U.S. Nuclear Regulatory Commission
Guide on "How Hard You Have to Look" as Part of Radioactive Contamination Control Program
HPPOS-072 PDR-9111210170
Title: Guide on "How Hard You Have to Look" as Part of
Radioactive Contamination Control Program
See the letter from R. C. DeYoung to E. D. Swartz
(Commonwealth Edison Company) dated May 18, 1982. The
intent of IE Circular No. 81-07 (IEC-81-07) was to give
guidance on "how hard you have to look" for radioactivity
when the use of portable survey equipment is necessary as
part of a radioactive materials control program. The
detection limits in IE Circular No. 81-07 (IEC-81-07) are
not release limits. The health physics position was
written in the context of 10 CFR 20.201, 20.301, and
20.302, but it also applies to the "new" 10 CFR Part 20,
Sections 20.1501, 20.2001, and 20.2002. HPPOS-071 and
HPPOS-73 contain related topics.
The intent of IEC-81-07 (see HPPOS-071) was to provide
guidance on acceptable limits of detection of portable
survey equipment; thus, defining "how hard you have to
look" for radioactivity when the use of portable survey
equipment is necessitated as part of a radioactive
materials control program. Low background, fixed
laboratory counting equipment can readily detect levels of
radioactivity several orders of magnitude less than the
detection levels discussed in the circular. However, the
use of laboratory counting equipment is not always
practical for all situations and portable survey equipment
may need to be employed.
The circular did not establish criteria for releasing
radioactivity contaminated materials from restricted areas
for unrestricted use. The regulations applicable to
nuclear power reactor licensees do not provide for release
of materials for unrestricted use that are known to be
radioactively contaminated at any level. Authorization for
disposal of specific radioactively contaminated materials
may be requested as specified in 10 CFR 20.302 [or 10 CFR
20.2002]. The Commission recognizes the need for "de
minimis" classification of wastes and has initiated work to
define "de minimis" levels on a specific waste basis. This
work is continuing. [Note: The statement concerning "de
minimis" classification of wastes is related to the below
regulatory concern (BRC) policy, which has now been
withdrawn.]
With regards to your request for concurrence with release
criteria in your "Radiation Protection Standards," we
cannot concur since the regulations do not contain release
criteria provisions as described above. The method
available to you for obtaining authorized release limits is
to submit to the Office of Nuclear Reactor Regulation (NRR)
a request for license amendment that addresses specific
release limits. Although we have sent a copy of your
letter to NRR for information, the excerpt you provided
from your "Radiation Protection Standards" lacks specifics
which would support a request for specific release limits
for radioactively contaminated materials.
If you desire a specific authorization for disposal or a
license amendment for specific release limits, please
direct your request to the Office of Nuclear Reactor
Regulation.
Regulatory references: 10 CFR 20.201, 10 CFR 20.301, 10
CFR 20.302, 10 CFR 20.1501, 10 CFR 20.2001, 10 CFR 20.2002
Subject codes: 7.6, 9.7
Applicability: Reactors
