ML20141G888

Forwards Disposition of IE 850827 Comments on State of Il Draft Proposal for Agreement State Status.Comments Incorporated Into Proposal During 851114-15 Meetings W/State

ML20141G888
Person / Time
Issue date:	11/19/1985
From:	Kerr G NRC OFFICE OF STATE PROGRAMS (OSP)
To:	Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML20140C976	List: ML20140C970 ML20140G713 ML20140G734 ML20140G788 ML20141C784 ML20141G834 ML20141G840 ML20141G852 ML20141G866 ML20141G871 ML20141G877 ML20141G883 ML20141G888 ML20141G894 ML20141G899 ML20141G904 ML20141G922 ML20141G928 ML20141G934 ML20141G939 ML20141G948 ML20141G960 ML20141G967 ML20141H002
References
NUDOCS 8604240013
Download: ML20141G888 (2)

Text

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HEMORANDUP. FOR: James !!. Taylor Director Office of Inspection and Enforcenent

, FR0!!: G. Wayne Kerr, Director Office of State Programs

SUBJECT:

DISPOSITI0fi 0F IE C0fif1EtiTS Oft DRAFT PROPOSAL FROM ILLIfl0I5 ,FOR AGREEMEf;T STATE STATUS Ihank you for your August 27, 1985 coments on the subject draft proposal. On flovember 14 and 15,1985 we met with Illinois representatives to discuss their proposal and incorporated most of your -

views in our discussions. The disposition of the individual coments are indicated by marginal notss on the attachment. If these are not acceptable I would appreciate being infonned promptly.

When the request for a Section 274b Agreement is formally submitted by Governor Thompson, we will prepare an fiRC staff assessment for publication.in the Federal Register and will coordinate it with you.

nggmatstgdeaqs gl%'YhW" G. Wayne Kerr, Director Office of State Programs

Enclosure:

As stated Distribution:

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MEll0RANDU!i FOR: James fi. Taylor, Director Office of Inspection and Enforccmnt FR0!!: G. Wayne Kerr, Director Office of State Programs

SUBJECT:

DISPOSITI0ft OF IE C0hilEftTS Oil DRAFT PROPOSAL FROM

ILLIfl0IS FOR AGREEMEllT STATE STATUS Thank you for your August 27, 1985 coments on the subject draft proposal. On flovember 14 and 15,1985 we met with Illinois representatives to discuss their proposal and incorporated most of your views in our discussions. The disposition of the individual coments arc indicated by marginal notes on the attachment. If these are not acceptable I would appreciate being informed promptly.

When .the request for a Section 274b Agreement is formally submitted by

, Governor Thompson, we will prepare an f(RC staff assessment for publication in the Federal Register and will coordinate it with you, original stgdedy

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G. Wayne Kerr, Director Office of State Programs

Enclosure:

As stated i

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UN1'TED STATES -

! o NUCLEAR REGULATORY COMMISSION J

WASHINGTON, D. C. 20555

%, .....) LH August 27, 1985 t

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 We have reviewed the proposed ipplication 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 approach. We have a few other comments to offer for your consideration and they are enclosed, h '

J mes M. Ta. r Director ffice of I spection and Enforcement

Enclosure:

As stated

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O o ENCLOSURE 1 Regulations t

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 our Part 40 regulations;

,' however, it was revoked in 1984. The reason for revocation was that jewelry was being imported by several companies that contaired uranium in the y glazing, causing unnecessary radiation levels in articles used for adornment.

pM S40.13 of 10 CFR 40 contains a footnote whfch states, "On July 25, 1983, the exemption of glass enamel or glass enamel frit was suspended. The exemption was eliminated on September 11, 1984."

2. Of the 15 sections, Section 4 of the regulations, Licensing of Radioactive Material, gives us some problems. Containing about 110 pages, it is f i

, difficult to follow because it jumps from one licensing category to another. '

For example, Chapter 4 starts out by defining responsibilities for general p licensees (pages 330-1 to 330-32) and beginning on page 330-52 discusses g specific licenses to manufacture and distribute generally licensed quantities and exempt quantities. Perhaps these two could be combined. Similarly,a8 few general requirements for specific licenses that authorizes all of the materials used in radiography, medicine and so forth, are discussed beginn on page 330-33 and page 330-77. However, most of the pages are devoted to

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specific licenses for manufacture and distribution of generally licensed h quantities and exempt quantities. Furthermore, licenses of broad scope ar 9 discussed in detail beginning on page 330-47, but the Table of radionuclid quantities for these types of licenses doesn't appear until page 330-110,)d following 2 or 3 other discussions.

be better organized.

Inshort,Section4appearstoneedtop y he hl,c

3. Decommissioning and decontamination of facilities is discuss (d eginning on f W 5' page 330-79 of Section 4. '

HowevMhe_ release limits for contamination appears on page 340-69 of Section 6 . Both should be together in a single j,

section. M

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r With respect to the decontamination lin.its on page 340-59, there are only numbers and no guidance is offered, even though the title states, "Decon- /

tamination Guides." Because of this, we have attached guida Icethatthe pia. , L NRC uses. Without guidance on how to decontaminate and perfo'rm surveys, /'**

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. i S

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 mi the NRC's 10 CFR Part 35. The ;ompounds listed are ford'iagnostic <* M and therapeutic procedures. Section 11 is entitled, "Use of Sealed

• hl Sources in the Hee. ling Arts." Couldn't human uses of radionucliaes be combined into one section, similar to the NRCs Part 35?

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5. Section 7, Transportation of Radioactive Material, Pages 341-4,5.

We note that the provisions of S 341.4(a) state that " Common and contract

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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 and other applicable sections of these regulations." S 341.3 requires that a general or specific license must be issued by the Department unless an ,.

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exemption is provided. The effect of these requirements, therefore, is

[f that an intra-state common or contract carrier would be required to get

)(b / a specific license from the State of Illinois to "... receive, possess, '

f transport, and store radioactive materials in the regular course of their e

h.#. carriers for another . . . . " We question whether this is intended. It is i# p c.. not consistent with the equivalent provisions of SS 10 CFR 30.13, 40.12, l and 70.12, upon which it would appear that the provisions of S 341.4(a) l were intended to be based. We, therefore, recommend deletion of the last sentence of S 341.4(a).

We also recommend that a "341.15" be added in the second line,of $341.1(b) following "341.14", since it would appear appropriate to include the .

requirements for the " routine determinations" of 341.15, as well as the

" preliminary determinations" of 341.14.

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l 6. We believe that Section 4 needs to be refined. Certain parts of Section 4 i '

, are much too detailed. It appears that Section 4 was meant to be equivalent to the NRC's P' art 30, 33, and 35. Section 4 could be divide up into more sections. A better solution would be to combine elements from Section 4 g

i into other sections, thereby reducing the size of that Section. h 6

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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 I

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 decontamination and survey of surfaces or premises and equipment. prior g to abandonment or release for unrestricted use. The limits in Tably 1 do

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not apply to premises, equipment, or scrap containing induced radioac)ivity

for whicn the radiological considerations pertinent to their use may be  !

different The release of such facilities'or items from regulatory control ** l is considered on a case-by-case basis. , l

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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, 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 j  ; covering. .

I 3. The radioactivity on the interior surfaces of pipes, drain lines, or ductwork shall be determined by making measurements at the traps, and other appropriate access points, provided that contamination at these locations is likely to be representative of contamination on the in-terior of the pipes, drain lines, or ductwork. Surfaces of premiscs, equipment, or scrap which are likely to be contaminated but are of J such size, construction, or location as to make the surface inacces-si ble for purpose of measurement shall be presumed to be contamin-i ated in excess of the limits.

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. 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.  ;

j 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 2

. e facilities to a long-term storage or standby status. Such requests j must: .

! a. Provide detailed, specific information describing the premises, equipment or scrap, radioactive contaminants, and the nature, extent, and degree of residual surface contamination.

i 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-j 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 limits specified in Table 1. . .A. copy of Qe .

survey report shall be filed with the Division of Fuelicycle and Ma-terial Safety, USNRC, Washington, D.C. 205S5, and also the Adminis-trator of the NRC Regional Office, having jurisdiction. The report i should be filed at least,30 days prior to the planned date of aban-donment. The survey report shall:

a. Identify the premises.

b. Show that reasonable effort has been made to eliminate residual contamination.

c. Describe the scope of the curvey and general procedures

,. followed.

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.

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TAmt I ACCEPTA8tt SURF ACE CONTAMINAil(Ni l[VtL5 i

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fqAXIM d I IttsgyAgl[b e f j NUtt ID(5 8 AvtRAf.[b c f U-nat. U-235,1D-230. and yg.000 dpm e/100 cm2 1.000 dpa e/100 ca? l assnclated decay products 5.000 dpm e/100 cm2 Iransuranics. Ra-226. Ea-228 300 dps/IGO car- 23 dpm/100 col Th-230. Ih-228. pa-231 100 dpm/100 cm2 l

At-227. I-Ili. 1-129 '

Ih.nat, th-232. 5r-90 3000dpe/100cM 200dyn/100cd Ra-723. Ra-224. U-232. 1-126, 1000 dpe/100 cM I-13I. 1-131 Reta garwa emitters (nuclides with decay rodes other than 15.000dpmsy/100cM 1000 dra p /iOO cd R elpha emission or spoe.taneous 5000 dpm e,/100 cM fission) cacept 5r-90 and .

others noted above.

tt:hcre surface contamination by both alpha- and beta-gasuna-emitting nuclides entsts. the ilmits estabitshed for alpha- and beta-gamma-emitting  ;

nuclides should apply independently.

1 bA s used l- this table, dpm (disintegrations per alnete) means the rate of emission b.e radleactive material as determined by correcting the'[

I counts per minute observed by an appropriate detector for background ef ficiency, and geometric factors asseclated with the instrumentatten.

I (tieasurements of average contaminant should not be averaged ever more than I sepsare meter. for objects of less surface crea, the average j l .

j sho sid be derived for each such object.

d ihe mastnum contaminatten level appIles to an area of not more titan 100 cm2

'the amount of removable radioactive material pe- 100 cm 2 er surface area should be determined by wiping that area with dry filter er soft absorb *nt paper. applying moderate pressure, and assessing the amount of radleactive mater 841 en the wipe 'eltk an appropriate lastrument of l Unen removable contaminatten en objects of less surface area is determined, the pertinent levels should be reduced nn e efficiency.

proportionally and the entire surface should be wiped.

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the average and monimum radiation levels associated with surface contaminatten resulting from beta-gamos ecitters should not

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I l 0.2 mrad /hr at I cm and 1.0 mrad /hr at I cm. respectively, seasured through not more than 2 milligrams per ser9are centimeter of

total absorter. .

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