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Decommissioning Plan Schwartzwalder Mine <br /> <br /> <br />RML CO -369-06 <br />Cotter Corporation (N.S.L.) 12 March 2017 <br />3.0 CRITERIA FOR LICENSE TERMINATION <br />Radiological criteria for license termination are usually based on concentrations of residual <br />radioactive material which allow release for unrestricted use. In this case, “release” pertains only <br />to RML areas with respect to license termination as the site as a whole is still subject to <br />decommissioning oversight by the Colorado Department of Reclamation, Mining and Safety <br />(DRMS) under reclamation permit M-77-300. <br /> <br />3.1 Structures and Equipment <br />Structures and equipment shall not be released for unrestricted use unless levels of residual <br />radioactivity on surfaces satisfy the applicable activity limits as shown in Table 3 for U-nat and <br />its decay products. <br /> <br />Table 3: Release criteria for buildings and equipment (NRC, 1993) <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br />3.1.1 Preliminary Scoping <br />The preliminary scoping survey of OWTP building structures and equipment in RML #2 was <br />performed in 2008 for 44 survey locations, including floors, walls, exterior surface of the former <br />IX column, cabinets, and other targeted surfaces and equipment. Frequency histograms of the <br />data (Figure 8) at that time showed that only 2 of the 44 locations exceeded a release limit (for <br />total activity), including a sink and countertop associated with a former laboratory area. <br />Additional contamination surveys will be performed on the remaining equipment and building <br />surfaces after the IX treatment system is relocated to the NWTP. Items will be decontaminated to <br />meet release limits or disposed. <br /> <br />3.1.2 NWTP Contamination Surveys <br />For the IX treatment system in the NWTP (RML #4), contamination survey locations will <br />include the interior and exterior surfaces of ion exchange vessels, piping and other targeted <br />surfaces and equipment. Surfaces exceeding the release limits will be decontaminated and <br />resurveyed. For equipment that cannot be released for unrestricted use due to contamination <br />levels, such as on the interior surfaces of the IX vessels and piping, these items may be <br />transferred from the site as U. S. DOT “surface contaminated objects” SCO-1, UN 2913 to <br />another party licensed to receive these materials for possible use at another treatment site. The <br />other option for equipment that fails to meet the unrestricted release criteria is to place these <br />items into the Minnesota Adit for disposal. <br /> <br />A final status survey of the building surfaces within the restricted area of the building which <br />housed the IX treatment system and resin storage totes will be conducted. These surveys will be <br />Removable Surface Ave.Total Activity Max.Total Activity <br />Element Activity (fixed +removable)(fixed +removable) <br />(d/m-100 cm2)(d/m-100 cm')(d/m-100 cm2) <br />det ts 14000 (total alpha)5 DOO-(total alpha)15,000 (total alpha) <br />Th-nal 200-1;OOD 3000 <br />Betargamma 4000 5,000 15ß00EmRters