Information Notice No. 85-92: Surveys of Wastes Before Disposal from Nuclear Reactor Facilities

                                                          SSINS No.: 6835 
                                                             IN 85-92      

                                UNITED STATES
                        NUCLEAR REGULATORY COMMISSION
                    OFFICE OF INSPECTION AND ENFORCEMENT
                           WASHINGTON, D.C. 20555

                              December 2, 1985

Information Notice No. 85-92:   SURVEYS OF WASTES BEFORE DISPOSAL FROM 
                                   NUCLEAR REACTOR FACILITIES 

Addressees: 

All production and utilization facilities, including nuclear power reactors 
and research and test reactors, holding an operating license (OL) or 
construction permit (CP). 

Purpose: 

The purpose of this information notice is to supplement the guidance of IE 
circular 81-07 as it applies to surveys of solid waste materials before 
disposal from nuclear reactor facilities. It is expected that recipients 
will review the information for applicability to their facilities. However, 
this information notice does not constitute NRC requirements; therefore, no 
specific action or licensee response is required. 

Description of Circumstance: 

Some questions have arisen concerning appropriate methods of surveying solid
waste materials for surface contamination before releasing them as 
nonradioactive (i.e., as wastes that do not contain NRC-licensed material). 

Discussion: 

The need to minimize the volume of radioactive waste generated and shipped 
to commercial waste burial sites is recognized by the NRC and industry. Some
nuclear power plants have initiated programs to segregate waste generated in
radiologically controlled areas. Such programs can contribute to the 
reduction in volume of radioactive waste; however, care should be taken to 
ensure that no licensed radioactive material is released contrary to the 
provisions of 10 CFR Section 20.301. In practice, no radioactive (licensed) 
material means no detectable radioactive material. 

In 1981, IE Circular 81-07 was issued by the NRC. That circular provided 
guidance on the control of radioactively contaminated material and 
identified the extent to which licensees should survey for contamination. It 
did not establish release limits. The criteria in the circular that 
addressed surface contamination levels were based on the best information 
available at the time and were related to the detection capability of 
portable survey instruments 

8511270325 
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equipped with thin-window "pancake" Geiger-Mueller (G.M.) probes, which 
respond primarily to beta radiation. Monitoring of aggregated, packaged 
material was not addressed. In 1981, there was no major emphasis on 
segregating waste from designated contamination areas. As a consequence, 
large volumes of monitored wastes were not being released for unrestricted 
disposal. However, because of recent emphasis on minimizing the volume of 
radioactive waste, current practices at many nuclear power facilities result
in large volumes of segregated, monitored wastes, containing large total 
surface areas, being released as "clean" waste. 

When scanning surfaces with a hand-held pancake probe, there is a chance 
that some contamination will not be detected. (See the papers by Sommers,1 
for example.) There is the chance also that the total surface area will not 
be scanned completely. Thus, when numerous items of "clean" material (e.g., 
paper and plastic items) are combined, the accumulation of small amounts of 
contamination that have escaped detection with the pancake probe may be 
detected using a detector that is sensitive to gamma radiation (e.g., by 
using a sensitive scintillation detector in a low-background area). Such 
measurements of packaged clean waste before disposal can reduce the 
likelihood that contaminated waste will be disposed of as clean waste, then 
found to be contaminated after disposal. (Some operators of sanitary 
landfills have begun to survey incoming waste for radioactivity using 
scintillation survey meters which in some cases are supplemented by portable
gamma-ray spectrometers.2) 

In order to preclude the unintentional release of radioactive materials, a 
good monitoring program likely would include the following: 

1.   Careful surveys, using methods (equipment and techniques) for detecting
     very low levels of radioactivity, are made of materials that may be 
     contaminated and that are to be disposed of as clean waste. These 
     survey methods should provide licensees with reasonable assurance that 
     licensed material is not being released from their control. 

2.   Surveys conducted with portable survey instruments using pancake G.M. 
     probes are generally more appropriate for small items and small areas 
     because of the loss of detection sensitivity created by moving the 
     probe and the difficulties in completely scanning large areas. This 
     does not preclude their use for larger items and areas, if supplemented 
     by other survey equipment or techniques. 

3.   Final measurements of each package (e.g., bag or drum) of aggregated 
     wastes are performed to ensure that there has hot been an accumulation 
     of licensed material resulting from a buildup of multiple, 
     nondetectable quantities (e.g., final measurements using sensitive 
     scintillation detectors in low-background areas). 
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                                                        IN 85-92        
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                                                        Page 3 of 3     

The foregoing does not constitute NRC requirements; therefore, no specific 
action or written response is required by this information notice. If you 
have any questions about this matter, please contact the Regional 
Administrator of the appropriate NRC regional office or this office. 


                                   Edward L. Jordan Director 
                                   Division of Emergency Preparedness 
                                     and Engineering Response 
                                   Office of Inspection and Enforcement 

Technical Contact:  John D. Buchanan, IE
                    (301) 492-9657

                    LeMoine J. Cunningham, IE
                    (301) 492-9664

Attachments:
1.   References
2.   List of Recently Issued IE Information Notices
.

                                                        Attachment 1    
                                                        IN 85-92        
                                                        December 2, 1985 

                                REFERENCES 

1    Sommers, J. F., (a) "Sensitivity of Portable Beta-Gamma Survey 
     Instruments," Nuclear Safe 16 (No. 4), 452-457, July - August 1975, (b) 
     "Sensitivity of GM and Ion-Chamber Beta Gamma Survey Instruments," 
     Health Physics 28 (No. 6), pp. 775-761, June 1975. 

2    Anonymous, "LA Nuclear Medicine Community Improves Radiation Monitoring 
     at Landfills, " J. Nuclear Medicine 26 (#4), 336-337, April 1985.