ML20141G894

Discusses Disposition of RES 851001 Comments on State of Il Draft Proposal for Agreement State Status.State Will Revise Proposed Regulations to Conform to 10CFR20.203(c)(6) Requirements Re Very High Radiation Areas

ML20141G894
Person / Time
Issue date:	11/19/1985
From:	Kerr G NRC OFFICE OF STATE PROGRAMS (OSP)
To:	Minogue R NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
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 8604240016
Download: ML20141G894 (1)

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NOV ) 919f6 MEl4ORANDUti FOR: Robert B. tiinogue Director Office of Nuclear Regulatory Research FROM: G. Wayne Kerr, Director i Office of State Programs l

SUBJECT:

DISPOSITI0fl 0F RES C0!ttE!!TS Off DRAFT PROPOSAL FR0!'

11LIll0IS FOR AGREE!4ENT STATE STATUS Thank you for your October 1,1985 coments on the subject draft proposal. Illinois will revise its proposed regulations to conform the requirements for very high radiation areas so those contained in 10 CFR 20.203(c)(6).

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

! Governor Thompson, we will prepare an NRC staff assessment for publication for public cornent in the Federal Register. This will be coordinated with RES.

orisin31Si8 9 g,pynegorg G. Wayne Kerr, Director '

Office of State Programs Distribution:

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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 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 approach. We have a few other comments to offer for your consideration and they are enclosed.

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Enclosure:

As stated

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' ENCLOSURE 1 f.

Regulations

1. Section 4, Licensing of Radioactive Material.

', On page 330-2, Iten;(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 contained uranium in the y glazing, causing unnecessary radiation levels in articles used for pJ A j adornment. S40.13 of 10 CFR 40 contains a footnote which states, "O'n July 25, 1983, the exemption of glass enamel or glass enamel frit was suspended. The exemption was eliminated or. 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 difficult to follow because it jumps from one licensing category to another.

For example, Chapter 4 starts out by defining responsibilities for general i licensees (pages 330-3 to 330-32) and beginning on page 330-52 discusses pp specific licenses to mar 1facture and distribute generally licensed quantities

. and exempt quantities. Perhaps these two could be combined. Similarly, a 8 few general requirements for specific licenses that authorizes all of the materials used in radiography, medicine and so forth, are discussed beginnin h1 on page 330-33 and page 330-77. However, most of the pages are devoted to specific licenses for manufacture and distribution of generally licensed quantities and exempt quantities. Furthermore, licenses of broad scope ar

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discussed in detail beginning on page 330-47, but the Table of radionuclid e ,

quantities for these types of licenses doesn't appear until page 330-110, )dt following 2 or 3 other discussions. In short, Section 4 appears to need to g(

be better organized. I, A M*d in b

3. Decommissioning and decontamination of facilities is discuss (d beginning en page 330-79 of Section 4. However .the release limits for contamination, j appears on pagr 340-69 of Section 6 . Both should be together in a single j section, yp

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l With respect to the decontamination limits on page 340-69, there are only

numbersand.noguidanceisoffered,eventhoughthetitlestages,"Decon- /

tamination Guides." Because of this, we have attached guidarMe that the

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NRC uses. Without guidance on how to decuntaminate and perfo'rm surveys,

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• an inspector's time might be wasted when requested to perform.a confirmatoryi

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survey, since a licensee could have missed something for lack of guidance.

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 g i the NRC's 10 CFR Part 35. The compounds listed are for diagnostic c'I f and tnerapeutic procedures. Section 11 is entitled, "Use of Sealed Nk Sources in the Healing Arts." Couldn't human uses of radionuclides be combined into one section, similar to the NRCs Part 35? j

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 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 and other applicable sections of these regulations." S 341.3 requires that a

! a general or specific license must be issued by the Department unless an p exemption is provided. The effect of these requirements, therefore, is f that an intra-state common or contract carrier would be required to get

,- gli t a specific license from the State of Illinois to "... receive, possess, '

3 ,pS l cp j transport, ana store radioactive materials in the regular course of their h . carriers for another . . . ." We question whether this is intended. It is 9 e.. / not consiste'nt with the equivalent provisions of SS 10 CFR 30.13, 40.12, i

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1. M and 70.12, upon which it would appear that the provisions of S 341.4(a) were intended to be based. We, therefore, recommend deletion of the last sentence of S 341.4(a).

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,' 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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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 1p be equivalent .

to the NRC':. Part 30, 33, and 35.

Section 4 could be divideI,F up into mo 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-I

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l GUIDELINES FOR DECONTAMINATION OF FACILITIES AND EQUIPMENT l I

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. PRIOR TO RELEASE FOR UNRESTRICTED USE OR TERMINATION OF LICENSES FOR BYPRODUCT, SOURCE, ,

. OR SPECIAL NUCLEAR MATERIAL 1 l j July 1982 l

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U. S. Nuclear Regulatory Commission Division of Fuel Cycle & Materials Safety

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) The instructions in this guide in conjunction with Table 1 specify the

' radionuclides and radiatien 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 Tab 1) 1 do notapplytopremises, equipment,orscrapcontaininginducedradicac)ivity l for which the radiological considerations pertinent to their usa may-~be different. The release of such facilities or items from regulatory control i

N is considered on a case-by-case basis. ,

1. The licensea shall make a reasonable effort to eliminate residual ,

contamination. ,

2. Radioactivity on equipment or surfaces shall not be covered by paint,

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or other covering material unless contamination levels, as 4 plating, determined by a survey and documented, are below the limits specified i i in Table 1 prior to the application of the covering. A reasonable i

! effort must be made to minimize the contamination prior to use of any  !

l coveri,1g.

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3. The radinactivity on the interior surfaces of pipes, drain lines, or 1 ductwork shall be determined by making measurements at the traps, and l j

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 pramises, )

,- equipment, or scrap which are likely to be contaminated but are of

- such size, construction, or location as to make the surface inacces-si ble for purpose of measureaent shall be presumed to be contamin- 1 i ated in excess of the limits. l I 4. Upon request, the Commission may authorize a licensee to relinquish l 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

• tuch as razing'of buildings, transfer of premises to another organiza-tion continuing work with radioactive materials, or conversion of l .

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, 7

i extent, and degree of residual surface contamination.

Provide a detailed health and safety analysis which refitet that f b.

the residual amounts of materials on surface areas, together

- with other considerations such as prospective use of the prem- ,

l i ises, equipment or scrap, are unlike~y 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 establishesythat contami-nation is within the limits specified in Table 1. .A survey report shall be filed with the Division of Fueli. copy cycle and Ma- of ge ,

terial Safety, USNRC, Washington, D.C. 20555, and also the Adminis- I trator of the NRC Regional Office, having jurisdiction, The report 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.

I c. Describe the scope of the survey and general precedures

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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.

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ACCEPTAOLE SURFACE CONTAflIN4f flBI lt9tL5 i

peng3 W d f g(pgyagggb e f j seuct tots a AttRA(;t6cf f i .  !

U-nat. U-235. U-238. and 2 15.000 dpm e/100 ce2 1.000 dpm e/10G ce?

aunclated decay products 5.000 dra e/100 ce transeramics. Ra-226. Ra-22d. 300 dpm/100 ce2 20 dpmVitS cm2 100 dpm/100 ce2 14 210. Th-228. Pa-231 ^

Ac 227.1-125.1-129 t

th-nat. Ih-232. Sr-90, 3000 dpmVIOS en? 200 dyn/100 ce2 y pa-221. Ra 224. U-232. 1 126, 1000 droll 00 ce? -

1-131. 1-133  !

Beta.garwa enleters (neclldes  ;

with & cay redes other than 15.000 dra sy/100 cm2 1000 dre ev/lbe ce2 R als,ha ceinte er spontaneous 5000 dpm sv/100 col t l

fluenn) except ir-93 and - .

cthers .::ted above.

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• at:hcre surface contaminatten by both alpha- and beta gamma-emitting nucildes esists. the lletts established for alpha- and beta-ganne-eeltting i

nuclides should apply independently. .

bAs used in this table, dpm (disintegrattens p-e almete) neans the rate of eelssten by redles:tlee esterial as determined by correcting the l counts per minute observed by an appropriate detector for background. ef ficiency. and geometric facters asseclated with the lastrumentatten. 6 ceteasurements of average cor.taminant should not be averaged ever more than I square seter, for objects of less surface area. the average shoald be derived for each such object.

d ihe maulmum centaminatten level appIles to an area of not more than 100 cm2 ,

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'the amowat cf removable redleactive material per 100 co2 of surface area should be detevelned by wiping that area with dry filter er soft f [

4hserb at paper, ai ,l fing nederate pressere, and assessing the amount of radioactlee material en the wipe with an aepropriate testygment o taa.o efficiency. When removable contaminatten en objects of less surface area is determined. the pertinent levels should be ceduced proportionally and the entire surface shCuld be wiped.

t I lhe average and samless radiatten levels assectated with surface contaminatten resulting free beta-gamme eeltters should no 0.2 mrad /hr at I cm and 1.0 erad/hr at I ca. respectively. erasured through not more than 2 milligrams per square centleeter of l

txtal absort.cr. .

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