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Regulations, Guidelines, Standards

Submitted 2/18/04
Q: 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?

A: Given 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."

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