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HPPOS-284 PDR-9306170040

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