Ask an Expert
Question and Answer Page
Regulations, Guidelines, Standards
I am currently working on a Final Status Survey Plan, which is using DOE
Order 5400.5 surface contamination release limits (same as Reg Guide 1.86
limits) as the DCGLs. The question came up as to how these limits were
developed, and what was the technical basis for these limits?
the recent emphasis on the release of solid materials by NRC, DOE and
others, a fair amount of attention has been given to Regulatory Guide 1.86
(1974) surface contamination guidelines, and their origin. As you indicated
in your question, the DOE 5400.5 (1990) surface activity guidelines are
virtually the same as those listed in Regulatory Guide 1.86. The surface
activity guidelines found in Regulatory Guide 1.86 are largely based on
instrument detection capabilities at that time (early 1970s), as opposed to
being dose- or risk-based. Consider the following excerpts on this subject
from recent documents. [Note: These references can be found on the Clearance
section of the DDSC web site].
Release of Solid Materials at Licensed Facilities: Issues Paper, Scoping
Process for Environmental Issues, and Notice of Public Meetings; Federal
Register / Vol. 64, No. 125 / Wednesday, June 30, 1999:
"...the values of which were based principally
on the detection capabilities of readily available instrumentation at the
time the guide was developed. The surface contamination levels were not
based on the potential dose to an individual that may result from coming in
contact with the released materials although such exposure is estimated to
be low. Regulatory Guide 1.86 does not contain dose criteria."
ANSI N13.12; August 1999 (p. 36):
" ...the groupings in Regulatory Guide 1.86
were primarily based on instrumentation detectability and are quite broad
(i.e., the general beta gamma emitter category included radionuclides that
produced highly different scenario results such as 60Co and 99Tc). Also,
since detectability, inhalation (through association with maximum
permissible concentrations in air), and ingestion (through association with
maximum permissible concentrations in water) were the primary bases for
Regulatory Guide 1.86, disagreements with the results of a full modeling
analysis can be anticipated."
The Disposition Dilemma: Controlling the
Release of Solid Materials from Nuclear Regulatory Commission-Licensed
Facilities National Academy of Sciences; 2002 (p. 41):
"...Table I guidance had been in informal use
for some time before 1974 and apparently was based on the detection limits
of the instruments available at that time, not on an assessment of risk."
Please visit this page again
soon for additional questions submitted to our D&D experts and the answers
that may assist you!
Return to Q&A Page