As a result of discussions held at the Accelerator Safety Conference at the Spallation Neutron Source (SNS) in August, we are developing a request to the Department of Energy (DOE) for approval to release bulk material that has been exposed to particles capable of creating activation products. This approval would be limited to bulk material which has potentially been made radioactive as a result of beam operations at accelerators. The proposed concept is that a surface radioactivity measurement showing levels less than the established surface contamination guidelines (from DOE Order 5400.5 or 10 CFR 835) indicates a material is safe to release without restriction. We can perform some limited pathway analyses in support of this concept, but these examples will have to be illustrative rather than exhaustive if we seek approval for release of all materials. The initial request will be for a nation-wide approval, not limited to one site or field office, and hopefully not limited to just a few materials.
In support of this proposal, I would be very interested in any surface radiation measurements which can be tied to analytical data for bulk-activated material. It seems that the most useful information would tie positive surface radioactivity measurements to quantified bulk activation in a uniform material. I would also appreciate any current approvals of this type another site may have either proposed to DOE or perhaps even had approved.