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LBNL Metals Moratorium. Robert Fairchild Lawrence Berkeley National Lab Radiation Protection Group ASW-2010 Metals Moratorium Breakout Session. 8/18/2010. Robert Fairchild. Moratorium vs. Suspension. Moratorium (known rad-added) Suspension (possible rad-added). 8/18/2010.
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LBNL Metals Moratorium Robert Fairchild Lawrence Berkeley National Lab Radiation Protection Group ASW-2010 Metals Moratorium Breakout Session 8/18/2010 Robert Fairchild
Moratorium vs. Suspension • Moratorium (known rad-added) • Suspension (possible rad-added) 8/18/2010 Robert Fairchild
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. 8/18/2010 Robert Fairchild
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: • Release of material (including public sale) if reused for intended purpose (machine tool example in Q/A #s 4, 6) • Non-metals • 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) • Property released prior to July 13, 2000 • Metals in light bulbs, batteries, etc. (Q/A #14) • Rebar in concrete (Q/A #19) • May dispose of metals at an offsite disposal facility if the metals meet release criteria (Q/A #11) 8/18/2010 Robert Fairchild
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 8/18/2010 Robert Fairchild
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) • All Controlled Areas at accelerators where metals may have become activated • Contamination Areas • 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 8/18/2010 Robert Fairchild
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 8/18/2010 Robert Fairchild
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 8/18/2010 Robert Fairchild
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) 8/18/2010 Robert Fairchild
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. 8/18/2010 Robert Fairchild
Disposition • Sent to excess equipment to be reused within DOE or sold (rare) • Buried at local sanitary landfill • Landfill contract prohibits reclaiming of materials for recycling • Landfill provides certificate of burial for each load of metal 8/18/2010 Robert Fairchild
QUESTIONS? 8/18/2010 Robert Fairchild