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NRC licensees are responsible for every bit of licensed radioactive material that they possess. Every facility has procedures for surveying items and personnel leaving the radiologically controlled area to ensure contamination control. But every place where contamination is monitored has natural background radiation levels, which fluctuate at least slightly from moment to moment, and the contamination survey instruments are good at detecting both background and contamination, but are not good at distinguishing between the two. Many facilities allow clean release if the survey reveals less than 100 counts per minute above background levels. In the late 1980s, NRC Region I inspector Sammi Sherbini brought this matter up as an unresolved item in an inspection of a commercial nuclear plant. He asked why the plant could allow release of anything above background. More than twenty years later, a comment by Nuclear Energy Institute on a proposed NRC Regulatory Guide, and NRC staff's response, reminded me of Sherbini's discussion:
Excerpt from p10 - NEI comment re Section C 1.4, "Surface Contamination Surveys," Paragraph e: This section implies that licensees have surface contamination limits. Rather, licensees have "acceptable levels" since there is no technical basis for surface contamination limits.
NRC response: The intent of RG 8.24, Section C.1.4,, Paragraph e. is that licensees will propose and justify allowable surface contamination limits, at which point decontamination will be implemented.
The first two sentences of RG 8.24, Section C.1.4, Paragraph e. read: “The regulations in 10 CFR Part 20 do not specify limits for surface contamination. Each applicant may propose and justify surface contamination limits allowable before decontamination is required in each work area.”
The last sentence of RG 8.24, Section C.1.4, Paragraph e. reads: “Appendix A of this regulatory guide presents the contamination limits for controlled areas that the NRC staff considers acceptable and that the applicant does not need to justify.”
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