# Presentation: 438689

## Radiological Control & Clearance of Property and DOE 5400.5 – Part 835 interfaceAndrew WalloNovember , 2007U.S. Department of EnergyOffice of Nuclear Safety and Environment (HS-20)

## Outline 

- Guidance and Supporting Tools
- Good Practices and Opportunities for Improvement
- Status of Volumetric Moratorium and Metals Recycle Suspension
- Authorized Limits Review and Approval Process
- Additions due to Part 835 Revision
- Revision of DOE Order 5400.5 and Associated Guidance: Opportunities for Clarification of Property Release Requirements

**Outline**

##  Control of Property Under DOE 5400.5:  Authorized Limits

** ****Control of Property Under**** DOE 5400.5:  ****Authorized Limits**

## DOE’s Radiation Protection Framework

_***Directive:***_	DOE Order 5400.5, Radiation Protection 		of the Public and the Environment
_***Related:***_
- DOE O 450.1, Environmental Protection Program
- DOE P 454.1, Institutional Controls Policy
- 10 CFR Part 835 Occupational Radiation Protection
- DOE O&P 226.1 Oversight Policy and Order
- DOE O 231.1 – ES&H Reporting
- DOE P 1210.1 – Public Participation
- DOE O 435.1 – Radioactive Waste Management

**DOE’s Radiation Protection Framework**

##  Clearance of Property:  Principal Requirements

- Derived through ALARA options analysis
- Property must be radiologically characterized or surveyed
- Public involvement and notification
- Comply with applicable federal and state requirements
-  Independent verification prior to property release
- Final documentation approved by DOE to demonstrate all requirements have been met; specifying any restrictions
- Records maintenance and reporting

** ****Clearance of Property:  ****Principal Requirements**

## DOE Dose Limit and Constraint

- 100 mrem/yr all sources and pathways
_**Dose Constraint**_** **
***Real Property****:*
- 25 mrem/yr, with a goal of a few mrem/yr or less
- Contingency analysis for worst plausible use
***Personal Property****:*
- Goal of <1mrem/yr and <10 person-rem
- Clearance at higher doses possible up to few mrem/yr should be for a restricted or specified use

**DOE Dose Limit ****and Constraint**

## Surface Activity on Property

- Used in lieu of dose constraint and dose assessment
- Application of ALARA process still required
- May be qualitative
- More detailed for certain radionuclides (e.g., Pu-239 and Th)
- Concentration limits provided for Ra-226 in soil and Rn-222 in structures

**Surface Activity ****on Property**

## Surface Activity Guidelines

**Surface Activity ****Guidelines**

## Key Guidance and Tools (www.hss.energy.gov/nuclearsafety/nsea/oepa) Search “Rad Protection (AEA)”

- EH Guidance Memorandum (1995)
- ALARA Guide, Volumes 1 and 2 (1997)
- Modeling Tools:
- RESRAD and RESRAD-OFFSITE
- RESRAD-BUILD
- RESRAD-RECYCLE
- TSD DOSE

**Key Guidance and Tools** _**(www.hss.energy.gov/nuclearsafety/nsea/oepa)**_ **Search “Rad Protection (AEA)”**

## Guide for Control and Release of Property with Residual Radioactive Material(DOE G 441.xx)

- Integrates policy memoranda with DOE Order 5400.5 requirements
- As allowed by DOE Order 5400.5, contains guidance on flexibility to permit use of DOE approved dose-based authorized limits

**Guide for Control and Release of** **Property with Residual Radioactive Material****(DOE G 441.xx)**

## DOE Property Release Limitation on Scrap Metal

- Release of volumetrically contaminated metal (January 2000)
- Metal with potential for volumetric residual activity
- Then, may not disposition into commerce for unrestricted use
**Secretarial Suspension**
- Recycle of scrap metal (July 2000, modified January 2001)
- Scrap metal in radiological area (per 10 CFR 835)
- Then, may not disposition for unrestricted recycle into commerce
**Both are Still in Place**
**EM Mixed Waste Moratorium and No Rad Added P.O.s**

**DOE Property ****Release Limitation on ****Scrap Metal**

## Opportunities for Improving DOE Release Practices

- “There is a need to improve radiation monitoring, independent verification, and record keeping and reporting.  We must also better engage the public in our decision making and help them better understand our release practices.”
- “These steps are consistent with existing provisions of DOE Order 5400.5 and should be incorporated into your existing release programs.”
- 												Secretary of Energy
- 					January 19, 2001

**Opportunities for Improving ****DOE Release Practices**

## Additional Areas for Improvement

- Well-defined, documented, and approved authorized limits
- Line management, in particular Field Offices, has the responsibility to ensure that contractors and DOE personnel comply with release requirements
- Internally review control and release of property systems and programs
- Appropriate independent verification

**Additional Areas for ****Improvement**

## A Guide to Good Practices for the Control and Release of Property

**Authorized limits **should not be an afterthought but should be integrated into life-cycle project planning.
**Key elements include:**
- Identifying needed authorized limits early;
- Applying DOE pollution prevention policies and guidance such that property is controlled and released in a manner that reduces or prevents the generation of new waste and pollutants, reduces the further contamination, and reduces life-cycle costs;
- Keeping stakeholders appropriately informed of authorized limits and release processes;
- Developing, coordinating, and obtaining appropriate DOE approval for and documentation as soon as practical in the contractor’s work planning and execution process; and
- Conducting self-assessments within the program, and implementing independent verification as part of DOE oversight activities.

**A Guide to Good Practices for the Control and Release of Property**

## Plans for Clarifying Process   

- DOE 5400.5 in Revision Process
- Guide 441.xx part of process
- Moratorium and Suspension?
- In interim HSS will issue Bulletin to address process given HSS creation and Part 835 recent revision

## DOE Real Property Release Review & Approvals

| Real Property | Approval | Time Required | Comments or Other Conditions |
| --- | --- | --- | --- |
| Lands (soil criteria) | Field Manager and PSO | Depends on Program circumstances | Depends on approval being delegated |
| Structures(Using SAGs)
 | Field Manager and PSO | Depends on Program circumstances | Depends on approval being delegated |
| Dose-based or with alternative surface limits | Field Manager and PSO | Depends on Program circumstances | Depends on approval being delegated: HS-20 for review |

## DOE Personal Property Release Review & Approvals

| Personal Property | Approval | Time Required | Comments or Other Conditions |
| --- | --- | --- | --- |
| Using Surface Activity Guidelines | Field Manager and PSO | Depends on Program circumstances | Inform HS-20(document in ASER) |
| Using dose-based; volume or in mass limits or alternative
  surface limits | HS-1
And For NNSA in coordination with NA-1 | Depends on complexity: desired 30< x< 45 working days for final package | Informal coordination with HS-20 recommended prior to submittal |
| Expedited Process if conditions met | HS-1 pre-approved, Field Manager with PSO submit to 
HS-20  | 30 working days(for HS-20 review and verification) | If Field to confirm pre-approval conditions are met; HS review  |
|  |  |  |  |

## Part 835 Exclusion

- (b)	_Exclusion._  Except as provided in paragraph (c) of this section, the requirements in this part do not apply to:
- (6) Radioactive material on or within material, equipment, and real property which is approved for release when the radiological conditions of the material, equipment, and real property have been documented to comply with the criteria for release set forth in a DOE authorized limit which has been *approved by a Secretarial Officer in consultation with the Chief Health, Safety and Security Officer.*

## Effects on ProcessIf Exclusion is Applicable 

**For the exclusion to apply,**
**new authorized limits must be approved by a secretarial officer in consultation with HSS.**
*Submit authorized limits to HS-20 and they will be coordinated in HSS (estimated response times will be longer)*
*Program Office approval procedures are to be defined by each office (cannot be delegated to field or site office)*
**Previously approved authorized limits for personal property:**
*need not be resubmitted to HSS*
*If they were not specifically approved by the HQ Program Office they need to be*
**Although HSS has assisted in numerous real property authorized limits, there are few that were coordinated and officially approved.**
*Need to be submitted to HS-20 for HSS coordination*
*Program Office needs to define process for approval. *

## Review of Authorize Limits: Frequent HS-20 Comments

- Include actual waste stream characterization data
- Include discussion of site procedures:
- Survey & release of the property
- Documentation, tracking, and reporting
- Independent verification
- Environmental background of radionuclides not included
- Estimated total volume and activity to be released

## Review of Property Releases: Frequent HS-20 Comments (continued)

- ALARA assessment:
- Considered various (higher/lower) concentrations?
- Provided collective dose estimate
- Various property disposition alternatives considered?
- Rely on average/expected concentrations; not on maximum concentrations
- Rely on reasonable & likely scenario; not on a bounding worst case, one
- Inform or coordinate with State or NRC

## DOE Order 5400.5 is the primary radiation protection standard used to protect the public and the environment from undue risk of radiation associated with DOE operations

- Establishes requirements and framework for the release of property (real and personal) with residual radioactivity from DOE control
- Last revised in 1993, DOE Order 5400.5 remains effective and continues to provide protection

**DOE Order 5400.5  ****Radiation Protection of the Public and the Environment**

## Why is HSS Revising DOE Order 5400.5?

- To meet a requirement established by the Office of Management (MA-1) in November 2006 to revise Orders and Manuals with a 4-digit numbering system
- To comply with format and content standards in DOE M 251.1-1B, *Departmental Directives Program Manual*
- To highlight current organizational structure, and to include roles and responsibilities for the National Nuclear Security Administration (NNSA) and the Office of Health, Safety and Security (HSS)
- To reflect today’s radiation protection concepts, technical standards and practices
- For consistency with June 2007 amendments to DOE’s Occupational Radiation Protection Rule (10 CFR 835)

**Why is HSS Revising DOE Order 5400.5?**

## DOE Order 5400.5 Work Group

**Purpose:**** **
- To encourage early interaction between HSS and other DOE elements, HS-1 requested participation by DOE Program Offices, including sites under their purview, on a Work Group to revise DOE Order 5400.5
**Goals: **
- Active and full participation by DOE radiation protection experts from across the DOE complex to assist HSS develop the revised Order
- Exchange of viewpoints on technical and policy issues related to proposed revisions and accommodation of different views by Work Group members in revising the Order to the extent possible
- A framework to foster consistency and flexibility in implementation of the revised Order
- Recommendations to HSS in identifying and prioritizing the development of final implementation guides for the revised Order

**DOE Order 5400.5 ****Work Group**

## Contacts for Additional Information and Assistance

**Gustavo Vazquez, 202-586-7629 **_[gustavo.vazquez@hq.doe.gov](mailto:gustavo.vazquez@hq.doe.gov)__** **_
**Colleen Ostrowski, 202-586-4997**
**  **_[colleen.ostrowski@hq.doe.gov](mailto:colleen.ostrowski@hq.doe.gov)_
**Edward Regnier, 202-586-5027**
**  **_[edward.regnier@hq.doe.gov](mailto:edward.regnier@hq.doe.gov)_

**Contacts for Additional ****Information and Assistance**