8/18/2010robert fairchild lbnl metals moratorium robert fairchild lawrence berkeley national lab...

8/18/2010 Robert Fairchild

LBNL Metals Moratorium

Robert FairchildLawrence Berkeley National Lab

Radiation Protection Group

ASW-2010 Metals Moratorium Breakout Session


Moratorium vs. Suspension

• Moratorium (known rad-added)• Suspension (possible rad-added)


July 13, 2000 Suspension Letter

• No detectable contamination using appropriate commercially available monitoring equipment and approved procedures.

• Maintain records on releases, such that records are easily accessible to members of the public.

• Must seek local public participation before resuming unrestricted release into recycling.


July 2000 Suspension FAQ from Office of Environmental Policy and Guidance, Air, Water and Air Division.

• Defines recycle as melting and production of new product from metal• Does not apply to:

o Release of material (including public sale) if reused for intended purpose (machine tool example in Q/A #s 4, 6)

o Non-metalso Recycle and reuse within DOE complex or transfer to individuals licensed to use

such material, but not with intent to recycle (Q/A #16, 17)o Property released prior to July 13, 2000o Metals in light bulbs, batteries, etc. (Q/A #14)o Rebar in concrete (Q/A #19)

• May dispose of metals at an offsite disposal facility if the metals meet release criteria (Q/A #11)


January 19, 2001 Suspension Letter Update

• Clearly define areas that can potentially contaminate materials and equipment

• Clearly define release criteria, including measurement and survey protocols

• Ensure released materials meet DOE release criteria• Better inform and involve the public• Include release program information in the annual site

environmental report


LBNL Implementation

• Implementation Agreement between BSO and LBNL (August 9, 2000)

• Agreement emphasized potential for contamination, not dose rate in area (e.g. Contamination Area vs. Radiation Area)o All Controlled Areas at accelerators where metals may have become

activatedo Contamination Areaso Metals stored in other areas that may have been removed from accelerator

Controlled Areas and not previously released (e.g. stored in Radioactive Materials Area).

• Use existing radiological clearance procedure (implements DOE O5400.5), modification required to address Suspension requirements.

• Did not account for information in the July 2000 FAQ


Implementation Agreement between BSO and LBNL revised (April 22, 2005)

• Accounted for information in FAQ• Better defined accelerator Controlled Areas where activation is

possible and required specific boundaries to be identified during any demolition project.

• Excluded rebar and other embedded metals in concrete as long as they meet release criteria.

Reviewed and updated in 2008


EH&S Procedure 708, Survey of Potentially Contaminated Materials and Equipment for Unrestricted Release

• Survey with 1x1 NaI or equivalent for potential activation (assumes self shielding for alpha/beta

• If thin item (e.g. target foil), also survey with alpha/beta probe (e.g. Ludlums 43-89)

• Swipes/samples as necessary/appropriate


Release Criteria

• No distinguishable count rate increase above background with NaI. This is left up to the RCT to decide if they believe they discern an increase above background.

• Below surface contamination limits (5400.5)


Control of Released Material

• Tagged with Radiological Release (green) tag.• Metals suspension materials have label stating that the materials

have been surveyed and found to be free of radioactivity, but are subject to the suspension.

• If destined for disposal, material is held in a closed-top and locked roll-off container pending transfer to local landfill.


Disposition

• Sent to excess equipment to be reused within DOE or sold (rare)• Buried at local sanitary landfill

o Landfill contract prohibits reclaiming of materials for recyclingo Landfill provides certificate of burial for each load of metal


QUESTIONS?

8/18/2010robert fairchild lbnl metals moratorium robert fairchild lawrence berkeley national lab...

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