Release criteria

[Lamont]

Can someone direct me to a regulation or a book on material release limits? For free release?

[moke]

Hi Lamont,

Who is the governing body regarding your question.

ie. DOE, DOD, NRC?

Have a great week!

Moke

[Lamont]

The NRC and the state of Texas. Wouldn't the NRC's guidelines rule over all as a standard and the others just regulate more for the safety of not violating the code of federal regs.? If it is the code of Federal Regs. What part and where.

I appreciate all your help and showing off is great!!! That is why I came here to the pros to find out.

[SloGlo]

Lamont,  Unfortunately, you have merely narrowed the criteria a few degrees.  It would depend on what type of free release you are concerned; liquid, gas, solid.  Are you releasing materials?  Are you doing shipments?  Is it a free release to the general public, or to another licensee?  It goes on and on.  Now, in RE: to whether the state or feds have jurisdiction, it depends on whether you are in an "agreement state" or not.  Another item to consider in RE: to state/fed is the isotope in question; for instance, the feds usually delegate Radium to the states.  I realize that this is probably not much help, but perhaps you undrstand why mr marssim was throwing all the regs and guides at you, and maybe, just maybe give you guidance for what he is looking for.  He does know what he is talking about.

[Rain Man]

States will exert rights over certain issues.  This is one of them under specific circumstances and depending on the state.  States rights has always been a bone of contention and some exercise them more vigorously than others.

[Lamont]

Once again thanks people...I appreciate the help...My name is Lamont(You know Sanford and Son..THE BIG DUMMY)So, please bare with me. Texas is an agreement state and it is the free release of diposable items. How about this, where could you find the limits for removable and fixed contamination to the public? Say a piece of metal?

[doctorbill]

As the previous responses, show, this is a complicated topic.  Let me provide my own lessons learned on this.  I assume that you're a NRC licensee, i.e., either a nuclear power plant or a material licensee in a non-agreement state.  If that's the case, 10 CFR 20 does not allow the release of any licensed material, except as an effluent, as allowed in your license, or by transfer to another licensee, such as a radwaste disposal facility.  Some states, such as TN, do have release limits.

A common misconception is that if you have an "exempt quantity," or an "exempt concentration," as defined in 10 CFR 30, you can free release that.  That's not true.  If you read 10 CFR 30, there's really no such thing as an exempt quantity or exempt concentration, only exempt "persons," i.e. a person (a licensee is a "person") can possess an exempt quantity without a license.  However, if you have a license, then all of your licensed material is subject to regulation.  Some sources, such as smoke detectors, luminous materials, and static eliminators exempt the end user (not the manufacturer or distributor) from 10 CFR 20 requirements.  These sources can be free released by the end user.  The key is exemption from 10 CFR 20.  Exemptions from 10 CFR 30 is not good enough.

Clearly, zero is not a practical release limit.  This is translated into "nothing detectable."  The question then becomes, "How hard do you have to look?"  For surface contaminated materials, the generally accepted answer is a good frisk with a standard frisker, for beta emitters.  For bulk contaminated items, such a liquids, sand, etc., the generally accepted answer, as expressed in a "Health Physics Position Statement," is that you have to test such materials to the LLD's generally required for a reactor's environmental monitoring program.  These are sometimes difficult to meet, especially for I-131 and tritium.  

Another practical concern, if the material is going to a landfill or scrap yard, is that many of these facilities have installed portal monitors with very low setpoints.  If your material alarms the monitor, it will generally not be accepted.

All of this emphasizes the importance of waste minimization and controlling what goes into your restricted area.

doctorbill

[SloGlo]

Oh good grief,  I hate Thursdays, the cranial activity hits a peak activity.... hey Lamont,  being in Tx and all, you wouldn't happen to be involved in drilling activity and trying to release equipment that is NORM contaminated, would you?  Oh lordy, I hope not.

[Lamont]

I am sorry I haven't been that specific. But, hey aren't you having fun.... All of the answers you have given me are great and the rope is getting closer to me or the sun is starting to shine light in my dark pit.

So the "Nothing detectable" means nothing above background or nothing above 100cpm? What about alpha? no detectable also? or <20counts? (Doesn't this question always come up?)

sloglo hit it on the head...NORM for drilling activities. Releasing of tools with NORM scale on them. Most licenses for well-logging do not allow for contamination because the sources they use are double encapsulated special form. Anyway, getting back to what I need. If I want to release a tool, should I go with a "nothing detectable" or "nothing over 100 CPM above background"  Also, which documents/books do you think I should use to reference this in case a procedure needs to be written? I have looked through 10CFR20 but, I can't see anything(it may be my eyes)

I hope this post was better to you guys because you have given me alot of help so far... thanks.

[SloGlo]

Lamont,  The good news is that you are in Texas, which does have statues regulating NORM. If I remember correctly, the Lone Star State has an exposure rate for the determination of NORM contaminated equipment, and I'm thinking that it is <50uR/hr at all areas make the equipment exempt from NORM regs.   I think that you can go with the 5Kdpm/100cm average and 15Kdpm/100cm2 Max for your direct readings RE: beta/gamma isoptopes,and 1kdpm/100cm2 for your removable.  However, if you're dealing with transuranics and/or othere alphas, you'd better check 'caise they're probably lower.Anyway, you have the applicable requlations within the confines of your state, check them out through your local Department of Environmental Protection or whatever it is that they call it in Texas.  And have a nice day.

[SloGlo]

Lamont,  your thread is now under "study and reference"...  I wish these moderators would find some way to let us know when they move the thread!

[doctorbill]

I did a little research on TX regs, and found that there is a special category of material called "oil and gas NORM."  There is  "memorandum of understanding" which assigns jurisdiction to the Railroad Commission of TX.  See the following link:

<http://www.tnrcc.state.tx.us/oprd/mou/95010.html>

One question to ask is whether your facility has a license from the State for NORM.  If so, this probably specifies any release criteria.

In general, the best place to research both state and federal regs is:

<www.firstgov.gov>

Do a search, setting the "radio buttons" to indicate that you want to search TX state files.  Search under "NORM" and you'll get a lot of hits, including the regs and summary documents.

Having said all that, I would guess that, for material limited to surface contamination, nothing detectable with a good frisk is the best way to go, with the following exception:  If you are surveying a lot of small items, then be sure to also perform an aggregate survey of the box or van, etc., using a sensitive instrument, such as a "micro-R meter."  This is necessary since small amounts of contamination not detectable on a single object may add up to detectable activity when a large number are aggregated.

doctorbill

[SloGlo]

Why, oh why is it that i get the feeling that this was merely a test