United States Nuclear Regulatory Commission - Protecting People and the Environment

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withdrawn.]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

Page Last Reviewed/Updated Thursday, March 29, 2012