U.S. Nuclear Regulatory Commission

Technical Assistance Request, Interpretation of 10 CFR Part 40 and Certain Decommissioning Issues Regarding Fixed Contamination

HPPOS-284 PDR-9306170040

Title: Technical Assistance Request, Interpretation of 10

CFR Part 40 and Certain Decommissioning Issues Regarding

Fixed Contamination

See the memorandum from J. E. Glenn to D. M. Collins dated

May 26, 1992, and the memorandum from J. H. Austin to J. E.

Glenn dated April 29, 1992. ITT made a telephone request

concerning interpretation of 10 CFR Part 40 and certain

decommissioning issues related to equipment with fixed

contamination. The licensee, ITT, was proposing to

terminate a specific license and transfer the material

(e.g., a contaminated grinder and saw) to themselves as a

general licensee.

The maximum fixed contamination is 15,000 disintegrations

per minute (dpm) per 100 square centimeters (100 cm2) on

the grinder and 10,000 dpm/100 cm2 on the saw. The

equipment was to be used with a thorium oxide polishing

compound containing 0.16 to 0.20 percent thorium by weight.

It was later determined that the licensee disposed of the

grinder at an authorized burial site and intended to use

only the saw and the polishing compound. The Th-232, which

was previously used at this facility in a grinding

operation, is a rare earth compound that is exempt under 10

CFR Part 40.13 (c) (1) (vi).

In view of this information, NRC recommended that ITT

decontaminate the saw according to the current guidelines

for decontamination of equipment (average and maximum fixed

Th-232 surface contamination of 1000 dpm/100 cm2 and 3000

dpm/100 cm2, respectively) before termination of the

specific license and release of the saw for unrestricted

use. If this level of cleanup is not achievable, ITT

should decontaminate the saw to an alternative level that

is "As Low As Reasonably Achievable" (ALARA). If the

licensee decontaminates the saw to ALARA levels (in excess

of existing guidelines), there should be no reason to

object to transfer of the saw from a specific license to a

general license.

Regulatory references: 10 CFR Part 40.13

Subject codes: 3.5, 5.8, 11.3, 11.4, 11.6, 12.4

Applicability: Source Material