how hot is clean?

[atomicarcheologist]

I was at the homefront this past weekend, mixing Cinco de Mayo and Mother's Day holidays when I ran across some old work buddies.  After some tequilas and catching up conversation, things turned to current affairs of the business.  We started discussing contamination levels, disposal practices, and some of the engineering tools now in place to deal with these things.  During the heat of the conversation, we could not agree on a limit of contamination (fixed) that could legally be left on interior surfaces of a building that is being delicensed.  I was appointed point man to put this subject to the readers of Nukeworker.com.  So, how much contamination can a licensee leave on their buildings' interior surfaces?

[PWHoppe]

Depends on who the licensee is. Are we talking the DOE or the NRC? Are we talking about EPA, State (various), and what sort of isotopes are we looking for; mfp, TRU, NORM, or other? The questions are almost endless. This can get into a really complex issue and one with no easy answer.

[RDTroja]

This can get into a really complex issue and one with no easy answer.

I couldn't agree more. The whole 'no detectable activity' mindset that the nuclear industry has adopted as a knee-jerk reaction to some mistakes that were made releasing contaminated materials is a prime symptom of the problem. As the science of detection improves and the limits get squeezed down, we are more frequently stuck with the 'by what standard' question. I dread the day when the MCA/GeLi is the release tool and the debate becomes 'how long a count is required to get the MDA low enough?', but I feel it coming if we don't get a good dose of sanity from somewhere.

[RDTroja]

Generally, (depends on the isotope) 5 k average, 15 k max.

Wow... if that is true, we should just leave everything we can't get out now in the buildings until they are delicensed and then they will be releasable... 

[JeffHawk]

Do a search for "MARSSIM" on the internet. This is the standard that we used to define what releasable means during the D&D work at Trojan.

[DDD]

You also have to consider inaccessable areas such as inbedded piping, If these areas are grouted you can get relief from the agencies to leave conciderably higher levels.

[alphadude]

You must look at the contributions- ground water, soil and structures as an integrated component. 25 mr/yr is a good limit. This must be divided up among the three components, if applicable, and there ya go.  Its always good to establish an ALARA limit like 10 mr/yr. 

Analysis of the Hard to Detects, then scale to Cs-137 or some nuclide you can readily detect and go from there. Pipe may be several thousand dpm/100cm2 before 1 mr/yr is reached, but that depends on the mix. Am-241 and the likes can lower your easy to detect limit. Dose based is always better than contamination based limits- Three Building Project was a good example of how much it cost...

[alphadude]

Yea seems to be some confusion, the LTP vs NRC license requirements are usually two different things. free release vs FSS  and so on. It all comes down to agreements. "clean" means no detectable in general. not really related to FSS, since we have Cs-137 and Sr-90 in the background and this must be integrated into the FSS when applicable.

[MrHazmat]

Hey DOT say's 22 dpm/cm2 Alpha , 220 dpm/cm2 Beta-Gamma , and 0.5 mRem/hr is clean 

[radgal]

That's for TRU. Depleted Uranium the numbers are different much higher,same is true but even more so for H3.  As others have stated above it depends on the isotope.

[SloGlo]

Hey DOT say's 22 dpm/cm2 Alpha , 220 dpm/cm2 Beta-Gamma , and 0.5 mRem/hr is clean 

dis iz what dot is sayeen these daze?  i thought it wazant crapped up until it waze, like, 22k or so, betagamma external to da package?

[atomicarcheologist]

This is beginning to sound like our conversation last weekend, albeit a whole lot more sober.
If you are allowed to leave 25 mr/yr, isn't that a lot more than 15Kdpm/100cm2 max per meter? 
Is imbedded piping involved?  Or is that a separate issue, ala groundwater/soil limits?

[Llama]

Most LTPs are written using the 25 mr/yr criterion. A Resrad is run using the resident farmer senerio to give you the DCGLs for the 25 mr/yr and then you are finished. Wrong! The state EPA and DEP looks at that and makes their determination. Some give and take goes on (mostly give) and a final criteria is decided on. Some states are going to a 10 mr/yr criteria and in some instances materials must meet a 1 mr/yr.

[alphadude]

back to the original question-are u looking for signs of pollution? or looking for some thumb rule to make things work?  pollution free or "clean" is "no detect."  and even thats based on methods used... (LLD, MDC etc)

all these numbers we see here, 5k 15k, 1mr/yr, dot limits, etc. are risk based limits. analytically thats not "clean." they may be acceptable which is different animal all together

[MrHazmat]

dis iz what dot is sayeen these daze?  i thought it wazant crapped up until it waze, like, 22k or so, betagamma external to da package?

The limits I posted are in cm2 not 100cm2, so actually it's 22000 and 2200 dpm/100cm2

[Phurst]

The limits I posted are in cm2 not 100cm2, so actually it's 22000 and 2200 dpm/100cm2

Perhaps you meant 2200 and 220 - know as Return to Service (RTS). DOT's way of saying clean. We recently asked them about it because it conflicts with NRC (None detectable). They reconfirmed that RTS is acceptable to send back to Mom and Pops Crib and pacifier shop.

[MrHazmat]

Perhaps you meant 2200 and 220 - know as Return to Service (RTS). DOT's way of saying clean. We recently asked them about it because it conflicts with NRC (None detectable). They reconfirmed that RTS is acceptable to send back to Mom and Pops Crib abd pacifier shop.

49CFR 173.443
(c) Except as provided in paragraph (d) of this section, each
transport vehicle used for transporting Class 7 (radioactive) materials
as an exclusive use shipment that utilizes the provisions of paragraph
(b) of this section must be surveyed with appropriate radiation
detection instruments after each use. A vehicle may not be returned to
service until the radiation dose rate at each accessible surface is
0.005 mSv per hour (0.5 mrem per hour) or less, and there is no
significant removable (non-fixed) radioactive surface contamination as
specified in paragraph (a) of this section.
    (d) Paragraphs (b) and (c) of this section do not apply to any
closed transport vehicle used solely for the transportation by highway
or rail of Class 7 (radioactive) material packages with contamination
levels that do not exceed 10 times the levels prescribed in paragraph(a)

(a) The level of non-fixed (removable) radioactive contamination on
the external surfaces of each package offered for transport must be kept
as low as reasonable achievable. The level of non-fixed radioactive
contamination may not exceed the limits set forth in Table 9 and must be
determined by either:
    (1) Wiping an area of 300 cm\2\ of the surface concerned with an
absorbent material, using moderate pressure, and measuring the activity
on the wiping material. Sufficient measurements must be taken in the
most appropriate locations to yield a representative assessment of the
non-fixed contamination levels. The amount of radioactivity measured on
any single wiping material, divided by the surface area wiped and
divided by the efficiency of the wipe procedure (the fraction of
removable contamination transferred from the surface to the absorbent
material), may not exceed the limits set forth in Table 9 at any time
during transport. For this purpose the actual wipe efficiency may be
used, or the wipe efficiency may be assumed to be 0.10; or
    (2) Alternatively, the level of non-fixed radioactive contamination
may be determined by using other methods of equal or greater efficiency.
    Table 9 is as follows:

    Table 9--Non-Fixed External Radioactive Contamination Limits for
                                Packages
------------------------------------------------------------------------
                                                  Maximum permissible
                                                         limits
                 Contaminant                  --------------------------
                                                Bq/cm2  uCi/cm2  dpm/cm2
------------------------------------------------------------------------
1. Beta and gamma emitters and low toxicity          4     10-4      220
alpha emitters..............................
2. All other alpha emitting radionuclides....      0.4     10-5       22
------------------------------------------------------------------------
If you follow this completely you come up with 2200 and 220,(10% Eff.) but if the limit is 220/cm2 and you have 100 cm2 you would actually have 22000 dpm/100cm2. Not easy to understand if you are not use to dealing with Lawyer written regulations.

[Phurst]

49CFR 173.443
(c) Except as provided in paragraph (d) of this section, each
transport vehicle used for transporting Class 7 (radioactive) materials
as an exclusive use shipment that utilizes the provisions of paragraph
(b) of this section must be surveyed with appropriate radiation
detection instruments after each use. A vehicle may not be returned to
service until the radiation dose rate at each accessible surface is
0.005 mSv per hour (0.5 mrem per hour) or less, and there is no
significant removable (non-fixed) radioactive surface contamination as
specified in paragraph (a) of this section.
    (d) Paragraphs (b) and (c) of this section do not apply to any
closed transport vehicle used solely for the transportation by highway
or rail of Class 7 (radioactive) material packages with contamination
levels that do not exceed 10 times the levels prescribed in paragraph(a)

(a) The level of non-fixed (removable) radioactive contamination on
the external surfaces of each package offered for transport must be kept
as low as reasonable achievable. The level of non-fixed radioactive
contamination may not exceed the limits set forth in Table 9 and must be
determined by either:
    (1) Wiping an area of 300 cm\2\ of the surface concerned with an
absorbent material, using moderate pressure, and measuring the activity
on the wiping material. Sufficient measurements must be taken in the
most appropriate locations to yield a representative assessment of the
non-fixed contamination levels. The amount of radioactivity measured on
any single wiping material, divided by the surface area wiped and
divided by the efficiency of the wipe procedure (the fraction of
removable contamination transferred from the surface to the absorbent
material), may not exceed the limits set forth in Table 9 at any time
during transport. For this purpose the actual wipe efficiency may be
used, or the wipe efficiency may be assumed to be 0.10; or
    (2) Alternatively, the level of non-fixed radioactive contamination
may be determined by using other methods of equal or greater efficiency.
    Table 9 is as follows:

    Table 9--Non-Fixed External Radioactive Contamination Limits for
                                Packages
------------------------------------------------------------------------
                                                  Maximum permissible
                                                         limits
                 Contaminant                  --------------------------
                                                Bq/cm2  uCi/cm2  dpm/cm2
------------------------------------------------------------------------
1. Beta and gamma emitters and low toxicity          4     10-4      220
alpha emitters..............................
2. All other alpha emitting radionuclides....      0.4     10-5       22
------------------------------------------------------------------------
If you follow this completely you come up with 2200 and 220,(10% Eff.) but if the limit is 220/cm2 and you have 100 cm2 you would actually have 22000 dpm/100cm2. Not easy to understand if you are not use to dealing with Lawyer written regulations.

You left out 173.443 (a) 1 where it gives the 10% efficiency

[MrHazmat]

It's there just out of order.

[atomicarcheologist]

Most LTPs are written using the 25 mr/yr criterion. A Resrad is run using the resident farmer senerio to give you the DCGLs for the 25 mr/yr and then you are finished. Wrong! The state EPA and DEP looks at that and makes their determination. Some give and take goes on (mostly give) and a final criteria is decided on. Some states are going to a 10 mr/yr criteria and in some instances materials must meet a 1 mr/yr.

How would you run a ResRad approach if you were not going to use the resident farmer scenario?  Perhaps the future use of the structure could be for an occupational or factory use only.  We could house lawyers or mill hunkies and that should change the numbers greatly, yes?

[Llama]

NUREGs have sugested a more realistic approach to the resident farmer. You can model it more realistically (i.e. if there are deed restrictions on the LTP). Therefore the modeling can reflect a truer future use of the land. The problem is to get a buy-in of all parties involved.


btw: MARSSIM I still have that cold brew awaiting you when you stop by

[RAD-GHOST]

AA,

You may be on to something with the Release Criteria based on Occupations!  I don't believe you could ever include lawyers in the D&D equation.  If you interjected lawyers into the calculation, " Worth vs Risk ", you would be Free Releasing the Commercial Plants at 100% Power!

Sorry, but I couldn't resist, RG! 

[atomicarcheologist]

AA,

You may be on to something with the Release Criteria based on Occupations!  I don't believe you could ever include lawyers in the D&D equation.  If you interjected lawyers into the calculation, " Worth vs Risk ", you would be Free Releasing the Commercial Plants at 100% Power!

Sorry, but I couldn't resist, RG! 

OK, thanks.  But to get back onto the topic, how much can one leave behind as clean with a delicense operation?  Could we assume that 100K/100 cm2 of Co60 would be OK?  Could we go to 150K if it was only U238?  What would the transuranics work out to?

[RDTroja]

OK, thanks.  But to get back onto the topic, how much can one leave behind as clean with a delicense operation?  Could we assume that 100K/100 cm2 of Co60 would be OK?  Could we go to 150K if it was only U238?  What would the transuranics work out to?

I have to admit total ignorance when it comes to D&D work, but if 100K/100cm² of Co60 is releasable anywhere, then what the hell are we worried about releasing items and areas that are over 1Kdpm/100cm² in the commercial end of the world? Or for that matter having release limits of 'No detectible activity' even considered if we are just going to release it all later at 100K?

That does not compute...

[raymcginnis]

At our site, the related questions that keep coming up are what is MDA and what is background.  We are politically driven on these two questions by protestors and community groups.  We have this big push from them to go to 10-6 levels, similar to chemical sites.  The problem is the natural radioactivity that has been here since the earth was created.  To get to 10-6 risk for uranium in soil, the labs would have to analyze the samples for 10 weeks to meet the MDA. 

If you have no community groups, then the answers given previously are correct.  For buildings, Mike was right.  Those are the most common limits.  For soil, you have to consider all the possibilities of land use and pick either the most likely, or if your politics drive it, the most conservative. 

When we use RESRAD for soil, we always go for "Family Farm" (most conservative) because of our politics.

We also use NDA for facilities and equipment when possible, but we have to state on our surveys what NDA is.  In general, we use ALARA as our goal.  For soil we use 15 mRem/yr as our limits in RESRAD, but we always try to get way below that.  MARSSIM explains all of these principals very well.  That is the path we are all on now, unless you are somehow grandfather claused out of MARSSIM.  Some NRC places may still be able to use 100 mRem/yr.  There is no standard for what is hot now.  It is all under debate.  There are NRC, DOE and DOD standards, but they all still disagree on this.  It is what you can negotiate with your regulator that sets your true limits.  That is determined by your local politics.  That is what I have found.  If you travel from place to place, your limits may change from place to place, depending on politics.

Nuff said.

[alphadude]

MARSSIM is a guide... the DQO process should drive your plans not MARSSIM which has become  "religion in a box!"

Back to the topic, are u looking for signs of pollution or some thumb rules or risk limits to get the job done.

[Shonkatoys]

Marssissms was intended for  small one radionuclide facilities.  To use it at large facilities with multiple radionuclides is a joke in my opinion.  It is also a joke to use 1940's instrumentation to check facilities when there is 21st century technology  available.  But if you have regulators using 1940's technology to check 1940's technology   I guess then  clean is what you get away with and marssisms has so many loop holes the best bet is to just make up numbers ask for your money and hope you dont get caught.   And if you do  get caught then say I  didnt survey there and help the regulator find a clean space.   If the regulator is still not happy ask your client for more money to tell him the regulator is wanting me to more than marrsisms and get paid twice.  Well eventually someone is going to catch on .   Then  we will all have to use 21st century technology and have to do it  right and be accountable.  Until then party hard and chump the client with the 1940's technology and Marssisms.

[alphadude]

well as you know humans are prone to error, and have an attention span of about 20 minutes on mundane tasks such as frisking.

usually the resistance to modern technology is the body shop mentality. YOU mean this will replace 15 techs? That is less money i can charge the customer if you use 3 techs and one machine!!!  Look again at the cost? Its the same ole same ole...

the technology is high right now due to this body shop mentality.  (horses were cheaper than cars if u remember and people were afraid of gasoline.) so, shonkatoys is right, its a statistical crap shoot. but as with MARSSIM and pigs, even a blind pig finds an acorn sometimes!

[Shonkatoys]

Having been a senior tech before, the problem with surveys not being logged somehow as you do them is a human factor one.  You have some techs who try to do the right thing and do accurate surveys.  They usually work together because they take some pride in what they do.  Then you  have the dirt balls who  are the lazy, stupid, latenight drunken party people, alcoholics,  don't give a damn techs etc.  They usually work together.  Thats why I kept my own note book at work to write down exactly where I was,  If you turned these people in  you were the one punished not them.  Thats why I kept my mouth shut and kept a log book.  I have seen the so called snitches run off, not the ones that needed to  be. I have found hot stuff on the 1940's technology when I went back to survey the scum tech areas. I never  heard of one instance where the 21st century technology was found in error. There fore Marssisms is  useless without 21st century technology in my opinion to log and map everything.   The body shops have a hard time filling spots sometimes and will bring back people they know messed up before. Marssims and a Blind squirrel like alpha dude says will find a nut every   once in a while.  I  myself trust in 21st century technology.  So  to answer the question how hot is clean?   You have a few answers,
1. With dirtball techs with 1940's technology instruments that do not log data then it is what you can get away with with a straight face.
2. With good techs with 1940's technology instruments that do not log data it is pretty close to  the set limits.  However with this technology you can not survey as quick   or  get the good data of 21st century technology. You  may  get  a  few hundred  readings a shift .
3. Dirtball techs with 21st century technology,  As Donald Trump says, Your FIRED.
These instruments time stamps, photographs what you survey, calculates the background, etc. If this looks wrong you will probably work one more shift to document this and then>   YOUR FIRED   This is good for Marssisms and the whole nuclear industry!!!!!
4.Good techs with good up to date 21st century equipment take pride in what they do, and do not have to deal with dirtballs for long. They  get great information and  can get right at the limits set forth by the project.  They get  about 100 thousand or more readings a shift.

Well  these  are my answers, feel free to  write more!!!

[raymcginnis]

Cool!  This topic took off! 

I agree with some of this and disagree with other parts of the postings.  I agree that you need people who care about their jobs.  I worked a site once where I was supervising people who had never done HP work ever.  They could care less about what they were measuring and we, the supervising HPs, could not make them care.  It was frustrating.

I worked a job in the 1980s where all I did was frisk walls, floors and ceilings for months, 7days, 12 hours a day.  I guarantee that I found way more than one acorn or one nut.  I must be a special nut case myself, LOL.

We have all 20+ year people who all love their job and they are all good at it, including our contractor technicians.  MARSSIM works fine for us.  The NUREG calculations include the surveyor MDC factor to account for standard Human error.  Nothing can account for people not caring about what they are doing though. 

We have pretty decent equipment, but we still sometimes use 1" NaI detectors to back up our soil sample data (along with a modern GPS large detector system).  But it works!  The confirmatory regulator groups rarely find anything behind us.

As far as small one isotope facilities, I disagree.  You can choose a surrogate isotope.  If you base you scan MDC on that isotope and can do your calculations to prove that you can detect that isotope, then whole site is clean, you are set.  The calculations for surrogates are in MARSSIM to tell you how to do this.  I recently proved that all you have to do is the sum of fractions based on individual isotope MDCs.  You come up with the same surrogate isotope MDC to do if you use calculations with the MARSSIM equations.  We have about 16 isotopes for a given facility, but I alway pick the predominate gamma emitter.  It works every time.

We also use our old pre-MARSSIM statistical method as a backup.  We created this program before most people even knew what D&D was.  It uses a statitical method called cumulative probability.  We created software and it is recently improved.  You can get it as freeware from my website: http://www.radprocalculator.com/software.aspx

It is called Cumulative Probabbility Plot

It is a plotting program that uses these statitical methods and is useful not only for releaseing sites, but interpreting large sets of data, whether nuclear or not (building widgets).

[atomicarcheologist]

I have to admit total ignorance when it comes to D&D work, but if 100K/100cm² of Co60 is releasable anywhere, then what the hell are we worried about releasing items and areas that are over 1Kdpm/100cm² in the commercial end of the world? Or for that matter having release limits of 'No detectible activity' even considered if we are just going to release it all later at 100K?

That does not compute...

OK, I may have gone overboard with the 100K Co60.  When we were sitting around (originally, please note starting post) finishing off the meager stash of XX and 1812 in the local tavern, we started messing with numbers.  I believe the we figured we could do at least 50K dpm/100cm2 direct read. 
This exercise did include the assumptions that it would be a single spot of residual, there would be no smearable, and singular isotope.  These were in place to preclude taunting and torment from those whose evening's intake may have adjusted their mentality from the analytical to the subversive.
Anyone care to play with us?  Not that the etheral discussions ongoing through this thread are misguided, quite the contrary as they are most welcome in this exchange of information and ideas and hasten the advancement of the Health Physics disicpline on the street. 

[Shonkatoys]

Forgot to mention when the Job site has numerous HP jobs to include job coverage and survey.  The survey techs are usually the bottom of the barrel techs who can not do anything else.  This also makes surveys suspect if they are not recorded with 21st century instruments.  Half the techs that did primarily surveys that I know I would not want to approve their surveys.  So how does Marssims fit into this equation? How hot is clean. Depends if a drunk even surveyed it or not. seen  over 1 million dpm come back and the tech sweared they surveyed it.  They let him slide cause he was one of the boys. So 1 million or more dpm for dirtballs is the answer. The limits set forth by the facility if it is recorded properly with 21st century technology.  So  like I said party hard because I believe the Marssisms game is about over, unless properly recorded.

[alphadude]

gee shonka toys now everybodies using a CFD (cumulative frequency distribution) imagine that!  ole Joe's preaching is finally sinkin in!!!! Next thing you know they will use a weiner filter. 

survey it all and let god sort it out!

[raymcginnis]

Wow, I was right!  There are no standards, really.  These replies made my head spin.  I had to go back to the original question.  You are all right.  The main thing is to assess every part of your site (facility, soil and groundwater) and then look at who is driving your limits.  Then you negotiate with them based on you analysis using RESRAD (usually) to determine limits.  Yes, if building license termination is the goal, that is a whole different ballgame, but if there is residual contamination left outside the facility, you may only get the building taken off the license.  You'll still have a license for everything else, unless you prove that it is all below your established limits.

We are trying to release our entire 1900 acre site.  We are very close to being finished, but we are going to have to go back and do MARSSIM soil samples under every radiological facility that we demolished in order to get to the end.

[Shonkatoys]

Marssims,I no longer work for a company that puts out a poor and questionable product. This company has been caught before shipping out "Hot Stuff"  Thats where I got my over 1 million DPM 100cm2 from.  They have been caught  doing this and other items. They however still get contracts.  This reminds me of steroids and baseball.  Baseball is now checking and putting out punishments.  However these punishments are  not enough and are laughable.  The company I  use to  work   keeps  getting caught but,  unfortunately nothing is done about it.  I  am glad you work for a decent company as I do now. But as I said before, unless everything is logged then marssims is a joke.  My company now can give you acres of maps in  color of contamination in large buildings or gamma spec with specific radionuclides over large tracts of land.  This is the best data logger.  Yes this may have existed before 2000, However I doubt it was anywhere close to what it is now and surely 1940's geiger muellers can not even compete against it. The question is do the regulators really want to  protect the public,  The company I worked for never was found out by a regulator to be wrong to my knowledge, but in fact was found out by people who were sent their product.
How many people just assumed they were given a good product and just took it?  One wonders!!!!

[raymcginnis]

Shonkatoys

I can feel your pain, but man I can never be as anti-nuclear as you are.  I once worked at an x-ray machine manufacturer where I had a tld, but no instrument to even check to see if the test box was leaking.  I have heard from old friends who just went back on the road.  They are trying to turn HP techs into robots, so everyone takes a smear the exact same way. 

All of the cool old techs, like me, took house jobs at places that they liked.  The rent-a-tech pool has been diluted, but there are still good ones out there.  I did a road job just a few years ago.  I can relate to you cynicism, but there were some really good young techs out there too.

Look at the bright side of life!  You are still doing it, even if you have to cover tracks for others not as bright as you!  That speaks for itself!

[alphadude]

shonak toys anti nuke thats a hoot! 

[Shonkatoys]

Alphadude is right!! I am not antinuke.  I  am for doing things right. We can run everything electrical in the United States for the next 700 years at current consumption with just the uranium at Oak Ridge, Paducah and Porthsmouth without digging any more up.  This would be worth 4 Quadrillion dollars.  However this is not going to happen if we reward incompetence and do no check properly.  I believe one way to start is to industry wide have a higher pay scale for NRRPT's as Senior HP's.  Most NRRPT's I work with  take pride in what they do and are far more knowledgeable than a  non NRRPT.  5 dollar differential should be a start.  I know some non NRRPTs would howl about this, but frankly half the seniors that I  have known or more can not pass it in my opinion.  That is why we all have to suffer because standards are not enforced through out or encouraged. The companies that do it right suffer because they do it right. Dirtball companies can bring in dirtballs and just blame it on human factors when they get caught. Hopefully We can generate most of our electrical power with Nuclear.  However this is not going to happen when dirtball HP is an acceptable practice.

[Phurst]

I agree about NRRPT $$$$ (cause I am one) but it doesn't' detract from some of the excellent seniors I have known that weren't mathematical enough to pass the test but could cover a job like a lead blanket and protect the workers better than an egg head that could pass the CHP but couldn't find a hot spot or understand the work flow for an outage. People are people and you can't test ethics and job coverage. 90% of the NRRPT test had nothing to do with power plant outage health physics. Maybe if the pool of technicians were all interconnected so each 'dirtbag' identified at one plant could be noted at another and soon wouldn't be hired by any, it would help. But it won't happen. We're stuck, so just do your best, teach the best, accept only the best, encourage the best, and hope for the best.

[radgal]

I agree about NRRPT $$$$ (cause I am one) but it doesn't' detract from some of the excellent seniors I have known that weren't mathematical enough to pass the test but could cover a job like a lead blanket and protect the workers better than an egg head that could pass the CHP but couldn't find a hot spot or understand the work flow for an outage. People are people and you can't test ethics and job coverage. 90% of the NRRPT test had nothing to do with power plant outage health physics. Maybe if the pool of technicians were all interconnected so each 'dirtbag' identified at one plant could be noted at another and soon wouldn't be hired by any, it would help. But it won't happen. We're stuck, so just do your best, teach the best, accept only the best, encourage the best, and hope for the best.

I agree that smarts doesn't make one ethical or a good HP.  More money for passing the exam is good.  Hard work should be rewarded(I know I'm NRRPT).  But if you do your best and lead by example maybe you'll rub off on the new ones and eventually the dirtballs will retire(hopefully they don't train newbies)

[atomicarcheologist]

If you work with bad techs, that's the fault of the facility management where you are sited.  Bad, dirtball, drunk, whatever, techs should be fired.  Not laid off, fired.  I applaud your attempt to make an extra $5/hr for NRRPT but business dictates that you already make what you are worth and those who are bad should be terminated.  That way, the pool of technicians shirnks and the wages rise, or the really gone tech-heads will flood the market with 21st century technology that requires no human interaction outside of an operator.  But these instruments are coming rapidly, so you might as well get all the $5/hr that you can.
However, since you are all so very much more qualified and technically competent that the average HP technician, would you mind getting back on the track of this thread?  I am looking for ideas exchanging regarding the maximum that you can have intact and have the building released.  All this smoke that's being blown is covering up the mirrors, or is it the glass walls of your career domicile?

[Phurst]

You're right.. Thanks for redirecting us back to the thread. Or perhaps it's dead.

[alphadude]

hey atomic the question has been answered several times.  its nudlide dependent, agency dependent, statistically dependent, politically dependent, and instrument dependent.  now back to the question i asked, are you looking for pollution indications or to apease the regulators?

if you want us to design your DQOs and determine your DCGLs ya got to give up da green$$$$$$$$$$$$$ cha-ching

[Shonkatoys]

Renhack is right, 5,000 and 15,000 for Uranium at DOE facilities,However if this is not good  then  Alpha dude is right also, It is mainly what you can convince the regulator what is right. Renhack and I are working at a facility where they started out with the DOE limit, However they have changed readings above 2 meters to be more than DOE limits.  But DOE has bought off on it.  So therefore it is cool and clean with over 100K at above 2 meters for spots. Below is the official DOE word!!!   But as I have seen it can be changed.

APPENDIX D TO PART 835—SURFACE
CONTAMINATION VALUES
The data presented in appendix D are to be
used in identifying the need for posting of
contamination and high contamination areas
in accordance with § 835.603(e) and (f) and
identifying the need for surface contamination
monitoring and control in accordance
with §§ 835.1101 and 835.1102.
SURFACE CONTAMINATION VALUES 1 IN DPM/100 CM 2
Radionuclide Removable 2 4
Total (Fixed +
Removable) 2,
3
U-nat, U-235, U-238, and associated decay products .........................................................1,000 5,000
Transuranics, Ra-226, Ra-228, Th-230, Th-228, Pa-231, Ac-227, I-125, I-129 .......................... 20 500
Th-nat, Th-232, Sr-90, Ra-223, Ra-224, U-232, I-126, I-131, I-133 ............................................ 200 1,000
Beta-gamma emitters (nuclides with decay modes other than alpha emission or spontaneous
fission) except Sr-90 and others noted above 5 ........................................................................ 1,000 5,000
Tritium and tritiated compounds 6 ................................................................................................. 10,000 N/A
1 The values in this appendix, with the exception noted in footnote 5, apply to radioactive contamination deposited on, but not
incorporated into the interior or matrix of, the contaminated item. Where surface contamination by both alpha-and beta-gammaemitting
nuclides exists, the limits established for alpha-and beta-gamma-emitting nuclides apply independently.
2 As used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as determined by
correcting the counts per minute observed by an appropriate detector for background, efficiency, and geometric factors associated
with the instrumentation.
3 The levels may be averaged over one square meter provided the maximum surface activity in any area of 100 cm 2 is less
than three times the value specified. For purposes of averaging, any square meter of surface shall be considered to be above
the surface contamination value if: (1) From measurements of a representative number of sections it is determined that the average
contamination level exceeds the applicable value; or (2) it is determined that the sum of the activity of all isolated spots or
particles in any 100 cm 2 area exceeds three times the applicable value.

[atomicarcheologist]

hey atomic the question has been answered several times.  its nudlide dependent, agency dependent, statistically dependent, politically dependent, and instrument dependent.  now back to the question i asked, are you looking for pollution indications or to apease the regulators?

if you want us to design your DQOs and determine your DCGLs ya got to give up da green$$$$$$$$$$$$$ cha-ching

Alphadude,
I don't want you to design anything for me.  I was sitting around with friends batting the business breeze and thought I'd bring the conversations here. Now, should I use Co60, I think that 50Kdpm/100cm2 will fly as as delicensed based on the dpm/mR/hr formulae that I have rattling around in dusty sections of the cranium.  But since I see little activity here with posters picking their isotopes then I guess my friends and I will have to find another table to have a few with like minded individuals.

[alphadude]

got to run it through the farmer scenario. the formula you may have from some old 108 card don't apply. use the resrad to run the farmer scenario and 10 mr/yr. I think you are mixing apples and oranges at this point.

[SloGlo]

what do you have to run resrad 'n a resident farmer scenario?  wut iffen yer ona site that ain't never gonna revert to farm material?

[alphadude]

its part of the Mad Max scenario- when ya cant figure it out- do the farmer- or if you plan to sell- disclose to the new potential owner- if it stays part of the license- who cares!! when in doubt send it to tennessee and let them frisk it out!

[RAD-GHOST]

ROF-LMAO! 

Alphadude, seems you know the game when it comes to making things go away!  Maybe RESRAD can adopt the factor?  The heading could be,

" If it doesn't Glow, it can Go "! 

Funny how things work in a self regulated state.....

[alphadude]

well you are exactly right- as a purist - any found is a sign of pollution-

but im paid to be a professional risk taker.. as all HPs are. the degree of risk that the client wishes to accept is always a matter of $$$$. fortunately, im in the less than 10 mr/yr risk zone right now which sets ok with my ethics.

[alphadude]

HEY SHONKA TOYS .... A little bird told me not to buy your competitors stock... seems all their work at the big 3 buildings is in question... can you say ROOT CAUSE!!

Need to send Smurf  daddy and mama carmen the bill.....



alphadude .. pending brain surgeon

[Shonkatoys]

Now now Alphadude, Where is the love?  Now back to how hot is clean.  Well if you are given so many pico curies per gram of soil as a limit and you are over,  just mix in more soil and it is clean. dilution is the solution to pollution.  When I was with the state they took a compoite sample of Milk at Mayfields.  So depending on which milk trucks came  in and where they were from.  Some came from Virginia.  That a good piece from Oak Ridge again dispersal is the solution. Then when I was with the state it was checking the deer with TWRA.  Too much strontium in the foreleg bone or too much cesium in the liver and the deer is gone.  I saw A guy sobbing because he could not keep his 13 point deer.  They at least let him take a picture of it before they packed it up for the incinerator. So when hunting Oak Ridge the further you hunt from X10 the better not too many K25 and Y12 deer bound for the incinerator.Now there is poop samples for u235.  I will let someone else explain that!!!!

[alphadude]

SHONKATOYS   as these yankees says up here "I gots yer luv right here!"

well i was on topic how hot is clean may be a good argument that would finally get answered by the "B" company

[atomicarcheologist]

Oh, my.  Doesn't any one like to play here?  There's so much smoke on these mirrors I'm getting concerned about my lung dosage.  Folks!  What I am trying to do here is explore the knowledge base of this site for information, possibly answers, and maybe even a little fun. But all that I am seeing posted is quick quotes from Nuclear Engineering Cliff Notes, discussion about different scenarios than what was put forth, and (of course) the fun.  Now, there is nothing wrong with fun, trust me, I enjoy it also.  But and comma can we do some numbers, please?
Let's try a set scenario.  That way the textbook twiddlers will be able to engage in the thread. 
There is an old concrete building in an urban sprawl.  Let's use Newark, although is any one has a problem with that, name a different scene.
This building was home to a laboratory which was licensed by the NRC.  The license was issued for P32, S35, I131, and Co60.  The operations ceased on January 1, 1999.  All Final Status Surveys have been completed.  There was one spot of contamination detected.  It is 50000dpm/100cm2.  There is no loose contamination associated with this spot and none detected during the course of the FSS.  The total area involved with this source is 100cm2.  It is on a wall at 1 Meter elevation from the floor.  It is totally unfeasible to remove anymore of the wall as it is an outside wall.  The readings on the exterior surface of the building are all congruent with background readings of similar materials.
I say this building is going to be delicensed.
You are welcome to make up your own scenarios.

[Rennhack]

You are welcome to make up your own scenarios.

You have a river behind an old weapons facility, reading 10 mr/hr... never liscensed....

Oops, wrong scenario...

[Shonkatoys]

You see a Mushroom cloud with the wind blowing in your face.  A few minutes later your tactical dosimeters purple viles all turn gold.  You start blowing chunks, does 5K 15K matter?

Your in a Helicopter flying across a fallout zone doing air to ground coorelation factors and the fallout is reading 100 R on the ground. When do you start letting your tanks drive through this?  how about infantry walking through this. hint,  There is a 7 10 rule for fallout which means for every 7 hours your fallout decays by a factor of 10,  Tanks provide shielding of 90 percent, troops no shielding,  troops walk at 4 miles an hour, tanks go at 45 miles an hour, the  fallout zone is 10 miles across, also as you enter the fallout zone the fallout is decaying as you walk or drive.  Also your troops tactical dosimeter is already reading 50 R.  You only allowed another 100 R  to complete your mission for a total does of 150 R. The tank is obvious, What about the troops??

[halflifer]

and how does the concept of -dpm's fit into this?....as in 167gcpm(measured)-240cpm(bkg) /15%(eff)= -487 dpm

[Shonkatoys]

Or better stated how hot in R an Hour for a tank to start crossing this fallout zone so that it is clean enough not to exceed the mission limit of 150 R Dose?

How about troops?   How hot is clean?

You are a nuclear target analyst, You Advise Generals on how close to drop nuclear weapons to your own troops.  You have three criteria, 1 negligible risk which means slight risk to your troops, 2. Moderate Risk some risk to your troops and 3. emergency risk which means you may have to wipe them all out.  You are drinking coffee with the General staff about 15 miles from ground zero, Your 10,000 troops are about to be overrun by 100,000 troops.  You make the call!!  How hot is clean??

Your Sub Base in the USA is being over run by fanatics, They get a hold of some nuclear subs with nuclear weapons and head out to sea.  What is the smallest nuclear weapon you can drop on your homeland?  How hot is clean?  1KT 100 KT 1Megaton?

[raymcginnis]

Man do I love this topic!  It went South a little, but it is back on track again.

Gosh am I great HP?  Yes, I am one of the best that God ever made.  Did I do NRRPT?  Nope, never felt the need to prove myself that way, although I could pass it.  I went to school and got a bachelors and masters degree in IT.

My @$$ is on the line here, because I don't hide behind a fake name.  My real name is out there when I post these things.  Think about it! 

These things need discussion, for sure.  OK, back on topic.  Some people in EPA and protestors want nuclear to go to E-6 risk limits.  That is impossible, becaue of natural background.  To go to E-6 limits, we would have to dig up the entire planet and bury it on Mars, LOL!

Clean is a thing negotiated with your regulating bodies.  Clean is what they accept. 

We have a good crew of people here.  We go with the ALARA concept.  We basically get rid of it all and that so far has been "reasonably achievable"  We have a lower limit than the rest of the country's nuclear sites, 15 mRem per year as opposed to 25 mRem per year.  We go to non-detectable all of the time, and it is always reasonable.

We may be the first site to achieve release, a few years from now.  From experience, if you can achieve this, do it!

I know that ALARA concepts may dictate different results from other sites.  In that case, you have to look at limits and leave residual radioactivity behind.  It can be done, but speculation and innuendo would agitate people who disagree.  E-6 is not achievable, but ALARA is.  We have proven that here.

ALARA is your best friend!

[raymcginnis]

Marssim,

Of course I realize that.  Ten years ago, I gave myself a belly chuckle when we were remediating a contaminated soil area.  My non-nuclear friends asked me what I was doing.  I said I was helping dig up radioactive soil.  They asked me "What do you do with it?"  I said "We bury it," LOL!

Good point for other readers of this thread.  Thanks for reminding me and bringing up this important concept.  The non-useful radioactivity is being brought together in a just a few places.  Most of the time, you are right, it is someone else's back yard.

Our commercial burial site in California looks like it will eternally be held up by lawyers and protesters.  Washington State's moratorium has all but shut down out of state waste to Hanford.

The expense has really gone up.

[Barley_Buddy]

ALARA should be ALATRA, As Long As The Regulator Approves. 

My company is working at a major site in CA.  It's a CERCLA site and has two regulators as far as release goes.  The state for buildings and the Fed EPA for the land areas.  Sorry Ray, we are releasing the land areas to E-6.  Risk, in the case of radioacitve materials and the EPA, has everything to do with the linear non-threshold theory (for those that believe, I guess it applies....."theory" has a different meaning to me). To spend massive $$$ on a "theory" just doesn't make sense to me.  Try seeing < 0.2 pCi/g of Cs-137 with a hand held instrument.  Ra-226 is at 0.6 pCi/g.  You live by gamma spec and at times, even that takes some effort to prove results.  We've actually released some of the areas, but it's been a major effort and ALARA has nothing to do with it.

Surveys and release now have everything to do with statistics and nothing to do with the technician or the actual "risk", in my opinion.  There is no skill of the craft.  As a matter of fact, using technicians decreases your total efficiency due to variance in the geometry, inconsistent speed for scans, etc.

The fact that you can't measure the associated dose rate or contamination level at E-6 risk has no bearing on discussions with the EPA (Environmental Panic Agency...).  It's your problem.  Prove it.  I still remember the basis for Reg Guide 1.86 and have applied it to many sites in the last 30 years.  I hate to think of the "risk" I've left for future generations....(that's sarcasm for those that might miss it...)

You can go to the EPA web site and run numbers by nuclide and scenario.  You might be very suprised by the numbers for Preliminary Remediation Goals (PRGs).  If you have the NRC as the lead agency, thank your lucky stars.  They at least still maintain some reason and some foothold in science.  Hard to measure what you can't see. 

Just my opinion......what do I know.....

Stay hungry...stay happy.

[Barley_Buddy]

what do you have to run resrad 'n a resident farmer scenario?  wut iffen yer ona site that ain't never gonna revert to farm material?

Younz havta prove that tha place won't ever be used for agriculture.  Try ta get a regulator to sign off on dat.

[raymcginnis]

Barley_Buddy,

You just stressed the point that I was trying to make.  We went with 15 mRem per year ( 25 mRem per year for NRC) with a family farm scenario.  Then we try to go as far below that number as possible.  We almost always go below NDA.  That is where the big questions from protestors come in.  What is your MDC and what is background?  I am sure on all of our releases that everything is gone, yet we have new agencies reporting that we are leaving 98% of the radioactivity behind, based on our 15 mRem per year limit.

We always try to get it all and I know that we do.  The real problem with e-6 is that natural soil, in our area was above e-6 levels, before anything humans did here with technology.  It cannot be achieved here without digging to the other side of the Earth.  These protestors would have us dispose of the lava, once we got to the molten core, because of the natural uranium content there.

This is what is ridiculous about e-6 release levels.  These limits were created for man-made stuff, like solvents and acids and such.  These things have no background, so they are easily measurable on the Earth at e-6 levels.  Radiation is present all over the planet.  The time taken to measure e-6 above natural background levels would be way above ALARA and ALATRA.  It is just not reasonable.  The people who contest this should just back off.  ALARA is what it is all about.  The protestors are not reasonable by any audience account.  They only represent their misguided paranoia. 

They would have us destroy the sun to get rid of solar radioactivity.  What reasonable person would do that? 

That is my real point in joining this thread.

[darkmatter]

How hot is clean? Sheeshh..... anyone not in the industry reading this thread will really be confused. The answer is of course, Nothing is non-radioactive if you use sensitive enough equipment. The road techs know you frisk or sample however the local supervision tells you and either it goes or it doesn't.

As for that 50K fixed spot on a concrete wall, release the site with a sticker on that spot saying " do not eat this concrete spot" That label makes as much sense as the warning with a new microwave oven telling you "not to dry animals in the oven"

[raymcginnis]

Darkmatter,

Yes, this thread has turned into a tornado.   No one meant it to, but this is how important this subject is to everyone!  Because it is different from state to state everyone has a different opinion about it. 

I say let the tornado go until it dies out.  One day we may all have a one group HP opinion about this.  I'd say, don't look for it tomorrow.

I still say this is a good thread and it is time for more discussion.  Everyone, keep pushing your opinion!  Yours is just as important as mine or any other person who jumps in on this thread.

Yes the multiple opinions about this topic can be confusing to a newbe.  I have been around for a while.  I am able to sort it all out.  There are some good ideas being shared with this thread.  I actcually have a smile on my face when I read all of the replies!  Darkmatter, I loved and understand your sheeshh, LOL!

[alphadude]

You answered your own question, "All final status surveys completed"  Which means it passed what ever criteria established. 

Gosh i love playing with the words.

[Shonkatoys]

There of course is Hormesis,  There has been numerous studies showing that a slight amount of Radiation is beneficial to ones health.  People living longer in areas of higher altitude and in areas of mineral deposits that give off more radiation.  There is a building in Taiwan that the steel in its structure was melted with a source. These people in this apartment building show less cancer than the average population. The dose to these people was approximately 5 R a year.  You also have the Cow nuker they had at X10 Oak Ridge these cows lived longer than regular cows.  Hormesis works with vitamins and medicine also.  None and you actually can have a negative effect, a little and you have a zero effect.  Optimal amount and you have your maximum positive effect,  slight over dose and you have a zero effect. And anything over you have a slight negative effect to  death at maximum dose. Therefore you may ask how clean is too clean.  Maybe we should distribute all the depleted uranium we have at Oak Ridge in small viles to everyone in the US  so they can get a hormetic effect and also clean up Oak Ridge. All your weak cells and rapidly dividing precancerous cells have a chance of being wiped out. Making a healthier you!!!  How clean is too clean?  I tell my wife that also. You clean too much and  kids have no chance of getting immunity in a too sterile environment.  So put up your cleaning rags and ask for your piece of Uranium for hormetic effect.

[jakester]

Can I wash down my peice of Uranium with some good 'ol fashioned radium water???

[alphadude]

oh i forgot, somebody should have cored the wall to get the spot out, obviously a low bid job...

[Shonkatoys]

No Washing the Uranium with Radium water   They had  a device in the 1930's I guess was the first attempt at hormesis.  The revigarator or something like that.  Unfortunately the radium  in the water depositd to the bone.  This is not good.  So  the hormesis  I  believe should be called vitamin R,  and should only be a external small radiation source and standards set by FDA .  No radium water to wash or grinding of the uranium to make a internal dose Vitamin R  How clean is too clean?

[Rennhack]

No Washing the Uranium with Radium water   They had  a device in the 1930's I guess was the first attempt at hormesis.  The revigarator or something like that.  Unfortunately the radium  in the water depositd to the bone.  This is not good.  So  the hormesis  I  believe should be called vitamin R,  and should only be a external small radiation source and standards set by FDA .  No radium water to wash or grinding of the uranium to make a internal dose Vitamin R  How clean is too clean?

http://www.google.com/search?q=Revigator

http://www.orau.org/ptp/collection/quackcures/quackcures.htm

[atomicarcheologist]

No Washing the Uranium with Radium water   They had  a device in the 1930's I guess was the first attempt at hormesis. 

They used to gargle and take Radium as a tonic.  Not to mention spa usage.  Duh.  You'd be surprised where the labs where and alot about that industry.  It's been very beneficial to me.

[atomicarcheologist]

You answered your own question, "All final status surveys completed"  Which means it passed what ever criteria established. 

Gosh i love playing with the words.

Scrabbler, are you?  Where I have worked, Final Status Survey is the last survey done.  Then the paperwork is compiled and submitted.  Then the license goes away, or not.  The survey completion does not necessarily indicate that passage has occured.

[atomicarcheologist]

This is what is ridiculous about e-6 release levels.  These limits were created for man-made stuff, like solvents and acids and such.  These things have no background, so they are easily measurable on the Earth at e-6 levels.  Radiation is present all over the planet. 

Wouldn't it be fun to use as a background, the back-calculated amount of Uranium in the earth's upper soil levels when mankind made his presence?  That'd get the tree huggers in an environmental evolutionary spiral!

[atomicarcheologist]

Younz havta prove that tha place won't ever be used for agriculture.  Try ta get a regulator to sign off on dat.

Perhaps, but I would challenge a NRC representative to prove to me that Newark is ever going to be able to be used as farmland without major challenging changes that would be much more engaging than a mere 50Kdpm/100cm2 spot on a building interior wall.

[atomicarcheologist]

and how does the concept of -dpm's fit into this?....as in 167gcpm(measured)-240cpm(bkg) /15%(eff)= -487 dpm

Why, I believe that concept would enter into this via "averaging".

[atomicarcheologist]

Or better stated how hot in R an Hour for a tank to start crossing this fallout zone so that it is clean enough not to exceed the mission limit of 150 R Dose?

How about troops?   How hot is clean?

You are a nuclear target analyst, You Advise Generals on how close to drop nuclear weapons to your own troops.  You have three criteria, 1 negligible risk which means slight risk to your troops, 2. Moderate Risk some risk to your troops and 3. emergency risk which means you may have to wipe them all out.  You are drinking coffee with the General staff about 15 miles from ground zero, Your 10,000 troops are about to be overrun by 100,000 troops.  You make the call!!  How hot is clean??

Your Sub Base in the USA is being over run by fanatics, They get a hold of some nuclear subs with nuclear weapons and head out to sea.  What is the smallest nuclear weapon you can drop on your homeland?  How hot is clean?  1KT 100 KT 1Megaton?

As a nuclear target analyst, I would advise the coffee drinking General staff to utilize the weapon that would give a (3) to the overrun attempt troops, while maintaining a level (1) for our troops. 
In regard to the Sub Base scenario, I wouldn't drop any weapon on the homeland, but I would nuke the sea in the closest proximity achievable to the captured sub.  Since there were no other limitiations, my version of this scenario is an East coast base with a prevailing wind from the west.

[atomicarcheologist]

You see a Mushroom cloud with the wind blowing in your face.  A few minutes later your tactical dosimeters purple viles all turn gold.  You start blowing chunks, does 5K 15K matter?

Your in a Helicopter flying across a fallout zone doing air to ground coorelation factors and the fallout is reading 100 R on the ground. When do you start letting your tanks drive through this?  how about infantry walking through this. hint,  There is a 7 10 rule for fallout which means for every 7 hours your fallout decays by a factor of 10,  Tanks provide shielding of 90 percent, troops no shielding,  troops walk at 4 miles an hour, tanks go at 45 miles an hour, the  fallout zone is 10 miles across, also as you enter the fallout zone the fallout is decaying as you walk or drive.  Also your troops tactical dosimeter is already reading 50 R.  You only allowed another 100 R  to complete your mission for a total does of 150 R. The tank is obvious, What about the troops??

First part; I wouldn't worry about 5K or 15K while chunk heaving, unless, of course, the units were R/hr.  Even then, my worry would not consume much of my thought process.
second part;  I figure the tanks go now, the troops move out in 5 hours and have a received dose of ~126 R.  This is making the assumption that there is a shielding wall available for a 100% dose reduction that the troops are able to await command to move out.

[alphadude]

hmm I think the DQOs were inadequate if you completed the FSS and it failed criteria and the surveys were allowed to stand without remediation. Seems like the developers of the DQOs were not well versed in this process. Surely they didnt use the WRS if you did ya gets what ya wanted.  Also, sounds like the characterization was inadequate. Take for example ETTP, the whole project was based on 3 or 4 swipes and characterization of 1/100 of the structure.  The contractor that was assigned FSS did rather well in this case. The other contractor that belived what the client belived in lost cedibility and tons of money.  Aint that da truth Shonaktoys???

As for leaving a hot spot.. shame on the contractor..simple areas like a hot spot can be remediated and must be considered in DQO design.

As for challenging a regulator.. is that the voice of inexperience?  You correct regulators, you inform regulators, you educate regulators, you agree with regulators and you listen to regulators-never, never challenge regulators.. If you have to do that, your DQOs were poorly designed to begin with.. (low bid again)

[atomicarcheologist]

hmm I think the DQOs were inadequate if you completed the FSS and it failed criteria and the surveys were allowed to stand without remediation. Seems like the developers of the DQOs were not well versed in this process. Surely they didnt use the WRS if you did ya gets what ya wanted.  Also, sounds like the characterization was inadequate. Take for example ETTP, the whole project was based on 3 or 4 swipes and characterization of 1/100 of the structure.  The contractor that was assigned FSS did rather well in this case. The other contractor that belived what the client belived in lost cedibility and tons of money.  Aint that da truth Shonaktoys???

As for leaving a hot spot.. shame on the contractor..simple areas like a hot spot can be remediated and must be considered in DQO design.

As for challenging a regulator.. is that the voice of inexperience?  You correct regulators, you inform regulators, you educate regulators, you agree with regulators and you listen to regulators-never, never challenge regulators.. If you have to do that, your DQOs were poorly designed to begin with.. (low bid again)

Oh, my!  I thought I had provided enough information for you to play.  Obviously, not.  Let me paint a broader picture for those who are imagery challenged.
Those with whom I toil, took over this disaster at the end of the current phase.  The previous contractor had gone bankrupt and had to get remove all corporate ties to the site.  The bankruptcy details are extremely messy, but the kernal was that they had become spread too thin domestically what with power plants, DOE, DOD, and EPA sites, and got tied up with some things in the fledgling E.U.  Although that wasn't bad enough, they had some mega bribes to pay to get some of their people out of areas in the Middle East that will remain nameless in order to prevent this thread from being placed in the political forum areas of this website where only the wealthy and well connected may play.  Anyway, the work had been almost all completed, with only this final spot left.  The Project Manager, Mr. Yurra Peon, looked at the area in question (please refer to the origin so I don't bore those who read and remember) and called the RSO in to see what could be done.  The RSO, a Ms. Betta Raye, thought at first it could be removed.  However, to cover her derriere, she contacted the local structural engineer, a Mr. Iman Ibeem.  When he examined the area, he said it would have grave consequences to the building to continue removal operations any further.  By the way, did I mention that this is a National Historic Landmark?  I'm sorry, it didn't seem necessary at the time.  I hope I have now given enough information.

RE: the NRC representative challenge.  Perhaps I miswrote.  I meant that I would engage him in conversation directed to his consideration of future farming in the region and whether he would let his family and their families dine on the consumables produced there.

[Shonkatoys]

AlphaDude you were right!! They are going to need a new rad engineer at ETTP, you need to ask them to come back so you can gloth!!

Now back to Hormesis, I checked out the Quack Cures Renhack posted a few posts up,  The Gram Maze Uranium Comforter, Just a few micro R an hour over back ground probably not enough over background for hormetic effect. need to Jam some more uranium in it to crank the comforter to 100 Micro R an hour or more. Maybe we can have volunteers to try different dosages for the comforter to see which is most hormetic. But how to wash this?

The Radium Suppositories in quack cures looked like the 1930's Viagra and states so>  Wait honey While I Put My Special Medicine in .  I wonder if you have to wait until they are fully melted and what happens when you put in 2?

[alphadude]

Shonka toys- put some mama carmen sauce on that thang and it will spit in yer eye!   

[halflifer]

Why, I believe that concept would enter into this via "averaging".

but how do you average something that doesn't exist?

[atomicarcheologist]

but how do you average something that doesn't exist?

Welcome to the world of statistics and analysis.  The concept of "-dpm's" does exist.  After all, you measured it, correct?  Simply because a value is less than the background value, doesn't mean it doesn't exist.  It simply means that it is a different value.  Let me explain it this way.  When you run a background for an instrument that will be used in a survey which will be of a reportable nature, ala Final Status Survey, it is customary to run a background count time of ten times the time to be used for the counting during the survey, then average for a one minute count rate to be recorded as "background".  Since survey counts are of a one minute duration, therefore the background count rate is to be run for ten minutes.  During that ten minute span, there are ten one minute segments which integrate during the time frame.  If you were to separate the segments and look at the individual counts, you would notice they do not equal the background count rate, some would be greater than and others less.  So if during your survey you wind up with a count rate that is less than the background count rate used for the day, it is a normal counting function for that instrument.  You must record this count rate in order to maintain statistical accuracy of the survey.  Using "less than background", "zero dpm", "below detectable limits" all throw the survey into question. 

[atomicarcheologist]

I'm sorry that I haven't been out to play for a couple of days.  The phone's been busy and soon I will be too. 

For the guys at the Cingo de Madre Day; you were right and the checks' are in the mail.  I've got to go, see you on the other side of Piratininga Lake.

[Shonkatoys]

Atomic Archeologist, good answers to the questions.  In the troop over run scenario, I think I was a little harsh.  I believe I would give a coded strikewarn message that the  nuke is coming in 90 minutes. The troops can set up hasty mine fields to slow down the bad guys, while they high tail it out of there.  After the first nuke, I would use some mini nukes to mop up any chasers!! LOL if any!!!

[SloGlo]

Younz havta prove that tha place won't ever be used for agriculture.  Try ta get a regulator to sign off on dat.

"younz?"  eye gotta getta pronunseeation guide to you!  yinz're starting to loose yer grip on proper ainglish.  i'll git ina snail this weekenn.  yinz expats phrum da burgh knead two be brought back too earth every now 'n then.

bttt (back to the thread).... iffen eyem ina middle of a freaken city, why do i gotta prove it won't be used fer agriculture?  eye mean, it'd be easy, just bring ina remax rep 'n have him splain the cost differential of land fer farming 'n land fer occupancy.  butt why don't they just realize where ya are 'n what ya got 'n let it go?

[raymcginnis]

This is how we did it the olden days.

http://www.radprocalculator.com/images/PREREMED.jpg

http://www.radprocalculator.com/images/POSTREM.jpg

[halflifer]

Welcome to the world of statistics and analysis.  The concept of "-dpm's" does exist.  After all, you measured it, correct?  Simply because a value is less than the background value, doesn't mean it doesn't exist.  It simply means that it is a different value.  Let me explain it this way.  When you run a background for an instrument that will be used in a survey which will be of a reportable nature, ala Final Status Survey, it is customary to run a background count time of ten times the time to be used for the counting during the survey, then average for a one minute count rate to be recorded as "background".  Since survey counts are of a one minute duration, therefore the background count rate is to be run for ten minutes.  During that ten minute span, there are ten one minute segments which integrate during the time frame.  If you were to separate the segments and look at the individual counts, you would notice they do not equal the background count rate, some would be greater than and others less.  So if during your survey you wind up with a count rate that is less than the background count rate used for the day, it is a normal counting function for that instrument.  You must record this count rate in order to maintain statistical accuracy of the survey.  Using "less than background", "zero dpm", "below detectable limits" all throw the survey into question. 

good answer, but that's not the way they had us do it. a bkg was 'assigned' to the instruments (all the instruments of the same model) based on the material (steel, concrete, transite walls, etc.). this did not change on a day to day basis....in fact, the only time it changed was in the middle of the project when they changed all of the instrument eff.'s but didn't change the backgrounds....the net result being an increase in the activity 'assigned' to 'background'.  we were told by the largedollarpeopleintheairconditionedtrailer that the backgrounds were based on the amount of NORM  that is present in the building material (the NORM norm?), which seemed to change in the middle of the project  .    I disagree with your contention that conventional practice of using the MDA value for those counts showing less than MDA (or <Bkg) would reduce the statistical validity of the survey. In fact, entering values that you cannot possibly measure with accuracy, or which don't really exist (such as - dpm's) artificially biases the evaluation to the low side.

[alphadude]

great reply, when you are in those regions of "below bkg or less than mda" using those values will ad "mush" to statistical values-mda should be used or bkg. only those values have been researched, reported, and are valid. the use of non-valid numbers is not a practice that should be applied to a stat analysis.  we have used the two sigma rule for positive indications to off set some of this mush region numbers- when values are near the reported mdc and greater than 2 sigma-will use those values as a positive bias however slight. (its part of informing the regulator that we are the good guys.) we know there is something there, maybe.

make sure you have a lab with valid and sound techniques,

[raymcginnis]

This is the best thread that I have ever been a party to.  I'm glad that it is still alive.  I can feel everyone's pain on this subject.  I just have one question.  If natural soil and cosmic radiation are above e-6 risk levels, before man intervened, how is it possible to clean up a site to below e-6 levels?  I think that it is impossible! 

I suppose if you spent millions of dollars and had your lab count each sample for months, it could be achieved.

But that goes against the ALARA princple.  The people in Southern California need to focus on the smog that they are breathing, not the tiny amount of radioactivity that is miles away from them anyway.

I have done the calculations to prove that if you built a house here, planted tomatoes, built a pond, ate fish from the pond, you would be at higher risk just from driving you car to buy new seed than you would from living on a former radioactive site.

The protestors, who have no idea how to calculate this risk, have a greater voice than is deserverd.  That is my two cents for today.  Keep this thread spinning.  I love all of your input!  This is a fun subject!

I am a happy participant!

[alphadude]

I guess thats when WRS comes in handy

[raymcginnis]

alphadude,

Yes WRS does come in handy, but the statistical data from the few samples that you put through WRS still are dependant on your 100% scan.  If you can't meet the scan MDC for your 100% scan survey, because of your natural background, you have trouble.  We have natural thorium in the rocks here.  It causes headaches. 

There is no way for us to prove e-6 levels here because of that.  That is why we use ALARA and try to demonstrate that we try to get it all.  We really do that.

[SloGlo]

In fact, entering values that you cannot possibly measure with accuracy, or which don't really exist (such as - dpm's) artificially biases the evaluation to the low side.

'n yz think dat giving a false numerical value doesn't artificially biase the evaluation to the high side?  yinz had better show da math on dis won!

[halflifer]

'n yz think dat giving a false numerical value doesn't artificially biase the evaluation to the high side?  yinz had better show da math on dis won!

Any 'false numerical value' will artificially bias the data, but using MDA when your results indicate <MDA is not 'false.' It is the most statistically valid number you can use under the circumstances. Also, it seems to me that when evaluating any health hazard it's better to bias high than low.
When we were told to use -dpm's I posed the question "If a D is the movement of an unstable nucleus toward a stable state, wouldn't a negative D be the movement of a nucleus toward a more unstable, or radioactive, state?"
They said "shut up and do it."

[RDTroja]

Any 'false numerical value' will artificially bias the data, but using MDA when your results indicate <MDA is not 'false.' It is the most statistically valid number you can use under the circumstances. Also, it seems to me that when evaluating any health hazard it's better to bias high than low.
When we were told to use -dpm's I posed the question "If a D is the movement of an unstable nucleus toward a stable state, wouldn't a negative D be the movement of a nucleus toward a more unstable, or radioactive, state?"
They said "shut up and do it."

The major flaw in statistical analyses is that they are good for predicting probability and behavior in large samples, but are woefully inadequate in predicting (or measuring) individual events. All you can get from statistics is a prediction of what may happen and a confidence level that the prediction will be right. When you try to apply the science to an individual event or even a small sample, you can get unpredictable or even misleading information. Negative dpms certainly do not exist in the real world and reporting them as results should bring a great deal of doubt upon the reporter's reliability (and perhaps sanity). Including the numbers derived from such samples when using the results to predict future events is valid. BUT... when you are using the information from such counts you have to include them before subtracting background and negative numbers should never be converted from counts to dpm. If you do the conversion, you are in effect validating the counting machine's operating parameters using data that is beyond the machine's ability to accurately measure given the sampling method. Counts below average background are important in establishing the measuring and counting statistics, but not in reporting data.

If we could eliminate background the real meaning of '<MDA' (actually MDC or MDCR would be more accurate because conversion should not take place in the absence of measurable data) would be 'statistically insignificant'. Even if we could develop a perfect shield where the true background was zero, we would still have to deal with the statistical reliability of the random nature of radioactive decay and the physical limitations of the counting system to get our confidence level in our measurements. Throwing background in is what mucks up the works (technical term) and makes us consider such things as negative dpms.

If we could just figure out how to move those isotopes to a less stable state and achieve the corresponding absorption of the normally emitted radiation, maybe we would have that perfect shield. But until then '<MDA' is the best we have and the only time that anything less should be used is in performing or validating the statistical analysis that gets us to what MDA is in the first place. Then we could start using 'statisticaly insignificant'... not much of an improvement.

[SloGlo]

Any 'false numerical value' will artificially bias the data, but using MDA when your results indicate <MDA is not 'false.' It is the most statistically valid number you can use under the circumstances. Also, it seems to me that when evaluating any health hazard it's better to bias high than low.
When we were told to use -dpm's I posed the question "If a D is the movement of an unstable nucleus toward a stable state, wouldn't a negative D be the movement of a nucleus toward a more unstable, or radioactive, state?"
They said "shut up and do it."

i feel yer pain.... once when i wuz ona dirt job, 'n wuz dune the same operation but with a  micro are meter, i axed the chp ona job iffen dune negative numberz wit a count rate instrument would be permissible also.  he said sure.  sew i axed iffen converting inta picocuries would be da next step.  he said sure, again.  sew i axed him iffen ya decay negative curies ain't ya growing isotopes?  he told me to get da hail outta da trailer 'n git back to work!
bttt, jist remember, skewed iz skued, iz schewed!  iffen ya figger that <mda is more preferential to recording a negative value, why don't you consider that recording a high value is less preferential than a less high one?  p'rhaps ya should count each data spot 10 times 'n record an average.  that way yer results would be even mostest best, right?  a value <bkg is no less valid than one that is >bkg, it's just value for that spot at that point in time.  if you take multiple readings on the same spot, you will get multiple results.  which are most valid?  'n remember, that great tool of using 2 sigma, only insures that you will be "correct" 95% offa time.  but to get that amount of "correctness" in yer data, ya gotta spread the values twice as far.  sorta like calling yerself a sharpshooter 'cause ya pulled the lanyard on the atomic canyon, ain't it?

[Aitch-Pee]

What's clean now is different than it was twenty or thirty years ago.  Clean gets cleaner as technology gets better and better.  Less than 2 (that's mr/hr) was clean at some environmental joints back in the 70's.  Now we get to go back and clean it up again because the rules changed.  Bad for the company, good for Aitch-Pee, and good for the new cleaning companies.  Isn't technology grand?

As for what's clean in 2005.  Well, you couldn't have asked a muddier question.  There is no possible correct answer that everyone would agree on.  I tend to think that if there is any consistently positive indication of activity holding the basic probes up to the object, then it must not be clean.  Course then there's tritium - let's not go there.

Now you don't really think it's possible to answer this question, do you?  If you do - just stick around for a while and get back with me in a couple of decades.  The answer might be different then than it is now - especially if anything weird happens to bump up the background - like a "nucular" burst.

[alphadude]

which brings us full circle- any found is a pollution indicator. the world is polluted by nuclear technology- fall out from weapons is readily detected in game and hunters, chernobly spread a nice wide band over the southern US, SNAP reactor and Russian reactor burn up in the atmosphere makes plut some what easy to find.  Now, what is the risk.. that is the question that should be asked. 25 mr/yr is a good number, 10 mr/yr is politically correct.   nuff said?

[atomicarcheologist]

which brings us full circle- any found is a pollution indicator. the world is polluted by nuclear technology- fall out from weapons is readily detected in game and hunters, chernobly spread a nice wide band over the southern US, SNAP reactor and Russian reactor burn up in the atmosphere makes plut some what easy to find.  Now, what is the risk.. that is the question that should be asked. 25 mr/yr is a good number, 10 mr/yr is politically correct.   nuff said?

This is an interesting hang-up of yours, pollution.  Using Webster's New Third International Dictionary, one finds the #1 definition as "emission of semen than at other times than in coition."  An interesting picture that you paint.  However, since radiation has been present on the face of the planet for as long as you care to measure, I am unsure of the relationship.

But I digress, this doesn't bring us full circle.  Maybe it brings us full spiral.  This thread intitiated a discussion designed to elicit discussion of releases of areas based on nuclide data.  That goal has not been gained.  I, personally, have lost interest in the thread as it has run away off course.  However, since there are so many who like this thread I am in favor of it's maintenance for the conversation and postings that have been and will be done.  However, please do not hijack this as another subject.  If you wish to start a thread on nuclear "pollution" I am sure that others will be willing to go to it.

RE: the issue of "negative dpm", this is a moot point.  When performing a survey that will be recorded as permanent, i.e. a Final Status Survey, do it in a manner that is statistically, technically, and politically correct.  Do not convert your data to dpm.  Record it as cpm along with the other pertinent items needed for the conversion such as meter/probe type, serial numbers, CDD, BKG, etc.  In this manner you will remove yourself from a possible discussion of this nature.  Anyone who wishes the dpm value can simply do the conversion themselves and, if they have your data in an easily manipulated program such as Excel, will be able to do it quicker and more accurately than you are able while in the field.  Besides, dpm is such a bogus venue.  Maintaining the data in curies (pCi for the lower ranges of contamination) is much more sensible as you are able to calculate different radiological scenarios rapidly such as; going from surface contamination to potential airborne contamination during different work levels, taking liquid concentrations and figuring out what's on the floor and in the air after you dump the drum, anticipating the dose rate in a room based on the concentration in the tank, etc.  Ooops, there I go, falling into the digression ditch again.  Leave the data in counts.

[raymcginnis]

This is still a very interesting poser to me.  I like what Mr. Troja said.  I think that he hit the nail on the head!

It is all about what you know about background, but more than that, it is all about what you can prove about background, whether it be natural or from fallout.  You all have good answers and I have enjoyed this thread.  I just cannot sort out the experienced nuke workers from the anti nukes, who are also allowed access to this site.

Yes, negative numbers can be hard to sell to some protestors, but they are statistically significant and should be used, in my opinion.

If 90% of your numbers are less than zero, before subtracting background how could that be a negative thing?

If everyone wants to release sites to ALARA or as previously posted, ALARTRA, is there some complaint here that I am missing?

The only thing missing on this thread is real science.  I have not seen any math opinions.   All I have seen is emotional or intellectual opinion.  I have no math to offer you today.  All I have to offer is what I know from 28 years of crawling in the belly of nuclear facilities.

I disagree with most of the dissenters of this topic.  I also agree with most of the agreerers! 

[alphadude]

well, pollution indicators are for most of us the way we make a living, including you atomic.  The any I speak of is Cs-137, Pu, Sr90 etc. which are pollution indicators readily found in most of the world. Not allowing for the deed of Onan which you hold dear to your heart, these indicators are signs of invertention by man-yadda yadda.  ( I guess you missed the connection: -bkg-pollutants Sr90, Cs137, KUT, assessment, what is clean. Its all about the same thing!-a mutlifaceted subject)

Clean is a non-polluted area. no man made indicators present!  Acceptable is another thing.. maybe that should be the guestion..How Hot is acceptable! as stated "how hot is clean" is somewhat perjoritive.

Well, why discuss DQOs here Ray, this is old stuff for us which we hack out every day using a set of risk based rules. Using negative numbers with lay people is not a good idea! However, we do use negatives when we look at reliance issues, prepare reports for geeks etc. but all of you know this. 

Look at the work of Shonka for bkg assessment if your interested in numbers. Those guys love the pure science-whereas, we apply it all and make a living out of risk management.

Background assessment.. something near and dear to my heart.(KUT is bkg-the rest we have to deal with!) Proving background is fun stuff. What we see is that in different "cultures" we have varying acceptance of what is actually background. What is background to a powerplant type is usually not acceptable to a D&D type so on. (its all about detection) Both perceptions work!  But who cares its all fun.

And Ray why would you care who is anti-nuke as long as the logic is sound.   

[alphadude]

I looked back at your first posting atomic.. here is your answer. you can leave what the regulators say you can.  its that simple.

[RDTroja]

...Sorry you have AADD.

Please keep the personal insults out of this and don't make us edit your postings.

[alphadude]

Edited because modertors rule.

[RDTroja]

Edited because modertors rule.

Actually that should read "Edited because I didn't follow the rules." But you may believe whatever you like.

[atomicarcheologist]

well, pollution indicators are for most of us the way we make a living, including you atomic.
 

I learn something new every day.  Unfortunately, this is not today's lesson.  Since I first learned to spell HP until the present, I have always labored under the impression that I earned my living, at least a part of it, from dealing with contamination.  However, to be fair, I looked at some references to ensure that I was not on the incorrect page of the HP almanac regarding this issue.  I journeyed through this site, but was unable to locate Moe.  "Darn", says I and proceeded to some other sources.  I checked in;

Basic Radiation Protection Technology 3rd Edition
      Daniel A. Gollnick PhD, Certified Comprehensive Health Physics ABHP

but was unable to find a definition of pollution there that would be agreeable to this discussion.  To be fair, Dr. Dan doesn't have a definition of contamination either, nor any other word.  "Double Darn", and onto the last great resource at hand;

The Health Physics and Radiological Health Handbook  Revised Edition
      Edited by Bernard Shleien, Pharm. D. Certified Health Physicist, ABHP FBPHA

but was unable to find pollution defined therein either!  However, there hidden under the letter "C" was the word I was seeking, "contatimation" and written thusly. 

Contamination- The deposition of unwanted radioactive material on the
surfaces of structures, areas, objects, or personnel.

I feel so relieved. renewed, and resourced that I feel I should go and partake of the events occurring during Thirsty Thursday.  But not to fear, I will not overindulge.  I do not want to ruin my reputation as a surveyor of radioactivity.

[halflifer]

From the Random House Webster's Dictionary 2nd Edition:
"pollute: to make foul or unclean, esp with harmful chemical or waste products; contaminate"
it's just a pocket dictionary and doesn't have a specific deffinition for 'pollution' but I don't think it's too much of a leap of faith to equate 'radioactive contamination' and 'radioactive pollution.'

[alphadude]

come on guys dont be so narrow scoped. as scientists and engineers we are trained to view the total risk of what we do, pollution indicators typically describe "man made stuff that has left the building." Man made rad materials are CERCLA listed and have RQs and are therefore deemed by law as harmful pollutants or hazardous substances.  the dictionary I use (American Heritage) provides one definition as "the contamination of soil, water or the atmosphere by the discharge of harmful substances." 

clean does not equate to hot in any degree. its either contaminated or its not. 0.1 pCi/g of Sr90 in soil indicates contamination (pollution indicator). now the risk is another story! (1.6 mr/yr)

[Rennhack]

I journeyed through this site, but was unable to locate Moe.  "Darn", says I.

Study Tab >> HP/RP/RCT Study >> Moe Handbook (Operational Health Physics Training By H.J. Moe)

[raymcginnis]

I hope that I was not one of the insulters.  I sure did not mean to be.  This has been an enjoyable and educational thread for me.  I have learned from everyone's posts.

I would personally build a house and grow tomatoes on 15 mRem/year.  I am sure that we probably go down to less than 1.6 mRem/year or e-6 levels at our site, but it gets quite expensive and tedious to prove that.

That is why we know that we can prove that we are well below our procedural limit of 15 mRem.year. 

How far below are we?  If you want an exact number, get ready for a tax increase.  If you will settle for ALARA or ALATRA then I think that I can reasonably convince you that there is nothing detectable left.

It still does not seem reasonable to me to count samples for 5 days just to prove the risk levels are where others want them to be.

Keep the ideas flowing and thank you all for jumping in on this subject.  It is educational for me and it is helping with my work.  Nukeworker rocks!

[radgal]

I've recommended this thread to the other HP Techs I work with.  Very informative and thought provoking.  Great thread Ray!

[SloGlo]

come on guys dont be so narrow scoped. as scientists and engineers we are trained to view the total risk of what we do, pollution indicators typically describe "man made stuff that has left the building." Man made rad materials are CERCLA listed and have RQs and are therefore deemed by law as harmful pollutants or hazardous substances.  the dictionary I use (American Heritage) provides one definition as "the contamination of soil, water or the atmosphere by the discharge of harmful substances." 

clean does not equate to hot in any degree. its either contaminated or its not. 0.1 pCi/g of Sr90 in soil indicates contamination (pollution indicator). now the risk is another story! (1.6 mr/yr)

kewlness!  when i'm at yer site eye kin call any contamination outside the buildings as pollution!  yinz got postings fer dat?  dew they caution against radioactive pollution or nuclear pollution, 'n dew they use the werdz caution err danger?  imagine wut the local tv station's gonna say at 5 pm about the pollution leaving the station, cause after all from wut yer posting here, iffen itz manmade 'n leaveen da building, itz pollution!

[Shonkatoys]

If you look at the JPG to the left very carefully you will see were some drums were sitting. These are white and orange rings with other contamination left over from drums in this area.  This is Hot!!! The Black areas are clean!!!! How hot is clean, The black areas are less than 5000 dpm 100 cm2 and therefore clean!!  IT is probably hot where these drums are at!!!  LOL  What great HPs these were!!!:'( [Hey did someone frisk these drums?   Its OK (Put in favorite dirt ball)I say!!!]

[SloGlo]

If you look at the JPG to the left very carefully you will see were some drums were sitting. These are white and orange rings with other contamination left over from drums in this area.  This is Hot!!! The Black areas are clean!!!! How hot is clean, The black areas are less than 5000 dpm 100 cm2 and therefore clean!!  IT is probably hot where these drums are at!!!  LOL  What great HPs these were!!!:'( [Hey did someone frisk these drums?   Its OK (Put in favorite dirt ball)I say!!!]

sew's iz dat 5k total or didn'tja take alphies inta consideration?   what's yer extrapolation fer an avg/sq meter?  is dis pic digital, photofilm, infared?  didja ever try to lightly spritz with water 'n take a timed exposure?  dat kin get very kewl.  btw, i dawn't see no nuclear pollution posting there...

[raymcginnis]

If I may jump in again, The risk levels of living in smog are way above the risk levels that are trying to be imposed upon us.  The tax dollars would be way better spent on making hydrogen fuel cells cheaper, rather than making radiation sites go to e-6 levels.  That is my opinion.  The Native Americans called where I live, the "Land of Smoke" in the olden days, because of wildfires.  Now it is the land of smoke because of automobiles.  Nobody is complaining about them now.  Everyone drives one.  Most people now complain about nuclear technology.  This battle baffles me from time to time.  Natural uranium on the Colorado plateau far exceeds e-6.  Smog in Denver and in LA far exceed those risk levels also.

If we can all agree on this, I will become a musician or a photographer again.  I don't need a nuclear job that bad, LOL!

[alphadude]

true true true ray.... but we make a living out of chaos....

[alphadude]

well pollution indicators designate a scope beyond nuclear power plant mind set, so i can see the resistants to a total risk method. But CERCLA listed items they is..
Oh yea, NPDES lists rad materials too...hmmmm wonder why???

no slo go the news only took pictures of the 5 mr/hr blocks and the pit dug in the guys yard down the road. what do they know!  I guess the give away was the rad materials sign and ribbon they found from the plant that was burried 6 feet down.

[atomicarcheologist]

well pollution indicators designate a scope beyond nuclear power plant mind set, so i can see the resistants to a total risk method. But CERCLA listed items they is..
Oh yea, NPDES lists rad materials too...hmmmm wonder why???

no slo go the news only took pictures of the 5 mr/hr blocks and the pit dug in the guys yard down the road. what do they know!  I guess the give away was the rad materials sign and ribbon they found from the plant that was burried 6 feet down.

I see that you insist on playing with only your own toys.  It's a good thing for this thread that my mother taught me to get along with playmates and not stamp my feet and insist that things go my way.
Thursday evening while partaking of Thirsty Thursday activities, I engaged some young engineering types of various disciplines in this discussion of pollution.  After beating it around in several venues we finally agreed on a definition that:
to pollute (in the non-carnal mode) was to introduce material into an environment in a quantity the would be detrimental.
We finally came to this after much lively discussion with plenty of insults for opposing viewpoints and occupations.  What a fun evening.  It was to a point where a non-participant tried to interject a viewpoint and was told that, after all, asbestos was a naturally occurring mineral and he should go snort a pile.  What a hoot, coming from a small slip of a female hydrogeologist.
  Isn't the NIOSH exposure limit for cobalt 0.05 mg/m3 ? Uranium exposure limit of 0.2 mg/m3 ?  Iodine limit of 0.1ppm (1 mg/m3 )? Cesium 2 mg/m3 ) ?  Not to mention beryllium ( 0.002 mg/m3 ) .
How does the NPDES AND CERCLA listed values differ from those of the NRC and other regulatory agencies that utilize the CFR?
Doesn't the Clean Air Act permit to exempt area sources if the EPA is able to determine that complying with the requirements is impracticable, infeasible or unnecessarily burdensome for the facilities?
It's been awhile since I had a nuclear power plant mind set.  Even when I did earn the majority of my annual income from the power plants I maintained active contacts and did work in environmental, remediation, D&D, and assorted other activities on property of private and various governmental concerns.  Thank you for your concern RE: my reistants (sic), but I do not see the need.

[alphadude]

CERCLA is a list provided by an agency, and NPDES is an agency program. Metal toxicity is typically not associated with rad with the exceptions of the Uranium family and maybe some other nasty items.  In D&D, pollution indicators for rad are called "plant impact" and tie into MARSSIM, but its still an indicator of a pollutant.

NPDES is the National Pollution Discharge Ellimination System- which lists rad materials as pollutants.  Some how the water is getting very muddy here.

HOW HOT is ACCEPTABLE?? that is the question...

[atomicarcheologist]

Alpha dude,
How hot is acceptable (red faced emphatic volume deleted)?  If that's the way I have to ask a question to get an answer, so be it.  I am getting exhausted asking and asking and asking on this thread.  I mean, when others have asked their questions and posed their scenarios, I have answered, have I not?  I started out asking 'how much', and anticipating numerical replies.  I then went with asking 'how about 100Kdpm/100cm2 co60 & 150K U238' which I downgraded the Co60 to 50K in response to a post.  Then I posed a scenario with 50000dpm/100cm2 fixed contamination of Co60 in an area that was 100cm2 and sited 1 meter above the floor.  However, the replies have not directly addressed the questions.  So, I am left with the feeling that many do not have answers, and those that do are reluctant to post them for fear of retribution.  However, if "acceptable" is preferable to "clean", then so be it.

[thenukeman]

The Knoxville Sentinel had on the front page that Bechtel Jacobs had about 100 Alpha instruments that they do not know how long they were not working.  So how hot is clean.  Hmmm it depends on what meter you were using, and if you  know if it was working or not.

[atomicarcheologist]

The Knoxville Sentinel had on the front page that Bechtel Jacobs had about 100 Alpha instruments that they do not know how long they were not working.  So how hot is clean.  Hmmm it depends on what meter you were using, and if you  know if it was working or not.

Well, yes.  I thought we were working professionals here, not media reporters.

[alphadude]

well archy, its too hard to explain how we do our jobs here in a few paragraphs.  it takes some of us days, weeks, months to determine what dose a few thousand dpm of some nuclide will deliver over a 1, 10, 25 year period.  You will never get a cut and dried answer... perhaps this thread has been pulled to the limit.

Looking at the replys they are all good and in the applied situation-acceptable.  As for us giving some universal number that will be used to make lite conversation over a few brews... aint gonna happen. 

ray, shonkatoys, myself and others told how it is! its not a black and white thumb rule situation!!!  (cha-ching.. thats why we make the big dollars$$$$)

read "Decomissioning Health Physics," Ablequist, and most of your concerns will be answered.

[raymcginnis]

Yes, as I expected, every site is different.  MARSSIM left that flexibility just as the founding Fathers left the flexibilities in the Federal laws.  The most important things in government are left up to local areas.  State and County and City laws are left up to how people in the area feel about it.  This is one of the wise provisions of MARSSIM.  It is only guidance.  If your federal regulators expect you to go by MARSSIM explicitly, then you have to negotiate with you State regulators.  If you can get them to agree that you plan is the best, the Feds may back off.

This is very complicated subject.  Most States have adopted MARSSIM, because it is easier on them.  Local opinion is another thing.  When you look at risk, ask yourself, would I live here?  If not then maybe you need to look at this.  If you are the only one out of 200 people on the release crew who answers no, it is time to move somewhere else.

We all have to remember background.  There is potassium at high levels (1460 keV), natural uranium. Natural thorium and Cs-137 fallout (~0.1 pCi/g) in our area. 

What are we talking about here?  How many lives will be saved by going below 15 mRem/year?  I say it is all math tricks and not reality.

2 lives per year over five years cannot be measured.   This is all smoke and mirrors by protestors.

We are all going to the other side of life, that I can guarantee.  Nobody lives forever.  People who are recalculating these measurements, good luck!  You will never get the calculations perfect because there is a higher power than you, whether you believe it or not.  I think that Humans will never be able to predict the number of deaths from any sort of pollution, much less, nuclear pollution, with natural background.  There is no natural PCB background, so it is easy for labs to see whether it exists or not.  If there is a radiation detector that can see e-6 levels, cost effectively, tell me the name.  I'll take a look at it.

This link has a thumbs up for NukeWorker.  It is very popular, which is why I keep joining in.  Nah, actually, I'd join in anyway, because it is fun for me also.  This is a fun link!  I think about this every day!
We all have to remember background.  There is potassium at high gamma levels (1460 keV), natural uranium. natural thorium and Cs-137 fallout (~0.1 pCi/g) in our area. 

What are we talking about here?  How many lives will be saved by going below 15 mRem/year?  I say it is all math tricks and not reality.

2 lives per year over five years cannot be measured.   This is all smoke and mirrors by protestors.

We are all going to the other side of life, that I can guarantee.  Nobody lives forever.  People who are recalculating these measurements, good luck!  You will never get the calculations perfect because there is a higher power than you, whether you believe it or not.  I think that Humans will never be able to predict the number of deaths from any sort of pollution, much less, nuclear pollution, with natural background.  There is no natural PCB background, so it is easy for labs to see whether it exists or not.  If there is a radition detector that can see e-6 levels, cost effectivly, tell me the name.  I'll take a look at it.

This link has a thumbs up on Nukeworker.  It is very popular, which is why I keep joining in.  Nah, actually, I'd join in anyway, because it is fun for me also.  This is a fun link!  I think about this every day!

[Shonkatoys]

If you look at a cumulative frequency distribution from a modern instrument you will see that about half the readings will be below 0 if the material is not contaminated, or slightly contaminated. Anything above 15,000 dpm 100 cm2  or above is hot for certain isotopes, 14,999 is not.  A  cumulative frequency distribution can be viewed  by clicking the Nukeworker tool bar,  Pictures,  Then go to Nuke companies, then click Shonka.  We have actually fired someone by looking at this distribution and seeing the background was wrong. We checked that person in the field, Sure enough he was cheating, TOO BAD out the door.  You can't get this with 1940's technology that most people still use.

[Shonkatoys]

I enclosed another Cumulative Frequency Distribution I lovingly call your fired.  This can be viewed under pictures>Nuke Companies>Shonka.  This shows by the too many negative readings that there was a probability that this survey was falsified.  We eliminated the instrument and P10 because the shift before and after it was working.  We checked on the person doing the survey and found him falsifying data. so as  the words of Donald Trump say" Your Fired"  No other instrument I know does this.  Thats why I like negative readings,  If I have more than 50 percent readings below 0,   I  want to know why, Tech, P10, Instrument.  I need to find out.  There was a company this week that admitted that they had about 100 instruments that did not work for a undetermined amount of time.  Thats unfortunate.  With  a cumulative frequency distribution you should know  within a shift if any 1 instrument failed because you  have  this data  reviewed and thousands of readings  are taken.  So how hot is clean is depending on, instrument, company ethics, company competence, company willingness to allow poor employees to continue etc.  Does not necessarily have to do with the requlation.  Also How hot is clean has to do with the regulators who check on companies and their willingness to let them slide.  Or if they check them at all.

[raymcginnis]

I love this topic.  Sometimes people are discussing other frustrating issues, I think.  Shipping regulations and RESRAD are way far apart.  People get frustrated by both, so I can see how they can end up in the same discussion.

RESRAD is a tool for calculating safe amounts of residual radioactivity to leave on an abandoned site.  49CFR tell you how to ship radioactive things safely.  Sometimes we forget that there are new people reading our posts.  This is a good post and all opinions are valid, but new people may not know what we are discussing. 

I deal with both release and shipping on a daily basis.

Real release and risk is what you can convince your neighbors of.  If you have people sending out flyers convincing you neighbors that they are going to die if they buy property on your released land, you are in huge trouble.  Most Humans will accept the worst story as true. 

I have done nuclear technology for years.  I have a gamma spectrometer at my disposal.  We have to keep it cooled down over the weekend so it available on Monday.  Last year, I knew there were no ethics violations for using it on Saturday and Sunday.  I own property back east.  I took 6 soil samples from it and flew them here and analyzed them myself, with long time counts.  They indicated 0.05 to 0.2 pCi per gram Cs-137, all from global fallout from above ground nuclear testing.

After doing all of this research, my opinion has not changed.  I would live on 9 pCi/g, a typical farmer resident scenario.  E-6 wants me to take Cs-137 to 0.04 pCi/g or less, way below fallout levels at places way far away from nuclear sites. 

I cannot find the logic in that request.  If we require all nuclear sites to get rid of all of the pollution, then we need to spend the tax dollars to clean up the entire planet from global fallout.  That would mean we would have to move to the moon and bury the Earth on Mars.  That way everyone would be safe, right?

I stretched my point a bit to get a logical response. 

[alphadude]

Now Ray, we can only surmise that the Cs-137 is from fall out, unless your facility did not have any onsite or was not a test site. If you are a not at a cesium production facility-lucky you! 

We take it into account to be conservative and hint that it is fallout from the global pollution that nuclear weapons released and from Chernobly.  There are a few papers on Cs-137 levels but not a lot of good information on local levels... We conducted a local study and found up to 1.8 pCi/g Cs-137 in this latitude-offsite. Some reports indicate as high as 4 pCi/g in the western states downwind from the test site.  Sampling several collective mechanism we have found up to 3 pCi/g in our area. The levels you found sound like open land levels typical of a lot of areas in the us. Sr-90 is another one to look for. Its everywhere and follows K-40 somewhat.

[atomicarcheologist]

well archy, its too hard to explain how we do our jobs here in a few paragraphs.  it takes some of us days, weeks, months to determine what dose a few thousand dpm of some nuclide will deliver over a 1, 10, 25 year period... thats why we make the big dollars$$$$)

I appreciate the sourcing the alfalphie!  I know it takes a long time to figure out this type of information.  That wasn't the idea.  You seem to think I am trying to "rip off" information to use in a professional sense.  I am not. If I was, I wouldn't do it out in the open in front of everybody in the business.   If I needed to have a problem solved for me, I'd hire someone to do it alot faster than your estimate and I would pay them well.  Because, after all, it's the client who truely pays, isn't it?  The contractors only make the middle money and get the tax write offs.   In the meantime, I'll keep my miserable $XXK and do my own thing.  You keep your big bucks, you'll need them for all the headaches you self generate.

[atomicarcheologist]

seems to me it all "....depends on what your definition of is is....",.....

Are you running in '08?  You have my vote!

[atomicarcheologist]

If you look at a cumulative frequency distribution from a modern instrument you will see that about half the readings will be below 0 if the material is not contaminated, or slightly contaminated. Anything above 15,000 dpm 100 cm2  or above is hot for certain isotopes, 14,999 is not.  A  cumulative frequency distribution can be viewed  by clicking the Nukeworker tool bar,  Pictures,  Then go to Nuke companies, then click Shonka.  We have actually fired someone by looking at this distribution and seeing the background was wrong. We checked that person in the field, Sure enough he was cheating, TOO BAD out the door.  You can't get this with 1940's technology that most people still use.

I like your attitude to readings below 0, assuming that is a net 0 and not a gross zero.  The concept does give some techs conniptions!  That's a nice toy that you have there.  I never needed to do a statistical analysis to ascertain if a tech was cheating, radioing, or otherwise falsifing data.  Maybe I missed some.  But I doubt it.  It seems most times I have to settle techs down when they're surveying interiors as they keep wanting to ascribe high levels due to not accounting for geometries, such as in the corners with the levels rising from 2 or more surfaces emitting energy instead of the one they are measuring.  I will keep it in mind for the future though, right along side of your truck mount.  I've had that in my file for a few years now.

[atomicarcheologist]

Real release and risk is what you can convince your neighbors of. 

So, if I were trying to release with the scenario posted, I should buy out the neighbors, resell at a loss, and make up the difference with the "succesful termination" clause in the delicensing contract?

[raymcginnis]

No, this is not what I was trying to say.  All I am trying to say is that ALARA or ALARTRA was created for reason.  The key word is reasonable.  It is not reasonable to abandon the Earth because of global fallout. Yes I did not spend out of pocket money to determine Sr-90 levels, nor PU levels.  I did what I could do for free, that was gamma spec.  The Cs-137 told me what I wanted to know.  What else did I need to know?  The Cs-137 came from somewhere was there on my property.  Some want to say that maybe the global fallout did not happen.  It must have come from a close by nuclear facility. 

OK, I say prove it.  Global fallout is indeed global.  It fell everywhere. 

People want me to prove that a tiny amount of radiation will not harm people every day.  For those opposed I say prove that it does harm Humans.  All you have is speculation.  There is no computer program written that is near the quality of RESRAD (which proves the opposite), etc!

[alphadude]

Everybody knows an artist takes what he needs!!! 

Its Frankensteen not Frankenstien!

[stownsend]

This topic has been interesting reading for several weeks and actually has opened my eyes to the many variables associated with remediation.I have gained alot of respect for the people making the decisions on how far they want us to dig etc.My only hope is if this has been a continuos discussion since your celebration of Cinci De Mayo you call a taxi to get home safely.

[atomicarcheologist]

.My only hope is if this has been a continuos discussion since your celebration of Cinci De Mayo you call a taxi to get home safely.

First, we need a definition of "home".

[halflifer]

People want me to prove that a tiny amount of radiation will not harm people every day.  For those opposed I say prove that it does harm Humans.  All you have is speculation. 

and if you had said that in 1950 about asbestos, what would the results have been?

[alphadude]

As far as I know, I have never proved anything except that my results will equal this in mR/yr. I think that is pretty much standard fare in remediation... the risk is well known, then the  limits  are agreed too, and then we set out to prove or disprove that the limits are met.  Dont know of but one or two HPs that have proved such a thing and I aint one of them (I did get to meet Dr. Lapp one time!) Thats for the ICRP to deal with not me!  I dont get paid enuff to prove that.

Keep focused on the mission boys!

[SloGlo]

and if you had said that in 1950 about asbestos, what would the results have been?

bout the same as iffen ya say the sun's rays won't hurt ya when yer ina tanning salon!

[SloGlo]

IReal release and risk is what you can convince your neighbors of.  If you have people sending out flyers convincing you neighbors that they are going to die if they buy property on your released land, you are in huge trouble.  Most Humans will accept the worst story as true. 

That would mean we would have to move to the moon and bury the Earth on Mars.  That way everyone would be safe, right?

'k ray!  when ya convince everybuddy two moov two da moon, eye'll bye yer nay booring property, 'n we kin partay!

[halflifer]

bout the same as iffen ya say the sun's rays won't hurt ya when yer ina tanning salon!

gotta agree with ya, glo......the sun's rays won't hurt ya when yer ina tanning salon (or a koal myne, or on a SG platform) ya mite wana wach out fer d'bulbs tho'

[radgal]

Risk?  How about the 2 pack-a-day smoker who is afraid of nuclear energy due to "radiation".  They are shocked to learn they get more than me.  One worker would come to work and light up the PCM.  It ended up his basement was smoking hot (radon).  Plainfield Il had to go to Lake Michigan water the Ra was twice EPA limit for radium in the water supply.

[RAD-GHOST]

I believe it's more of a word game?

For Decades, the Industry has Operated under the philosophy of a Fail Safe Standard.

Today's Release Criteria, has converted it to Safely Failing!

One has to Wonder?  RG!   

[raymcginnis]

I started a new topic just about risk.  It is pretty cool new thread so far.  I wanted to put once last post on this one.  Rad-Gal, if you look at my new topic, your cigarette analogy plays right into my automobile analogy in my soap boxing on the initial post.

Rad Ghost, yes I can relate to your humor.  I once worked at a plant where the motto for the outage that we saw on what were then modern signs saying: "We shall not proceed in the face of uncertainty."  After a 3 month outage was into it's 12th month, we all knew that they should cut off the second half and just have it say "We shall not proceed."  Not that I was complaining, because I liked the job.  A job like that today would make everyone drool!

It was frustrating to setup a job and have it canceled because procedure steps were out of order.  They have fixed that all now and jobs are shorter.

My new post has people talking about the consequences of that.

I wanted to have people talk only about risks of residual radioactivity for remediation sites under MARRSIM, but there are intelligent remarks from people about the risks from working at operating nuclear facilities.

I know these risks, because I recently worked at one, and people were complaining!  I was OK, because I was yard dog, but people in the BRT were complaining.

I say let us all continue this on my new post and see what everyone says.  I like this site very much, but the subject can change very fast on a particular post, especially when it get emotionally hot. 

Check out the new thread, and let us go from there.  The old thread went a different direction from the original question, and for a person to have to dig through 7 pages of posts to try to figure out what the original question was about, is too much to ask.  The whole thing went into risk and what we all think about risk.  Engineers calculate risk and HP technicians take them every day and they try to protect everyone form those risks.

Let's all go there for risk posts. http://www.nukeworker.com/forum/index.php/topic,5707.0.html

For background issues, let's stay here.  For risk and RESRAD, let's use my new thread.

Just a suggestion from an IT/HP dude.

[SloGlo]

Risk?  How about the 2 pack-a-day smoker who is afraid of nuclear energy due to "radiation".  They are shocked to learn they get more than me.  One worker would come to work and light up the PCM.  It ended up his basement was smoking hot (radon).  Plainfield Il had to go to Lake Michigan water the Ra was twice EPA limit for radium in the water supply.

that's basically how the hole radon abatement biz got started.  an operator at limerick station got tired of setting off the pcm's after he got to work, so one day he went thru them on the way in...... the rest is history,

[Shonkatoys]

10 micro R an hour is clean in Denver, it is not in Oak Ridge.  5 micro R an hour is clean in Oak Ridge, it is not in Panama City Florida.

[RAD-GHOST]

The Key Word, " CHANGE "! 

My guess, the limits and levels associated with the current release protocol, will change dramatically and very soon!

If you established a release criteria of 10% of the current models, your probably still to high!

It wiull be interesting, RG!

[SloGlo]

If you established a release criteria of 10% of the current models, your probably still to high!

it just doesn't matter iffen they change the criteria tomorrow.  iffen it's clean 'n gone today, it's good to go!  period.  done deal.  'n yes, i too have worked sites that were cleaned before and not clean later.  the trick is to make it go away, far, far, away.  udderwise, it's like an upset cow..... it'll kick ya in yer dairyaire when ya think it's safe.

[alphadude]

i dont think you can sell your liability slo go.. out of sight dont really mean out of mind. 

[SloGlo]

i dont think you can sell your liability slo go.. out of sight dont really mean out of mind. 

so iffen the regulators buy off on the license 'n it is terminated, 'n i sell the property, i'm still liable?  i think i know what the donald would tell the engineers that negotiated with the regulators.... do yew?

[alphadude]

under nuke no you are not but a holding company is as well as the underwriter. for RCRA yep you are!

[SloGlo]

under nuke no you are not but a holding company is as well as the underwriter. for RCRA yep you are!

explain this, as you lost me.  when a license is terminated, and then the property is sold, then the criteria changes, who is liable?  the licensor?

[halflifer]

I'm not sure, but I think the 'cradle to grave' concept applies to nuclear material as well as all other contaminates (pollutants?)....you know the drill, once it's yours it's yours forever

[raymcginnis]

Right Halflifer, unless you are a government site and the contract gets sold to someone else.  Then the ball is in their court.  I know this from experience.  I am possibly in the middle of getting sold for the second time.

Who would have thunk that I would have lived this long, to see that happen, LOL?

[darkmatter]

Who would have thunk that I would have lived this long, to see that happen, LOL?

Owww.....I resemble that remark.

[halflifer]

wow!!! y'mean the government has one set of rules for themselves and another set for the rest of us? i find that sooooo hard to believe !!

[alphadude]

well nuke waste does have some release from liabilities, the sites collect a fund to handle the rad material in case of some leaking containments- take Barnwell for example they have a trench that has leaked but is being monitored.(one of the early trenches.) the sites do map where your waste goes. (wink, wink, nod, nod) However, if you have RCRA or related issues- its yours until your kids spend your last dime and you croak-then the kids get to deal with it. with rad the issues are corporate- with RCRA its personal.

oh, if you fail to disclose properly, all rules dont apply.

[MrHazmat]

Hey, I worked at Barnwell for over 16 years,
and I know where your waste is. 

[alphadude]

you are not the guy with the magic stick are ya?  he nailed us on a hic with some water and that stick... 

[MrHazmat]

No that was the DHEC rep, but I tell you that old country boy caught a bunch of people with that stick of his. You had to have an ear for it, and I NEVER saw him miss. He did not check every shipment, but when he did if he said water it was there.

[alphadude]

well maybe he was just following southern tradition  "poke it with a stick" 
when chem nuke was in power they spoke highly of his methods and his score.
have fun

[SloGlo]

I'm not sure, but I think the 'cradle to grave' concept applies to nuclear material as well as all other contaminates (pollutants?)....you know the drill, once it's yours it's yours forever

wail, hail!  iffen we're dealing with pollutants, then the brownfields that have been restored green and givn and/or sold to other parties which have installed playgrounds, parks, shopping malls, homes, industrial parks, 'n every other venue of contemporary society are in deep doo-doo!  'cause iffen the rules change, then the originators have gotta pony up, huh?  let me have your references on this, so's i kin git my lawsuits in order.

[alphadude]

confusion of issues slo go. brownfields are areas that are remediated and gone thru environmental restoration. we are talking about waste in the can here.

rule changes, if there is an identified hazard after the fact may be under consent orders, SWMUs, or special ruling. if the owner disclosed properly and the property changed hands legally, underwriters would be bear the burden of the liability- (banks, insurance, bonds etc.)

[SloGlo]

confusion of issues slo go. brownfields are areas that are remediated and gone thru environmental restoration. we are talking about waste in the can here.

rule changes, if there is an identified hazard after the fact may be under consent orders, SWMUs, or special ruling. if the owner disclosed properly and the property changed hands legally, underwriters would be bear the burden of the liability- (banks, insurance, bonds etc.)

yo, weight a minnit there, alphadude!  i ain't confusing anything that you haven't muddled up already.  you brought the pollution banner into this discussion.  i was talking about a finalized, remediated nuclear site, a yellow/majentafield.  i ain't talking bout no waste in no stinkin can!  i used a brownfield as an example that is similar in nature, although the contaminate is different.  p'rhaps yinz should go back 'n read my posts on 7/1/05 @ 14:24:18, 'n 7/1/05 @ 08:37:41. maybee it'll help ya.  in the meantime, ya got an answer, yet?  or ya just got more smoke to blow in front of yer mirrors?

[raymcginnis]

SloGlo,

I'm no lawyer, but I think you go a long way in relieving the burden of liability if you get a federally sponsored agency to do a confimatory survey and write a report agreeing with you findings.  We go further and have the State buy off on our releases also.  If your Federal Regulators buy off all confirmatory buy-offs and then publish the release in the Fedral Register, then I think your liability shrinks to almost nothing.  That is how we do it.

Under State law, we would still have to put a disclaimer that it was a former nuclear site on any real estate transaction.  That could limit your buyers and price, but once purchased, with the disclaimer, I don't think anyone would even get to court with a liability claim, unless they could prove that you and all of the government agencies intentionally lied about the release to falsely get it into the Federal Register.  That never happens, trust me.  It is like pulling teeth to get a facility officially released.  We have done it many times here though, over many years.  We are really close to finishing the whole site now.

Two of our other released sites are being sold to another company.  The ex-RA areas did not stop the sale.

We released both NRC and DOE regulated sites using this procedure, starting in the 1970's.

[RAD-GHOST]

What's good for today, isn't necessarily good for tomorrow!

Anybody remember the EPA rules of the 70's?  The ones that wipped out a ton of business owners and set the course of todays shell companies!  Of course it was legal to do business that way yesterday, but we changed our minds today!  Nobody can argue that the dumping practices of decades gone by, were completely out of control.  The prime factor was the responsibility assessed with what you dumped, or in our case what you leave behind!  Federal, State, or Local Agencies can give you a clean bill of health, but I don't believe a walk away will ever be guaranteed! 

I recall a remediation project, I worked outside of the nuclear field, metals contamination.  They also received a clean bill of health for the site.  The final release was granted in the late 70's.  Some Idiot, supported by the city officials, decided it would be a great location for a low cost housing project!  Everything was great, for years, until a number of individuals started to contract strange symptoms.  That action took place in the mid 90's and the company is still married to the site, at a huge annual cost!  Funny, all the official who supported the housing venture have long gone.  All the new officials are standing out front, pointing their fingers! 

The companies view, " You said it was fine yesterday"!  The Officials view point, " It ain't yesterday"!

In the D&D industry, everything seems to be maintaining itself under the rules of statistics.  I just hope someone has calculated the little Billy factor into the equation!  Once little Billy arrives at the house, with a chunk of DU, Strontium, or Cesium in his hand, all previous rules are VOID!

RG

[alphadude]

mixed terminology does muddy the water-brownfields are not a nuke related- cradle to grave concepts follow container waste methods- rad materials are listed as pollutants under EPA-hence the RQ list.

as i said and it seems to be confrimed by further verbage- disclosure-is the key, any future situation resulting from improper disclosure would bring the burden on the underwriters, and previous owner-no matter what. The reduction in risk as discussed does become a fact when we clean up to the 10-6 uci, ppm, ppb etc.  since the state or some agency says the area is at an acceptable risk level (notice I did not say clean) they also share the burden. if you sell and disclose properly-you are free!! unless the site becomes cercla in some future time. (PRP list) then you have to prove innocent.

No smoke nor mirrors, just 32 years of dealing with epa, AEC, NRC, state and federal agencies and teaching environmental law for a few years.   


no where does anything say you are suit free... but thats another issue.

All this is being tested at Rocky Flats-

[SloGlo]

mixed terminology does muddy the water-brownfields are not a nuke related-

 if you sell and disclose properly-you are free!!

No smoke nor mirrors, just 32 years of dealing with epa, AEC, NRC, state and federal agencies and teaching environmental law for a few years.   

part one... sew sorry yinz don't understand allegorical speech.

part two... thanks for finally answering the question.

part three... eye knew there was sum lawyering in yer bkg watt with the way ya dance around every question 'n insist ya answered it.

[raymcginnis]

Holy cow, this topic is still going.  I am not surprised.  I hoped that my "Radiation Risk" topic would have diverted this topic to the new topic.   OK, everyone is still posting about "How Hot Is Clean?"  I will jump in again.

"How Hot is Clean" depends on the citizens of your State, in the USA, if you read your State's constitution and laws (as well as USA laws. especially DOT laws).

That is the one thing that is left up to you, in your local area.  Whatever radiation that you have is in control by you (and your local laws)!  You can bury, but FedEx shipping has to be done under the new International rules for sure!

There is no way of getting around that.  We trudge though these rules every day.  Anyone interested in my story on this, contact me at: calculator@nukeworker.com

Gosh!  I just told my favorite environmentalist joke to a company person who had way more power than me.

I told him that I heard about the environmentalist that died in his hometown of Seattle.  "He had a heart attach when he saw a Spotted Owl eating a Pacific Salmon."  Now come on, that is funny!

[SloGlo]

I told him that I heard about the environmentalist that died in his hometown of Seattle.  "He had a heart attach when he saw a Spotted Owl eating a Pacific Salmon."  Now come on, that is funny!

but da coroner ruled he had an excessive uptake of iodine, ruling that it must have been the releases from the nuke subs ina harbor, ignoring alla salt on da environmentalist's dining table. karma to ya ray.

[raymcginnis]

but da coroner ruled he had an excessive uptake of iodine, ruling that it must have been the releases from the nuke subs ina harbor, ignoring alla salt on da environmentalist's dining table.  karma to ya ray.

Yeah, funny also SloGlo!  You make me laugh about serious subjects sometimes.  This is a thing that many people deal with day to day.  It does deserve serious discussion.  I try to be serious most of the time, but sometimes I throw my hands up and make a joke about it.  It just seems funny to me from time to time, so I become the jokester.  This is what all experienced NukeWorkers deal with every day, as well as the rest of society.  Everyone wants to know not "How Hot Is Clean," but am I safe? 

I have done this nuclear thing for many years and I still feel safe.

Anyone out there feel unsafe?  If so, why?

[raymcginnis]

only when I'm within 100 miles of sloglo,....heheheheheheh,.....

OK, nice  joking around.  We are all friends.  To continue your joke, how many miles away would you be willing to be from me?

People only feel safe when they feel safe.  I protect Humans every day.  Do you do the same, MARSSIM?  I suspect that you do, but in a different way than I do.  There is nothing wrong with you and I being on different paths.

Dave Mason, the excellent poet said it best: "There ain't no good guy. there ain't no bad guy.  There's only you and me and we just disagee." 

I do like you ideas, however, and I learn from them.  Keep posting!

[alphadude]

you know spotted owl taste just like bald eagle.. kinda stringy

[raymcginnis]

Funny you should ask, here's my answer:

Good answer!  Peace back to you.  It turns out that we do agree.  You said it great this time.  It is hard to communicate through bulletin boards.  I split the topic off into risk versus background.  I know your question.  I think that they are two closely related, separate issues.  Maybe that is where I thought that we disagreed, but it turns out that we do agree.

Double peace back to you, MARSSIM and good luck at work!  Keep us all posted of your new work.  It will benefit us all.  That is the cool thing about NukeWorker.  Sharing of info is everything, in the digital age!

Your knowledge is some of the best!  Keep it coming!

[atomicarcheologist]

I have done this nuclear thing for many years and I still feel safe.

I too, have more than a couple of decades in doing the nuclear thing, and yes I still feel safe.  Sometimes, while playing in the dirt, I don't feel as safe as I did swinging from the jib cranes in the power plants, but it's an OSHA thing, not an atomic agent.  Sometimes, while poking around in old structures and finding >500KDPM I get a little nervous, but that's because I think of all the people who have been where I am that didn't have a meter, training, or the slightest clue.  Then, when it's done, the fuzzies turn warm to the touch, again.

[alphadude]

i got an "eerie" feeling while on the test site... and the thorium site in baltimore didnt give warm fuzzy either...

[raymcginnis]

Sometimes, while poking around in old structures and finding >500KDPM I get a little nervous, but that's because I think of all the people who have been where I am that didn't have a meter, training, or the slightest clue.  Then, when it's done, the fuzzies turn warm to the touch, again.

I understand.  We mostly go into areas that noboby has ever entered now, as far as where our unknowns are.  This is a great site, which is why I have stayed here so long.  They did things by today's standards back in the 1960's even though they did not have to back then.  They were careful back then.

We do run into things hotter than expected from time to time.  We are lucky enough to to have experienced people who know to back off and regroup when that happens.

I know that this is off topic, but this original post has brought so many feelings and ideas from related topics, I don't see the harm now in replying to the posts.  This "how hot is clean" gets to the core of what we do and it naturally drives discussions on sidetracks.  I join in on the sidetracks also because I enjoy the discussions about all of this.

There is probably a paper for someone in this post. 

[alphadude]

Ray I think it has come full circle.. how hot is clean is basically contribution that would assume no more burden than provided by background.  as we have said, acceptable, low risk is the amount that would contribute no more burden than 25 mr/year on the resident farmer scene.  whats acceptable is what the regulations dictate for that particular industrial situation. (DOE, Hospitals, Power Plant Fence line etc.) what we do is provide the client with what the contract specifications call for any thing more is gratis. The scope of the question was somewhat gray but it did generate chatter.. which is always fun.

[atomicarcheologist]

The scope of the question was somewhat gray but it did generate chatter.. which is always fun.

I'm not trying to rain on the chatter parade.  However, since the original question was considered "gray" by some, other questions designed to elict thought provoking answers were posed in-line with the original.  To wit;

So, how much contamination can a licensee leave on their buildings' interior surfaces?

If you are allowed to leave 25 mr/yr, isn't that a lot more than 15Kdpm/100cm2 max per meter?

  Could we assume that 100K/100 cm2 of Co60 would be OK?  Could we go to 150K if it was only U238?  What would the transuranics work out to?

This building was home to a laboratory which was licensed by the NRC.  The license was issued for P32, S35, I131, and Co60.  The operations ceased on January 1, 1999.....


I can see where someone who was playing with Th in Balitmore might have a problem with the questions posed.  After all, I was laying with piles of Th in Baltimore Harbor in the mid 70s.  I guess that's why I make "gray" questions.

[raymcginnis]

Everyone is frustrated by this.  There is an old joke about an environmentalist in Seattle who died from a heart attack.  He had the heart attack when he witnessed a spotted owl eating a Pacific salmon.

We are all talking about "what is background," the original subject, but we are also indeed talking about what level of MDA is acceptable.  Do we really feel unsafe enough that samples must be counted for weeks to appease the e-6 people?  The tax dollars versus the risk just seem unreasonable to me.  As far as pollution goes, how can you slightly radioactively pollute an already radioactive Earth?  Yes there should be a release limit, but we should not have to clean up fallout that is barely indistinguishable from natural background, unless we pay hundreds of thousands of dollars to count each soil samples for 3 weeks.

Companies should not be held accoutable for natural radioactivity or fallout.

They should all clean all sites up to ALARA levels.  They should demonstrate that they are pretty sure that it is all gone.  We have a 15 mRem/yr limit, but we always go way below that.  Proving e-6 is very expensive though.  I am not for 3 week counting periods of samples nationwide.  I say dig until you see it no more.  When you know that you are below an acceptable MDA to your regulators, then you are done. 

We always go way below 15 mRem/yr.  We try to get it all.  The environmentalists don't believe this though.  This what causes all of the gray areas previously discussed.  We are accused of trying to leave harmful levels behind.  We never do that though.  We always try to get it all!

This is a matter of trust and perception, not of law, in my opinion.  For goodness sake, the Earth is radioactive.  I still say what is the difference between 390 mRem/year and 405 mRem/yr?  That is why I started the risk thread.  If someone can tell me this, then I will listen.  Otherwise, I cannot understand why this is even an important topic.  I do agree that it is affecting all of us and it needs to be discussed.  This is why I keep jumping in.

That is my 2 cents on this for today.

[SloGlo]

how hot is clean is basically contribution that would assume no more burden than provided by background. 

yeah, ok.  but iffen yer inna bkg like at grand central station, then yer fricken 25 mr/yr goes right outa the window, don't it now?  what's yer bkg in yer living room iffen yinz got a house built of granite stone in reading, pa?  what's yer bkg fer an office building built of poured concrete?  sumbuddy splain alla dis!  da weigh i reed this thread, it started off releasing a building.  i didn't see where the building wuz getting torn down 'n tomatoes planted.  what happens iffen yer releasing a building to be used as a building for non-nuclear occupational use?

[alphadude]

a released nuke building for non nuke can be controlled by local zonning laws. The resident farmer example covers the building released for residential use. (25 mr)

Grand Central Station is not a living space. The "bag lady scenarion" was not adopted by regulators.

the 25 mr is above bkg.

So, how much contamination can a licensee leave on their buildings' interior surfaces?    Depends on the radionuclide and the termination plan.

If you are allowed to leave 25 mr/yr, isn't that a lot more than 15Kdpm/100cm2 max per meter?   Of what radionuclide?

Could we assume that 100K/100 cm2 of Co60 would be OK?  Could we go to 150K if it was only U238?  What would the transuranics work out to? What is the surface area?

I can see where someone who was playing with Th in Balitmore might have a problem with the questions posed.  After all, I was laying with piles of Th in Baltimore Harbor in the mid 70s.  If you are talking about WRG, this has been remediated and FSS. Levels of Th there were unacceptable and high risk. When we surveyed it, well over 100k dpm/100cm2 were found. (not fixed), and the area had been a work area for non-rad workers for years.(State of Md issue) That place is a legal can of worms.

[atomicarcheologist]

a released nuke building for non nuke can be controlled by local zonning laws. The resident farmer example covers the building released for residential use. (25 mr)

Grand Central Station is not a living space. The "bag lady scenarion" was not adopted by regulators.

the 25 mr is above bkg.

So, how much contamination can a licensee leave on their buildings' interior surfaces?    Depends on the radionuclide and the termination plan.

If you are allowed to leave 25 mr/yr, isn't that a lot more than 15Kdpm/100cm2 max per meter?   Of what radionuclide?

Could we assume that 100K/100 cm2 of Co60 would be OK?  Could we go to 150K if it was only U238?  What would the transuranics work out to? What is the surface area?

I can see where someone who was playing with Th in Balitmore might have a problem with the questions posed.  After all, I was laying with piles of Th in Baltimore Harbor in the mid 70s.  If you are talking about WRG, this has been remediated and FSS. Levels of Th there were unacceptable and high risk. When we surveyed it, well over 100k dpm/100cm2 were found. (not fixed), and the area had been a work area for non-rad workers for years.(State of Md issue) That place is a legal can of worms.

OK

Your pick

We have been using 100cm2 all thread long.

It was not WRG.  It was out in the open, not in a building.  Historical review and diligence with survey techniques revealed many movement of the material over the previous time spans.  A very interesting  welcome to the world of environmental reclaimation.

[alphadude]

well that 100cm2 was from our experience and perspective. since you have a new faclility we would have to change perspectives.  answer the questions I posed back and then run RESRAD build and you will have your answer.. to the query.

[SloGlo]

alphadude... iffen i remember rite, that bit about local zoning laws controlling a released nuke building was bandered about on page won of this thread, but eye am not sure it was done seriously as they wuz talking bout doing it via occupations.
since ya gots the goods on me fer the grand central station thing, pleaz to reeliz i wuzant using it as a living space either, but since ya wanna go there.... what kinda discernible and attributable effects can be given based on the residents of landowne, pa who had living spaces  >/= 2 mr/hr?  alot of them wuz in existence for what, 80 years?  must be some kinda data available!

ya wanna new question?  iffen yer drilling fer oil in maryland, what is the dose limit of the material ya leave on the ground when ya finish? what's the dose limit on the tools and equipment ya take with ya?

[RDTroja]

If you are drilling for oil in maryland, take a short break to have your head examined.

[darkmatter]

How hot is clean? -------- still flogging a dead horse, I see.

Breathing oxygen causes cancer, life is fatal, risk analysis can not be defined without a knowledge and understanding of the facts. And just why should I let the government or anyone else tell me what is acceptable for my life?

[alphadude]

because you cannot control yourself.. within weeks you would be living wild on some tropical beach and not wearing clothing..

hmmmm yea why should government rule me!!!

[SloGlo]

If you are drilling for oil in maryland, take a short break to have your head examined.

cranial scan complete.  garrett county has been a producer of oil and natural gas.  it's reserves are part of the appalachin basin.  the appalachin basin is a result of the catskill delta depositions ~4e8 years ago.

so what's the answer to the question?

[atomicarcheologist]

Tsk, tsk, tsk.  SloGlo, you don't play fair!  Imagine, asking a question that people who know, do not want to answer, and people who don't know, don't want to hear. 

[alphadude]

my reply is who cares?? NORMs have been lobbied hard by API and are laying around every where there is an old drilling station. those primordials are rather nasty. but unless its in a facility im doing D&D on..... cant see it from here. 

[raymcginnis]

you know spotted owl taste just like bald eagle.. kinda stringy

OMG, Alphadude!  You ate the spotted owl that ate the Pacific salmon.  LOL!  Don't move to Seattle.

[raymcginnis]

my reply is who cares?? NORMs have been lobbied hard by API and are laying around every where there is an old drilling station. those primordials are rather nasty. but unless its in a facility im doing D&D on..... cant see it from here.

Alphadude,

Local regulators care here as well as environmentalists (public meetings) who are insisting that we get rid of all of the radiation on the Earth, including the radiation from above-ground testing from all nuclear testing Countries.  Soon we will all be defining boundaries between sites about who cleans up which portion of the entire planet from fallout.  These people make money at complaining.  Next they will go after us to clean up natural radioactivity.  If they accomplish that, they will find ways to make laws to exterminate all the people that had anything to do with the cleanup, because we will expose members of the public with the miniscule amount of radiation in our bodies, during social events.  Eventually they will all commit suicide for their cause when they discover that they also are radioactive from potassium, thorium and uranium in their bodies from their food.  It is the end of Humanity if we let them win, LOL!

[raymcginnis]

yeah, ok.  but iffen yer inna bkg like at grand central station, then yer fricken 25 mr/yr goes right outa the window, don't it now?

That enhances my point.  Imagine being a facility where you handled tons of natural uranium and tried to release the soil on the site, once you knew that you were clean.  Imagine that you were a mile away from Grand Central Station (GCS) and tried to prove that none of your stack releases got into the building.

I say so what.  Try to sue me if you ride the train from GCS every day and get cancer.  I also say in LA, you breathed smog every day.  Prove that a few gamma rays from the local Nuke site, after cleanup gave you cancer.  I say in Denver, prove that a few extra mRem/yr gave you cancer after living in smog and being a mile above sea level and getting cosmic rays gave you cancer.

The people who give in to these lowered limits are all talking to lawyers, not CHPs.  It is time to stand up to both sides of lawyers.  Ours should not live in fear, because we all know what we are doing.  The other side's should find another ambulance, because we know what we are doing.


Stuff like that.

[raymcginnis]

So, how much contamination can a licensee leave on their buildings' interior surfaces?

If you are allowed to leave 25 mr/yr, isn't that a lot more than 15Kdpm/100cm2 max per meter?

  Could we assume that 100K/100 cm2 of Co60 would be OK?  Could we go to 150K if it was only U238?  What would the transuranics work out to?

AA,

Now this question I can answer.  Even tough there is accepted software out there that is isotope specfic, the regulators for surface contamination still like the old numbers.  You bring up a good point for others to learn from.  Disributed activity is differnent from deposited activity which is different from activated activity.  They all have to be looked at differently.  In D&D or remediation, the math can became quite different for all 3 situations.  Which computer program or formula from a book can change from day to day do you use?  If your site is small, you may find that one or two combinations work until the end of the job.  My experience is that the unknown can make you scramble to rethink your thinking. 

I say stick with the trio thinking of regulations for surface contamination (apha limit, beta limit, and different for certain isotopes), until RESRAD Build is accepted nation wide as a way to release buildings to be left in place.  That may happen, but Congress will have to act on it.  For most common isotopes beta emitting isotopes the limit is 5000 dpm per 100 cm2.

[bmr176]

Maybe this is one of those rumor things but I've heard if a dirty bomb was detonated in D.C. we would never be able to release some of the Government buildings because the granite and marble used in their construction were mined at greater than the current EPA release limits.  What do we do about stuff like that?  I have no idea

[Shonkatoys]

You would run a cumaltive freguency distribution of known clean granite and marble   You can see one of these at.  http://www.nukeworker.com/pictures/thumbnails410.html  This will give you a zero baseline for your background.  You then would run your survey.  Of course it would help if you had a Surface contamination monitor that does its own Cumaltive freguency distribution to compare it against clean  granite and marble, but hey I am prejudice, I work for Shonka>   You can also look at the cumaltive freguency distribution for your fired picture I put in this group of pictures,  It shows how a person was surveying the wrong material and fasifying data and the cumaltive freguency distribution caught him. And as Trump says, your fired!!!!

[alphadude]

Shonka is right, the dirty bomb place could be surveyed and cleaned up. Just don't go low bid with some company that comes  in with hand held friskers. (listen for the clicks..)   

[SloGlo]

my reply is who cares?? NORMs have been lobbied hard by API and are laying around every where there is an old drilling station. those primordials are rather nasty. but unless its in a facility im doing D&D on..... cant see it from here. 

duz ennybuddy remember whena rem was a rem, 'n a dpm a dpm?  so it's better iffen yer picnicing with yer girlfriend, grandkids, local trout unlimited chapter (pick one, all, err make up anudder), 'n yer buttocks is parked ona pile of drill scale that's reading 200 mr/hr than it is to be eradicating hemaroydz wit a coupla extry dpm of 60?  is it rilly too much two care unless our pay ist directly effected?  duz yer body know da difference between the gammies interacting with it?  duz yer bank know why that paycheck wuz originated that you deposited?

[PWHoppe]

I agree with SloGlo  , what we are talking about gets into the realm of silliness don't you think? If your talking a few dpm who cares? There will come a time when we see one dpm we shutdown the world, how silly is that?

[alphadude]

its all about LET.  trout streams and drilling brine are not likely to be in the same area.

[stownsend]

Local regulators care here as well as environmentalists (public meetings) who are insisting that we get rid of all of the radiation on the Earth, including the radiation from above-ground testing from all nuclear testing Countries.(Quote from Ray)

I love it when these people insist I clean up to greater than common sense levels because my wife said she likes to sleep under a roof that doesn't leak and eat three times a day.When I have to remove RAM from one area to another I'm employed and I hear "cha-ching" in my sleep.After working at Electric Boat and building houses I made my second best choice of my life and joined the Military and learned to be an HP.After 28 years I can still say there's alot of money to be made in confusion.If we didn't have to clean to extreme levels the ranks of HP would be short and the unemployment lines long.Long live the Environmentalist.

[alphadude]

well, its not about the environmentalist- its about real estate. clean up to high standards benefits the future potential of property values. In DOE it has very little to do with environmentalist and more to do with risk assessment and getting the vote. The power plant stuff is fluff, compared to the DOE stuff.  The oil drilling stuff is hidden in a cloud of ignorance and high dollar lobby.

[Doc_REM]

stownsend...."there's lot's of money to be made in confusion"...I like the statement made at BNFL..."where there's confusion there's money...and I've made ALOT of MONEY here"

[Dave Warren]

Well said Doc.
CHAOS = CA$H[/b]

[SloGlo]

its all about LET.  trout streams and drilling brine are not likely to be in the same area.

yinz reely wanna geography lesson here?  alls i get is that ya don't care what the dose is to the general public, long's it ain't isotopically tied to your pet project.  so iffen ya pull over at a rest stop ona interstate, 'n walk thru alla dis mud 'n muck dat fell offa a drill rig, it'd be ok.  'n when yer shoes light up the frisker at the new job tomorry morning during g.e.t., wail, hail; whutz a guy to due but grin the grin?

[raymcginnis]

I love it when these people insist I clean up to greater than common sense levels because my wife said she likes to sleep under a roof that doesn't leak and eat three times a day.

I understand about appreciating job security, but I would prefer bettering myself and getting a fun job that actually contributes to society.  That is why I went back to school for multiple degrees.  I worked for a plant once where I did silly stuff every day.  It seemed like the place to be at the time and they weren't huting people, so I just accepted the fact that I had to do silly stuff to work there.  I was relieved when I finally got laid off.  I have never done that again.  I like to contribute to the job and to the country.  I would prefer that all of the job security people get a productive job and save all of the tax payers wasted money chasing the last dpm on the planet for billions of dollars.  We are all intelligent people.  Why can't we all do intelligent and productive jobs and still get paid?

This is still a fun post.

[stownsend]

Ray
I enjoy and respect reading your posts and your website.I comment you for wanting to better yourself with advance degrees and more responsible job opportunities.It takes a mangement team with common sense to dictate to the the in-field techs what they need to write final reports and to have a proper technical basis to justify why they did this or why they didn't.
Now to say that I have a non productive job who is squeezing the taxpapers by wasting their money and I don't have the intelligence to get a productive job,you can get off your high horse anytime.I have been an Hp many years and several of those in position of supervision.I like doing field work so that is what I'm doing.Supervision tells me what they need and I produce.I don't sit in a office doing soil anylsis,pouring over MARRSIM data,chatting at the coffee pot complaining about the lowly HP's in the field.If I have to do "silly stuff" it's because I'm told to, not because I thought that would be a good thing to do today.Bottom line Ray I have an agreement whith mangement here.They tell me what to do ,I do it in a timely and professional manner and they give me a paycheck each month.If you have a different arrangement that lets you do as you feel like it then I expect to see your advertisements on the job board for Techs who want to get paid for doing whatever they decide to do that day.If you go back and read what you said I'm sure you really didn't mean to come across that  way.Have a great day.

[SloGlo]

Why can't we all do intelligent and productive jobs and still get paid?

This is still a fun post.

hay ray....(datz sew phat!)  we kin all due intellahjint 'n producktiff jobs 'n still git payed!  butt itz a beeg diffarance 'tween intellahjint pay 'n wut producktiff peeple want.   'cause it seams dat dere's sew many peeple inflating there wages (ona corporate scale) bye kutteen peeplz wages who r below them.  udderwise, alla wages shud go up proportionally all year long at revue thyme.

butt, bttt (bak two the thred) howz come i ain't seeing no answers to da questions?

[raymcginnis]

howz come i ain't seeing no answers to da questions?

SloGlo,

Your question is answered by how many posts there are to the main question "how hot is clean?"  You have to write a MARSSIM (lots of guidelines) plan that is accepted by your regulators.  You remediate to the approved plan.  Then your regulators send in confimatory people (usually 3rd party) to verify that the site is below the limits that they accepted.  At that point you apply to have the site as released and it gets posted in the Federal Registry.  Then you are legally released.  Now if the company wants to reuse the land, they only have to worry about lawsuits from future employees.  If you want to sell it, that is another story.  In our state, we have to disclose that it used to be radioactive.  That could affect the price dramatically or prevent any sale because of public fear of radiation.  Getting it released is never the final story.  In the eyes of some, once contaminated, the land or building is doomed and a death trap.  Most of us know that is just hogwash, but perception of the ignorant can be a headache after release.

[Doc_REM]

is 1000 dmp/1000  clean?
Oh, smear or AUP?

[halflifer]

.  We are all intelligent people.  Why can't we all do intelligent and productive jobs and still get paid?

the answer to that one is easy........we don't all work for intelligent people. (for SloGlo: wee doant all werk four intelagint peepl )

[atomicarcheologist]

howz come i ain't seeing no answers to da questions?

Rad Tech, Rad Tech, what's you going to do?
What's you going to do when they won't answer you?

[SloGlo]

Rad Tech, Rad Tech, what's you going to do?
What's you going to do when they won't answer you?

tanks, atomicarcheologist.... now eye'm gonna hafe dat song dune da cranial carom fer the next 3 ours!

guess i'll jist hafta answer da question, how hot is clean.  after reading alla these posts, it's obvious that clean is at least 10 times what your limits are.  otherwise, there'd be numerical values shown for stuff, 'n since there ain't nuttin but people tellin everybuddy else that 'it's all what you can get yer regulator to agree to...' (i know, that's not a direct quote 'n ain't meant to be, it's a generic quote averaged out over hundreds of posts ona buncha pages over months of time) 'n udder items of superior based knowledge.  but to put it inot perspective; iffen yer at a sop, 'n yer release limit is 1kdpm fixed, then yer shocked that the generic limit is 15kdpm, huh? (i know, itza max/meter, 'k?)  'n that person drops his jaw at peeple talkin 100kdpm.  but when ya gits all dun waving yer flags wit alla differing alphabet soop on 'em, there ain't no real limits.  which is where i wuz going with the drilling thing, 'cause iffen ya drill 'n leave in md, ya kin leave rads worth laying around.  not in every state, 'cause states with alot of that activity have limited it (like texas, that home of the prez  ) to a numeric value.  'n a numeric value states what is clean 'n what ain't.  nuttin else does.  period.

[raymcginnis]

since there ain't nuttin but people tellin everybuddy else that 'it's all what you can get yer regulator to agree to

SloGlo:  Everybody is using MARSSIM now, except Grandfathered sites.  MARSSIM is not a regulation, but a guideline.  MARSSIM reiterates through the whole document that you have to sell your survey plan and release limits to you regulators.  That is why you have seen that phrase hundreds of times.

You seem to be dealing with building limits.  Most people are dealing with soil limits.  The problem is from State to State, the State regulations vary.  In our State, we have a moratorium from the Governor that says that no debris from D&D may go to a regular landfill, even if you prove it clean through MARRSIM.  We quit doing MARRSIM surveys on buildings.  We just prove they are clean through DOE standards (we survey them like a tool going out of a control point, get the State's approval through their confirmatory survey and demolish the clean building and ship the debris to a controlled hazardous waste site.  That site will not accpt the debris without a letter from the Stae regulatory agency.  We are in constant contact with them.  We get preapproval of our plans before we even start.

You wanted numbers.  We are a DOE site, so our release criteria are based on DOE's basic release criteria.  We never had pure strontium here so our beta release limits for the debris are based on a mixture of beta-gamma emitters.  They are less than 5,000 dpm/100 cm2 when averaged over a one square meter area.  You can have hot spots up to 15,000 dpm/100 cm2 as long as your average over one square meter limit is not exceeded.

For soil, we went with the EPA recommended 15 mRem/year limit.  That limit never passed as law, so we are lower than the law requires.  This 1E-6 limit thing is preposterous!  We ran RESRAD and got limits for each isotope and for isotope mixtures, we do the sum of fractions.  For our site parameters, family farm scenario, our limt for Cs-137 is 9.2 pCi/g.  Since we have a mixture of isotopes, Cs-137 generally drops to ~ 7.0 pCi/g.  That limit makes the sum of fractions under the 15 mRem per year, but we recalculate it for every project.

We always use ALARA for every cleanup though.  We are generally below MDA for every project.  If it were to get cost prohibitive for a site, we would discuss the limits and how far we could reasonably get below it.

Hope these numbers and comments helped you and everyone.  We have been doing D&D since the 1970s.

[wlrun3@aol.com]

Mr. McGinnis,
     I have been following your posts and I am impressed. You mentioned a recently acquired masters degree. Please tell me about it. I am familiar with some of the d&d sites in california. Where is your site. You mentioned resrad...would attending the five day anl class for six hundred dollars be worth it.

[raymcginnis]

would attending the five day anl class for six hundred dollars be worth it.

wlrun,

Yes it is a most excellent class with most excellent teachers.  It was the best off-site class that I ever took.  They take you through the code for soil release, building release, etc.  I highly recommend it. 

Thank you for the compliment, but awe shucks,  it made me blush.  There are many better people than me posting on this forum.  I am still learning from other's experiences on NukeWorker.

Talking about my degrees or my site is not appropriate for this forum topic.  We are talking about release limits here.

[atomicarcheologist]

You seem to be dealing with building limits.  Most people are dealing with soil limits.  The problem is from State to State, the State regulations vary.  In our State, we have a moratorium from the Governor that says that no debris from D&D may go to a regular landfill, even if you prove it clean through MARRSIM.  We quit doing MARRSIM surveys on buildings.  We just prove they are clean through DOE standards (we survey them like a tool going out of a control point, get the State's approval through their confirmatory survey and demolish the clean building and ship the debris to a controlled hazardous waste site.  That site will not accpt the debris without a letter from the Stae regulatory agency.  We are in constant contact with them.  We get preapproval of our plans before we even start.

You wanted numbers.  We are a DOE site, so our release criteria are based on DOE's basic release criteria.  We never had pure strontium here so our beta release limits for the debris are based on a mixture of beta-gamma emitters.  They are less than 5,000 dpm/100 cm2 when averaged over a one square meter area.  You can have hot spots up to 15,000 dpm/100 cm2 as long as your average over one square meter limit is not exceeded.

I'm not meaning to butt in here, and my apologies to the Mssrs. involved.  However, I believe this information would indicate that your answer to the original scenario (65K Co60) posed would be that it would not be clean.   

[raymcginnis]

I'm not meaning to butt in here, and my apologies to the Mssrs. involved.  However, I believe this information would indicate that your answer to the original scenario (65K Co60) posed would be that it would not be clean.

Interesting question Atomic A.  My first statement would be butt in whenever you want.  This is a free and open forum.  That is what I love about NukeWorker.  No apologies are ever needed.  This topic varies from site to site and the generators of the limits have made it flexible on purpose.  Every site has a different mixture of isotopes, so the regulations require you to do your own calculations for your mixture to protect you.

Yes, you are right, if RESRAD Build tells you for pure C0-60 that your limit is 65K dpm/100cm2, you are still limited by the basic DOE, NRC, EPA guidelines.  That is 5000 dpm/100cm2 fixed for beta emitters, averaged over one square meter and no "hot spot" over 15K dpm/100cm2..  I don't see a way to get around this, and we have found that this is achievable here.  Generally, we go for ALARA or NDA and that is reasonably achievable  The real question is what is background and what is MDA on analysis equipment?  How low should you go, given the ampount of natural radioactivity and the amount of man-made introduced through all fallout. 

Reply if you would like data.

[Shonkatoys]

I have been working the Mound site recently.  Pretty interesting.  300 dpm max spot 100 cm square alpha and 100 dpm 100cm square average alpha.  My opinion is that if you use convential hand scanning or floor monitors without set speeds for this is that you are either stupid, lying or both.  Fortunately the Mound people see this and are using the Shonka Surface contamination monitor to survey.  You can check it out at.
http://www.nukeworker.com/pictures/thumbnails410.html
This is very good for low Alpha limits that you can not realistically expect people to frisk at 1 inch every 11 seconds or push a floor monitor cart that has a 600 cm2 surface to see this.  First you would probably push the cart too fast and if all your 300 dpm was in one spot your cart would average this out over 600 cm2 when the regs clearly state 100 cm2.  Can some one explain how a floor monitor is used with about 600 cm2 surface that can be rolled the right speed at all times and interplate  100 cm2 in it without looking for 1800 dpm 100 cm2 which would assume  300 dpm in each 100 cm2 of the cart?

[atomicarcheologist]

I have been working the Mound site recently.  Pretty interesting.  300 dpm max spot 100 cm square alpha and 100 dpm  Can some one explain how a floor monitor is used with about 600 cm2 surface that can be rolled the right speed at all times and interplate  100 cm2 in it without looking for 1800 dpm 100 cm2 which would assume  300 dpm in each 100 cm2 of the cart?

Without getting too rudimentary, one would use the floor monitor in a search mode at 1/3 probe width/second travel speed with the alarm rate set to the corresponding point.  For those without the set point characteristic on the assigned meter, the observed rate for an alarm condition would have to be agreed upon.  Once that count rate has been breeched, then the proper sequence of events would dictate the usage of a 100cm2 probe to survey the area detected by the large area probe on the floor monitor. 
Of course, I assume that usage of this type of instrumentation has been agreed to by all parties involved in the planning group and that it will not violate the Lower Boundary of the Grey Region.   

[alphadude]

hit or miss i guess. seems the floor monitor is just used for the "blind pig finds the acorn" type of survey,

i think you got a nibble there shonkatoys. chum the water sum more!

rascals galore

[Shonkatoys]

Alpha Dude put in for Mound!!! Scanning at .4 inches a second for alpha at the 300/100 limit using the surface contamination monitor.  Your the Alpha Dude< just do it!!! Now without being derogatory to any particular company do you think that any other company is scanning for this properly?  Anyone think they can hand scan 100 DPM 100 cm2 average properly.  If so what speed would you move your detector to meet the MDC and what detector would you use. 

[atomicarcheologist]

Shonkatoys,
I think that whoever is paying me has all ready made the deal with their regulators and run the programs to acceptable percentiles, therefore I can do it.

[alphadude]

same ole same ole---

[atomicarcheologist]

Yes, you are right, if RESRAD Build tells you for pure C0-60 that your limit is 65K dpm/100cm2, you are still limited by the basic DOE, NRC, EPA guidelines.  That is 5000 dpm/100cm2 fixed for beta emitters, averaged over one square meter and no "hot spot" over 15K dpm/100cm2..  I don't see a way to get around this, and we have found that this is achievable here. 

I am sorry that this is so belated a reply, but I didn't notice this post previously.  I thought these 5K/15K limits were for licensees, and that when License Termination territory was entered, these limits were not necessarily valid.

[Shonkatoys]

I agree that 5000 square meter average and 15,000 100 cm2 is acheivable using the right instruments and set up properly for speed or static counts.  Unfortunately I have seen 2 sites were these levels are not done properly because they are using a floor monitor with about a 600 cm2 probe.  But if the contractor and subcontractors agree to it and DOE can not do the math or know how the instrument works than so be it.  I also have heart burn with the 100 dpm average and 300 cm2 hot spot for low alpha limits.  Like I said before someone rolling this with a floor monitor has to be stupid or lying or both to believe this. 

[atomicarcheologist]

Is this type of survey any worse than someone cruising over a grassy field with a scintillation gamma counter and making MARSSIM work?

[Shonkatoys]

People really need to get their act together to check for what they say they are checking for.  I thought DOE had people smart enough to figure it out or had people that would check to see if survey plans had instruments that could check for MDC.  Also to see if instruments are set up properly.  I seen 2 diffrent sites where they set there instrument up for tech which discriminated against hard betas which was what they were checking for anyway when your in a Uranium environment.  So I guess they do not care or are stupid. Sorry hate to be blunt!  Open up the waste dumps!!!! DOE don't care should be the motto!  Or bring me a Health Psychic (Yes I mean Psychic)and have him bless it with a stick, You can not get any worse than what you are getting now.  Hopefully they will figure it out one of these days, Then what unbury the psychic and stupidly checked stuff? So I guess how hot is clean is what you get away with if no one checks or is too stupid to know the difference.

[atomicarcheologist]

So I guess how hot is clean is what you get away with if no one checks or is too stupid to know the difference.

I'm giong out on a limb here and taking this to mean that you are in accordance with the original 100KDPM/100cm2 Co60 scenario.

[alphadude]

i'm thinkin this horse is dead?

[sweetpea]

i thought the limit depended on who was checking behind you 

[HydroDave63]

been dead,....it's startin' to stink to high heaven now

there is still interest yet in this! 

[Shonkatoys]

Went to a meeting this week where a CHP from a major company was speaking.  He basically said that the state and DOE do not know how to check us so it is our responsibility to check ourselves.  I thought about raising my hand and say obviously your company does not know either, therefore no one has it right.  Sadly, I know that would have got me in trouble and my company so, I kept my mouth shut and will work through other channels to help people get it right.  So Sweetpea is right, so if you have no checkers smart enough to figure it out and your company does not know what it is doing then it just does not matter how hot is clean!    So I guess this topic is over and stinking more ways than one!!!!

[alphadude]

Scoundrels at work again.  I hope Joe wasnt there Shonkatoys to hear this guy speak.

[Shonkatoys]

I was thinking of a fox guarding the hen house on this and the state and DOE watching.  The fox says I got a chicken detector that detects low energy beta white and high energy beta green chickens which are bad, all other colors are good.  But the fox is told that his detector really does not check for high energy green chickens very well, well the fox says the state and DOE do not know how to check for green chickens so it does not matter I will let them out.  Also my 43-37 probe has 6 pens which I will herd my chickens in and average.  But what if all your green and white chickens are in one pen and over the 100 cm2 corral average.  What question averaging my 6 pens the Fox says!  and there you have it.  LOL The Foxs is right!! do not question him. 

[atomicarcheologist]

I would imagine that if you questioned the Fox, you would get an interesting answer.  One scenario question/answer could be;  Mr. Fox, what are you going to do with > the allowable average number of green and white chickens in your six pen 43-37?  Mr. Fox replies, although I have > the allowable average limit , they are still < the maximum number/square meter and this maximum is not in more than one pen of the six, nor do they exceed 0.2 and 1.0 flock limit at 1 cm.

[Shonkatoys]

I can imagine the state checking an area and finding a lot of green chickens in one area with their GM chicken detector and bringing this up to the fox who has a very poor high energy beta green chicken checker.  The fox being the fox he is has many options, He can say

1. We used marssisms and only did 10 percent.  We missed that spot.

2.  Your detector must be calibrated wrong, I know the state has no CHPs,  See my detector shows a lot less on that spot.   Let my CHP tell you what you have done wrong.

3. We averaged that spot out using our 43-37 probe.  Take probe and show it averages out.  Hope state does not figure out maximum 100 cm2 average.

4.  Your instrument also checks for Alphas( Which it does, just not very well) and say I am allowed the max beta and alpha so divide by 2 and average.

5.  We have not got to that spot and will check it shortly, thanks for helping us out.

[atomicarcheologist]

Should the fox have had a good cup of coffee and be ready for this inspector, I can imagine his number one response as  "Perhaps you should remove those sunglasses, sir.  They appear to be tinted with the hue of green predominate in the matrix and have skewed your visual interpretation of the real time situation present.  Those are white chickens, not green, sir."

[raymcginnis]

Pretty funny AA.  I use rose colored glasses now to see the world in a different light.  The chickens all look pink to me now, LOL!  I do know what a white chicken looks like, however, if I take my glasses off.  Good comment on current status of how hot is clean.

[raymcginnis]

AA,

Are you sure that you are not a gifted stage actor, doing Sherlock Holmes, or might you be Sir Arthur Conan Doyle reincarnated?  LOL!  I like your posts, none the less.  Touche.  Keep up the thinking.  You make me think.

[SloGlo]

Pretty funny AA.  I use rose colored glasses now to see the world in a different light.  The chickens all look pink to me now, LOL!  I do know what a white chicken looks like, however, if I take my glasses off.  Good comment on current status of how hot is clean.

hay, ray!  saw yer name on the home page list fer threads, 'n hadda stop bye 'n reed dis.  whacha dune, braggeen hare bout yer isite?  hail, iffen eye take oph mie specks, eye kant sea iffen ders enny chickens.  unlease dey bin dun up rite with herbs, spices, 'n a goot basteen!
bttt, remember wan ya could drink coffee outa a fiesta ware cup that coodant be released phrum site?  which puts the how hot is clean ina hole knew lite.... wood dat cup be clean only iffen it went thru a dishwasher that wuz "n" stamped?

[Shonkatoys]

The state or DOE brings a high energy beta green chicken source NIST traceable source to have the fox check.  The fox tells them it is 10,000  since he has a poor high energy beta green chicken checker when it is really 100,000.  The fox has many options,
1. Obviously the source has not been corrected for half life.
2. You must have the wrong certification.
3. Some one must have swiped it and wiped off the Green Chickens.
4.  Your correction factor is wrong.

How hot is clean is how smart or stupid the regulators are.  Being a former regulator I know they do not get paid much or trained enough in Health Physics

[atomicarcheologist]

The state or DOE brings a high energy beta green chicken source NIST traceable source to have the fox check.  The fox tells them it is 10,000  since he has a poor high energy beta green chicken checker when it is really 100,000.  The fox has many options,...

#5.  100,000 what?  This is obviously a trick scenario that you are using, sir, and I shall consult with my legal staff regarding this atomic harassment.

[Rennhack]

"How clean is clean"
http://www.ead.anl.gov/project/dsp_topicdetail.cfm?topicid=21

The RESRAD family of computer codes was developed by EVS to provide a scientifically defensible answer to the question "How clean is clean?" and to provide useful tools for evaluating human health risk at sites contaminated with radioactive residues. The RESRAD methodology was cited in DOE Order 5400.5 for dose assessment and determining guidelines for clean-up of radiologically contaminated sites. The RESRAD codes include (1) RESRAD for soil contaminated with radionuclides; (2) RESRAD-BUILD for buildings contaminated with radionuclides; (3) RESRAD-CHEM for soil contaminated with hazardous chemicals; (4) RESRAD-BASELINE for baseline risk assessment with measured media concentrations of both radionuclides and chemicals; (5) RESRAD-ECORISK for assessment of ecological risk from hazardous chemicals; (6) RESRAD-RECYCLE for recycle and reuse of radiologically contaminated metals and equipment; (7) RESRAD-OFFSITE for off-site receptor radiological dose assessment; and ( 8 ) RESRAD-BIOTA for assessment of radiological dose to biota. Four of these seven codes (RESRAD, RESRAD-BUILD, RESRAD-RECYCLE, and RESRAD-OFFSITE) also have uncertainty analysis capabilities that allow the user to input distributions of parameters.

RESRAD has been widely used in the United States and abroad and has been approved by many federal and state agencies, including the U.S. Department of Energy and the U.S. Nuclear Regulatory Commission.

[GLW]

Study Tab >> HP/RP/RCT Study >> Moe Handbook (Operational Health Physics Training By H.J. Moe)

dead link,...

[Rennhack]

Updated.