ML20140G713
| ML20140G713 | |
| Person / Time | |
|---|---|
| Issue date: | 08/27/1985 |
| From: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Kerr G NRC OFFICE OF STATE PROGRAMS (OSP) |
| Shared Package | |
| ML20140C976 | List: |
| References | |
| NUDOCS 8509030045 | |
| Download: ML20140G713 (4) | |
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~,, UNITED STATES 8 o NUCLEAR REGULATORY COMMISSION /
- E WASHINGTON, D. C. 20555
) LH August 27, 1985 13
, MEMORANDUM FOR: G. Wayne Kerr, Director Office of State Programs FROM: James M. Taylor, Director Office of Inspection and Enforcement
SUBJECT:
DRAFT PROPOSAL FROM ILLINOIS FOR AGREEMENT STATE STATUS I
We have reviewed the proposed application for Agreement State status and find that it is well written and complete in detail. Of particular interest are the " Agency Notes" that are found throughout the regulations that are used to define or interpret certain parts of the regulations. This is a good and novel I
approach. We have a few otner comments to offer for your consideration and they are enclosed.
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J mes M. Ta
% r, Director ffice of I spection and Enforcement i
Enclosure:
As stated i
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ENCLOSURE 1 Regulations
- 1. Section 4, Licensing of Radioactive Material.
On page 330-2, Item (2)(B) references an exemption for products containing /
glass enamel and glass enamel frit. This was in cur Part 40 regulations; however, it was revoked in 1984. The reason for revocation was that jewelry was being imported by several companies that contained uranium in the glazing, causing unnecessary radiation levels in articles used for adornment. 940.13 of 10 CFR 40 contains a footnote which states, "On July 25, 1983, the exemption of glass enamel or glass enamel frit was' suspended. The exemption was eliminated on September 11, 1984."
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- 2. Of the 15 sections, Section 4 of the regulations, Licensing of Radioactive Material, gives us some problems. Containing about 110 pages, it is difficult to follow because it jumps from one licensing category to another.
For example, Chapter 4 starts out by defining responsibilities for general licensees (pages 330-1 to 330-32) and beginning on page 330-52 discusses specific licenses to manufacture and distribute generally licensed quantities and exempt quantities. Perhaps these two could be combined. Similarly, a few general requirements for specific licenses that authorizes all of the materials used in radiography, medicine and so forth, are discussed beginning on page 330-33 and page 330-77. However, most of the pages are devoted.to l specific. licenses for manufacture and distribution of generally licensed quantities and exempt quantities. Forthermore, licenses of broad scope are ;
discussed in detail beginning on page 330-47, but the Table of radionuclide quantities for these types of licenses doesn't appear until page 330-110, 9 following 2 or 3 other discussions. In short, Section 4 appears to need to '
l be better organized.
- 3. Decommissioning and decontamination of facilities is discussed beginning on page 330-79 of Section 4. However, the release limits for contamination '
appears on page 340-69 of Section 6. . Both should be together in a single section.
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1 l With respect to the decontamination limits on page 340-69, there are only
! numbers and no guidance is offered, even though the title states, "Decon-tamination Guides." Because of this, we have attached guidance that the I - !
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j NRC uses. Without guidance on how to decontaminate and perform surveys, l an inspector's time might be wasted when requested to perform a confirmatory survey, since a licensee could have missed something for lack of guidance. !
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- 4. In Section 4, page 330-105, there is listed the medical groups of radioactive pharmaceuticals, Groups I through VI, the same as listed in j the NRC's 10 CFR Part 35. The compounds listed are for diagnostic 7 l and therapeutic procedures. Section 11 is entitled, "Use of Sealed I
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j Sources in the Healing Arts." Couldn't human uses of radionuc1 ides be
't combined into one section, similar to the NRCs Part 35?. '
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j 5. Section 7, Transportation of Radioactive Material, Pages 341-4,5. ;
We note that the provisions of 5 341.4(a) state that " Common and contract carriers who are not subject to the requirements of the U.S. Department
! of Transportation or the U.S. Postal Service are subject to Section 341.3
! i j and other applicable sections of these regulations." 5 341.3 requires that
] a general or specific license must be issued by the Department unless an
- exemption is provided. The effect of these requirements, therefore, is
) that an intra-state common or contract carrier would be required to get a specific license from the State of Illinois to "... receive, possess, ,
! transport, and store radioactive materials in the regular course of their f carriers for another ...." We question whether this is intended. It is
{ not consistent with the equivalent provisions of 55 10 CFR 30.13, 40.12, and 70.12, upon which it would appear that the provisions of 5 341.4(a)
I were intended to be based. We, therefore, recommend deletion of the last 4 sentence of 5 341.4(a).
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1 We also recommend that a "341.15" be added in the second line of $341.1(b) f following "341.14", since it would appear appropriate to include the ,
1 requirements for the " routine determinations" of 341.15, as well as the '
l " preliminary determinations" of 341.14.
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- 6. We believe that Section 4 needs to be refined. Certain parts of Section 4 are much too detailed. It appears that Section 4 was meant to be equivalent to the NRC's Part 30, 33, and 35. Section 4 could be divided up into more -
sections. A better solution would be to combine elements from Section 4 into other sections, thereby reducing the size of that Section.
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ENCLOSURE 2 -
GUIDELINES FOR DECONTAMINATION OF FACILITIES AND EQUIPMENT PRIOR TO RELEASE FOR UNRESTRICTED USE OR TERMINATION OF LICENSES FOR BYPRODUCT, SOURCE, ,
OR SPECIAL NUCLEAR MATERIAL July 1982
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U. S. Nuclear Regulatory Commission Division of Fuel Cycle & Materials Safety Washington, D. C. 20555 -
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The instructions in this guide in conjunction with Table 1 specify the radionuclides and radiation exposure rate limits that should be .used in i decontamination and survey of surfaces or premises and equipment. prior g to abandonment or release for unrestricted use. The limits in Table 1 do ~
l not apply to premises, equipment, or scrap containing induced radioactivil.y !
for which the radiological considerations pertinent to their use may be different. The release of such facilities or items from regulatory control "
is considert:d on a case-by-case basis. ,
- 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 covering material unless contamination levels, as determined by a survey and documented, ere 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. ,
f l 3. The radioactivity on the interior surfaces of pipes, drain lines, or
! ductwork shall be determined by making measurements at the traps, and i other appropriate access points, provided that contaminatica at these l locations is likely to be representative of contamination on the in-terior of the pipes, drain lines, or ductwork. Surfaces of premises, I equipment, or scrap which are likely to be contaminated but are uf I such size, construction, or location as to make the surface inacces-si ble for purpose of measurement shall M presumed to be contamin- l ated in excess of the limits. 1
- 4. Upon request, the Commission may authorize a licensee to relinquish possession or control of premises, equipment, or scrap having sur- .
faces 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 organiza-tion continuing work with radioactive materials, or conversion of facilities to a long-term storage or standby status. Such requests must: ,
- a. Provide detailed, specific information describing the premises, equipment or scrap, radioactive contaminants, and the nature, extent, and degree of residual surface contamination.
- b. Provide a detailed health and safety analysis which reflect that
- the residual amounts of materials on surface areas, together with other considerations such as prospective use of the prem- '
ises, equipment or scrap, are unlikely to result in an unreason-able risk to the health and safety of the public.
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- 5. Prior to release of premises for unrestricted use, the licensee shall make a comprehensive radiation survey which establishes that contami-nation is within the lir.;its specified in Table 1. .A copy of Qe -
survey report shall be filed with the Division of Fuel Cycle and Ma-terial Safety, USNRC, Washington, D.C. 20555, and also the Adminis-trator of the NRC Regional Office, having jurisdiction. The report should be filed at least 30 cays prior to the planned,date of aban-donment. The survey report shall:
- a. Identify the premises.
- b. Show that reascnable effort has been made to eliminate residual contamination. l
- c. Describe the scope of the survey and general procedures-
,, followed. ,
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- d. State the findings of the survey in units specified in the instruction. !
Following review of the report, the NRC will consider visiting the ,
facilities to confirm the survey. i
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TA8tt I .
l ACCEpTAttE $UnfACE ColliAMlleAiloit ttVfL5 Maggge We d f g(gq)yggggb e f ,
Isott IDt S* AVERAGEbcf ,
U-nat. U-235. U-238, and yg 000 dpm e/100 ce2 1.000 dpm e/100 cm2 anociated decay product! 5.000 dpm e/100 ce2 Transeranics. Ra-22fe. Ra-228 300 dpa/100'ce2 20 dpm/100 col Th-230. Ih-228. pa-231 100 dpm/100 cm2 Ac-221. 1-125. 1-129 th-nat, th-232. Sr-90 200 dpm/100 cm2 1000 dys/100 cm2 3000 dre/IOS cm2 R2-123. Ra-224. U-232. I-126 -
I-131. 1-133 Beta-garu'a emitters (nuclides esith decay redes other than 15.000 dre 3y/100 ce? 1000 dpm ev/100 cm2 R aipha enission or spontancous 5000 dpm ev/100 c,2 fi n ian) except 5r-90 and '
others noted above.
ekNre surface contaminatten by both e!p:.a- and beta-games-emitting nuclides entsts.'the limits established for alpha- and beta-ganna-selttleg nuclides should apply independently.
bAs used in this table, dpm (disintegrattens per minute) means the rate of emission by radleactive material as determined by correcting the counts per minute observed by an appropriate detector for background. ef ficiency. and geometric facters associated with the instrumentation.
(Measurements of average contaminant should not be averaged ever more than I square meter. For objects of less surface area. the aeerage shoald be derived for each such object.
2 d Iha maulmum contaminatten level applies to an area of not more than 100 ce .
'The anovat sf removable radleactive material per 100 cm2 et surface area should be deteralmed by wiplag that area with dry filter er sof t absorb at paper, applying moderate presser?. and assessing the amount of radleactive material en the wipe with an appropriate lastrument of i nrm i etficiency. When removable contaminetten en objects of less surface area is determined, the pertinent levels should be reduced l
reoportionally and the entire surface should be wiped. ~
I the average and masimum radiatten levels asseclated with serface contaminatten resulting from beta-games emitters sleculd not [r i'
O.2 mrad /hr at I cm and 1.0 mrad /hr at I cm. respectively. measured through not more than 2 milligrams per sepsare centimeter of 1 tstal absorter.
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- o g uni TED STATES 8 o NUCLEAR REGULATORY COMMISSION h $ WASHINGTON, D. C. 20555 ,
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AUG 3 01985 \
LM-MEMORANDUM FOR: G. Wayne Kerr, Director /4 Office of State Programs FROM: Harold R. Denton, Director l Office of Nuclear Reactor Regulation
SUBJECT:
DRAFT PROPOSAL FROM ILLIN0IS FOR AGREEMENT STATE STATUS In response to your request of August 12, 1985, we have reviewed the draft proposal from Illinois for Agreement State Status. Our review has focused on Sectica 6. " Standards for Protection Against Radiation," of Volume III, i "Regulat. ions," of the State of Illinois Application for Agreement State Status.
l We have reviewed the State's proposed radiation protection regulations according to the Criteria for Radiation Protection Standards contained in NRC's Policy Statement.* We find that those portions of the State's proposed standards that '
are within NRR's area of expertise are in accordance with the radiation protection standards in 10 CFR 20.
Aai.
, ffarold . De t n, Director Ly0ffice of Nuclear Reactor Regulation b I
- " Criteria for Guidance of States and NRC in Discontinuance of NRC Regulatory Authority and Assumption Thereof by States Through Agreement" (46 FR 7540, January 23,1981).
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