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 "deminimis" 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 "deminimis" classification of wastes is related to the below regulatory concern (BRC) policy, which has now been withdrawn.]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