Development of Doe Complexwide Authorized Release Protocols for Radioactive Scrap Metals

Within the next few decades, several hundred thousand tons of metal are expected to be removed from nuclear facilities across the U.S. Department of Energy (DOE) complex as a result of decontamination and decommissioning (D&D) activities. These materials, together with large quantities of tools, equipment, and other items that are commonly recovered from site cleanup or D&D activities, constitute non-real properties that warrant consideration for reuse or recycle, as permitted and practiced under the current DOE policy. The provisions for supporting this policy are contained in the Draft Handbook for Controlling Release for Reuse or Recycle of Property Containing Residual Radioactive Material (1) published by DOE in 1997 and distributed to DOE field offices for interim use and implementation. The authorized release of such property is intended to permit its beneficial use across the entire DOE complex. To facilitate the release process for radioactive metals, a computerized management tool – P2PRO(RSM) – has been developed with protocols for implementing the Handbook provisions regarding release of scrap metals for reuse and recycle. The protocols provide DOE with an effective oversight tool for managing release activities. INTRODUCTION Provisions for release of DOE property containing residual radioactivity have been specified in DOE Order 5400.5, “Radiation Protection of the Public and Environment” as amended, which was first issued on February 8, 1990. On March 25, 1993, DOE proposed to codify (proposed rule 10 CFR 834) standards and requirements that have been further interpreted in DOE guidance. Releases have generally been limited to materials with surface contamination, for which explicit release levels have been prescribed in Order 5400.5. Although these release levels were not specifically related to dose or risks, a screening analysis indicated that the implied doses to a hypothetical individual are largely at a level of a few mrem/per year (2). No equivalent release levels for materials with volumetric contamination are currently sanctioned by DOE or any U.S. regulatory agency. Because of the lack of explicit release standards, a process of “authorized” release, which is based on a case-by-case (but systematic) approach, is permitted under the existing Order 5400.5 or the proposed rule of 10 CFR 834. This approach provides for the development of authorized release limits through a series of prescribed steps before approval for release is granted. Specific requirements include the following: (1) pertinent radiological characteristics are identified and specified for the materials, (2) release limits are derived to meet the as-low-as-reasonably-achievable (ALARA) WM'99 CONFERENCE, FEBRUARY 28 MARCH 4, 1999 objectives, (3) requisite documentation is complete and approved by DOE authorities, and (4) concurrence by appropriate stakeholders is sought and obtained. Although authorized release has been ongoing within DOE, the applications have primarily been limited to scrap metals with only surface contamination. Furthermore, the practice has lacked systematic and detailed guidance. In support of the authorized release, the DOE has published interim guidance that has been incorporated into the proposed ruling of 10 CFR 834. To further clarify the provisions and to implement the policy, the Draft Handbook for Controlling Release for Reuse or Recycle of Property Containing Residual Radioactive Material (1) (herein referred as the Handbook) was published by DOE. The document has been distributed throughout DOE field offices for interim use and implementation. The release process prescribed by the Handbook applies only to non-real DOE property for which the preferred future use involves reuse or recycle. Release occurs when the property is transferred out of DOE control by sale, lease, gift, or other disposition, provided that the property does not remain under the radiological control of DOE, the U.S. Nuclear Regulatory Commission (NRC), or a responsible Agreement State. The release does not apply to real property, radioactive wastes, soils, liquid discharges, or gaseous or radon emissions. Examples of categories of property that are covered include: • Consumable Items such as wood, containers, labwares, and paper; • Personal Items such as clothing , brief cases, bags, respirators, and gloves; • Office Items such as computers, telecommunication equipment, unused office supplies, and furniture; • Tools or Equipment such as hand tools, construction machinery, vehicles, tool boxes, ladders, and scales; and • Scrap materials such as wood, tanks, scrap metals, concrete, wiring, doors, and windows. The authorized release approach described in the Handbook consists of 10 steps for nonreal property that address the general areas of property characterization, evaluation and development of authorized limits, approval of release, verification and implementation of release. It is important to note that authorized or supplemental limits may be derived for individual releases of non-real property (e.g., one-time sale of reusable copper wire), or for categories of non-real property (e.g., scrap metal or office machines) that are routinely released over time. In the latter case, once authorized limits (or supplemental limits [the secondary limits applied only to special conditions]) have been approved for the category, individual releases of non-real property within the category are assumed to meet ALARA requirements if compliance with the limits has been demonstrated. Therefore, the entire 10-step process is not necessarily required for each proposed release. Determining the possible existence of previously established authorized or supplemental limits applicable to the proposed release is addressed early in the 10-step process. The 10 major steps of the release process for non-real property are as follows (3): WM'99 CONFERENCE, FEBRUARY 28 MARCH 4, 1999 • Characterize property and prepare a description. • Determine whether applicable authorized or supplemental limits exist. • Define authorized or supplemental limits needed. • Develop authorized or supplemental limits. • Compile and submit application for DOE Operations Office approval. • Document approved limits in the public record. • Implement approved limits. • Conduct surveys/measurements. • Verify that applicable authorized or supplemental limits have been met.