ML20015A354

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Attachment - NRC-2020-000076 - Appeal Response to NRC-2019-000132. (Part 4 of 29)
ML20015A354
Person / Time
Issue date: 01/08/2020
From:
NRC/OCIO
To:
Shared Package
ML20015A350 List:
References
FOIA, NRC-2019-000132, NRC-2020-000076
Download: ML20015A354 (14)


Text

"*"* NUCLEAR REGULATORY C~M::.~.- - - -- ~~~;

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, I 6425 S. Highway 191 I ..i. b.piralion Dalt' P.O. Box 789 i -- ------- -- *-*-..*--* March _31 ~- 2007 _______________ _

Blanding, Utah 84511 1

, .5 Dod,er or i Rl'lert*m:e No. 40-8681

h. Byprodut'I. Snurct*. anJ/or 7. Chl'lllh:al ,lllJ/or Ph\ ,1l'.tl 8. Maximum Amounl Iha! Lict*n,t'l' Special f\ udl!ar Malt*rial hirm
  • Mav Po..,..,e,.., at Anv Otw Time l 'nJer This Licen ... t:

Natural Uranium Any Unlimited SECTION 9: Administrative Conditions 9.1 The authorized place of use shall be the licensee's White Mesa uranium milling facility, located in San Juan County, Utah.

9.2 All written notices and reports to the NRC required under this license, with the exception of incident and event notifications under 10 CFR 20.2202 and 10 CFR 40.60 requiring telephone notification, shall be addressed to the Chief, Uranium Recovery Branch, Division of Waste Management, Office of Nuclear Material Safety and Safeguards.

Incident and event notifications that require telephone notification shall be made to the NRC Operations Center at (301) 816-5100.

9.3 The licensee shall conduct operations in accordance with statements, representations, and conditions contained in the license renewal application submitted by letter dated August 23, 1991, as revised by submittals dated January 13, and April 7, 1992, November 22, 1994, July 27, 1995, December 1~, 1996, and January 30, 1997, which are hereby incorporated by reference, and May 10, 1994, for the ,tandby Trust Agreement, except where superseded by license conditions below.

Whenever the word *will" is used in the above referenced documents, it shall denote a requirement.

9.4 A. The licensee may, without prior NRC approval, and subject to the conditions specified in Part B of this condition:

9703190298

~DR ADOCK i~ggi: PDR01 1'1 lflh.'d

  • 11) 11.'\ \ !. kd J'tlj '* I

u.s NUCLEAR REGULATORY COMMISStON F~L1crn ,_. Number

_ _ _ _ _PAGES 11 I

SUA-1358 1,


1,

.,IATERIALS LICENSE SUPPLEMENTARY SHEET

______J_

~ke1 .. r Rt>fcrent~ Nurpticr I

r------ 40-8681 March 14. 19__ 97_ _

__ _ I I

(1) Make changes in the facility or process, as presented in the application. I I

(2) Make changes in the procedures presented in the application. I ll (3) Conduct tests or experiments not presented in the application.

I I

B. The licensee shall file an application for an amendment to the license, unless the following conditions are satisfied.

(1) The change, test, or experiment does not conflict with ~ny

~

requirement specifically.. $1alfd in this 1icensa, or impair the licensee's Jbtlity*to meet 'all applicable NRC regulations. =

(2) 1"here is no degradation in the essential _safety or environmental c,,n111itrnents in the 1icense application, or provided by the ap~roved reclamation plan.

(3) The change, test, or experiment are cons1steni with the conclusions of actions analyzed and selected in this EA.

C. The licensee's detenainations concer~ing Part B of tbis condition, shall be made by a "Safety and Envirdnllental Review panel (SERP)." The SERP shall consist o, a minifflltffl of i*ree individual~. One member of the SEQP shall have expertise in MIJ\lt&IM!nt and sh~tl be responsible for managerial and financial apJtrOVal chaftges; one 111fmber shall have expertise in operations a11d/or ~onstruction and shall have respoRafbility for implame11ting any oper*tional cqftges; and, one member sJta 11 be the corporate radiatiof\ safety officer (CRSO) or equivalent, with the responsibility pf assuring changes conform to radiation s1fety and environmental ....,irements. Additional members

  • ay be inclKded in the SERP as appropriate, to address technical aspects such as health physics, groundwater hydrology, surface-water hydrology, specific earth sciences, and other technical disciplines.

Temporary members or permanent meJ,llben, other than the three above-specified individuals, May be coftsultants.

D. The licensee shall maintain records of any changes made pursuant to this condition until license tennination. These records shall include written safety and environmental evaluations, made by the SERP, that provide the basis for determining changes are in compliance with the requirements referred to in Part B of this condition. The licensee shall furnish, in an annual report to NRC, a description of such changes, tests, or experi11ents, including a sun111ary of the safety and environmental evaluation of each. In addition, the licensee shall annually submit to the NRC changed pages to the Operations Plan and Reclaaation Plan of the approved license application to reflect changes made under this condition.

U.S. NUC~~~R REGULATORY COMMISSION l. _. . . _ .__ . _P_A<3-_~_ .... 3_ __ ?_;:_ ____ j __

11.1, ms,* ",/umtwr MAl'l:<;RJALS LICENSE r'i:i,~i,:j~;; R~:r~r,*n~;. *Nun~-f;~ --***-----

SUA-1358 - .. ... -***** . . ...... .

i SUPPLEMENTARY SHEET 1*I .

40-8681 l

L __________ M~.C~h____l~-~.J.9 9 7.... __ ...... _________ ..

The licensee shall submit to the NRC by April 30, 1997, for review, the standard operating procedures (SOPs) needed to implement this license condition. The licensee shall not implement any provision of this license condition until NRC has found the proposed SOPs acceptable.

9.5 The licensee shall maintain an NRC-approved financial surety arrangement, consistent with 10 CFR 40, Appendix A, Criteria 9 and 10, adequate to rover the estimated costs, if accomplished by a third party, for decommissioning and decontamination of the mill and mill site, for reclamation of any tailings or waste disposal areas, ground-water restoration as warranted and for the long-term surveillance fee. Within three months of NRC approval of a revised reclamation/dec0111issioning plan, the licensee shall submit, for NRC review and approval, a proposed revision to the financial surety arrangement if estimated costs in the newly approved plan exceed the amount covered in the existing financial surety. The revised surety shall thEn be in effect within 3 months of written NRC approval.

Annual updates to the surety 3mount, required by 10 CFR 40, Appendix A, Criteria 9 and 10, shall be submitted to the NRC at least 3 months prior to the annivet'sary date which is designated as June 4 of each year. If the NRC has not approved a proposed revision to the surety coverage 30 days prior to the expiration date of the existing surety arrangement, the licensee shall extend the existing surety arrangement for 1 year. Along with each proposed revision or annual update, the licensee shall submit supporting documentation showing a breakdown of the costs and the basis for the cost estimates with adjustments for inflation, maintenance of a minimum 15 percent contingency fee, rhanges in engineering plans, activities performed and any other conditions affecting estimated cos~s for site closure. The basis for the cost estimate is the NRC approved reclamation/decommissioning plan or NRC approved revisions to the plan. The previously provided guidance entitled "Reconwnended Outline for Site Specific Reclamation and Stabilization Cost Estimates" outlines the minimum considerations used by the NRC in the review of site closure estimates.

Reclamation/decommissioning plans and annual updates should follow this outline.

The currently approved surety instrument, lrrev~cable Letter of Credit No.

S00017012, issued by The Bank of New York in favor of the NRC, as amended, May 10, !994, to include a Standby Trust Agreement, shall be continuously maintained by UMETCO in an amount not less than $10,915,467 for the purpose of CORlplying with 10 CFR 40, Appendix A, Criteria 9 and 10, until a replacement is authorized by the NRC.

9.6 Standard operating proce~ures shall be established and followed for all operational process activities involving radioactive materials that are handled, processed, or stored. SOPs for operational activities shall enumerate pertinent radiation safety practices to be followed.

Additionally, written procedures shall be established for non-operational activities to include in-plant and environmental monitoring, bioassay

U.S. NUCLEAR REGULATORY COMMISSION: PAGE 4

_ _ QI-h f

11 .:mr -.;;;mht*r SUA-1358 MATtRIALS LICENSE 1l><>t l..t*I or Rl'l,*r,*1Kt' Numt,:r SUPPLEMENTARY SHEET :t- .

40-8681 l March 14, 1997 analyses, and instrument calibrations. An up-to-date copy of each written procedure shall be kept in the mill area tow' *~hit applies.

All written procedures for both operational and non-operational activities shall be reviewed and approved in writing by the radiation safety officer (RSO) before implementation and whenever a change in proced 11re is proposed to ensure that proper radiation protection principles are being applied. In addition, the RSO shall perform a documented review of all existing operating procedures at least annually.

9.7 Before engaging in any activity not previously assessed by the NRC, the licensee shall administer a cultural resource inventory. All disturbances associated ***ith the proposed development will be completed in compliance with the National Historic Preservation Act (as amended) and its implementing regulations (36 CFR 800), and the Archaeological Resources Protection Act (as amended) and its implementing regulations (43 CFR 7).

In order to rnsure that no unapproved disturbance of cultural resources occurs, any .. ork resulting in the discovery of previously unknown cultural artifacts shall cease. The artifacts shall be inventoried and evaluated in accordance with 36 CFR Part 800, and no disturbance shall occur until the licensee has received authorization from the NRC to proceed.

The licensee shall avoid by project design, where feasible, the archeological sites designated "contributing" in the report submitted by letter dated July 28, 1988. When it is not feasible to avoid a site designated "contributing" in the report, the licensee 5hall institute a data recovery program for that site based on the research design submitted by letter from C. E. Baker of Energy fuels Nuclear to Mr. Melvin T. Smith, Utah State Historic Preservation Officer (SHPO), dated April 13, 1981.

The licensee shall recover through archeological excavation all

  • contributing" sites listed in the report which are located in or within 100 feet of borrow areas, stockpile areas, construction areas, or the perimeter of the reclaimed tailings impoundment. Data recovery fieldwork at each site meeting these criteria shall be completed prior to the start of any project related disturbance within 100 feet of the site, but analysis and report preparation need not be ~omplete.

Additionally, the licensee shall conduct such testing as is required to enable the Co*ission to determine if those sites designated as

  • undeten11ined" in the report and located within 100 feet of present or known future construction areas are of such significance to warrant their redesignation as "contributing.* In all cases, such testing shall be ce>11pleted before any aspect of the undertaking affects a site.

Archeological contractors shall be approved in writing by the Conmis~ion.

The C011111ission will approve an archeological contractor who meets the minimum standards for a principal investigator set forth in 36 CFR Part 66, Appendix C, and whose qualifications are found acceptable by the SHPO.

NRC FORM 374A

  • (7-k).

U.S. NUCLEAR REGULATORY COMMISSION '*. ___ PAGE 5 OF 9 PAGES  ;

£. I:~8

!Llcen~ Number I]

L--* SUA- Ii MATERIALS LICENSE Dod,e1 or Reteff'llce Nu~r_ 8 681_  :*

SUPPLEMENTARY SHEET


**** March 14, 1997 _______ 11 9.8 The licensee is hereby author~zed to possess byproduct material in the form ~

of uranium waste tailings and other uranium byproduct waste generated by the I licensee's milling operations authorized by this license. Mill tailings ll shall not be transferred from the site without specific prior approval of IJ the NRC in the form of a license amendment. The licensee shall maintain a IJ permanent record of all transfers made under the provisions of this *II condition.

I 9.9 The licensee is hereby exempted from the requirements of Section ,~.1902 (e) I of 10 CFR Part 20 for areas within the mill, provided that all entrances to I the mill are conspicuously posted in accordance with Section 20.1902 (e) and I with the words, "Any area -.i ~~in \bis mil 1 may contain rad i oact 1ve material."

9.10 Release of equipment or packages from the restricted area shall be in *I accordance with "Guidelines for Decontamination of Facilities and Equipment I Prior to Relea,* for Unrestricted Use or Termination of Licenses for i Byproduct, Source, or Special Nuclear Material," dated May 1987, or suitable I alternative procedures approved by the NRC prior to any such release.

SECTION 10: Operttional Contn,ls~ Limits. and Restrictions 10.1 The mill production rate shall not exceed 4380 tons of yellowcake per year.

  • 10.2 All liquid effluents frOII mtll process buildings, with t~e exception of sanitary wastes, shall be returned to the mill circuit or discharged to the I tailings i,apoundment.
  • 10.3 Freeboard limits for Cells 1-1, 3, and 4A, and tonnage limits for Cell 3, shall be as stated in Section 3.0 to App81dtx E of the approved license application.

10.4 Disposal of material and equipment generated at the mill site shall be I conducted as described tn the licensee's llbmittals dated December 12, 1994 and May 23, 1995, with the followtng ldditfon:

A. The maximu* lift thickness for materials placed over tailings shall be less than 4-feet thick. Subs~quent lifts shall be less than 2-feet thick. Each lift shall be compacted by tracking of heavy equipment, such as a Cat 0-6, at least 4 times prior to placement of subsequent I 1i fts. I I

10.5 In accordance with the licensee's submittal dated May 20, 1993, the l1censee I is hereby authorized to dispose of byproduct material generated at licensed in situ leach facilities, subject to the following conditions:

  • A. Disposal of waste is limited to 5000 cubic yards from a single source.

I

- * ~ ~ ' ' l l l l l n r .... . _ . . _ - * - - * - - - . - .... - - - .-..-.- - - _.. - - --"- -~- - -

NRC FORM 374A License Num~.

PAGES _ I SUA-1358 i I

MATERIALS LICENSE SUPPLEMENTARY SHEET IJt)( k~I nr Rdt"renr.e NuiiJ~

8681 ________ -/:I

  • - - - -- ---*-*-*- _CMarch 14, 1997 I
8. All contaminated equipment shall be dismantled, crushed, or sectioned I to minimiLe void spaces. Barrels containing waste other than soil or I sludges shall be emptied into the disposal area and the barrels l crushed. Barrels containing soil or sludges shall be verified to be I full prior to disposal. Barrels not completely full shall be filled I with tailings or soil. f w

C. All waste shall be buried in Cell No. 3 unless prior written approval is obtained from the NRC for alternate burial locations.

0. All disposal activities shall be documented. The documentation shall include descriptions ~f tile Wii$t,8 and the di~posal locations, as well as all actions reqijired by this conditiln. An annual su1Y111ary of the amounts of wa$te disposed of from off-site generators shall ~e sent to the NRC.

10.6 The licensee ts authorized to receive and process SOijrce materials from the Allied Signil Corporation's Metropolis, Illinois, factlity in accordance with the amendnlent request dated June 15, 1993.

10.7 The licensee. is authorized to receive and process source *aterial from Allied Sigsyl, Inc. of Netropolist Illinois. in acrordance with the amendment request dated September 20, 199&~ and amended by letters dated October 30, and November ll, 1996.

SECTION 11: Monitoring. Recordfnr, and Bookkeeping Requirements 11.1 The results of sampling, analyses, surveys ~ftd monitor1ng, the results of calibration of equipment, reports on audtts and inspections, all meetings and training courses required by this lie~ and any subsequent reviews, investigations, aftd corrective ictions, shall be documented. Unless otherwise specified in the NRC regulations all SijCh documentation shall be maintained for a period of at least fi*i1e (5) years.

11.2 The licensee shall implement the effluent and environmental monitoring program specified in Section 5.5 of the renewal application as revise~ with the follo~ing modifications or additions:

A. Stack sampling shall include a determination of flow rate.

8. Surface water samples shall also be analyzed semiann~ally for total and dissolved U-nat, Ra-226, and Th-230, with the exception of the Westwater Creek, which shall be sampled annually for water sediments and analyzed as above. A sediment sample shall not be taken in place of a water sample unless a water sample was not available.

C. Groundwater sampling shall be conducted in accordance with the requirements in License Condition 11.3.

. ';

NACFCRM3MA 17-IM) 0 U.S. NUCLEAR AEOULATOAY COMMISSION PAGE 7 OF 9 PAGES_ JI License Number SUA-1358 i i

MATERIALS UCENSE _ _ [Docker or Refettnce Nu'1fr!S6Sl I SUPPLEMENTARY SHEET I I


_ March 14, 1997 I

0. The licensee shall utilize lower limits of detection in accordance with t Section 5 of Regulatory Guide 4.14 (Revision 1), for analysis of effluent and environmental samples.
  • It I

E. The inspections performed semiannually of the critical orifice assembly connitted to in the submittal dated March 15, 1986, shall be

  • I documented. The critical orifice assembly shall be calibrated at least every 2 years against a positive displacement Roots meter to obtain the
  • if required calibration curve.

11.3 The licensee shall implement a groundwater oetection monitoring program to ensure compliance to 10 CFR P1rt '1, AJ)l)efldix A. The detection monitoring program shall be in accordance ~ith the tefort entitled, "Points of Compliance, White HesaUraniumMill," subm1tted bi' letter dated October 5, 1994, as modified by the following:

A. The leak dtttection system for all ponds will be checked weekly. If liquid is present, it shall be analyzed for chlol'1de, sulfate, seleni.lllll. and pH. The samples will be statistica11y analyzed to

  • =

detenatne if significant linear trends exist, and the results will be submitted to NRC ,,, review.

B. If a significant linear trend is indicated, the 1icensee will submit a proposed correctiYe action for review and approval to NRC. The corrective action shall include a ct1,cussion 1n de~1'neation of the areal extent and concentratiOII of hazardous Lonstituents.

C. The Hcensee shall sanaple 10n1toring wells WMMW-5, -11, -12, -14, -15, and -17. on a quarterly basts. s--,las shall ~~ ,nalyzed for chloride, potass f u11, nickel, and uranium, and thl results of such sampling shall be included with the environmental Mt\1toring reports submitted in accordance with 10 CFR 40.65.

11.4 During extended periods of mill standby, eight-hour annual sampling for U-nat, Ra-226, Tti-230 alld Pb*210 may be aUmi nated if routine airborne sa111pling show levels below 10 pewicent of the appropriate 10 CFR Part 20 limits.

During periods of standby, sampling frequencies for area airborne uranium sampling within the mill may be reduced to quarterly, provided measured levels remain below 10 percent of the derived air concentration (DAC). If these levels exceed 10 percent of the DAC, the sampling frequency should follow the recORnendations i~ Regulatory Guide 8.30.

11.5 Calibration of in-plant air and radiation monitoring equipment shall be performed as specified in the license renewal application, under Section 3.0 of the *Radiation Protection Procedures Manual," with the exception that in-plant air sampling equipment shall be calibrated at least quarterly and air sampling equipment checks shall be documented.

.. *-*-*---- . *1 u.s. NUCLEAR REGULATORY COMMISSION l. ____ **--*- .__ ~~?_E___ . _?_F 9. PA_G_Es__ 1 Il.1,Tnsc :',iumhn 1 i

~***-* ... -****--**--

SUA-1358 I

MATERIAi S LICENSE SUPPLEMENTARY SHEET r: Doi:kl*1 m l<--frremc Nu111l>t'r 4_0:~8L

________ -**-* __ .... L .... _Ma.r.ch 14~ 199L ___ . ......... **-***-11 11.6 lhe licensee shall perform an annual ALARA audit of the radiation safety program in accordance with Regulatory Guide 8.11.

SECTION 12: Reporti~g Requirements 12.1 The licensee shall submit to NRC for review, by June 30, 1997, a detailed reclamation plan for the authorized tailings disposal area which includes the following:

A. A post-operations interim stabilization plan wi11ch details methods to prevent wind and water erosion and recharge of the tailings area.

8. A plan to determine the best meth~dology to dewater and/or consolidate the tailings cells prior to placement of the final reclamation cover.

C. Plan and cross-sectional views of a final reclamation cover which details the location and elevation of tailings. The plan shall include details on cover thickness, physiral characteristics of cover materials, proposed testing of COier materials (specifications and quality assurance), the estimated volumes of cover materials and their availability and location.

O. Detailed plans for placement of rock or vegetative cover on the final rec'laimed tailings pile and mill site area.

E. A proposed implementation schedule for items A through D above which defines the sequence of events and expected time ranges.

F. An analysis to show that the proposed type and thickness of soil cover is adequate to provide attenuation of radon and is adequate to assure long-term stability, as well as an analysis and proposal on methodology and time required to restore ground water in conformance to regulatory requirements.

G. The licensee shall include a detailed cost analysis of each phase of the reclamation plan to include contractor costs, projected costs of inflation based upon the schedule proposed in item E, a proposed contingency cost, and the costs of long-term maintenance and 111<>n itori ng.

--*** _9_ _ _ PAGES_.

l.1n:n~t* Numht'r MATERIALS LICENSE l.lot:kl.'I ur Rdert'nn: Numt>t*r SUPPLEMENTARY SHEET ,________________________ J9-!l.~~-L________ .______ ---**-*. - /

  • -*- *--*-------- * -*---~-. _-* --- *-_*- * - ___J__ -*- _______ Mi!.fC 'l 14
  • __ l 99 7_ -**------- __ --i 12.2 The licensee shall submit a detailed decommissioning plan to the NRC at /

least twelve (12) months prior to planned final shutdown of mill operations. 1 FOR THE NUCLEAR REGULATORY COMMISSION I cd7.*iL{l{i;~P Uranium Recovery Branch Di~,sion of Waste Management Office of Nuclear Material Safety and Safeguards

Enclosure 5 "Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material" May 1987 revision

Gll!DFl *r;Es FOR OECO~'.TMqN.ATH'N OF FAC[L!TiES ftND f1':i11!r~ENT PRIOR TO RELF.A~E FOR UNRESTRICTED USF.

0P TERM[NATJO~I OF ! l(EN~ES FOR BYPROuUCT, SOURCF, OR SPECIAL NUCLEAR MATfRTAL U.S. Nuclear Regulatory Corm,ission Division of Fue1 Cycle, Medical, Acadel'llc, and Corm,ercial Use Safety Washington, OC 20555 May 1987

_,,., ,. ___ . __ *-. -- ..... _~-- .--- -- -

- -----~--.

TABLE 1 ACCEPTABLE SURFACE CONTAHINATIOIC L[V(LS AV(RAG(b Cf HAU~b d f RU()VASLEb e f NUCLlO(Sa U-nat. u-23S. U-238. and Clllz 1.000 dpm o/100 ~

  • ssociated decay products s.ooo dpa o/100 caz l S , 000 dpll o/100 Tran~ur*nics. RJ-2~6. Ri-228.

Th-230. lh-2:8. Pa-231. 100 dplll/ l 00 ,.2 JOO dp11/ l 00 cm2 20 dpm/100 caZ hC-227. t-125. 1-12?

Th-nat. lh-l32. Sr-90. 3000 dpm/ 100 CJQ2 200 dpm/100 aa2

~a-223. ~t-ZZ~. U-232. t-126. 1000 dpm/lOO cm2 1-131. I-133 Ce~~-~J~~ ~~ittcrs (nuclides

~ith dcc~y ~ocle~ o~her than 15,000 dpna ly/100 cmZ 1000 dpia h /100 cm2 alpha c~issi~n or spontaneous SOOO dpna ly/100 cmZ fission) except Sr-90 and others n~t~~ a~ove.

~-~----~~~~~~~~~~~~~~~~~~~~~~~~~~~-:-~~~~~

a~hcre surface cor.ta~inat;on by both alpha- and bP'~-galTlllil-emttting nuclides e*ists. t~ limits established for alpha- and bet!-ganma-tnattttng nuclidcs should apply independently.

bA~ used in this table. dpm {disintegrations per minute) ineans the rate of.emission by radioactive IILiterial as detennfned by correcting ihe co,m:.s per minute observed by an apprvpriate detector for background. efficiency. and geOCDetric factori usochted "With the instn.imentation.

c:~~surcr.cnts of average contaminant should not be averaged over more than l square meter. For objects of less surface area. the average

~hould be derived for each such objec'.

~;he ~~x;mu~ contamination level applies to an area of not 1110re than 100 cm2.

eihc a::10unt ,r removable radioactive ~aterlal per 100 cm2 of surface area sho~id be deterrni~ed by wtp1ng that area ~ith dry filter or soft

~hsoru~nt rJpcr. applyin~ mo~erate pressure. and assessing the ar:10unt of rad1oacttve mater1al on the -ipe -1th 1n appro~riate instrument of l..:1.:>,:n efficiency. \..'hen removable contamin.stion o~ objects of less surfacP area is determined. the pertinent levels should be reduced prc~or:ionally and the entire surface should be w1ped.

frh -~ and _,vi~u~ radiation levels associated wtth surface conta-ination resulting from beta-ga,,_. ea1tters should not exceed

.,vcr.:i*;... at 1,.....

O.Zi! mrad/hr cm, and

, , 1.0 mrad/hr at 1 cm, respect,vely.

. measured thruugh not more than 7 ~tlligr*ms per square centimeter of to~al absorber.

t' I ThP *nstructions in this o~*de, in canjun(tinn with Table 1, spec;fv thP racinn1Jclides and r"diatiC'n e.xposure rJtr> lil'TlitS which should be *;-;ec in r!P.contal"*nation and survr.: of st*r'dces or preriises and P<:uipment prior to iJbandonment nr rPlease *o*r unrest1*~rted use. The limits in ;'e!'lP 1 do nnt apply to premisP~. equipment, or scrap cc~taining induced radioactivity for which thP. rad1nlogicdl considerations pertinent tr. their use may be different. The relea~e of such facilities nr items from regulatory cc~trol Is cr~sidered on a case-by-case.

1. The licensee sh~ll make a reasonable effort to eliminate resi~ual contamination.
2. Radfoactfvity on PQuipment or surfaces shall not ~e covered by paint, plating, or other covering material unless tontamination levPls, as determined by a survey and ~ccumented, Jre below the limits specified in Table 1 prfor to th~ application of the covering. A reasonable effort must be made to minimize the crntam1nation prior to u5e of any covering.
3. The radioactiv;ty on the interior surf~ces of pipes, drain 11nPs, or d11ctwcrk shall be detemine~ h.v makinq measurements at all traps, and other appr~priate occess point~. prov1~Pd *hat contamination a~ ~hese locations is likely to be rPpresentative of contam~nation on the interior n~ the pipes, drain lines, or ductwork. Surface~ of premises, ~auipment, or scrap which are li~ply to b~ cnntaminated but are of such size.

construction, or lor?.t,on as to make the surf~ce inaccessihle for purposes of rneasurr~ent shall be prPsumed +o be contaminated 'n excess of the limits.

4. Upon request, thL Corrrni~sion may authorize a 11r.ensee to relinQuish possP.ssion or contrnl of premises, equipm~nt, or scrap having surfaces cont~minated with ~ater1al~ 1n excess of the limits ~pecified. This may include, but would not be limited to, special circumstances such ~5 razinq of uuild1ngs, transfer to premises tn ~nother organization r.nntinuing work with radioactive ~aterials, or c~nversation of facilitie~ to a long-term storage or standby ~tatus. Such requests ~ust:
a. Provide detailed, specific 1nfomation descrihinf'.1 the premise.s, equipment or scrap, radioactive conta~1nants, and the nature. e*tent, and deqree of res1dual surface contamination.
b. Provide a detailed health and safPty analysis which reflPcts that the res 1dua 1 amounts of mated~ 1s on surface areas, toqether with other considerations s~ch as prosp~ct1vt use of the prem~ses, eou1rMent, or scrap, are unlikely to result 1n an unreasonable risk ~" the heal~h ~nd safety of the public.
5. Prior to relP~se of premisrs 'or unrr(!ricted use, t~e licpn(~P shall make a cn~prehens1ve radiatinr surv~y wh1ch establl~~PS that rortaminat1rr ,r wiHiin t~P limits srPcifi1;1~ ;n Ti\ble I. A ccrv n'" the (,tJrvey r~port shall hr 1

filer "ith t"P ri,vidon n' F11Pl Cycle, Medicai'. Academ1c. and (or'T'Prcial 1 se Sdfety. IJ. S..'-lur'Par Regulatorv Cn1T1Y1iss1on, wash1noton. DC 2r5ss, and al5o the Adm11'1istr"tor of the NRC PPcional Office having J11r1sdiction. The repor*

~hould be filed at 1Past JO days prior tc the planrr.d date of aba~rlo,,~ent.

The survev rP.port sh~ll:

a. Jc'c,ntHy the premises.
b. Show that reason!ble effort has been made to eliminate residual contamination.
c. Describe the scope of the survry and qeneral procedures followed.
d. State thP findinos of th~ sJrvey in units spec1f1ed 1n the 1nstructlun.

Followiro reviPw of the repo,**.. the *:QC will consider visiting the facilities to conf1rr, thp survey.