u.e.= r, ci--.u.e.~una.woaw. ee aa ..cu.* **' ~ v s. .,u. or.re m . ~.~ c. ,e u I c. si. w oi cu. +, ...c.-~~.o - ne =s o-wa, o. ei n.,,,.c . o.,,. ...w e. e..~...... ~.,, u e -~ =~ = ~ Sean i q. c.~

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W x t r ..on the site.Those radioacuve matenals remairut.g on the Guids and waste should be removed from' the site. site must be isolated from the pubhc by physical barners Adequate radiation monitonng, environmental surveil. or other rneans to prevent public acceu to hazardous lance, and appfopnate secunty procedures should be , levels of radiation. Surveillance is necessary to assure the established under a posseuion only license to ensure that a f long arm integnty of the barners. The amount of tre health and safety of the pubhc is not endangered. sur ' ace requhed depends upon (1) the potential . ha: c to.the heahh and safety of the pubhc from

b. In-Place Entombment. In. place entombment con-radioactive matenal remaming on the site and (2) the sists of sealing all the remammg highly radioactive or mtegnty of the physical barners. Before areas may be contarrmated components (e.g., the presure vessel and released for unrestricted use. they must have been reacto. internals) within a structu e integral with the decontaminated or the radioacuvav must have decayed biolopcal shield after havmg all fuel asemblies, radio-te less than presenbed hmits (Table t).

active Guids and wastes, and certam selected com. ponents shipped offsite. The st:tecture should prende The huard auociated with the reured facthty= is integrity over the period of. time m which sirGcant evaluated by conuderms the amount and type of quantities (greater than Table I levels) of rad.wivity remaming contanunation, the degree of confinement of remain with the matenal in the entombment. An the remammg radioacuve matenals, the physical secunty appropriate and continums surveillance program should provided by the, connnement, the suscepubihty to be estabhshed under a ponession onl) license. release of radiation as a result of natural phenomena, and the duration of required surveillance ~

c. Remo al of Radioacdve Coreponents and Dis-J mantling, All fuel-assemblies, radioactive fluids and C. REGULATORY PostTION waste, and other materiaP havmg activ ties above ac-ccpted uraestricted actinty levels (Table 1) should be
1. APPLICATION FOR A LICENSE TO POSSESS BLT rernoved from the site.The facihty oviner may then have NOT OPERATE (POSSESSION;0NLY LICENSE) unrestricted use of the site with no requirernert for a hxnse. If the facility owner so desires, the remamder of

' A request to arr*nd an operatm., beense to a the teactor facility rnay be dismantled and all vestiges possession only licens' should be nude to the Direnor removed and disposed of. of Licensmg. U.S. Atomic Energy Commission,Washmg. l ton, D.C. 20545. The request t.hould include the

d. Conversion to a New Nuclear System or a Fossil 8

following informanon: Fuel System. This alternatise wruch apphes only to nuclear powc plants, utilizes the existing turbme system

a. A descnption of the. current status of the facility.

with a new steam supply system. The onpnal nuclear i steam supply system should be separated from the LJ ' b. A desenpuon of meawres that will be taken to electric generatmg system and disposed ofin accordance prevent er ucahty or reactmty changes and to mmimize with one of the previous three reurement alternatives. E releases of radioactmty froin the facihty.

3. $URVEILLANCE AND SECURITY FOR THE RE-L

_ c. Any priposed changes to the tecnnical specifica-TIREMENT ALTERNATIVES WHOSE FINAL tions that redect the possesuon only facihty status and STATUS REQUIRES A POSSES $10N ONLY the necessary disassembly. retirement acuvines, to be LICENSE ' performed. lo A facihty wtuch has been heensed under a posses-d, A safety analysis of bo:h the activities to be non only license may contain a ognificant amount of h

accomphshed and the proposed changes to the technical radioactmty in the form of actWated and contanunated specincauens, hardwaie and xrauctural materiajs. Surveillance and 7

commensurate secunty should be provided to assure that

e. An mventory of acuvated materials and their the public heahh and safety are not endangered.

'L location m the faciht).

a. Physical security to prevent inadvertent exposure l.H; 1.' ALTERNATIVES FOR REACTOR RETIREMENT of personnel should be provided by multiple 'iocked lhh barners. The presence of these barriers should make it

!'=>s 1Four aterr.atives for retiremer.t of nu: lear tractor extumely difficult for an unauthonzed person to gam facihties 'are conudere.1 acceptabie by the Regu!atory access to areas where radiauon or contamination levels- ~D y - stiff;These are. exceed those specified in Regulatory Positan CA. To l,ci prevent inadvertent exposure, radiation areas above 5 l j% '

a. Mothballing Mothbalhng of a nuclear reactor mPJhr. such as near the activated pnmary system of a f

' ncihty consats of putting the fa cihty m a state of power platit, should be approprntely marked and should lhf ' protectne itorage. In genera!. the facihty may be left not be w;cessible except by cuttmg of we.ded clotures or ~ jg Emtset except that all tuel assernbhe! and the radioacuse the disassembly and remova! of substantia) structures QM M L l.86 2 QQ: +., I jy ml GC :r. 'N 1 y q yiUA!;u U nM",

and/or shieldmg matenal. Means such as a remote. readout mtresion alarrn system should be provided to (1) Ennronmental surveys, mdicate to iesignated personnel when a phyucal barrier u penetrated Secunt> personnel that prende access (2) Facthty radiation surveys, control to the facihty may be used mstead of the j physical barriers an.: the mirusion alarm systems (3) Inspections of the physical barners. and

b. The phy.ical barriers to unauthortted entrance (4) Abnormaj occurrences mto the faciht), e g. fences. buddings, welded doors, and access opemngs. should be insrceted at least quarterly to assure that these barners have not detenor.
4. DECONTAMINATION FOR RELEASE FOR UN.

ated and that locks and lockmg apparatus are mtact RESTRICTED USE

c. A facihty radiatien survey sh<,uld be performed at if it is desired to terminate a license and to ehmmate least quarterly to venfy that no udioactne matenalis any further survedlance requirements, the facdtty should escapmg or bemg transported through the contamment be sufficiently decontaminated to prevent risk to the barners m the facdity Samphng should be done along pubhc health and safety. After the decontammation a the most probable path b> which radioactive material satafactonly accomphshed and the site mspected by such as that uored m the mner contamment regions the Commnuon the Commission may authortze the could be transported to the outer reg)ons of the factht) hcense to be terminated and the facihty abandoned or and ulumately to the environs released for unrestncied use. The beensee should pet, form the decontamination usmg the followtng guide.

hnes d.An ennronmental radiauon survey should be performed at least semiannually to venf> that no ugnScani amounts of radiation have been rele: sed to the

a. The bcensee should make a reason.nteffort to ennronment from the faciht). Samples such as sod, ehmmate rendual contammation.

vegetation, and water should be taken at locanons for which statisucal data has been estabhshed dunng reactorb. No covermg should be apphed t radioactive surfaces of equipment or structures by pana, platmg. or operauons. other coverms matenal untilit is known that contamma. A ute representative should be designated to be tion levels (determmed by a survey and documented) are e reponsible for controumg authonzed access eto and below the hmits specified m Table 1. In addition, a movement withm the facdity reasonable effort should be made (and documented) to funhet mmimize contammation pnor to any such

f. Administranve procedures should be estabhshed covenng.

for the notificauon and reportmg of atr.ormal occur.

c. The radioactmty of the mienor surfaces of pipes, rences such as (1 ne entrance of an unauthonzed dram imes, or ductwork person or persons mto the facthty and (2) a ugmficant should be determmed by change m the radianon or contamirttien levels m the making measurements at all traps and other appropnate facihty or the offsite enuronnient.

access pomts. provided contammation at these locations n hkely to be representative of contarruiution on the

g. The fouowmg repons should be made mienor of the pipes, dram lines. or ductwork. Surfaces of premnes, equipment or scrap which are likely to be (1) contsmmated but An annud report to the Director of Licensmg.

are of such size, construction, or Commission, Washmgton. D C. location as to make the surface maccesuble for purposes U.S. Atorruc Energy 20545, desenbmg the results of the ennronmental and of measurement should be assumed to be contartunated facihty radiation survey s the status of the facdtty, andin exceu of the permnsable radianon hrruts. an evaluation of the performance of secunty and

d. Upon request, the Comfruuson may authonze a surseibnce measures bcensee to rebnqunh poneuton or control of premnes.

(2) An abnormal occurren.c report to the Regula-eqwpment, or scrap hanng surfaces contammated m tory Operadons RegionM Office by telephone withtn 24 excess of the hrfuts specified. Th s rnay include, but is houts of dncovery of an abnormal occurrence. The not htmted to, specta) circumstances such as the transfer abnormal occurrence wdl also b rported m the annual of premises to another heensed organization that will report descrbed m the precidmg item. contmue to work with radioactive materials Requests for such authontation should provide:

h. Records or logs rehitne to the following items should be key and retamed untd the beense is termi.

(1) Detailed. specific informauon desenbtng the nated, after which they may be stored with other plant premises. equipment scrap. and radioactne contami records nants and the nature, extent, and degree of res dual surface contsmination. 1.86 3 ,p p, m-(~Of m

~ y :- j t .U andlos shieldmg material. Means such as a remote-(1) Enwronmentalsurveys, .- readout intrunon alarm system should be provided to mdicate to designated personnel when a physical barner (2) Facility radiation surveys, is penetrated.' Secunty personnel that provide access control to the facihty may be used instead 'of the (3) Inspections of the physical barners. and - physical barriers and the intrusion alarm systems. ~ b. The physical barners to unauthonzed entrance mio the facthly, e.g., fences. but! dings, welded doors, and access opemngs, should be inspected at least 4 DECONTAMINATION FOR RELEASE FOR UN-quanerly 30 assure that these barners have not deterior-RESTRICTED USE ated and that locks and locking apparatus are intact, li it is desired to terminate a license and to eliminate e, A facility radiation turvey should be performed at - any it rther surveillance requirements, the facdity should least quarterly to venf> that no radioactive matenalis be su<ficiently decontaminated to prevent risk to'the' g escapmg or beiag transported intough the contamment publi: health and safety, After the decontammation is - barners in the facDity. Samphng should be done along satisfactorily actomplished and the site inspected by the most probable path by which radioactive material the Commission, the Commission may authonze the such as that stored in the inner contamment regions-license to be terminated and the facility abandoned 'or

could be transported to the outer regions of the facihty released for unrestncted use. The licensee should per.

and ultimately to the environs. form the decontarrunation using the following guide-Imes:

d. An ennronmental radiation survey should be performed at least semiannually to venfy that no
a. The licensee should make a reasonable effort w signficant amounta of radiation have been released to the elimmate residual contammation.

environment from the facihty. Samples such as soil, vegetation, and water should be taken at locations for

b. No coveririg should be applied to radioactive wtuch statistical data has been estabbshed dunng reactor surfaces of equipment or structures by pamt, plating,or operations.

other covering matenal untilit is known that contamina-non 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 controuing authonzed access mto and reasonable effort should be made (and documented) to movement within the facuity, further mmimize contammation pnot. to any such covenng.

f. Administrative procedures should be estabhshed for the notification and reportmg of abnormzl occur-c, The radioactinty of the intenor surfaces of pipes, rences such as (1) the entrance of an una~ thonzed drain lmes, or ductwork should be determmed by u

person or persons mto the fac0ity and (2) a significant makmg measurements at all traps and other appropnate change in the radiation or contammation levels in the, access pomts, provided contammation at these locations facdity or the offsite enuronment, is likely to be representative of contarrunation on v intenor of the pipes, drain lmes, or ductwork. Sun:cs gc The following reports should be made: of premises, equipment, or scrap which are likely to be contaminated but are of such size, construction, or (I) An annual repo.t to the Director of Licensmg, location as to make the surface inaccessible for purposes U.S. Atomic Energy Commission, Washmgton, D.C. of measurement should be assumed to be contartunated 20545, describing the results of the environmental and in exceu of the permissable radiation hmits. facihty radiation surveys, the status of the facility, and an evaluation of the performance of secunty and

d. Upon request, the Commission may authonze a surveillance measures.

hcensee to relinquish possession or control of premises, equipment,' or scrap havmg surfaces contaminated in (2) An abnormal oi;currence report to the Regula-excess of the h, nits speci"ed. This may include, but is tory Operations Regional Office by telephone within 24 not limited to, special circumstances such as the transfer hours of thscovery of an abnonnal occurrence. The of prermses to another licensed organization that will abnormal occurrence wul also be reported m the annual contmue to work with radioactive materials. Rer,uests report described m the precedmg item. for such authonzation should provide:

h. Records or logs relative to.the followmg items (1) Detailed, specific information describmg the should be kept and retained untd the license is termi-premises, equipment, scrap, and radioactne contami-nated, after which they may be stored with other plant nants and the nature, extent, and degree of residual records:

surface contamination. 1.86 3 G

n, - (2) A detailed health and safety analysis' mdi. cr a change in the technical specificati5ns sh:uld be 1 catmg that the residual amounts of materials'on surface reviewed and approved m accordance with the require-areas, together with other considerations such as the ments of 10 CFR l50.59. prospecuve use of the premises, equipr.1ent,or scrap,are . un!.kely to result in an unreasonable risk to the health lf major structural changes to radioactive omponents and safety of the public. of the facihty are planned, such as removal of the pressure vessel or major components of the primary

e. Prior to release of the premises for unrestricted system, a &smantlement plan meludmg the mformation use, the licenser should make a comprehensive radiation required by l50.82 should be subrrutted to the Commis-survey establishing that' contarnination is within the sion. A dismantlement plan should be submitted for all limits specified in Table 1. A survey report shovd be the alternatives of Regulator / Position C.2 ev. cept filed.witn the Director of 1.icensmg. I.'.S. Atomic Energy mothballing. Howe.er, msnor disassembly activities may Commission, Washington, D.C. 20545, with a copy to still be performed in the absence of such a; plan.

the Director of the Regulatory Operations Regional provided they.are permitted by existmg operstmg and Office having junsdiction. The report should be filed at mamtenance procedures. A dismantlement plan should least 30 days prior to the planned date of abandonment, include the following: The survey report should:

a. A description of the ultimate status of the facihty (1) Ider.tify the premises.
b. A description of the dismantling actimies snd the,

(2) Show that reasonable effort has been rtade to precautions to be taken, reduce residual contammation to as low as practicable levels

c. A safety analysis of the dismantimg activities including any effluents which may be released.

(3) Describe the scope of the survey and the general procedures follow ed: and

d. A safety analysis of the facility in its ultimate status.

(4) State the fin 6ng of the survey in units specined in Table 1. Upon satisfactory review and approval of the dis-mantling pian, a dismantling order is issued by the After review of the report, the Commission may Commission m accordance with $50.82. When dis-mspect the facihties to confirm the survey prar to mant!!ng is completed and the Commission has been l grantmg approval for abandonment. notified by, letter. the appropnate Regulatory Opera-tions Regional Office inspects the facility ard venfies 5.' REACTOR RETIREMENT PROCEDURES compleuon in accordance with the dismantlement plan. If residual radiauon levels do not exceed the values m 1" As indicated - m P.egulatory Position C.2, several Table 1, the Commission may termmate the beense. If alternatives are acceptable for reactor facility retirement. these. levels are exceeded, the. hcensee rete.is the if mmor disassembly or "mothballmg" is planned, this possession only -heense under which the dismantling could be done by the exisung operstmg and mamte. activities have been conducted or,as an alternative.may nance procedures under the license m effect. Any rnake application to the State Of an Agteement State) planned actions mvolvmg an unreviewed safety question for a byproduct materials license. 1 1.66-4 x--- r w

i ? TABLE! i ACCEMABLE SURFACE CONTAMINATION LEVELS NUCLIDE: l AVERAGE c MAXIMUMbd. REMOVABLE e I b b b U.nat. U 2 35, U.238, and 5,000 dpm c/100 cm 15.000 dpm a/U. cm. 1.000 dpm a/100 cm2 2 2 associated decay products ; 2 2 Transuranics. Ra 226. Ra 228. 100 dpm/100 cm2 300 dpm/100cm : 20 dpm/100 cm Th 230, Th 226, Pa 231, Ac 227,1125.1129 2 2 3000 dpm/100 cm2 200 dpm/100 cen Th nat, Th 232, Sr 90, 1000 dpm/100 cm Ra 223. Ra 224 U 232. 1 126.1 131,l.133' 2 15.000 dpm 09/100 em - 1000 dpm 09/100 cm2 ) Beta gamma emitters (nuclides. 5000 dpm 0 7/100 cm with decay modes other than alpha emtssion or spontaneous fission) except St 90 and others noted above. -[ a%here surface. contamination by both alpha and beta gamma emitting nuchdes exists, the bmits established for alpha and - beta gamma emitting nuclides should apply mdependently. 7 bas used in this table, dpm Idisintegrations per trunute) means the rate of emission by radioactive matenal as determmed by correcting =

  • the counts per minute obsersed b) an appropriate detector for background, effiewncy, and geometric factors associated with the instrumentation.

(Measurements of average coritami..?nt should not be averaged over more than I square meter. For objects of less surface area. the average should be densed for each such object. r 2 dThe maumum contamination lesel applies to an area of not more than 100 cm. 2 of surface area should be determared by wiping that area with dry filter or : 'The amount of removable radioactne material per.100 cm soft absorbent paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropnate 4 mstrument of known efficieno % hen removable contammation on objects of less surface area is determmed the periment levell .. should be reduced proportionaUy and the entire surface should be wiped. L o 1 . i. ~ 1.86 5 e-9 'l +

.~ u O Federal Repster / Vol. 46. No. 205 l' Fnday, October 23 1981 / Notices $206_1 The Assmant Secretary finds that good Technical Position for ademistraton by assure that bunal of radioactve wwws cause exats for not pubbshms the the Uranium Falls.ensma Branch. would not pruant an unreasonable supplement to the Puerto Rico State Plan Drvnion of Fuel Cxle and Matenal health hacard at some future date. L es e proposed change and m61dng the Safety. Offlee of Nuclear Matenal The deleted provisions of I 20.304 I l Regional Admuustretor's approval Safety arid Safeguards. previously peruutted bunal t.f up to 100 efrecuve upon pubbcation for ths. Dafts: Comments on the options for sni!!icunes of thonum or natural urasuum at any one tune, with a yearly limitation followmg reasons: disposal or onsite storege of thenum or of 12 bunals for each type of matenal at 1.The standard: sre identcal to the uratuum are encouraged. Such each site. The only disposal standards j-Federal stancards which were c.omments will be considered in any specified were (1) bunal at a minimum h proroulgated m accordance wie Federal subsequent mision of the Branch JePth of four feet. and (2) successive L law meeung requirements for pub! e Techrncal position. Comments an due 'bunals sepersted by at least six feet parte:pation. December 22.1981. Thus a total ofIJ cunes of these 2.The standards were ad, opted la Note.--Cotaments rossived eher the matenals were persutted to be disposed accordance with the procecural expireuen date wi!! be considstad if 6t is of each year by bunalin a 12 foot by 18 requirement of Stoe 1.aw and h;.rther precuce! to do so, but assursace of foot or la:ger plot of ground. considereuta osanot be riven encept as to perucipation would be unnecessary. comments fuod on or before that date. Under the amended regulations,itla The decision n efleceve October 23, Pos PuerTwan to PosataTices coerf aCTt incumbent on an applicant who wants Ralph 0. page, Chief. Uranium Fuel to bury radioacuve wastes to - 1981. (Sec. ti pub. ! et-as6. e4 Stat teos 12e U.Sc 1.icenems Branch. Division of Fuel Cycle demonstrate that local land burial is ser)) and Matenal Safety.OfBca of Nuclear. preferable to other disposal alterneuves. Signed at New York Cary, New York, this Matenal Safety and Safeguarda, he evaluation of the application takes 15th day of lune test. Washington. D.C. 20t&&. telephone 301-lato account the following infeemstion: } nog., A, m 42 6 Types and quantities of maternal to be Aaysons/ Mmuustroser. sumssaawTam neeonesaTwee buried inon.m.asuras m us.y hM MW %une esos este.sNs - g, g,g,,ggggg,, Buriallocation Some of the sites formerly used for Characteristics of burial alta i m NUCLE.AR REGULATORY procassms thonum and uranium an Depth of burial known toesy to be contasmated with Access testrictions to disposal site COMMi&SION residual recljoacuve matanals. Some are Radiation safety procedures durms - Advlacry Committee on Reactor currently covered by NRC licenses. disposal operauons Safeguartes, Suecommittee on Others were once licensed. but the Recor6sepas _ Callaway Plant; Location Change licenses to possess and use mantial kcalbunalrenrictons,if any have expired. In many cases, the total For applications involvmg disposal of The ACRS Subcommittee en amount of contammated soilis large, but soils contarnineted with low level Callaway Plant will hold a meetmg on the acudy concentrauas of contentrations of thonum and utaalum Novernber 4 and 5.1981, at the radioacuve matenals are believed Wu the enemum = HOlJDAY INN-%T.ST.19001-r0 Dnve sufEcient) low to lus their disposal pg 4 Southwest. Columbia, MO t.Jtead of the cn pnvate y owned Ian a or storegs Hilton inn. onsite rather than ther transport to a Concentrations of thorium and uranium Neuce cf this meeung was pub!!shed Licused radioactive materiale disposal (either in secular equilibnorn with in the Federal Register en October 19. (commercial) site. in many instances their coughters or without daughtere 1981 (46 FR 51329), and all other items packagmg and transporting these wastes present) remam the same except for the locaten to a licensed disposal site would be too Volume of contaminated soll change as edicated abeve, costly and not jusufied from the Costs for offsite and onsite disposal Deied. October 19,1981. standpoints of risk to the public beslth John C. Hoyle. or cogg. bene 6L Furthermore, because of Availability of o!! site bunal space unsory commmse.Menesemem 07,eer: the total volume of thess wastes, limited Disposal site charactenstics commercial waste disposal capacity. Depth of bunal and accessibility of in oor.ei-awn nw i a ei.us est and restnetions placed en receipt of buried wastes long. lived wastes at commercial sites,it State and local governmant views siu.mo ooon rien.ews ' I D. kand TWW Moe a$tsat e al w evel . Disposal or Oneite Storege of Thorium ese Dere are five acceptable options for or Uranium Westen From Past wesie disposal sites. disposal or onsite storage of thonum Operevons Effecuve January 28.1981, NRC and uranium co.tamme>ed wastes. regulations in to CFR 20. " Standards for aoatecy; Nucieer Regulatory Protection Agamet Radiaton", were Applicanons for disposal or storage wil! Comnussion (NRC). amended (45 FR 71781-71762) to delete be approved if the guidelines discussed acTicec Dacussion of cptiens for NRC i 20.304 which provided general under, eay option are met. Applications approval of applications for cisposal cr authenty for disposal of radioactive for ciner methods of disposal may be onsite storege of thonum or uranium matenals by bunal in sotl. Under the submitted and these will be evaluated wastes: mtenrr. use and public cor. ment. amended regulauens. licensees must on their own ments.

1. Disposal of acceptably low suuuamv:This notice discusses five appiy for and obtam specific NRC concentretions (which meet DA options for NRC approval of disposal or approval to dispose of radioactive cleanup standards) of natural thorium metenals in this mariner under the g

wastes from past nuclear operations. provisions of to CFR :0.30:. A case.by. with daughters m secular equilibnum. . ensite storege or thonurn or uranra The options are contamed m a Branch case review was believed needed to depleted or ennt.hed uratuum, and .q +

3.. ..us.s 4] 33062 Federal Register / Vol. & No. 205 / Friday'. October 23, 1981 / Notices ? / a'anium cres with daughters m ' secular and natural uranium ore wastes

3. Disposal of low concentrations of

. equilibnum eth no notnction on bunal contamms daughters not at secujar natural uranium cres with all daughters , e methid. equibbnum can be calculated on a case-in equilibnum when buned under . Undir this option the concentratioria by case basis usms the applicable presenbed conditons m areas coned for ,, of natural thonum and depleted or isotopic scuvites esta. mdustnal use and the recoroed utte enriched uranium westes are set

2. Disposal of certain low documents are amended to state that the sufficiencylow that no member of the concentreuens of natural thonum with specified land centsms buned pubhc is expeeJed to receive a radiaton dayhters m secular equilibnum and red oscuve matenals and are

, -dise comtrutment from the disposed dep eted or ermched uratuum w th no condiuoned m a manner acceptable Catenals in excess of1 miDired per year daugniers present when buned under under state law to impose a covenant t2 the lung or 3 millirade per year tu the presenbed cooditions mth no rurmms with the land that the specified . bone from inhalanon and invesuon. subsequent land use restnetions and no land may not be und for residennal ender any foreseeable use of the contcums NRC bcensms of the buildmg. (There is no contmuing NRC Cateri:1 or property. These recanon matenal. 1;eensms of the mstenal.) ' dose sundelines were recommened by Under this option the concentrat.ons Dispoul will be approved if the bunal . Me Envsrorunental Protection Agency of natural thonum and uranium are set entens outlined in option 2 (meludmg (DA) for protection asemst sufficiently low so that no member of bunal at a mirurnuto of 4 fut) are met. - tansuraruum elements present in the the pubhc will receive a radiation dose Dependirig uponlocal soil env ronment as a result of unplarmed exceedmg those discuued under opcon charactensucs. bunals at depths greater . eentaminston (42 FR 9005M0959). In 1 when the wastes are buned in an than 4 feet may be required. In order to

addib!n. the concentranons are approved menner abunt intrusion into assure protecuon against redon 222

' mSNently low so that no individua] the bunal grounda. This opcon will releases (daughter in decay cham of . Cay receive an external dose in excess requin estabhshing prescribed uraniura 233 and uranium 234). it is of to microroentgens per hour above con 6tions for dispoul in the license' necessary that the recorded t0e background.This is compatible with such as depth and distnbution of documents be amended to state in the matenal, to mminuze the likelihood of permanentland records that no E suidelinee DA proposed as cleanup

standards for inact.ve mnium intrusion. Bunal mil be permitted only i.f nsidential building should be permitted It can be demonstrated that the buntHe over speciSed areas ofland where processing sites (46 m 2,5W2663).

matenals wiu be stabilized in place and natural uranium ore residues (U-238 - For natural uratuu:c ores havmg daughters in equilibnum. the not be transported away from the site. plus U-234)in concentrations exceeding so:centrauon hmit is equal to that set Acceptability of the site for disposal to pCi/gm has been buned. Industnal , E by the DA (46 m 25W2563) for wiu depend on topogra hical, bundmg is acceptable u IW as se ' endium.226 (i.e. 5 oCilgm. including geological,hydrologica and concentranon of buned matenal does , background) and its decay products. metecrological charactenstics of the riot exceed $0 pCl/sm of uranium (i.e.. site. At a mmimum. bunal depth mil be Ra426 shall not exceed 20 pCi/gm). The concentrauons specified below at a o a ace. are beheved apprepnate to apply. lt is

4. Disposal of land use limited g

concentrauens of naturalthonum or expected.however that curren0y beans:d cperanons will be conducted in pdhI a1 deb d no mber oI ge natural uranium with daughters in . auch a minner as to minimise the excess fo 170 millimms to a entical secular equillbnum and depleted or possibili of soil conta= nation and ennched uraruum without daughters organ. An average dose not exceeding ,. crhen suc occurs the contarntesuon 170 miUirems to the whole body for au present when buned under presenbed con 6 cons in areas zoned for industnal trill be reduced to levels as now as members of a general population ts un and the ree.orded title documents are reasonably achievable, recommended by internaconal and national rs6ation expert bodies ta bmit amended to state that the land contains buned radioacuve matenal and an population doses. With respect to con 6 toned in a manner acceptable j :- h= tmg doses to individual body a rgans, 7,,, the concentrations an sufficient!) low under state law to impose a covenant that no mdividual wiu receive a o 'se in runnmg with land that the land (1) may not be excavated below stated depths in y ; excess of 170 millireme to any orgas, specified areas ofland unless cleared by . emme ow= tsar w wash a m from exposure to natural thonum. o,",,,,",O,~"'~""*'"" an==e = - so depleted uranium or ennched uranium. appropnete health authentes. (2) may '" w cm twrm = won e

  • The average activity concentration of not be used for residenual or mdustnal ra6cactve matenal that may be buried structuns over specified areas where under this opuon in the case of natural es&oactive matenals in concentrauens

- The analysis upon which the Branch thenum (Th-232 plus Tb-228) is 50 pCi/ higher than specified in opuans.t and 3 Techrucal Posmon it based is available g=. if all daughters are present and in are buned. and (3) may not be used for for mopecuen at the Commission's equibbnum: for ennched uranium it is agneultural purposes m the specified L Public Docurnent Room at 1717 H St.. 100 pCilgm if the urstuum is soluble and areas. (There is to contmutng NRC N.W. Washmsten. D.C. 250 pC /gm if mooluble:for depleted licensms of the disposal site.) The c:ncentrauons specified under uranium it is 100 pCi/stu if the uranium Under this option. condiuons of bunal ' this.opticn may be competed with is soluble and 300 pCi/gm if insoluble. will be such that no member of the naturally ocurnrig tnonum and uranium Natt.ral uranium ores contammg radium pubhc will receive re&auon doses m are uncent stions of 1.3 pCi/sm m 226 and its daughters an not tncluded excess of those discussed under option 1 . igneous rock and uranium uncer this opuen. because of possible absent mtrusion mte the bunal ground. soncentratons of 120 pCi/sm in Fionda reden 2;.2 emanauena and resultant Cntene for 6sposal under these g phosphate rock and 50-60 pCi/gm m . higher than acceptable exposure of con &uons is predicated rpon the (Tennessee bitummous shale. mcivicumis m pnvate residences !! assumption that mientional mtrusion is (Conctntrauon hmits for natural thonum houses were built over buned matenals. less bkely to occur if a warnmg is given (. W .v-

Federal Registe? / Vol 46 No 205 / Fndas Octobe? 83. 398's / Noticos $2063 in land documents of record not to the svadabihty of an appropnate OFFICE OF THE UNf?ED STATES excavate below bunal oepths m 6sposal site. TRADE REPRESENTATIVE specified areas ofland mthout When concentrations exceed those Fiesolution of Complaint of Pnce-clearance by heahh outbonnes. not to speedied in opuen 4. long term esposaj Uncettuftme of SuesN3tase Cheese construct residental or mdustnal other than at a beensed disposal site I*#0"8 budding on the site, and not to use mil not nonnally be a noble opton specifiec areas of land for egneultural under the provisions of 10 CR 20.3C2. In On October 1.1981 the United States purposes Because of this we beheve it such cases, tas thonum and utaruum Trade Representative received a letter appropnete to apply a maxirnum entical may be permitted to be stored onsite from the Secretary of Agneulture organ exposure hmit of 500 mdhrems per uneer an NRC bcense until a swtable informma bim of the Secretary's findmg year to thonum and aranium buned method of disposalis found. License that imported Crede A Swiss type oder this restncuen mstead of 170 con 6tions will require that recauori cheese produced m Fir. land has been offered for sale in the United States at albrems as used in opnons 2 and 3. In doses not excee'd those specified in to ad6uon. any exposure to such matenals CHL Part 20 and be mactamed as low duty. paid wholesale pnces which are five cents per pound less than the is hkely to be more transient than as tvuonably achievable. domestic wholesale market pnce of assumed (essentially conunual Befon approvmg an applicaten to stmilar cheese produced in the United exposure) under those opuona.Thes, 6spose of thonum or uraruum under g,,,,, two factors combine to tacrease the acunty concentration limits calculated optiora 2. 3. or 4. NRC will sobcit the in accordance with Section ?c2(c)(2) under opean 2 by about 10. Thus. the view of appropnate State health of the Trade Agreements Act of1979 1 ofBeals etbn the State m wbch the (the Act)(19 U.S.C.1202 notal 6 OtSce average concentreuen that may be buned under this onton for thonum disposal would be made, of the United States Tnde (Tb-232 plus Tb228)is 500 pO/gm a all Dated at Silver Spnne. Marytsad this 19th Representative notined Flsland of the daughters are present acd m day of October.teet. pnce undercutting deteramation made by the Secretary of Agricultws. eeu111bnum; for enriched urazuum it is Itichard L t'uanat am h requested 'het comsetive ution be 1000 pQ/gm if the uranium a soluble g taken, and enked for appropriate and 2600 pC/gm insolub e. and or S#ery. OSce #tiucMoana/S#ery and assurances concernas the commitments depletcd uranium it is 1000 pCl m if the sg,yvera, made in the Arrangement Between the F uratuum is soluble and 3000 pCug= d rn o,,, United States and Finland Coocetning insoluble. amasse cose ram.es.e Cheees. With respect to naturaj araruum mth daugnters present and m equibnum-On October 14.1981. Finland notifled the concentration that may be buned the United States Trade Representative under this opcon i 00 pCi/sm of U-238 OFFICE OF PERSONNEL that measurge have been taken to t plus U-24.e.100 pCu gm Ra-22t, Dus MANAGEMENT ensure that the duty. paid wholesale concentration is based on a hmited pg.ca ofimported Grade A Swiss type exposure of 2.4 hours per day to h: rut the Portponement of Application Deadline cheese produced m Finland mil not be radon dose to less than 0.5 workang level for Funo Raismg Pnvlieges Among less than the domesoc wholesale market month (WLM) which is equivalent to Federal Employees by Prtvate pnce of sunilar cheese produced in the contnuous exposure to 0 0; wericng Voluntary Organizations United States. In ad6 tion. Finland gave assurance that it mil respect the pnce level (WL). Depencitig upon local soil Secuen 5.43 of the " Manual on Fund-comeutmenta in the Arrangement. Since charactenstics. bunais at deptns g eater Raising Within the Federal Sernce for the above notdication by Faland has than 4 fut may be requeed. Voluntary Health and W alfare ogg.urred wem h 15 day pened Sswwamv os umwww Concewmnows Agencies" sets December 1 of each year prended m Secuen 702(c)(3) of the Act. Psaweto vuota Dis >csA omcas as the deadhne by wbeb nanona} the Uruted States Trade Representative voluntary agencies must submit has nonfied the Secretary of Agneulture apphcauons for parucipanon m the of bs behef that no further acuen is w..u Combmed Federal Campaign (CFC) to required. ,,,,,,,,,,,,,. rmau m l j j be conducted in the fall of the follomng WEman L Beesk. year. The year's deadlme to bems UrusedStases Trode Aspresariseuve 9l,! 'eamar==* w ***! postponed from December 1.198L to p n, [---']**l**' ,,, 7,,,,,, m. m j February 1.1982 In June 1981. the U.S. ,,2,,, agog,,,,,,w =* e e -*====== el Office of Personnel Management (OPM) e,,, "'f',',,,,,, j as sec - ' oce announced that the ehgibiury cntena for I mas 6,, %., ' parteipsuen m the 1982-43 CFC are 34CURf71ES AND EXCMANGE y. ~ y being reviewed. The deadhne date ts COMMIS$10N g. x betng postponed to avoid national -.c,aa,'gg=q_ _,,,,, voluntary agenciet navtng to rense thett (metasse NS 2 m e.7 M 680) apphcations to meet ebgibdity entena Arkansas Power & Light Co.: Proposed c $2%% P, " "*"" "'*"" ""*

  • wbch ma y be : hanged.

lasuance and Seie et First Mortgege 2';"',~2,**,.Wi,"M',*, dh*",,,",,$ Donald J. Devias, Bonda c w --sm=== * ** g,, m, Octobot to test. in on ew'*wn e m *e w 5 Storage of heensed concentrations Arkansas Power & Light Company of thenum and uranium casne pendmg ausso ocos ease ew g

p 1w-s 4 BACKGROUND i o Gems have been irradiated. in reactors since the 1950's on a limited ' basis 4-o Irradiation can be Neutrons, Alpha, Beta, or Gamme o Neutron-Irradiated Blue Topaz. became very popular ~' " #" # '_ l In Mid-1980's Induced radioactivity in Blue-Topaz. ranges up to o ~ ' ^ " " ' '. v-. '~.. ' w:.. '.' '- - 10 nanocuries per gram. e-o Primary radionucIldes 'are Scandium -48 Tantalu m-182 Manganese-54 . I t . 5 n-m ,.m ,r

c..k, v 4..=

.,%'I.,,.

/ m i "~ POLICY ISSUES p.=** "'^ o 10 CFR Part 30 allows " Exempt Concentrations" which may be considered as BRC limits ,,,.('r,'"2^.-.'.'.',.}o 10 CFA Part 30 prohibits radioactivity in food, .,,,.... e.,. e....,.s bevereges, or -cosmetics " i *< .,,., t...c r<....,,,,.,.,.,.. +.,..,, u,.. ..,s..,..,,,.,<,, 4.v,,.,.. z ,.. w,, r.. ' 7. - <r, e. . 6 o "Justifice tion" '1965 AEC/NRC Policy prohibits . s,.. i.., frivolous radioactive products such as jewelry i.i. c f. r *. a i t 6 i l ..=

+ [' o_ a. COMMISSION DECISION OM GEMS o NRC will accept license. appilcations for dIntrfbution -of radioactive gems Radioactivity levels must be below " Exempt Concentrations" ~ w 'o o [ ~ ~~. r Set aside "frtvolous" Issue

f.. - f, /, - f W~ < '

,o r......,,,,,,,, g' o Key issue is low health risk; ',.,,33 . radiosotivity in gems i ,l ' [,,,[..,' Is in the Below.; Regulatory Concern range ...e., J~ ,..:,..as~ r o Commission directed statt' to expedite policy development on ' BRC issues c I l i i g-# .sw ,e g 7 -..aJ '-pg g j'w... _.,,.,p g g 3- -+ 4

_s h ( 9 POTENTIAL HEALTH RISK FROM GEMS 4 o Cancer risk is very low 2 n, 4.a.pco ~, o Localized dose to skin: " Worst Case" , c.. ..,_ g. ' ' ' ' ' " '~'

  • C# ""

several hundred millirems per year o,.. a........ ra.. r.... <,,,,, _ p..,., _. 3 r . r r. r.,c..c.* r. .,.c,. t '.*, u,- a o Whole body. dose equivalent-4 a few millirems or less per year "r #4' o Dose decreases over time due to decay sc. a e< j,,,. ~ -s~ . o : s..,. the much higher if gems. are not o Doses can ' 't ' ' L'- "^""a' """" held. for decay properly t (le J ftI?* v5 W 70

  • *e f

o Cutting or grinding gems could cause ' " " " ' - ~ ' significant Internal exposures . "u t, r "--. ~- t.L n_ t t .. - t ro, Tr.., t'. .s ~ -,.>c. .~ . =

'N. n d L TECHNICAL ISSUES \\ r.r... r. o Measurement Techniques .'..',7. .. < - r. + o Induced radioactivity varies widely ,,.r.,...-.. <.,,/...,. s, a.,~ depending on mineral content

n... r... c -

s ,,..,1.- .-i. 1... o . Risk frorn cutting or ' grinding g e m s ',', ' ..' s,r. < ~ u ,. n.. r..,i....... i ...,,, r r. o Applyireg a BRC limit to gems , a n . t. ~ t.... r... r. r. c c .,, n.,,. ~ r... - n, 1. t... /.. e, > a.<, < c. i... 1 i. <......-<. t.<<,..., , r.r

u. i - e -.

y, .,.. r,, r > ,,-<-i.~,.r.- , gw. f, - ff. A!4 -**,' '** - l"* ' p., de e.- g c -..f,.' la., '

a..

i i

===:.

.sM -Q ?', ~ - i j. l l l i COMPARISON OF ALLOWABLE LEVELS o Transportation Exemption Levels 74 Bq/g (2 nCi/g) o European "De Facto" Exemption -Levels ~ l 74 - 370 Bq/g (2 - 10. nCI/g) o NRC 10 CFR Part 30.70' Exemption Levels 15_Bq/g (O.4 nCi/g) t h g m%, ~,,_ _ _ _ _, _.,_ _ _ _ _ _ m g, w

.._. s _ __. ___1-fg IRRADI ATED GEMS , s o

Background

j o Policy Issues q I o Commission Decision on Gems o Potential HesIth Risk From Gems l i o Technical Issues o Compa rison of. Allowable Levels o Application Information j i h i + -arm Mv-ye e-=t-ut.* p-s~ = y.- ,enq s_-c-- pv y e ',e77 ,ye+y q g g __ _____ __ x s 3

s . ) t ? i e l INTERNATIONAL ACTIVITIES .i o History a o Basic Criteria o- ~ General Philosophy for Exemption Framework for Exemption Levbls o o Guidance for. Trivial Levels - { General Procedure for Exemption Analysis o. [ 1 (- e W W e 6 f s

er, 1 2 's 4 I l r Y b HISTORY is t IAEA' Basic Safety Standards provide for exemption of o ,~ 'certain~ sources or practices from the system of notification, registration and licensing. I l Group of Experts not in 1985 and outlined a framework o. for below. regulatory concern exception. 1 ICRP outlined basis for exemption in' waste disposal. [ L o areas in Publication 46 " Radiation Protection Principles i for the Disposal of Solid Radioactive Waste." Joint NEA/IAEA expert group meeting in March 1988 prepared o draft consensus guidar.ce, e-

m,.. y "h-? i $( b i > ^ no + P i< t-3 s 4 L, 4 i BASIC CRITERI A o " Radiation Protection must be optimized" r t 'o~. "Indivicual risks must be sufficiently low" t I l l-t i l-I ~ l r .-G t v d a

(e 5-i;. 4.- 7 l k k l l ' GENERAL PHILOSOPHY FOR EXEMPTION o The use.of additional controls on a practice of source l of exposure does not result in an additional reduction i in the dose received. o The t.osts of the regulatory controls is.not balanced by the benefits of dose reduction that could be achieved,- 3 p l; p l-I i i. r l L L i l j u l l ,#1 ,m

n

i' 4"

i m - 5 ~- g i J n> J U FRAMEWORK FOR EXEMPTION LEVELS Ii I o Dose Limits values that are not be be exceeded,:even by licensed activities 2 represent boundary of exposures considered to be unacceptable o Selow1 Regulatory Concern E values that may be. considered-for reducing or l eliminating-regulatory controls represent range of' doses when costs do not l achieve further reductions, or are not l balanced by benefits l i o Trivial Dose .I values where regulatory controls are unnecessary. represent dose that can be judge as the: point-at which individuals who are aware of the risks i l they run would not canmit.significant resources of their own to reduce them i 1 Lf l l. L i 1 e-t l

y[ d 6- -[ 'l i Basic Regulatory Dose Liniit f r ? ALARA Applicable 1. i; I -' i } l I

Secondary

.Stancards i Source / Specific BRC levels- .s Generic BRC Negligible -Individual Risk i 1 I h .e-p j.' a.

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+ 4 6 l! t 1 GUIDANCE FOR TRIVIAL LEVELS. o Level of individual effective dose equivalent of some 10's of'uSy per year can reasonably be regarded as~ trivial by regulatory authorities. ~ Collective dose levels should be small, and determined i o as optimal (ALARA). This may be on the order of about: r 1 man Sv per year of practice. s i N

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r 1 t l } GENERAL PROCEDURE o-Ar.alysis of exemption i, characteristics of the practice to be exempted characteristics of the sources in the practice s o Calculation of individual ano-collective doses involved L-o Specification of exemption conditions constraint on total activity -I j, chemical' and physical form of materials identification of location or activity material may L L be released to L - o Establish method for_ determining compliance L L - o Periodic reanalysis of basis for exemption to determine if adjustments are appropriate L 1 . *:e ,h

LOW-LEVEL RADIOACTIVE WASTE POLICY. AMENDMENTS.'CT A SECTION 10: RADIOACTIVE-WASTE BELOW REGULATORY CONCERN ~ REQUIRED THE COMMISSION TO ESTABLISH STANDARDS AND PROCEDURES ^AND THE TECHNICAL CAPABILITY TO ACT.IN AN EXPEDITED MANNER ON PETITIONS TO EXEMPT SPECIFIC WASTE STREAMS FROM NRC REGULATION AND DO SO IN SIX MONTHS(JULY 1986).- 4 i 1 t e I

NRC' RESPONSE TO DATE POLICY STATEMENT AND STAFF IMPLEMENTATION PLAN PUBLISHED AUGUST 29,1986. ADAPTED IMPACTS-BRC COMPUTER CODE FOR PC AND PUBLISHED DRAFT USER GUIDE JULY 1986 4 PUBLISHED ADVANCED NOTICE OF PROPOSED RULEMAKING (ANPRM). DECEMBER.2, 1986 t s jg g

,.h n h s. w I POLICY STATEMENT h ADDRESSES DISPOSAL ALTERNATIVES INTENDED FOR MULTIPLE PRODUCERS 1 V BURDEN IS ON PETITIONERS - t l r I I I l { l i l l l c l t 4 2%. ~ ,4 c. -. b.:. e .s m'~.>,E-. .-..r,.: w..,

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BELOW REGULATORY CONCERN PETITION DECISION CRITERIA DECISION CRITERIA-GENERAL 1. NO SIGNIFICANT ENVIRONMENTAL. IMPACT 5. SIGNIFICANT SOCIETAL COST REDUCTION DOSES 2. EXPECTED INDIVIDUAL DOSES SMALL 3. COLLECTIVE DOSES SMALL-4. INSIGNIFICANT ACCIDENT-CONSEQUENCES L WASTE 6. COMPATIBLE'WITH PROPOSED TREATMENT / DISPOSAL L 7. -USABLE ON A NATIONAL SCALE 8. CHARACTERIZED WASTE AND ACCEPTABLE ~ VARIABILITY-l 9. REAL WASTE DATA - 1 10. NEGLIGlBLE POTENTIAL FOR RECYCLE IMPLEMENTATION I l 11. COMPLIANCE PROGRAMS FEASIBLE a 12. NO LICENSE NEEDED FOR OFFSITE TREATMENT / DISPOSA 13. STANDARD TREATMENT / DISPOSAL PRACTICES 14. NO REGUL ATORY OBSTAC'.t *) 9

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s, i R s l STAFF IMPLEMENTATION PLAN y l l. DESCRIBES INFORMATION NEEDED IN PETITIONS DISCUSSES THE RATIONALE FOR DECISION CRITERIA-ESTABLISHES RULEMAKING PROCEDURES t I F-i g 4 e w q, f a. y p r w g-w,,_.q,.y.y f .3,+ .w--, y 3,.c.

'"i', ).ij- . $1 N 4. ~ W . IMPACTS-BRC CODE 1 j. f TOOL NRC WILL USE INCLUDES ALTERNATIVE DISPOSAL METHODS ..f ADDRESSES RANGE OF IMPACTS (PROCESSING, TRANSPORT, DISPOSAL,' POST DISPOSAL) l i I f ( I l t . i l .. u

4,;, u, t g.. 4 .c g. x-; ANPRM GENERAL QUESTION OF "WHETHER AND HOW TO PROCEED ON THE MATTER--OF EXEMPTING SLIGHTLY CONTAMINATED RADIOACTIVE-MATERIALS" -h SIX SPECIFIC QUESTIONS l l li f i e t' 4 w' VM '~ tr'+7-'* t "P

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t SPECIFIC QUESTIONS. CODIFY DECISION CRITERIA AND CONTINUE ON WASTE STREAM-BASIS? 1) TAKE-A CONCENTRATION / QUANTITY OR DOSE LIMIT APPROACH? 2) BETTER WAYS TO ADDRESS MULTIPLE EXPOSURE POTENTIAL? 3)

4) GUIDANCE INSTEAD?
5) DEFER TO EPA?
6) RELY ON INTERNATIONAL WORK?

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7 ~ 4 UTILITY BRC PETITIONS j ELECTRIC POWER RESEARCH INSTITUTE.(EPRI)

t RESEARCH/ TECHNICAL-BASIS FOR 8 WASTE STREAMS 2 YEAR /$2 MILLION EFFORT EDISON ELECTRIC INSTITUTE (EEI) EXPECTS TO FILE 4. PETITIONS FOR THE 8 WASTE STREAMS (1988)

COMPACTABLE DRY TRASH FROM PWRS AND BWRS WASTE OIL FROM PWRS AND BWRS SOIL FROM PWRS AND BWRS AND BWR GRIT PWR SECONDARY SIDE RESINS 'T _m

-) i .:e. Application Inf o rmation. w -i o ' Basic Information o Background Information o Information specifically IdentIfled -In the regulations (e.g., ~10 CFR 30.33, 32.11) [ 3 o Information on instrumentation, counting, sampling and q.uality assurance programs o Information needed for support of exemption from 10 CFR. 32.11(c) o Fee Information ~ " / . k; i y y ,m3 r -~- e, 4 3 m ,y -~ ,,y 3 ,g m i

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_ +. OVERVIEP CF NRC'S RE5FCNSE TO l SECTION 10 0F THE LOW-LEVEL RADIDACTIVE WASTE POLICY AMEN 0MENTS ACT OF 1985 July 1987 l i Section 10: Radicactive Waste Belew Regulator'y Concern recuired the Nuclear Regulatory Corrission (NRC) to establish standards and procedures and the technical capability to act.in an expedited manner en petitions to exempt specific waste streams from NRC regulation and to do so in six months (i.e., by. l July 1986). Q: What has been NRC's respense to date? A: NRC has responded with three actions. A Commission Policy Statement and Staff Implementatien Plan were published August 29, 1986 (51 FR 30839). A j computer code for calculating radiological impacts from unregulated disposal was adapted for personal computer use and a draft user guide was published in l L July of 1986 (Volume 2 of NUREG/CR-3585). An advance notice of proposed l l rulemaking was published en December 2,1986(51FR43367). l Q: What was the purpose of the Policy Statement and Staff Implementation l Plan? o l A: These two documents provide cuidance to potential rulemaking petitioners. Existing Ccemission rules in 10 CfR 2.802 set forth the procedures for i L submitting rulemaking petitions for Cc=issien consideration. The Policy I-Statement and Staff Implementation Plan previce aeditional guidance for those petitions that relate to the exemption of slightly contaminated wastes. The statement and plan establish the standards and procedures that will permit the Co=ission to act up:n rulemaking petitiens in an expedited manner as required by Section 10 of the Act. Q:. Does the Pelicy Statement grant approval for below regulatory concern disposals? A: No. Rulemaking en petitions is recuired. '0: What opportunities exist for public input on rulemaking petitions to exempt waste streams? A: Petitions will be'cutlished fer public ccmment when received. Although i the petitiens will be handled in an expedited manner as recuired by Section 10 of the Act, any proposed rule that would grant part or all of any petition must follow the normal rulemaking pro:edure and be noticed for public cec =ent. Q: Have any rulemaking petitions been filed in respense to the Policy Statement?

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  • \\ l A:

No, but petiti0ns may be filed at any time. 0:' How dees the policy Statement address protection of the public health and safety? A: The policy Statement sets out fourteen decision criteria the Corrnission expects to follow when adoressing the overall' impacts of the disposals, maximum ' potential exposures to indivicuals from routine and accidental events, and potential cumulative exposures. Both short-tem and long-term potential exposures from handling, transport, treatment, disposal and post disposal are to be considered. The criteria also address the need for a comprehensive understanding of the properties of any wastes proposed for exemption and the need for licensees to be able to determine that actual wastes comply with concentration or wantity limits that will be set. Q: What methods of treatment and dispesal of slightly contaminated wastes may-petiti:ners prtpose as alternatives to disposal in licensed disposal sites? l l A: Petitioners may prepose alternatives such as onsite burial or incineration, burial at. sanitary landfill or ha:ardous waste facilities, or treatment or incineratien at municipal or ha:ardeus facilities. Q: What does below regulatory concern mean? A: A Comission finding that the radioactive centent is below regulatory concern means that the pctential radiological exposures from treatment, handling, or dispcsal of the wastes are so small that they do not ret;uire or warrant regulation. For example, below regulatory concern wastes may be suitable fer dir nal in a sanitary landfill ano the landfill operator would l not need to menitor incoming wastes, keep records, or conduct environmental menitoring for radienuclides. The landfill operator would be exempt frem all regulatien by NRC. Hcwever, NRC's exemption would not relieve anyone from the applicable rules of state, local or federal agenciet which cover tne nenradiological preperties of the wastes. l l Q: Who is expected to file rulemaking petitions? A: Staff are aware that trade or professier.al organizations representing l gro-.s or categories of licensees (e.g., hospitals, pharmaceutical manufacturers, or pcwer reactors) are censidering filing petitions but inoividual licensees or anyone can file a petition. Q: What was the purpose of the advance notice of proposed rulemakirig? A: The notice asked for public inout on the general cuestion of whether and how NRC shculd preceed on tne matter of exempting slightly contaminated wastes. The Ccmmission reccgni:ed that NRC-initiated rulemaking might facilitate processing of rulemaking cetitions on individual waste streams or provide mere generic estions.

+s m. 3 i Q:- khet issues were adoressed in the advance notice? A: Six specific cuestions were asked. The tcmmission asked if it should: (1) codify the decision criteria from the Policy Statement and continue on a waste stream basis? (2) take a more generic approach involving radionuclide concentrations or cuantities er dose limits? (3) consider better ways to address the potential for exposures to multiple waste sources? (4) issue additional guidance instead cf developing new regulations? (5) defer to the Environmental Protection Agency in this area totally or in part? or (6) rely on international standarcs and guidance? i Q: What'was the public response? A: Over 90 coment letters were submitted in response to the advance notice. Comenters expressec diverse views on the merits of below regulatory concern disposal and offered a variety of suggestions. For example, many comenters i opposed the cencept of any level of radioactivity being below regulatory concern and others urged NRC to proceed promptly on generic rulemaking. Commenters also addressed each of the specific questions raised in the advance notice. i Q: What are the NRC's next steps on the generic rulemaking? A: NRC staff are currently analyzing the cem.ents received on the Advanced Notice of Propcsed Rulemaking. Based en the comments and other considerations, the Commissien will cecide whether and how to proceed with a generic rulemaking addressing wastes belcw regulatory concern. If the decision is to proceed, staff would initiate technical and environmental studies to support rulemaking. After ccepletion cf the supporting studies, a proposed rule would be published i for comment, j [nclosures: I! f j l '}}