ML20199C755
| ML20199C755 | |
| Person / Time | |
|---|---|
| Issue date: | 11/13/1997 |
| From: | Greeves J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Trottier C NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| References | |
| REF-WM-3 NUDOCS 9711200121 | |
| Download: ML20199C755 (3) | |
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- ,& tlovember 13, 1997 L
MEMORANDUM TO: Cheryl A. Trottier, Chief Radiation Protection and Health Effects Branch Division of Regulatory Applications Office of Nuclear Regulatory Research FROM: John T. Greeves, Director * 1N'" Y Division of Waste Management Office of Nuclear Material Safety and Satepards
SUBJECT:
REVIEW OF CONTRACTOR REPORT ON RECYCLE in a rnemorandum dated October 10,1997, you requested the Division of Waste Management to review a draft report prepared by Science Applications International Corporation, entitled
" Radiological Assessment of Clearance of Equipment and Material from Nuclear Facilities."
Due to limited staff resources, we have not performed a detailed review of this report. Our general comments on the report are provided below for your consideration.
- 1. The report provides a methodology for translating surficial contamination on, as well as volumetric contamination in, a single piece of equipment or material into radiological dose to e critical group. This is an important first step in developirg a supporting technical framework for possible rulemaking on recycle and reuse of contaminated material. Future technical work should also address the total flow of material for recycle and reuse, radionuclide mixes, and measurement capability. Although not addressed in the report, it is recommended that RES and NMSS staff discuss the issue of applying collective dose criteria to support possible recycle / reuse rulemaking.
It would be helpful for RES to deve)op a table that compares the assumptions usef to 2.
develop the anit dose conversion factors for surficial contamination in the reuse scenario with the assumptions used to develop unit dose conversion factors for translating surface contamination into radiological dose for the radiological criteria rule for lands and structures.
- 3. The report states that existing NRC guidance and practices for releasing equipment and material are inconsistent with current risk-based regulatory dose standards and as low as reasonably achievable (ALARA) practices. This implies that the existing NRC 99ggy regulatory framework may not be ALARA, which may be beyond the narrow technical scope of the report. It is recommended that the report explain this issue further or defer it to other documents that aod7ess similar technical and policy issues.
CONTACT: Anthony Huffert, NMSS/DWM (301)415-6416 z
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- 4. The release limits in the draft report do not compare consistently with those contained in Regulatory Gu;de 1.86. For example, some limits are less restrictive (H-3, Pu-241),
some limits are more restrictive (Np-237), and some limits remain the same (Co-60).
Regulatory Guide 1.86 continues to t's applied at SDMP sites that are grandfathered under the recent rule on radiological criteria for the decommissioning of lands and structures. Understandably, it is beyond the scope of this report to address how the new release limits would affect cunent regulatory guidance, such as Regulatory Guide 1.86. This issue may need to be addressed by the staff or Commission in future policy and technical documents on recycle and reuse since changes in releaue limits would impact materials licensing practices.
- 5. It is recognized that implementation techn; ques are beyond the scope of the draft report, but it would be helpful to know whether some of the release limits are detectable by off-the-shelf radiological survey instruments. If the radionuclides were difficult to detect in volume-contaminated material (e g., beta-particle emitters), would assays be necessary to determine compliance with the limits?
- 6. Using the unit dose conversion factors contained in the report, it would be helpful for RES to compare the proposed volume-contaminated material limits with existing limits (e.g., baghouse dust, prior NRC licensing actionc involving release of material, etc.)
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C. Trottier November 13, 1997
' 4.- The release limits in the draft report do not compare consistently with ; hose contained in v .
Regulatory Guide 1.86, For example, some limits are lees restrictive (H 3, Pu 241),
some limits are more restrictive (Np-237), and some limits remain the same (Co-60).
Regulatory Guide 1.86 continues to be applied at SDMP sites that are grandfathered under the recent rule on radiological criteria for the decommissioning oflands and structures. Understandabiy, it is beyond 'he scope of this report to address how the
' rev/ release limits would affect current regulatory guidance, such r i Regulatory Guide c - 1.86. This issue may need to be addressed by the staff or Commission in future policy and technical documents un recycle and reuse since chai:ps in release limits would impact materials licensing practices.
- 5. It is recognized that implementation techniques are beyond the scope of the draft report, but it would be helpful to know whether some of the release limits are detectable by off-the-shelf radiological survey instruments. If the radionuclides were difficult to detect in volume-contaminated material (e.g., beta-particle emitters), would assays be necessary to determine compliance with the limits?
- 6. Using the unit dore conversion factors r,ontained in the report, it would be helpful for RES to compare the proposed volume-contaminated materiallimits with existing limits (e.g., baghouse dust, prior NRC licensing actions involving release of material, etc.)
l TICKET: DWM-215 DISTRIBUTION.SeMrelf8 Hog LLDP r/f NMSS r/f PUBLIC RJohnson ACNW DWM r/f t/f MFederline TCJohnson LBell To receive a copy of this documentin small box on "OFC;"kne enter: "C" = Copy without attachment / enclosure;"E" = Copy with attachment / enclosure "N* = No copy j
- See previous concurrence Path & File Name: S:\DWM\LLDP\AMH1\ RECYCLE.017 OFC LLDP / LLDP LLDP DWM NAME AHuffertk RNelson* JHickey* 'Y DATE 11/6 /97 11/ 6 /97 11/ 7 /97 11/ G97 OFFICIAL RECORD COPY ACNW: YES K., NO _ Category: Proprietary _ or CF Only _
IG : YES _ NO _
LSS : YES _ NO _ Delete file after distribution: Yes _ No _
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C Trpttier . - 4.- -
The release limits in the draft report do not compare consistently with those contained in Regulatory Guide 1.86. For example, some limits are less restrictive (14-3, Pu-241),
some limits are more restrictive (Np-237), and some limits remain the same (Co 60). ,
Regulatory Guide 1.86 continues to be applied at SDMP sites that are grandfathered .
under the recent rule on radiological enteria for the decommissioning of lands and structures. Understandably, it is beyond the scope of this report to address how the new release limits would affect current regulatory guidance, such as Regulatory Guide
- 1.86. This issue may need to be addressed by the staff or Commission in future policy and technical documents on recycle and reuse since changes in release limits would impact materials licensing practices.
- 5. .It is recognized that implementation techniques are beyond the scope of the draft report, but it would be helpful to know whether some of the release limits are detectable by off-the-shelf radiological survey instruments, if the radionuclides were difficult to detect in volume-contamasted material (e g.', beta particle emitters), would assays be necessary to cetermine compliance with the limits?
- 6. Using the unit dose conversion factors contained in the report, it would be helpful for RES to compare the proposed volume-contaminated material limits with existing limits (e.g., bagho"se dust, prior NRC licensing actions involving release of material, etc.)
s C. Trottier November 13, 1997
- 4. The release limits in the draft report do not compare consistently with those contairwd in Regulatory Guide 1.86. For example, some limits are less restrictive (H-3, Pu-241),
some limits are more restrictive (Np-237), and some limits remain the same (Co-60).
Regulatory Guide 1.86 continues to be applied at SDMP sites that are grandfathered under the recent rule on radiological criteria for the decommissioning of lands and structures. Understandably, it is beyond the scope of this report to address how the new release limits would affect current regulatory guidance, such as Regulatory Guide 1.86. This issue may need to be addressed by the staff or Commission in future policy and technical documents on recycle and reuse since changes in release limits would impact materials licensing practices.
- 5. It is recognized that implementation techniques are beyond the scope of the draft report, but it would be helpful to know whether nome of the release limits are detectable by off-the-shelf radiological survey instruments. If the radionuclides were difficult to detect in volume-contaminated material (e.g., beta-particle emitters), would assays be necessary to determine compliance with the limits?
- 6. Using the unit dose conversion factors conteined in the report, it would be helpful for RES to compare the proposed volume-contaminated material limits with existing limits (e.g., baghouse dust, prior NRC licensing actions involving release of material, etc.)
TICKET: DWM 215 DISTRIBUTION: Central File LLDP r/f NMSS r/f PUBLIC RJohnson ACNW DWM r/f t/f MFederline TCJohnson LBell To receive a copy of inis documentin small box on "OFC." hne enter: "C" = Copy without attachment / enclosure."E" = Copy eth attachment / enclosure "N" = No copy
- See previous concurrence Pcth & File Nsme: S:\DWM\LLDP\AMH1\ RECYCLE.017 OFC LLDP t[}
Ju LLDP LLDP DWM l
NAME AHuffersbg RNelson* JHickey* %
l DATE 11/ 6 /97 11/6 /97 11/7 /97 11/\297 OFFICIAL RECORD COPY ACNW: YES 2L NO _ Category: Proprietary _ or CF Only _
IG : YES NO _
LSS : YES _ NO _ Delete file after distribution: Yes _ No _
l C. Trottier November 13, 1997
- 4. The release limits in the draft report do not compare consistently with those contained in Regulatory Guide 1.86. For example, some limits are less restrictive (H-3, Pu-241),
some limits are more restrictive (Np-237), and some limits remain the same (Co-60).
Regulatory Guide 1.86 continues to be applied at SDMP sites that are grandfathered under the recent rule on radiological criteria for the decommissioning of lands and structures. Understandably, it is beyond the scope of this report to address how the new release limits wpuid affect current regulatory guidanco, such as Regulatory Guide t86. This issue may need to be addressed by the staff or Commission in future policy and technical documents on recycle and reuse since changes in release limits wou'd impact materials licensing practices.
- 5. It is recognized that implementation techniques are beyond the scope of the draft report, but it would be helpful to know whether some of the release limits are detectable by off-the-sMtf radiological survey instruments. if the radionuclides were difficult to detect in volume-contaminated material (e.g., bett particle emitters), would assays be necessary to determine compliance with the limits?
- 6. Using the unit dose conversion factors contained in the report, it would be helpful for RES to compare the proposed volume-contaminated materiallimits with existing limits (e.g., baghouse dust, prior NRC licensing actions involving release of material, etc.)
TICKET: DWM 215 DISTRIBUTION 3Centret Files LLDP r/f NMSS r/f PUBLIC RJohnson ACNW DWM r/f t/f MFederline TCJohnson LBell To receive a copy of this documer.,in small box on "OFC;"line enter: "C" = Copy witnout attact.mont/ enclosure;"E" = Copy with attachment / enclosure "N" = No copy 4
- See previous concurrence P:th & File Name: S:\DWM\LLDP%MH1\ RECYCLE.017 OFC LLDP I/h/ LLDP LLDP DWM NAME AHuffert/h RNelson* JHickey* Y DATE ill6 /97 11/ 6 /97 11/ 7 /97 11/ G/97 OFFICIAL RECORD COPY ACNW: YES 2L NO _ Category: Prophetary _ or CF Only _
IG : YES _ NO _
LSS : YES _ NO _ Delete file after distribution: Yes _ No _
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'4o f a WASHINGTON. D.C. 20555 4001
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October 10, 1997 M
MEMORANDUM TO: John T. Greeves Director A< -
Division of Waste Management ,
t Office of Nuclear Material Safety and Safeguards Seymow H. Weiss, Director Non Power Reactors and Decommissioning Directorate
+
Division of Reactor Program Management Office of Nuclear Reactor Regulatioq g Charles L. Miller, Chief-Emergency Preparedness and Radiation Protection Branch Division of Reactor Prograrn Management Office of Nuclear Reactor Regulation FROM: Cheryl A. Trottier, Chief Radiation Protection and Health Effects Branch Division of Regulatory Applications .
Office of Nuclear Regulatory Research
SUBJECT:
REVIEW OF CONTRACTOR REPOP.T ON RECYCLE Your assistance is requested in reviewing the attached draft report prepared by our contractor sal.C on " Radiological Assessment for Clearance of Equipment and Material from Nuclear Facilities," and providing (ne with your comments. The foilowing is a summary of this request.
1.
Title:
Draft contractor report on " Radiological Assessment for Clearance of Equipment and Material from Nuclear Facilities"
- 2. -RES Task Leader Robert A. Meck,415- 6205
~ 3. Requested Action: Review and comment
- 4. Requested Completion Date: November 3,1997 s
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- 5.
Background:
This is a draft contractor report prepared by SAIC on the techical basis on which to establish regulatory standards for release of equipment and material from Nuclear Regulatory Commission licensees. This work forms part of the basis for a Commission paper which is being prepared to send to the EDO ln November 1997.
Attachment:
Vclumes 1 and 2 of Draft Contractor Report
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cc: w/ attachment (s)-
J. Hickey, NMSS A. Huffert, NMSS '
C. Jones, NMSS S. Klementowicz, NRR 1
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' O. T,rottier . 4. The release limits in the draft report do not compare consistently with those contained in Regulatory Guide 1.86. For example, some limits are _less restrictive (H-3, Pu-241),
- some limits are more restrictive (Np-237), and some limits remain the same (Co-60).
Regulatory Guide 1.86 continues to be applied at SDMP sites that are grandfathered under the recent rule on radiological criteria for the decommissioning of lands and structures. This report does not address how the new release limits wo +
regulatory guidance, such as Regulatory Guide 1.86. RES ss this issueshould in addr[u this report or future technical documents on recycle and reuse.
- 5. It is recognized that implementation techniques are beyond the scope of the draft report, but it would be helpful to know whether some of the release l' its we detectable by off-the-shelf radiological survey instruments. If the radionucli s were difficult to detect in volume-contaminated material (e.g., beta-particle emitte s), would assays be necessary to determine compliance with the limits?
- 6. Using the unit dose conversion factors contained ip the report, it would be helpful fer RES to compare the proposed volume-contaminated material limits with existing limits (e.g., baghouse dust, prior NRC licensing actions involving release of material, etc.)
DWM-215 -
?@DISTRIBUTION:
TICKET: Central File LLDP r/f NMSS r/f PUBLIC RJohnson
!- ACNW DWM r/f t/f MFederline TChhnson LBell l To receive a copy of this documentin small box on "OFC:" hne enter. "C"% Copy without attar.,hment/ enclosure;"E" = Copy with attachment / enclosure l "N" = No copy /
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Pcth & File Name: S:\DWM\LLDPiAMH1\ RECYCLE.017 i.
OFC LLDP jd - - LLDh LL'DP b DWM NAME AHuffert[th RNhson 1/Jhckey DATE -11/6 /97 11/h /9 [ 11/ l /97 11/ /97 OFFICIAL RECORD COPY
. ACNW; YES X NO _. Category: P ' prietary _ or CF Only __,
IG : YES _ NO n//
LGS : YES _ NO jf Delete file after stribution: Yes _ No_.
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