The PDF version 
NOT MEASUREMENT
SENSITIVE
DOE G 441.1-XX
XX-XX-02
IMPLEMENTATION GUIDE
CONTROL AND RELEASE OF PROPERTY WITH
RESIDUAL RADIOACTIVE MATERIAL
for use with DOE 5400.5, Radiation Protection
of the Public and the Environment
[This Guide describes suggested nonmandatory approaches for meeting requirements. Guides are not
requirements documents and are not construed as requirements in any audit or appraisal for compliance
with the parent Policy, Order, Notice, or Manual.]
U.S. Department of Energy
Washington, D.C. 20585
DISTRIBUTION:INITIATED BY:
All Departmental ElementsOffice of Environment, Safety and Health CONTENTS
ACRONYMS . . . . . . . . . . . . . . . . . . . . . . . . . . .vii
1. PURPOSE, SCOPE, AND ORGANIZATION . . . . . . . . . . . . . .1
1.1 PURPOSE AND SCOPE. . . . . . . . . . . . . . . . . . . . .1
1.2 ORGANIZATION . . . . . . . . . . . . . . . . . . . . . . .1
1.3 ENHANCEMENTS AND IMPROVEMENTS TO DOE'S
MONITORING AND RELEASE PRACTICES . . . . . . . . . . . . .2
2. DEFINITIONS. . . . . . . . . . . . . . . . . . . . . . . . .5
3. PRINCIPAL REQUIREMENTS . . . . . . . . . . . . . . . . . . .7
3.1 DOSE LIMITS AND CONSTRAINTS. . . . . . . . . . . . . . . .7
3.1.1 Dose Limit . . . . . . . . . . . . . . . . .7
3.1.2 Dose Constraint. . . . . . . . . . . . . . .7
3.2 ALARA PROCESS. . . . . . . . . . . . . . . . . . . . . . .8
3.3 RADIOLOGICAL SURVEYS . . . . . . . . . . . . . . . . . . .8
3.4 PUBLIC INVOLVEMENT AND NOTIFICATION. . . . . . . . . . . .8
3.5 VERIFICATION AND QUALITY ASSURANCE . . . . . . . . . . . .9
3.5.1 Verification . . . . . . . . . . . . . . . .9
3.5.2 Quality Assurance. . . . . . . . . . . . . .9
3.6 PROCESS AND HISTORICAL KNOWLEDGE CLEARANCE
OF PROPERTY. . . . . . . . . . . . . . . . . . . . . . . 10
3.7 COMPLIANCE WITH OTHER APPLICABLE FEDERAL OR STATE
REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . 10
3.8 FINAL DOCUMENTATION AND AVAILABILITY . . . . . . . . . . 10
3.8.1 Specific Elements of the Final Documentation10
3.8.2 A Graded Approach to Documentation . . . . 11
3.9 RECORDS MAINTENANCE AND REPORTING. . . . . . . . . . . . 11
4. THE RELEASE OPTIONS ANALYSIS PROCESS . . . . . . . . . . . 13
4.1 DOE ALARA PRINCIPLES AND PROCESS AS THE BASIS
FOR AUTHORIZED RELEASE LIMITS. . . . . . . . . . . . . . 13
4.1.1 ALARA Requirements . . . . . . . . . . . . 13
4.1.2 ALARA Principles and Process . . . . . . . 13
4.1.3 Guidance for Implementing the ALARA Process13
4.2 USE SCENARIOS AND LIMITS FOR AUTHORIZED RELEASE. . . . . 14
4.2.1 Doses Under Likely Use Scenarios . . . . . 14
4.2.2 Doses Under Worst Plausible Use Scenarios. 14
CONTENTS (continued)
4.3 EVALUATION OF INDIVIDUAL DOSE IN THE RELEASE
OPTIONS ANALYSIS PROCESS . . . . . . . . . . . . . . . . 15
4.4 EVALUATION OF COLLECTIVE DOSE IN THE RELEASE
OPTIONS ANALYSIS PROCESS . . . . . . . . . . . . . . . . 15
4.4.1 Collective Dose. . . . . . . . . . . . . . 16
4.4.2 Appropriate Time Intervals for Integrating Collective Doses
and for Assessing Doses to Current versus Future Generations16
4.5 EVALUATION OF OTHER FACTORS IN THE RELEASE OPTIONS
ANALYSIS PROCESS . . . . . . . . . . . . . . . . . . . . 18
5. SPECIFIC APPLICATIONS OF THE AUTHORIZED RELEASE PROCESS. . 19
5.1 NATURALLY OCCURRING AND ACCELERATOR-PRODUCED
RADIOACTIVE MATERIAL . . . . . . . . . . . . . . . . . . 19
5.2 SOILS. . . . . . . . . . . . . . . . . . . . . . . . . . 19
5.2.1 Appropriate Averaging Areas for Authorized Releases19
5.2.2 Hot-Spot Criteria. . . . . . . . . . . . . 20
5.3 RADIUM AND RADON . . . . . . . . . . . . . . . . . . . . 21
5.3.1 Radium . . . . . . . . . . . . . . . . . . 21
5.3.2 Radon. . . . . . . . . . . . . . . . . . . 22
5.4 SURFACE ACTIVITY ON PROPERTY (STRUCTURES AND
PERSONAL PROPERTY) . . . . . . . . . . . . . . . . . . . 22
5.4.1 Surface Activity Guidelines. . . . . . . . 22
5.4.2 Surface Activity Guidelines and Their Use in Setting Authorized
Limits for Buildings. . . . . . . . . . . . . . . . 23
5.4.3 Surface Activity Guidelines for Tritium. . 23
5.4.4 Surveys and Measurements . . . . . . . . . 25
5.5 VOLUME AND MASS CONTAMINATION AND ALTERNATE
SURFACE LIMITS . . . . . . . . . . . . . . . . . . . . . 25
5.6 RELEASE OF PERSONAL PROPERTY INCLUDING EQUIPMENT . . . . 26
5.7 RELEASE OF PROPERTY TO DOE ONSITE LANDFILLS. . . . . . . 27
5.8 RELEASE OF PROPERTY TO OFFSITE LANDFILLS . . . . . . . . 29
6. POSTING AND PROPERTY CONTROL . . . . . . . . . . . . . . . 31
6.1 UNRESTRICTED AND RESTRICTED RELEASE OF PROPERTY. . . . . 31
6.2 DOE-OWNED PROPERTY . . . . . . . . . . . . . . . . . . . 31
6.3 NOTEWORTHY DIFFERENCES BETWEEN 10 CFR 835 AND
DOE 5400.5 POSTING REQUIREMENTS. . . . . . . . . . . . . 31
7. ORGANIZATIONAL APPROVALS . . . . . . . . . . . . . . . . . 35
CONTENTS (continued)
7.1 CONDITIONS FOR EXPEDITED APPROVAL. . . . . . . . . . . . 35
7.2 REQUESTS FOR TECHNICAL ASSISTANCE. . . . . . . . . . . . 36
8. REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . 39
APPENDIX A. SECRETARIAL MEMORANDUMS REGARDING POLICY
AND GUIDANCE FOR MANAGING THE RELEASE OF
DOE SURPLUS AND SCRAP MATERIALS . . . . . . . . . .A-1
APPENDIX B. OVERVIEW OF SUPPORTING GUIDANCE AND TOOLS . . . .B-1
This page intentionally left blank. ACRONYMS
Ahs
area of the hot spot
ALARA
as low as reasonably achievable
ANSI
American National Standards Institute
CERCLA
Comprehensive Environmental Response, Compensation, and
Liability Act
D&D
decontamination and decommissioning
DOE
U.S. Department of Energy
FR
Federal Register
MARSSIM
Multi-Agency Radiation Survey and Site Investigation Manual
NNSA
National Nuclear Security Administration
NRC
Nuclear Regulatory Commission
RCRA
Resource Conservation and Recovery Act
RESRAD
RESidual RADioactivity
TEDE
total effective dose equivalent
WL
working level
This page intentionally left blank. 1. PURPOSE, SCOPE, AND ORGANIZATION
1.1 PURPOSE AND SCOPE
The U.S. Department of Energy (DOE) operates a variety of nuclear facilities including reactors,
accelerators, and weapons test facilities. Many of these facilities are undergoing remediation
and decommissioning. This Implementation Guide (hereafter referred to as Guide) references
DOE's requirements and presents DOE's guidance for the control and release of property that
may contain residual radioactive material. Implementation guidance is provided for Department
and contractor personnel who perform cleanup of property contaminated with residual
radioactive material and who must determine the disposition of property under the requirements
in DOE 5400.5, Radiation Protection of the Public and the Environment (DOE, 1990), and its
proposed successor, 10 CFR 834, "Radiation Protection of the Public and the Environment."
This Guide is applicable to decommissioning, deactivation, decontamination, and remedial
action of property with residual radioactive contamination.
Guidance for implementing DOE 5400.5 requirements for the release of property has been
provided by the Office of Environmental Policy and Guidance over the past 10 years through
individual memorandums, guidance documents and handbooks, and modeling and analysis tools.
A principal objective of this Guide is to integrate the key elements of these individual guidance
documents and tools into one document as a principal resource for DOE and contractor
personnel.
1.2 ORGANIZATION
Definitions of key terms used in this Guide are provided in Section 2. The Guide then presents
the principal requirements for control and release of property (Section 3); provides
implementation guidance on essential elements of the authorized release options analysis process
(Section 4); and follows with guidance on the authorized release process for specific types of
materials (Section 5). Posting and property control for unrestricted and restricted release of
property is presented in Section 6. Section 7 reviews the organizational approvals required and
the conditions that must be met for DOE field office approval of the release of property.
References are provided in Section 8. Appendix A provides a copy of each of the Secretarial
memorandums cited in Section 1.3. Appendix B provides a list of supporting guidance and tools
for implementing the authorized release process.
1.3 ENHANCEMENTS AND IMPROVEMENTS TO DOE'S MONITORING AND
RELEASE PRACTICES
DOE has been actively reviewing ways to improve its management of materials that might be
released from Departmental control. Several Secretarial memorandums describing recent policy
changes and guidance relative to the control and release of DOE surplus and scrap materials
have been issued during the past 3 years.
On January 12, 2000, DOE placed a moratorium on the release of volumetrically contaminated
metals pending a decision by the Nuclear Regulatory Commission (NRC) on whether to establish
national standards (DOE, 2000a). The NRC continues to review this issue and the moratorium
remains in effect.
On July 13, 2000, DOE suspended the unrestricted release for recycling of scrap metal from
radiological areas within DOE facilities (DOE, 2000b). This suspension was to remain in effect
until improvements in DOE release criteria and information management were developed and
implemented through a revision of DOE 5400.5.
On January 19, 2001, DOE issued a memorandum stating that although DOE had developed
procedures that, when implemented, would permit unrestricted releases of metals for recycling
without detectable radioactive contamination, internal and public comments on these proposed
changes raised significant and substantive issues (DOE, 2001). Consequently additional
deliberation is necessary, and the new requirements are not complete. Therefore, the moratorium
on the unrestricted release for recycling of scrap metals from radiation areas within DOE
facilities remains in effect. The Department also determined that an environmental impact
statement should be prepared to allow an open, healthy discussion of the broadest range of
concerns associated with the unrestricted release of materials from DOE sites. The memorandum
also provided guidance to help DOE sites improve their monitoring and release practices. These
steps are consistent with and serve to emphasize existing provisions of DOE 5400.5 and,
therefore, should be incorporated into DOE's existing release programs.
Details of the Department's guidance for improvements to it's monitoring and release practices
are presented and emphasized in the appropriate sections of this Guide. A summary of the key
elements of the guidance is provided below.
Clearly define areas and activities that potentially can contaminate property. It is
important that DOE evaluate the potential for radiological contamination before property is
released from DOE radiological control. It is necessary for DOE to establish and document
clear process-knowledge-based procedures for those releases that have no potential to
violate DOE's radiological protection requirements. There should be an opportunity for
public participation in establishing and implementing these procedures.
Clearly define release criteria, including measurement and survey protocols, for property
released from areas or activities that have potential to contaminate. Property that cannot be
certified for release through process knowledge procedures must be reviewed using authorized
limit-based release procedures consistent with DOE 5400.5 requirements and associated
guidance. All such property must be appropriately surveyed and its compliance with DOE-
approved authorized limits confirmed.
Ensure that released property meets DOE requirements. DOE has both the authority
and responsibility for regulating the release of property under DOE radiological control.
Line management, in particular field offices, is responsible for ensuring contractors and
DOE personnel comply with DOE requirements. DOE encourages line management to
internally review property release and control systems to ensure they are compliant with
DOE directives. In addition, DOE field offices, working with their lead program offices,
should establish independent verification programs to further confirm that survey and
evaluation processes are in place and are being appropriately implemented and that
property released from DOE radiological control meets authorized limits.
Better inform and involve the public, and improve DOE reporting on releases. Field
office managers should incorporate information on property control and release programs,
including information on authorized limits, certification and verification survey programs,
and process knowledge decisions, into site public involvement and communications
programs. Site release policies and protocols should be coordinated with the public, and
public input considered in DOE's development and approval of site release programs.
Field office managers should ensure information on authorized limits and surveys and
independent verification program results are included in the site's annual environmental
reports.
This Guide is responsive to the requirements contained in DOE 5400.5 and the policy and
guidance put forth in the Secretarial Memorandums summarized above regarding DOE's control
and release of surplus and scrap materials. The Secretarial Memorandums cited above are
provided in Appendix A of this Guide. They can also be downloaded from the Department's
Web site for the management and release of surplus materials, http://www.eh.doe.gov/oepa,
(click on "Focus Areas," then select "DOE Directives Development Initiative for the
Management and Release of Surplus Materials"). A set of answers to frequently asked questions
regarding the July 13, 2000, suspension of the unrestricted release for recycling of scrap metal
from radiological areas within DOE facilities is also available (DOE, 2000c), and can be
downloaded from the Web site referenced above.
This page intentionally left blank.2. DEFINITIONS
Unrestricted Release of Property: A transfer of personal or real property from DOE control
without restrictions or controls on current or future use of the property.
Restricted Release: A transfer of personal or real property from DOE control for a limited,
specifically stated application subject to controls or restrictions on use implemented by a
designated party or through a specific process.
Authorized Limit: A limit on the concentrations of residual radioactive material on the surfaces
of or within property that has been derived consistent with the as low as reasonably achievable
(ALARA) process, given the anticipated use of the property (either restricted or unrestricted),
and that has been authorized by the Department to permit the release of the property from DOE
control.
Supplemental Limit: A DOE-approved limit on the release of property with residual
radioactive material. The supplemental limit is used when circumstances make the authorized
limit inappropriate or impracticable to apply.
Real Property: Refers to land and anything permanently affixed to the land such as buildings,
fences, and those things attached to buildings, such as light fixtures, plumbing and heating
fixtures, or other such items, that would be personal property if not attached.
Personal Property: Property of any kind, except for real estate and interests therein (such as
easements and rights-of-way), and permanent fixtures that are Government-owned, chartered,
rented, or leased from commercial sources by and in the custody of DOE or its designated
contractors. For the purposes of this Guide, examples of personal property include consumable
items such as wood, containers, "labware," and paper; personal items such as clothing, brief
cases, respirators and gloves; office items such as computers, unused office supplies, and
furniture; tools and equipment such as hand tools, power tools, construction machinery, vehicles,
tool boxes, ladders, and scales; and debris such as wood, tanks, scrap metal, concrete, wiring,
doors, and windows. This page intentionally left blank.3. PRINCIPAL REQUIREMENTS
The principal requirements relating to the control and release of property containing residual
radioactive material are presented in DOE 5400.5 (Chapters II and IV). Releases must also be in
compliance with other applicable Federal or State requirements. The principal DOE
requirements are summarized in this section.
DOE's Principal Requirements are Intended to Achieve the Following Goals:
Property is evaluated, radiologically characterized, and, where appropriate, decontaminated before
release.
The level of residual radioactive material in property to be released is as near background levels as
is reasonably practicable, as determined through DOE ALARA process requirements, and meets
DOE authorized limits.
All property releases are appropriately certified, verified, documented, and reported; public
involvement and notification needs are addressed; and processes are in place to appropriately
maintain records.
3.1 DOSE LIMITS AND CONSTRAINTS
3.1.1 Dose Limit
The primary dose limit for any member of the general public is 100 millirem (mrem) total
effective dose equivalent (TEDE) in a year. This limit applies to the sum of internal and external
doses resulting from all modes of exposure to all radiation sources other than background
radiation and doses received as a patient from medical sources [DOE 5400.5, II.1.a.(3)(a)].
3.1.2 Dose Constraint
Because the primary dose limit is for all sources, a dose constraint of one quarter of the primary
dose limit (i.e., 25 mrem/year) is applied to each DOE source or practice. Therefore, authorized
limits for annual dose from the release of property should be as far below 25 mrem as is
practicable. This dose constraint represents an upper bound or "cap" for ALARA-based
authorized limits for release of property containing residual radioactive material. This dose
constraint ensures DOE real property releases are consistent with dose requirements in
10 CFR 20, "Standards for Protection Against Radiation," subpart E, "Radiological Criteria for
License Termination." Additionally, depending on circumstances, DOE 5400.5 either permits or
requires use of concentration-based constraints as well.
3.2 ALARA PROCESS
An ALARA analysis is to be conducted in the assessment of potential release options and to
support the final authorized release option selected for the property being released. DOE
requires all releases and exposures to the public be controlled to ensure they are maintained at
levels that are as low as reasonably achievable below the applicable dose limits. Releases are to
be assessed in a manner consistent with the DOE ALARA process for protection of the public
and environment (DOE, 1997a).
3.3 RADIOLOGICAL SURVEYS
Any property known or suspected to have residual radioactive material must be appropriately
surveyed or characterized (DOE 5400.5). Radiological surveys and measurements of residual
radioactive material on and in property must be adequate to demonstrate that authorized limits
(e.g., established to ensure compliance with the dose limits and based on ALARA process
decisions) are met. Survey protocols, procedures, and equipment must be sufficient to meet data
quality objectives for radiological screening, characterization, certification, or verification, as
appropriate, to ensure the authorized limits for release have been met. Surveys for real (e.g.,
land, structures, and associated fixtures) and personal (e.g., hand tools, material, and equipment)
property should be conducted in a manner consistent with the recommendations contained in the
Environmental Implementation Guide for Radiological Survey Procedures (DOE, 1997b) or, for
real property, the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)
(DOD-DOE-EPA-NRC, 2000). Although the MARSSIM only addresses the survey of surfaces
on real property, the methods and statistical analysis approaches may be useful when evaluating
subsurface conditions and personal property. Surveys designed to support process knowledge
clearance of property should be commensurate with the complexity of the site or property use
history and potential for contamination.
3.4 PUBLIC INVOLVEMENT AND NOTIFICATION
Public participation is a fundamental component of program operations, planning activities, and
decision making within the Department. DOE P 1210.1, Public Participation (DOE, 1994),
presents the purpose, scope, goals, and core values of the Department's policy on public
participation. As mandated by this Policy, public participation programs are being implemented
to promote openness and two-way communication tailored to meet specific program, site, and
stakeholder needs. DOE managers need to include information on the process for evaluating and
setting authorized limits in existing public participation programs. This need was highlighted in
the Department's July 2000 and January 2001 memorandums regarding improvements needed
for DOE's release criteria, information management, and monitoring practices (see Appendix A).
Field office managers should incorporate information on property control and release programs,
including information on authorized limits, certification and verification survey programs, and
process knowledge decisions into site public involvement and communications programs. Site
release policies and protocols are to be coordinated with the public and public input considered
in DOE's development and approval of site release programs. Documentation on all releases
must be made available to the public and the property owner or recipient, as appropriate.
3.5 VERIFICATION AND QUALITY ASSURANCE
3.5.1 Verification
In consultation with the responsible program secretarial offices, DOE field offices should
establish independent verification programs to confirm that survey and evaluation processes are
in place and are being appropriately implemented and that property released from DOE
radiological control meets authorized limits. The DOE organization responsible for the release
of property should verify or provide for independent verification of the radiological condition of
the property before release. Personnel involved in verification must be independent of the
operating contractor and DOE project management responsible for certifying the release or
releasing the property and must report directly to DOE (DOE, 2001). The results of the
verification should also be part of the permanent record of the release. The independent
verification should be commensurate with the scope, complexity, and hazard associated with the
action. It may be accomplished by DOE or independent contractor review of survey protocols
and post-remedial-action data. In more complex situations, it may be necessary to evaluate split
samples or conduct onsite radiological investigations to confirm post-remedial-action survey
results. Where releases are part of regular operations such as the release of excess personal
property, field offices should consider periodic audits of the releases to verify that the authorized
limits are being appropriately implemented.
3.5.2 Quality Assurance
All DOE activities are subject to the Department's quality assurance requirements contained in
10 CFR 830, "Nuclear Safety Management," subpart A, "Quality Assurance Requirements."
These requirements apply to the release and control processes for property containing residual
radioactive material.
DOE elements and DOE contractors or subcontractors involved in radiochemical sampling and
analysis should participate in an interlaboratory comparison program such as the Department's
Environmental Measurement Laboratory Quality Assessment Program and should evaluate the
results to ensure the analyses are meeting data quality objectives. Participation and performance
in this program should be documented as part of the radiological characterization record.
3.6 PROCESS AND HISTORICAL KNOWLEDGE CLEARANCE OF PROPERTY
It is important to evaluate and clearly define areas and activities that potentially can contaminate
property. DOE activities and areas should be evaluated for radiological contamination before
property is released from them. Property may be released from DOE control if it has been
evaluated and determined not to be contaminated with residual radioactive material or has not
been impacted since a previously documented authorized release. Operational records, operating
history, and process knowledge for the property being released should be evaluated. Property
that cannot be certified for release through process knowledge procedures (i.e., if records and
process knowledge are not fully adequate) must be reviewed using DOE's authorized limit-based
release procedures consistent with DOE 5400.5 requirements. All such property must be
appropriately surveyed and its compliance with DOE-approved authorized limits confirmed.
The evaluation process for property clearance should include a periodic review and verification
program to ensure historical and process knowledge clearance is being effectively implemented.
3.7 COMPLIANCE WITH OTHER APPLICABLE FEDERAL OR STATE
REQUIREMENTS
Releases must also be in compliance with other applicable Federal or State requirements. For
example, property may be subject to NRC or Agreement State licensing. The Department will
not transfer licensable materials to members of the public who are not licensed to receive them.
See Section 5.6, "Release of Personal Property Including Equipment," for detailed guidance in
this area.
3.8 FINAL DOCUMENTATION AND AVAILABILITY
Final documentation supporting the release of property [per DOE 5400.5, II.5.c.(5), II.8 and
IV.2] should be made part of the Department's permanent record and should be publicly
available. Documentation should indicate the authorized limits and include other data
supporting the release of property, such as radiological certification and independent verification
results.
3.8.1 Specific Elements of the Final Documentation
The final documentation should
describe the property being released and its radiological history;
identify the DOE-approved authorized limits;
describe the ALARA options analysis and the application of its results in decision making
relative to the property being released;
describe the survey and provide details on instruments used, dates of the surveys, and
results of the surveys;
indicate the final radiological condition of the property;
indicate the quantity and disposition of waste resulting from decontamination of the
property;
identify the disposition of the property;
identify public involvement and notification programs to ensure the public was
appropriately involved and informed of the release of property; and
identify how the final documentation was/will be made available to the public.
Documentation should be at least available in DOE public reading rooms at field or operations
offices. It may also be useful to distribute all or some of the material to local government
organizations and public libraries.
3.8.2 A Graded Approach to Documentation
The contents of documentation or the mechanism for documenting information should be
tailored to the need, situation, and type of property being released. Documentation may describe
the release process and the property regulated by the specific authorized limits, or it may be
specific to the property or to an area from which individual items are released. For example, the
documentation associated with releasing small-sized personal property (e.g., hand tools) may be
different from that for large-sized personal property (e.g., a tractor), and the documentation
associated with releasing real property (e.g., a 1,000-acre site) would be different from that
associated with personal property. Documentation for small-sized personal property, such as
hand tools, could be the record of the clearance process and oversight of the clearance program.
Documentation for large-sized personal property, such as a tractor or bulldozer, could be specific
to the item being released. For real property, such as a 1,000-acre site, one could maintain a
docket on the site.
3.9 RECORDS MAINTENANCE AND REPORTING
All records relating to the release of property from a controlled area are to be maintained in
compliance with DOE O 200.1, Information Management Program (DOE, 1996a), and when
finalized, DOE O 243.X, Records Management Program (DOE, 2000d). DOE sites and
facilities releasing property are to summarize and report these activities in their annual site
environmental reports as required by DOE O 231.1, Environment, Safety, and Health Reporting,
(DOE, 1996b). The annual site environmental report should include DOE authorized limits and
survey and independent verification program results. This page intentionally left blank. 4. THE RELEASE OPTIONS ANALYSIS PROCESS
4.1 DOE ALARA PRINCIPLES AND PROCESS AS THE BASIS FOR AUTHORIZED
RELEASE LIMITS
4.1.1 ALARA Requirements
Doses to the public from residual radioactive material must be maintained as low as is
reasonably achievable below the primary dose limits (DOE 5400.5, II.2). A remedial action goal
should be to return the levels of residual radioactive material in property being considered for
release to near-background levels. In certain cases this may not be practical or even technically
possible. DOE 5400.5 requires that all releases of property be assessed and the ALARA analysis
process applied no matter how small the potential dose from residual radioactive material.
However, the level of detail in the ALARA analysis should be commensurate with the value of
potential-dose reductions.
4.1.2 ALARA Principles and Process
DOE has established a graded level of control and oversight to ensure doses to the public are
low. The degree of control, treatment, processing, and remedial action or other method of
limiting doses to workers and to members of the general public should be determined by
implementing a process that identifies and considers all factors important to decision making
(e.g., in this case, selection of an authorized release option).
ALARA, as Applied by DOE, is a Process
ALARA, as applied by DOE, is not a level or limit to be achieved in controlling radiation exposures or
doses, but rather a process to ensure appropriate factors are taken into consideration in arriving at
decisions that affect the degree of protection against radiation for workers and the public.
4.1.3 Guidance for Implementing the ALARA Process
Guidance has been developed for applying the ALARA process to environmental releases (DOE,
1991a; DOE, 1997a). The guidance (1) identifies factors that should be considered; (2) presents
a logical sequence for assessing these factors to support decision making or options selection;
and (3) references a number of analysis techniques and tools (e.g., cost-benefit analysis;
multiattribute decision theory) that may be used to quantify some of these factors. The guidance
recognizes the difficulties in ascertaining quantitative evaluations of alternative options using
tools such as cost-benefit analyses and acknowledges that decisions must inevitably involve a
great deal of technical and managerial judgment.
4.2 USE SCENARIOS AND LIMITS FOR AUTHORIZED RELEASE
4.2.1 Doses Under Likely Use Scenarios
As stated in DOE 5400.5, authorized limits and, where appropriate, supplemental limits must be
developed for the release of property. DOE line program elements (and under certain
circumstances the Office of Environment, Safety and Health) must review and approve
authorized limits before properties with residual radioactive material are released for unrestricted
or restricted use. The limits should be selected to ensure doses to individuals using the property
under "actual" and "likely use" scenarios will be well below the primary dose limit and at a
level that provides a reasonable expectation doses will be less than the dose constraint of
25 mrem in a year. Based on DOE experience gained in applying these requirements under DOE
5400.5, it is expected doses will be on the order of a few millirem or less in a year. To the
extent practicable, property to be released for use where close contact by users is likely (e.g.,
personal property such as hand tools and chairs) should have no measurable contamination when
leaving DOE control areas.
4.2.2 Doses Under Worst Plausible Use Scenarios
The evaluation to support establishment of an authorized limit also should consider the "worst
plausible use" of the property over the long term. Allowable doses for release of the property
calculated under this type of scenario may be a relatively large fraction of the general dose limit
if the probability of the scenario occurring is relatively low. It is not expected that the worst
plausible use of property will occur, and it is not DOE's intent to permit releases expected to
cause doses that are a significant fraction of the primary dose limit. Rather, this analysis is
conducted to assess potential consequences should restrictions that control use of the material
fail or expectations of use be incorrect. Where analysis of this option suggests the potential for
high doses or a high likelihood for failure of control mechanisms, additional restrictions should
be imposed to reduce such potential or additional measures taken to reduce the potential
consequences. In cases where the probability of the worst plausible use scenario is high and
reasonably certain, the 25-mrem/year dose constraint should be applied, ensuring doses
associated with the potential release would be limited to a very small fraction of the
100-mrem/year dose limit. In such instances, the worst plausible use may be considered the
likely use. No assessment of worst plausible use scenario dose is required where authorized
limits are set at "indistinguishable from background" levels.
4.3 EVALUATION OF INDIVIDUAL DOSE IN THE RELEASE OPTIONS ANALYSIS
PROCESS
Within the authorized release process, it is required that no action will cause individual doses to
a member of the public in excess of the primary dose limit. Given the fact that the primary dose
limit applies to all sources and pathways combined and the assumption there is real potential for
an individual to receive radiation doses from other sources (e.g., NRC- or State- licensed
facilities; normal DOE operating releases), it is not acceptable to release property that is likely to
cause an individual to receive a dose at or near the primary dose limit.
On this basis, DOE requires that authorized limits derived through ALARA options analysis be
constrained at 25 mrem in a year to the maximum exposed individual, considering actual and
likely future use. The ALARA options analysis should assess the benefits, costs, and other
considerations associated with several levels below this dose constraint and result in the
selection of an authorized release option having a dose that is as low as is reasonably achievable.
ALARA Analysis to Demonstrate a Release Option Meets
the 25-mrem/year Dose Constraint
Analysis should be completed for several dose levels, with at least two dose levels below the
25-mrem/year recommended limit.
The dose levels should be spaced to adequately describe the dose cost-benefit relationship.
At least one alternative that controls potential annual individual doses to about 3 mrem or less
should be evaluated. For personal property at least one alternative below 1 mrem/year should be
considered.
This quantitative ALARA analysis is recommended for a dose-based process. If DOE-approved
surface activity guides are used, a more qualitative ALARA analysis can be conducted.
4.4 EVALUATION OF COLLECTIVE DOSE IN THE RELEASE OPTIONS
ANALYSIS PROCESS
Although the individual dose constraint is used to ensure an individual or group of individuals
does not receive an inordinate fraction of a potential dose, in general, it is the collective dose
averted that should be compared to costs and other factors when conducting the release options
analysis process. Therefore, in those cases where collective dose is significant, it should be a
controlling factor in the ALARA analysis on which the authorized limits are based.
4.4.1 Collective Dose
Collective dose is the term used to describe the sum of the doses to all persons from exposures
from a particular radiation source, activity, or site. The unit of collective dose is person-rem.
The collective dose is important because it is assumed to be indicative of the potential number of
radiation-induced health effects to the population from the activity being evaluated. Although
most of the references cited here address potential doses to individuals and do not provide
guidance on estimating collective doses, the dose estimates for individuals should be useful in
making collective-dose estimates.
Collective-dose estimates should be provided for actual or likely use scenarios. In most cases,
collective doses relating to actual use of the site or property need to be assessed quantitatively.
If collective dose under one or more of the various options considered is likely to exceed
100 person-rem from the annual release or the release of the property in that year, an
optimization analysis should be considered. When collective dose from the release is less than
10 person-rem, the primary focus of the ALARA analysis is more likely to be on doses to
individuals; qualitative consideration of collective impacts may be all that is warranted for
situations where collective dose is not significant. It is recommended that ALARA analyses of
one or more alternatives that reduce collective doses to less than 10 person-rem and individual
doses to less than a few millirem in a year be considered.
4.4.2 Appropriate Time Intervals for Integrating Collective Doses and for Assessing
Doses to Current versus Future Generations
Most residual contamination concerns stem from the presence of long-lived radionuclides. In
many instances, for economic reasons, short-lived radionuclides would be permitted to decay
rather than be removed by remedial actions. However, the long-lived contamination might have
the potential for causing doses to persons for more than one generation. In many cases
(primarily those involving personal property), when developing authorized limits for release of
property, evaluations of the potential doses for the first generation of users (i.e., those affected
by the selected scenarios) will provide sufficient data to compare options. However, if screening
assessments suggest doses to future generations may be important to the evaluation of options
(which might be the case for release of real property), optimization analyses should integrate
collective doses for periods longer than the first generation of use, possibly up to 200 years.
Although longer periods may be useful for comparing otherwise equal alternatives, uncertainties
in such data are too large for the data to be useful in quantitative ALARA assessments. It is
therefore recommended that the data for periods exceeding 200 years, when considered, only be
evaluated qualitatively. Where long periods of time are being considered, a multiattribute utility
analysis considering all factors would be a more appropriate assessment tool than standard cost-
benefit techniques.
Ultimate disposal of property with residual radioactive material, by recycle or other means,
should be factored into the policy decision on the cleanup efforts. Determination of the entire
collective doses from unrestricted use of property with residual radioactive material would
require integrating the doses over all time and space, including all affected populations. In most
situations, extensive calculations over time and space are unnecessary for the decision-making
process and may actually be counterproductive. For practical reasons, the integration of
environmental doses for real property assessments are generally limited spatially to about
50 miles (80 kilometers) or less from the source because of the limited availability of population
distribution information and the incomplete knowledge of dispersion of the material in the
environment (DOE, 1997a).
In most cases, collective doses relating to actual use of the site or property need to be evaluated
quantitatively. Offsite exposures or secondary uses need only be addressed if they are likely to
significantly affect the incremental collective dose (e.g., by more than 10 percent). Similarly, as
noted above, the time-integral used for action or site-specific assessments is generally limited to
the first generation and in some cases a few generations of users or a few half-lives of the
radionuclide, whichever is shorter. Evaluations that might extend the dose-integral over all time
and space should only be necessary for generic policy or standards development, if at all. There
is no de minimis dose value or a dose level that has been determined to be below regulatory
concern. Significant contributions to collective doses should be evaluated. However, at some
level, the uncertainty involved in modeling the dose distribution overwhelms the significance of
the incremental collective dose and there is no need to continue the integration. It will be
sufficient, generally, to determine that most of the total collective dose has been quantified.
Uncertainties in modeling are factors that may be considered in making this judgment. Volume
II of the DOE ALARA Technical Standard (DOE, 1997a) contains a number of example
assessments that evaluate doses for periods that are reasonable for the decision-making process.
Important Considerations When Evaluating Collective Dose
It is important to focus on the objective of the calculation, which is to provide data to support
comparison of alternative remedial actions or authorized limits.
Conservative overestimates of collective dose are useful as a screening tool to demonstrate
collective dose is insignificant for all alternatives. In such cases, a clear statement that collective
dose is not a significant factor in evaluating alternatives, using the screening estimates as a basis,
should be sufficient.
It is not necessary to estimate collective dose to all populations and all places over all time.
Representative values provide adequate information for comparative assessments. However, care
is needed to ensure such results are not biased for selected alternative actions.
4.5 EVALUATION OF OTHER FACTORS IN THE RELEASE OPTIONS ANALYSIS
PROCESS
Assessments of potential doses associated with releases should be specific to the particular
release being considered. Although this Guide is limited to control of radionuclides, coincident
nonradioactive contaminants and their possible impacts also need to be considered. When
nonradioactive contaminants are present coincident with residual radioactive material,
decontamination or remedial measures should be rational and effective considering the hazards
of all materials and in compliance with other applicable regulations governing such materials.
DOE ALARA guidance recognizes other factors in addition to dose/health risk and cost may be
important in establishing authorized limits. Public concerns and political sensitivity, although
difficult to quantify, should be considered in the development of authorized limits. Applicable
State and local standards also need to be addressed. Factors of a site-specific nature may also be
important. For example, specific waste management units may have waste acceptance criteria
based on local background radiation levels. Wastes, such as soil, from a region having high
background radiation levels could conceivably exceed waste acceptance criteria if local radiation
background levels are low, even if the wastes had very little residual contamination. Similarly,
actions to remove soil with small amounts of residual radioactive material in low background
soils may in balance have a negative dose reduction (i.e., increase dose to the public) if
background levels in the replacement soil are high. Such factors should be considered when
selecting remedial alternatives for mitigating the effects of residual radioactive material. 5. SPECIFIC APPLICATIONS OF THE AUTHORIZED RELEASE PROCESS
5.1 NATURALLY OCCURRING AND ACCELERATOR-PRODUCED RADIOACTIVE
MATERIAL
DOE regulates the use of naturally occurring and accelerator-produced radioactive material at its
facilities under the authority and responsibilities provided through the Atomic Energy Act, the
Energy Reorganization Act, and the Department of Energy Act relating to the protection of
health and safety. Property affected by accelerator-produced radioactive material should be
evaluated and authorized limits determined consistent with the goals and recommendations
provided in this Guide and associated DOE directives. This guidance and the DOE 5400.5
requirements are applicable to residual radioactive material above background levels. These
background levels include natural and anthropogenic radioactive materials. Background does
not include materials containing natural radionuclides whose concentrations are significantly
enhanced as a result of DOE activities. If DOE activities or processes significantly enhance the
concentrations of radionuclides in a material (e.g., if doses are a significant fraction of the dose
limit for soils, liquids, wastes, and equipment), the material must be evaluated under the ALARA
process to determine whether it is acceptable for general release. This requirement is not
applicable to small quantities of materials such as reagents used for laboratory analysis,
especially where the material is used for its intended, commercial purpose.
5.2 SOILS
Authorized limits for release or control of residual radioactive material in soils should be
developed consistent with the requirements, goals, and recommendations noted above. The
RESRAD (RESidual RADioactivity) code was developed at Argonne National Laboratory with
technical direction and support from DOE's Office of Environment, Safety and Health and the
Office of Environmental Management. Supporting documentation in the RESRAD user's
manual (Yu, C., et al., 2001) and the RESRAD data collection handbook (Yu, C., et al., 1993) is
intended for use in assessing the potential dose associated with the release or use of soils
containing radionuclides. Although use of other codes is permitted, unless there are site-specific
requirements that necessitate the use of an alternative model or it is determined such alternate
approaches will provide better results, RESRAD should be used in such assessments. DOE line
management should ensure there is appropriate justification for use of alternative models and
that such models meet DOE quality assurance and quality control requirements.
5.2.1 Appropriate Averaging Areas for Authorized Releases
DOE 5400.5 requires authorized limits for soils to be applicable to each 100-square-meter (m2)
area. In 1995, DOE's proposed rule, "Radiation Protection of the Public and the Environment"
(10 CFR 834), did not include a requirement for a specific averaging area for residual radioactive
material in soil. However, under the proposed rule the derived soil limits should be applied to
concentrations of residual radioactive material above background averaged over 100-m2 areas
unless specific analyses are completed to support alternative averaging areas. Averaging areas
larger than 100-m2 are permitted, subject to DOE approval, in cases where concentrations are
relatively uniform. Sampling should be consistent with DOE survey guidance (DOE, 1997b;
DOD-DOE-EPA-NRC, 2000). Where the modeling in support of the authorized limits
specifically addresses the averaging area or defines the survey unit, larger areas may also be
appropriate. Methods and rationale for site-specific survey and averaging areas (survey units)
and statistically based sampling protocols are discussed in the MARSSIM (DOD-DOE-EPA-
NRC, 2000). These methods are acceptable for establishing measurement protocols for
authorized limits under proposed 10 CFR 834, and can be incorporated as alternative approaches
under DOE 5400.5 through the supplemental limit process (see DOE 5400.5, Chapter IV).
5.2.2 Hot-Spot Criteria
In areas where residual radioactive material concentrations are not uniform, the need for hot-spot
criteria should be considered. Hot spots are small areas (e.g., less than 100 m2) with residual
radioactive material above levels in the surrounding area. Authorized limits for soil assume a
homogeneous distribution of radionuclides for large areas and are to be averaged over 100-m2
areas (default) or other survey units based on modeling and MARSSIM-based considerations.
Because of this averaging process, hot spots with radionuclide concentrations significantly
higher than the authorized limit can exist. To ensure individuals are adequately protected from
nonhomogeneous levels of residual radioactive material, the following hot-spot criteria may be
applied along with the approved authorized limit.
Formula for Hot-Spot Criteria
The hot-spot criteria for field application are concentrations of radionuclides in areas equal to or less
than 25 m2 and should average less than the approved authorized limit for the property times the square
root of the quotient of 100 m2 and the area of the hot spot (Ahs) in square meters:
Hot-Spot Criteria = Authorized Limit * (100/Ahs)0.5
(Note: For practical application, Table 1 of this Guide may be used in place of the formula.)
In many cases, authorized limits are selected at levels that represent very low potential doses,
and the hot-spot criteria suggested above are not relevant. These hot-spot criteria were derived
conservatively, assuming the authorized limits were based on a dose constraint of 25 mrem in a
year and selected to ensure unlikely exposure conditions would not cause the primary dose limit
to be exceeded. In cases where authorized limits are based on much lower doses or where
sampling protocols are based on site-specific survey areas (e.g., MARSSIM-based protocols),
site-specific hot-spot criteria may be derived in place of the generic guidelines to ensure the
public is protected from inhomogeneous levels of residual radioactivity. Note that proposed rule
10 CFR 834 permits these considerations as part of the authorized limit process; however, under
DOE 5400.5, Chapter IV, alternative hot-spot criteria must be implemented under the
supplemental limit process.
Table 1. Guidelines for Nonhomogeneous Residual Radioactive Material in Soila
Aerial Range for Criteriab,c
Factor
(Multiple of Authorized
Limit for 100 m2)
< 1 square meter
10
1 to < 3 square meters
6
3 to < 10 square meters
3
10 to 25 square meters
2
a As specified in DOE 5400.5 requirements, Chapter IV, 4.8.1; and in DOE, 1989.
b Areas greater than 25 m2 are subject to authorized limits.
C Areas less than 1 m2 are to be averaged over a 1-m2 area and that average shall not exceed 10 times the authorized limit
for the property.
5.3 RADIUM AND RADON
5.3.1 Radium
DOE 5400.5 provides specific concentration limits for radium in soils (5 pCi/g within the top
0.15 m of soils and 15 pCi/g in any subsequent 0.15-m layer). These levels represent the
maximum concentrations permitted in soils for properties being released from DOE control.
They are largely based on EPA analyses for uranium mill tailings, which EPA indicates are
based on considerations specific to mill tailings sites. The Department has evaluated the EPA
standard and finds the limits generally acceptable for most situations. However, this standard
was derived for 40 CFR 192 ("Health and Environmental Protection Standards for Uranium and
Thorium Mill Tailings") actions specifically; DOE requires that ALARA be implemented when
these standards are applied. Authorized limits for any project should be selected at or below
these concentrations consistent with the DOE ALARA process unless site-specific dose
assessments can justify alternative concentrations. Such justifications must consider the
potential impacts of the soil concentrations on indoor radon levels if habitable structures are
likely to be constructed on the soil.
5.3.2 Radon
Indoor 222Rn doses are exempted from the DOE primary dose limits. Instead, specific indoor
radon limits are provided in DOE 5400.5. They require that remedial actions be taken to remove
residual radioactive materials to reduce radon levels, including background, below 0.02 working
level (WL). If this is not possible, active controls (e.g., ventilation or building modification)
should be taken to reduce levels to at least 0.03 WL. These limits are provided as annual
average radon decay product concentrations. If measurements of radon are made, it may
generally be assumed that 4 pCi/L radon is equivalent to the 0.02 WL limit. While the limits
include background, they are applied to situations where residual radioactive material derived
from DOE or DOE predecessor activities are causing the limits to be exceeded. They are not
applicable to situations where indoor concentrations are due entirely to natural background
radiation.
5.4 SURFACE ACTIVITY ON PROPERTY (STRUCTURES AND PERSONAL
PROPERTY)
The guidelines for surface activity on property released from DOE control are provided in DOE
5400.5, Chapter IV, and in Office of Environment, Safety and Health guidance, including the
following.
March 15, 1984: guidance memorandum from J. Maher, Office of Nuclear Safety, to field
elements (DOE, 1984).
June 1989: DOE/CH/8901, Manual for Implementing Residual Radioactive Material
Guidelines (DOE, 1989).
November 17, 1995: memorandum from Raymond Pelletier, "Application of DOE 5400.5
Requirements for Release and Control of Property Containing Residual Radioactive
Material" (DOE, 1995).
These surface activity guidelines are also generally equivalent to existing NRC guidelines (NRC,
1974, 1987) and may be used in lieu of the dose constraint for managing the release of personal
property and structures having the potential for residual radioactivity on surfaces.
5.4.1 Surface Activity Guidelines
DOE total residual surface activity guidelines, which provide for allowable total residual surface
activity in disintegrations per minute per hundred square centimeters (dpm/100 cm2), are in the
references above and Table 2 of this Guide. The guidelines in Table 2 are applicable to both real
(except lands) and personal property. The surface activity guidelines are also generally
equivalent to existing NRC and DOE guidelines (NRC 1974, 1987; DOE 1995b).
These guideline values were set on the basis of past measurement capabilities and do not equate
to uniform doses or risks. Both the NRC and DOE criteria are being reevaluated to determine
whether a risk-/dose-based approach would be more appropriate. However, the Department has
reviewed the guidelines several times. The potential doses associated with the surface activity
limits provided in Table 2 (as implemented by DOE) are generally consistent with the DOE dose
limits and dose constraints. Release of property consistent with these surface activity guidelines
will provide reasonable assurance that doses are well below the primary dose limit and less than
25 mrem in a year for even the most radiotoxic radionuclides. Application of the ALARA
process to determine whether these levels are as low as is reasonably achievable is required, but
the effort expended in this analysis should be commensurate with the risks from the residual
radioactive material. The analysis should consider the costs associated with reducing levels
further than those defined in Table 2 and the difficulty in measuring levels lower than those
specified. The authorized limit should be based on an ALARA assessment giving due
consideration to these and other factors. For several radionuclides potential doses are so low or
measurements are so difficult that a reduction of these levels is not practical, and the ALARA
analysis should be no more than a qualitative statement of fact regarding the potential risks or
measurement difficulties. For other radionuclides under certain conditions of use, potential
doses at measurable levels may be sufficiently near the 25-mrem-in-a-year dose constraint to
warrant a more detailed ALARA assessment.
5.4.2 Surface Activity Guidelines and Their Use in Setting Authorized Limits for
Buildings
When using the ALARA process and the surface activity guidelines in Table 2 to establish
authorized limits for release of buildings, primary emphasis should be placed on continued use of
the structure under an appropriate use scenario. However, secondary consideration should be given
to the ultimate disposition of the structure in the future. If the facility is likely to be demolished or
sections recycled, appropriate analyses should be completed to ensure concentrations of residual
radionuclides in such materials do not exceed existing authorized limits for these uses.
5.4.3 Surface Activity Guidelines for Tritium
The Department has reviewed the analysis conducted by the DOE Tritium Surface
Contamination Limits Committee in the report Recommended Tritium Surface Contamination
Release Guides (DOE 1991b) and has assessed potential doses associated with the release of
property containing residual tritium. The Department recommends the use of
10,000 dpm/100 cm2 as a guideline for removable tritium. This guideline for removable surface
contamination ensures nonremovable fractions will not cause exposures that approach DOE dose
constraints.
Table 2. DOE Total Residual Surface Activity Guidelines:
Allowable Total Residual Surface Activity (dpm/100 cm2)a,b
(From: DOE 5400.5)
Radionuclidesc
Avgd,e
Maxd,e
Removablef
Group 1 Transuranics, 125I, 129I, 227Ac, 226Ra, 228Ra,
228Th, 230Th, 231Pa
100
300
20
Group 2 Th-natural, 90Sr, 126I, 131I, 133I, 223Ra, 224Ra,
232U, 232Th
1,000
3,000
200
Group 3 U-natural, 235U, 238U, associated decay
products, alpha emitters
5,000
15,000
1,000
Group 4 Beta-gamma emitters (radionuclides with
decay modes other than alpha emission or spontaneous
fission) except 90Sr and others noted aboveg
5,000
15,000
1,000
Tritium (applicable to surface and subsurface)h
N/A
N/A
10,000
a The values in this table (except for tritium) apply to radioactive material deposited on but not incorporated into the interior
or matrix of the property. No generic concentration guidelines have been approved for release of material that has been
contaminated in depth, such as activated material or smelted contaminated metals (e.g., radioactivity per unit volume or
per unit mass). Authorized limits for residual radioactive material in volume must be approved separately.
b As used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as determined by
counts per minute measured by an appropriate detector for background, efficiency, and geometric factors associated with
the instrumentation.
c Where surface contamination by both alpha-emitting and beta-gamma-emitting radionuclides exists, the limits established
for alpha-emitting and beta-gamma-emitting radionuclides should apply independently.
d Measurements of average contamination should not be averaged over an area of more than 1 m2. Where scanning surveys
are not sufficient to detect levels in the table, static counting must be used to measure surface activity. Representative
sampling (static counts on the areas) may be used to demonstrate by analyses of the static counting data. The maximum
contamination level applies to an area of not more than 100 cm2.
e The average and maximum dose rates associated with surface contamination resulting from beta-gamma emitters should
not exceed 0.2 millirad per hour (mrad/h) and 1.0 mrad/h, respectively, at 1 cm.
f The amount of removable material per 100 cm2 of surface area should be determined by wiping an area of that size with
dry filter or soft absorbent paper, applying moderate pressure, and measuring the amount of radioactive material on the
wiping with an appropriate instrument of known efficiency. When removable contamination of objects on surfaces of less
than 100 cm2 is determined, the activity per unit area should be based on the actual area, and the entire surface should be
wiped. It is not necessary to use wiping techniques to measure removable contamination levels if direct scan surveys
indicate the total residual surface contamination levels are within the limits for removable contamination.
g This category of radionuclides includes mixed fission products, including the 90Sr that is present in them. It does not apply
to 90Sr that has been separated from the other fission products or mixtures where the 90Sr has been enriched.
h Measurement should be conducted by a standard smear measurement but using a damp swipe or material that will readily
absorb tritium, such as polystyrene foam. Property recently exposed or decontaminated should have measurements
(smears) at regular time intervals to prevent a buildup of contamination over time. Because tritium typically penetrates
material it contacts, the surface guidelines in group 4 do not apply to tritium. Measurements demonstrating compliance of
the removable fraction of tritium on surfaces with this guideline are acceptable to ensure nonremovable fractions and
residual tritium in mass will not cause exposures that exceed DOE dose limits and constraints.
5.4.4 Surveys and Measurements
Measurements to demonstrate compliance with the residual surface activity requirements should
be completed in accordance with the recommendations in the Environmental Implementation
Guide for Radiological Survey Procedures (DOE, 1997b) or other DOE-approved procedures.
Per the survey procedures Guide, surveys and measurements should be sufficient to demonstrate
that the limits are achieved with a 90 to 95 percent confidence level for measurement. In some
cases, confidence limits between 1 and 2 sigma may be appropriate but should be clearly defined
and justified in the survey plans or procedures. In many cases and for many radionuclides,
conventional scanning-type surveys cannot achieve this level of confidence (i.e., the Table 2
levels). As a result, it will be necessary to make static measurements at representative locations
of the item or property being surveyed. Because it is not possible to survey 100 percent of a
surface in this manner, the location and number of static measurement locations should be
selected to produce a statistical average (or other measure of central tendency) that is
representative of the items or property being surveyed. The methodology used should be clearly
described in the survey plan and in the final documentation for the release of any property. It
should be approved by DOE as part of the authorized limit for any project before the initiation of
decontamination and release activities.
For tritium, the measurements should be conducted by a standard smear measurement but using a
wet swipe or piece of polystyrene foam (DOE, 1997b). If the property has been recently
contaminated or recently decontaminated, follow-up measurements (smears) should be
conducted at regular time intervals before release to ensure there is not a buildup of tritium on
the surface over time.
Several radionuclides in categories listed in Table 2 are extremely difficult to detect but have
low radiotoxicity (e.g., 125I and 129I from Group 1) and pose low dose and risk of exposure to
levels in Table 2. For these radionuclides, measurement confidence of 70 percent (e.g.,
one sigma) would be appropriate when it is impractical, because of time or resource constraints,
to achieve greater than 90 percent confidence in the measurement system.
5.5 VOLUME AND MASS CONTAMINATION AND ALTERNATE SURFACE
LIMITS
DOE has not established DOE-wide approved guidelines for release of personal property or
structures containing residual radioactive material in mass or volume. Authorized limits for
property subject to contamination in mass or volume must be derived consistent with the
requirements and processes discussed previously in this Guide and approved by DOE.
Similarly, authorized limits for residual radioactive material on surfaces different than those in
Table 2 may be approved by DOE on a case-by-case basis specific to the properties of the
materials being released. As noted in Table 2, the surface guidelines are tied to specific
averaging areas. These averaging areas may not be appropriate for ALARA-based authorized
limits and, therefore, alternative authorized limits should specify measurement procedures
appropriate for their application. Refer to the Environmental Implementation Guide for
Radiological Survey Procedures (DOE, 1997b) or MARSSIM (DOD, DOE, EPA, NRC, 2000)
for additional details. Additional tools that are available for developing alternative limits for
release of personal property or structures containing residual radioactive material include the
RESRAD-BUILD and RESRAD-RECYCLE computer codes (Yu, C., et al., 1994, 2000).
In August 1999, the American National Standards Institute (ANSI) approved ANSI/N13.12,
Surface and Volume Radioactivity Standards for Clearance (ANSI, 1999). Consistent with the
requirements of the National Technology Transfer and Advancement Act of 1995 and Office of
Management and Budget circular A-119 (Federal Register v.63(33), 2/19/98), DOE is evaluating
the standard for use within the Department. However, the evaluation is not complete, and
therefore, ANSI/N13.12 may only be used in place of the DOE-approved surface guidelines on
the basis of a case-by-case review and approval. Although ANSI/N13.12 includes numeric
guideline values for residual radioactivity on surfaces (as do the DOE surface activity
guidelines) and in volume, the standard has many other conditions and requirements; it is not
merely a table that can be substituted for the DOE surface activity guideline values in Table 2
(see Section 5.4.1 of this Guide). Users of this Guide who are considering seeking DOE
approval for use of ANSI/N13.12 need to recognize these limitations and requirements in their
request for use of the standard. Such requests should be consistent with a request for DOE
approval for authorized limits using derived or alternative standards recommended in this
guidance. Note that the ANSI/N13.12 standard is not applicable to the release of regulated
facilities for unrestricted use [i.e., it is not a decontamination and decommissioning (D&D)
standard for real property].
The NRC, as part of its development of guidance for the NRC D&D standard in 10 CFR 20,
subpart E, has developed and issued screening surface activity levels for the release of structures.
NRC's general standards for the control and release of structures are consistent with DOE
requirements and guidance as they require derivation of dose-based criteria constrained to
25 mrem/year and application of the ALARA process. NRC has determined the screening levels
generally meet this criteria. However, as with the ANSI standard, DOE has not made a specific
determination with regard to the NRC screening activity guidelines and their generic
applicability to DOE. Use of these levels in lieu of the Table 2 (Section 5.4.1) values or an
ALARA-based authorized limit requires DOE approval on a case-by-case basis.
5.6 RELEASE OF PERSONAL PROPERTY INCLUDING EQUIPMENT
When the Department releases personal property from DOE radiological control or transfers
ownership (either by sale or other means) to members of the public, the limits for equipment and
personal property are the same as for those applied to real property. Although DOE and DOE
contractors generally are exempt from 10 CFR 61, "Licensing Requirements for Land Disposal
of Radioactive Waste," and 10 CFR 20, individuals receiving materials are not. The Department
will not transfer licensable materials to members of the public who are not licensed to receive
them. Therefore, as part of the process for developing authorized limits for residual radioactive
material, the Department must ensure such property and material do not contain licensable
amounts or concentrations of radionuclides. Therefore, the following criteria should be
implemented to comply with DOE 5400.5 residual radioactive material requirements.
Authorized limits for property must ensure doses to the public from all sources are less
than the primary dose limit for all sources (100 mrem in a year).
Authorized limits for the property must be developed and approved by DOE consistent
with the ALARA process. Appropriate protocols for survey and review of the release of
such property must accompany the approval of the authorized limits. These limits will be
based on a documented finding that they are as low as practicable as determined through
the ALARA process with a goal being to maintain individual doses low in comparison to
background (e.g., a few millirem in a year or less). In any case, the limits must be a
fraction of the primary dose limit for the public (e.g., one-fourth or 25 mrem in a year or
less). The ALARA analysis should be consistent with DOE ALARA guidance (DOE,
1997a).
Authorized limits for the release of property from DOE control should be coordinated with
the NRC or with appropriate Agreement State representatives to ensure DOE releases do
not violate NRC licensing requirements.
The all-source criterion may be assumed satisfied if the ALARA criterion and its associated dose
constraint and goals are adequately addressed. Generally, the use of the surface activity
guidelines discussed above will satisfy all the criteria and will not require a quantitative dose
assessment or detailed ALARA analysis; however, a qualitative review should be done and
documented to determine whether it is practicable to set authorized limits for surfaces lower than
the surface activity guidelines.
5.7 RELEASE OF PROPERTY TO DOE ONSITE LANDFILLS
The Department has the responsibility and authority to establish limits for protection of the
public and environment either in the form of radionuclide release criteria or waste acceptance
criteria for disposal of materials in a DOE onsite landfill. Disposal of such material must
conform to the requirements of DOE 5400.5 and to applicable portions of DOE O 435.1,
Radioactive Waste Management (DOE, 1999) if the property is managed as radioactive waste.
In any case, DOE must implement controls to ensure doses to the public will be as far below the
dose limits in DOE 5400.5 as is practicable. This is determined on the basis of the ALARA
analysis. Unless the landfill is authorized to receive radioactive waste under DOE O 435.1, the
criteria should be such that it is not likely disposal of materials into the landfill will result in a
future need to remediate the landfill to meet the requirements of Chapter IV of DOE 5400.5. In
making this determination, consideration should also be given to radionuclide limits established
in the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
and Resource Conservation and Recovery Act (RCRA) corrective action Records of Decisions in
neighboring areas of the site.
To ensure these requirements and goals are achieved, authorized limits for material sent to a
DOE landfill (which is not an authorized low-level waste disposal facility) should be
selected on the basis of an assessment under the ALARA process to optimize the balance
between risks and benefits, including costs and collective doses, and selected to ensure
individual doses to the public are less than 25 mrem in a year with a goal of a few millirem
in a year or less;
evaluated to ensure groundwater will be protected in a manner consistent with the site's
Groundwater Protection Management Program (as required by DOE 5400.1, General
Environmental Protection Program; DOE, 1988) and other applicable State regulations
and guidelines;
evaluated to verify release of the landfill property would not be expected to require
remediation under DOE 5400.5 requirements for release of property containing residual
radioactive material, giving due consideration to experience gained from past or ongoing
CERCLA or RCRA cleanup actions; and
approved by DOE.
The ALARA process should consider factors such as (1) estimated concentrations in waste,
(2) total activity (source term) likely to be disposed in the landfill, (3) fraction of total waste
containing residual radioactivity, (4) estimated individual doses from expected or likely use
scenarios, (5) estimate or assessment of collective doses in relation to other alternatives, and
(6) potential impacts on natural resources such as groundwater. Land-use plans, site
maintenance, benchmark cleanup standards, and special waste form characteristics may be
considered in assessing doses for the development of authorized limits and acceptance criteria.
The detail and complexity of the analysis should be commensurate with potential risks and costs
(i.e., if potential individual and collective doses are very low, a semiquantitative or screening
analysis may be acceptable).
Other factors may also be important in determining the level of detail needed to approve such
limits. For example, although screening analyses (conservative bounding estimates) of activity
and potential doses that demonstrate low risk potential may be adequate to show ALARA has
been implemented, they are likely to significantly overestimate residual activity. The use of
bounding estimates without adequate documentation of uncertainties, likely doses, or quantities
of material may result in misleading documentation that in turn could lead to costly and
unnecessary investigations in the future. Therefore, it is recommended that procedures be
established to document source-term estimates as realistically as practicable or that bounding
estimates be qualified with a discussion of uncertainty or estimates of expected quantities of
residual radioactive material. Documentation supporting the authorized limits or acceptance
criteria and disposal records should be sufficient to ensure the site will not have to be remediated
in the future or unnecessarily surveyed to document its radiological condition.
5.8 RELEASE OF PROPERTY TO OFFSITE LANDFILLS
DOE may establish and approve authorized limits and associated survey and release protocols
for material that will be disposed in a non-DOE landfill. The recommended criteria for such a
situation are similar to those established for release of property except that there is an additional
consideration. Many local landfills have waste acceptance criteria or are subject to State
requirements for radioactive material.
In addition to meeting DOE requirements to establish authorized limits and surveys and the
required review and documentation protocols that ensure doses are as far below the primary dose
limit as is practicable, authorized limits and release protocols must meet waste acceptance
criteria and State requirements for the subject landfills.
To ensure these requirements and goals are achieved, authorized limits for material sent to a non-
DOE landfill (which is not an authorized low-level waste disposal facility) should be
selected (and approved by DOE) on the basis of an assessment under the ALARA process
to optimize the balance between risks and benefits (e.g., collective doses and costs) and to
ensure individual doses to the public are less than 25 mrem in a year, with a goal of a few
millirem in a year or less;
evaluated to ensure groundwater will be protected consistent with the objectives of the
applicable State regulations and guidelines;
assessed to ensure release of the landfill property would not be expected to require
remediation under DOE 5400.5 or other applicable requirements for release of property
containing residual radioactive material as a result of DOE disposals; and
coordinated with and acceptable to the landfill authority (e.g., municipal or private
operator) implementing the acceptance criteria, and with State representatives responsible
for implementing solid waste regulations to ensure DOE releases do not violate landfill-
specific radiological protection requirements.
These criteria may also be applied to disposal of material at RCRA-regulated hazardous waste
treatment, storage, and disposal facilities (see the guidance memorandum, "Establishment and
Coordination of Authorized Limits for Release of Hazardous Waste Containing Residual
Radioactive Material;" DOE, 1997c). The Department has also developed the computer model
"TSD-dose" to assist in the assessment of such disposals and the development of appropriate
authorized limits (Pfingston, M., et al., 1997).
This page intentionally left blank.6. POSTING AND PROPERTY CONTROL
6.1 UNRESTRICTED AND RESTRICTED RELEASE OF PROPERTY
DOE residual radioactive material control requirements addressed in this Guide relate to
unrestricted and restricted release of property. This includes transfer of the property through
sale, lease, gift, or otherwise. Restrictions associated with any of these actions may be taken into
account in assessing and evaluating potential doses and in making ALARA determinations.
However, where restrictions are necessary to control potential doses, there must be a reasonable
expectation that these restrictions will be implemented and in the unlikely event that restrictions
fail, levels of residual radioactive material should be such that doses will not exceed the primary
dose limit. DOE may choose to implement active institutional controls in lieu of the restriction
failure constraint. These controls may be in the form of periodic reviews (at least every 5 years)
to ensure restrictions are being maintained, and the Department must have sufficient authority to
take corrective actions should they be needed.
6.2 DOE-OWNED PROPERTY
If DOE chooses to continue to own and actively control access or use of property, this guidance
and DOE 5400.5 (Chapter IV) requirements do not specifically apply. Rather, the radiation
protection requirements in the other sections of DOE 5400.5 apply to DOE-owned and
maintained facilities. DOE previously issued guidance recommending that soil contamination
areas not meeting DOE 5400.5 release requirements should be posted as soil contamination areas
(see the Radiological Control Manual; DOE, 1992). Where these guidelines are being applied,
it is not necessary to develop authorized limits for unrestricted release under DOE 5400.5
(Chapter IV) to establish soil posting criteria. That is, the soil posting criteria should be
developed based on actual or likely use conditions and assumptions that consider DOE
ownership and appropriate continued control, rather than on the basis of assumptions that
presume release of the site for general public use. They should be developed considering
accessibility of the property to the public and the associated potential for exposure and to
minimize the potential for spread of contamination and the consequences associated with
anticipated maintenance activities in the area. Although DOE continued use or control can be
considered (where justifiable) for the likely and actual use assessments, reviews of potential
impacts under worst plausible use should consider loss of such DOE control for a permanent or
temporary period as is appropriate to the circumstances.
6.3 NOTEWORTHY DIFFERENCES BETWEEN 10 CFR 835 AND DOE 5400.5
POSTING REQUIREMENTS
DOE recognizes some differences in 10 CFR 835, "Occupational Radiation Protection," posting
requirements compared to DOE 5400.5 requirements for controlling and releasing property
containing residual radioactive material. The regulation has promulgated a set of surface
concentration guidelines that constitute the basis for continued radiological control under that
rule. DOE 5400.5 allows dose-based authorized limits for structures and personal property that
may be different than the 10 CFR 835 limits. In many cases, dose-based limits result in derived
concentration limits that can and do exceed the 10 CFR 835 concentration guidelines. In these
cases, apparent conflicts or confusion arises between DOE 5400.5 release requirements
compared with 10 CFR 835 control requirements. Specifically, this relates to requirements in
the monitoring, entry control, and posting sections of 10 CFR 835, where some degree of
monitoring, posting, and control are necessary in contamination areas [835.603(e)] that exceed
10 CFR 835 Appendix D values. However, for most situations where DOE 5400.5 requirements
are met there are no conflicts.
Appendix D (Surface Contamination Values) of 10 CFR 835 is not applicable to soils (open
land). Therefore, lands released under DOE 5400.5 authorized limits are not subject to 10 CFR
835 posting, monitoring, or control requirements except that such releases should not create a
condition where the tracking or movement of soil will cause structures to exceed 10 CFR 835
Appendix D values. Where other property (e.g., structures or personal property) is being
released from DOE control (e.g., transfer ownership to another non-DOE party), DOE 5400.5
limits are applicable and 10 CFR 835 requirements do not apply. When compliance with
approved DOE 5400.5 authorized limits is demonstrated and documented, property may be
released from DOE control without further consideration of 10 CFR 835 posting, monitoring, or
control requirements. The only exception to this requirement is restricted release where a
specific use restriction requires consideration or implementation of a portion of 10 CFR 835. In
such cases, the specific 10 CFR 835 requirement becomes part of the authorized limit.
There may be some situations where DOE or DOE contractors may prepare property for release
under DOE 5400.5 but choose to maintain control of the property for some undetermined period
of time. Based on DOE experience and because the DOE surface activity guidelines (Section
5.4.1, Table 2) are equal to or more restrictive than 10 CFR 835, Appendix D, in most cases,
property meeting these requirements also will meet all 10 CFR 835 requirements. However,
because authorized limits may also be derived on a dose basis, situations may exist for some
structures where the dose-base authorized limits exceed Appendix D values. Although part
835.603(e) requires posting as contamination areas where Appendix D values are exceeded,
10 CFR 835 provides flexibility in 835.1101, which waives the entry control and posting
requirements of 835.501 and 835.603 if conditions of 835. 1101(c) are met. Section
835.1101(c)(1) indicates areas with fixed contamination exceeding the fixed contamination
levels in Appendix D may be located outside a radiological area if the removable residual
radioactive material is less than Appendix D requirements. This is conditional on requirements
that dose rates are below 10 CFR 835 requirements, and the location is appropriately marked and
routinely monitored [ 835.1101(c)(2)]. In the case of a structure demonstrated to meet DOE-
approved authorized limits, the dose limit requirements are presumed to be met provided the
DOE-approved authorized limits are met. The marking requirement may be satisfied by a sign
or label indicating the property meets DOE authorized limits. The sign or label should
specifically reference the authorized limits. Routine monitoring requirements are considered
satisfied by that level of monitoring required under the authorized limits. Therefore, under these
conditions, there should be no conflict between DOE 5400.5 release requirements and 10 CFR
835 posting, control, or monitoring requirements.
If the authorized limit derived under the DOE process, including ALARA, exceeds the
10 CFR 835, Appendix D, removable values, an exemption from part 835 (sections 835.501,
835.601, 835.603, and 835.1101) may need to be obtained to be in full compliance with DOE
requirements. The Assistant Secretary for Environment, Safety and Health will expedite review
and approval of such exemption requests if
the authorized limits have been approved by DOE consistent with the Order and this
guidance, including the required approvals as discussed in this guidance;
DOE has confirmed (or will confirm before release) the radiological condition of the
property complies with the authorized limits and mechanisms are in place to provide
reasonable assurance any necessary restrictions will be implemented; and
the authorized limits, radiological condition, and exemption process are documented, with
this documentation being available to the public.
This page intentionally left blank.7. ORGANIZATIONAL APPROVALS
Under DOE 5400.5, implementation of the control and release requirements for property
containing residual radioactive material is the responsibility of DOE line management, in
particular the heads of DOE field elements. Table 3 summarizes responsibilities and authorities.
Implementation and oversight is the responsibility of heads of DOE field elements. They must
ensure all property released conforms to DOE requirements and is released consistent with DOE
approved authorized limits. They are also responsible for coordination with program offices
and, where necessary, with the Office of Environment, Safety and Health in the implementation
of the requirements.
Line management is empowered to review and, as appropriate, approve authorized limits for
lands (e.g., soils) and for structures or personal property (to the extent such limits conform to the
surface concentration guidelines in DOE 5400.5 and this Guide). Authorized limits for property
containing residual radioactivity distributed in mass or volume and authorized limits based on
alternatives to the surface activity guidelines must be approved by both the Assistant Secretary
for Environment, Safety and Health and the field office. Field offices, in coordination with the
appropriate program office, may approve supplemental limits as alternative limits to the surface
activity guidelines for real property consistent with Chapter IV of DOE 5400.5. However, it is
recommended that such limits be coordinated with the Office of Environment, Safety and Health
in a manner similar to the approval process for residual radioactive material in mass or
alternative surface limits for personal property discussed in Section 7.1.
Neither DOE 5400.5 nor this guidance establishes time limits for reviews of authorized or
supplemental limit requests. In those cases where program and field offices have approval
authority, they are better positioned to assess program priorities and assign the appropriate level
of qualified staff to complete an independent and comprehensive review of the request in a
timely manner. In those cases where Office of Environment, Safety and Health approval or
consultation is required, the staff will strive to complete timely and responsive reviews. To aid
in this process, the Office of Environment, Safety and Health has established a graded approach
to its review process that enables staff to respond to requests within 60 to 90 working days,
under normal circumstances. Early involvement of the Office in the process can help reduce
these time periods. Under certain conditions, the Office may conduct expedited reviews. These
conditions are discussed in Section 7.1.
7.1 CONDITIONS FOR EXPEDITED APPROVAL
Authorized limits and survey protocols for residual radioactive material in mass or volume or
personal property limits for residual radioactive material on surfaces in lieu of surface activity
guidelines (Section 5.4.1, Table 2) may be derived and approved by DOE field office managers
without written approval of the Assistant Secretary for Environment, Safety and Health if all of
the following conditions are met.
The applicable criteria described in this Guide are appropriately addressed.
The release or releases of the subject material will not cause a maximum individual dose to
a member of the public in excess of 1 mrem in a year or a collective dose of more than
10 person-rem in a year.
A procedure is in place to ensure records of the releases are maintained consistent with
DOE 5400.5 requirements and survey or measurement results are reported consistent with
the data reporting guidelines in the Environmental Implementation Guide for Radiological
Survey Procedures (DOE, 1997b) and the DOE Environmental Regulatory Guide for
Radiological Effluent Monitoring and Environmental Surveillance (DOE, 1991c).
A copy of the authorized limits; measurement and survey protocols and procedures;
supporting documentation, including a statement that the ALARA process requirements
have been achieved; and appropriate material documenting any necessary coordination
with the States or NRC are provided to the Office of Environment, Safety and Health,
Office of Environment, (Office of Environment) at least 45 working days before the
authorized limits become effective. The Office of Environment will provide written
notification to the field office upon receipt of the material, and will notify the field office
within 30 days of receipt if the authorized limits or supporting material are incomplete or
not acceptable. In cases where the Office of Environment determines the material is
incomplete or not acceptable, the field office must address those incomplete or
unacceptable elements of the proposed authorized limits and then resubmit revised
authorized limits and documentation for a second Office of Environment notification and
review cycle. A new notification and review cycle, using the same time frames identified
above, would be conducted by the Office of Environment on this revised submission of
authorized limits and supporting material. Otherwise, the authorized limits (including any
conditions or limitations set forth by the approving DOE field elements) may be considered
approved without written approval from the Assistant Secretary for Environment, Safety
and Health.
Where the responsible program office is within the National Nuclear Security Administration
(NNSA), approval of alternative limits must be granted by the NNSA Administrator in
consultation with the Assistant Secretary for Environment, Safety and Health.
7.2 REQUESTS FOR TECHNICAL ASSISTANCE
Field elements may request technical assistance in the review or development of authorized
limits. However, such assistance should be requested as early as possible in the process and at
least 90 working days before the desired implementation date for the authorized limits. Nothing
in this Guide should be construed to override or replace the need for field elements to coordinate
or consult with DOE program offices having jurisdiction over actions or portions of the actions
covered by the authorized limits. Authorized limits for residual radioactive material in mass or
volume that do not meet the criteria for approval by the field office as stated above must be
approved in writing by the Assistant Secretary for Environment, Safety and Health. It is
recommended that the DOE elements responsible for requesting approval from the Office of
Environment, Safety and Health coordinate the analyses with the Office of Environmental Policy
and Guidance's Air, Water and Radiation Division before submitting the request to the Assistant
Secretary for Environment, Safety and Health.
Table 3. Approval Responsibilities for the Authorized Release Process
Action and Condition
Organizational Functions
Approval of authorized limits for the recycle and
reuse of personal property containing residual
radioactivity and for disposal of wastes.
See Sections 5.4, 5.5, 5.6. 5.7, and 5.8 of this Guide.
1. Limits consistent with surface activity
guidelines or other DOE-approved
concentration guidelines.
1. Request reviewed and approved by DOE field
elements consistent with Section 5.4 in
coordination with program offices.
2. Alternate ALARA/dose-based derived
authorized limits for surfaces or activity in
mass or volume where potential doses are less
than 1 mrem and 10 person-rem in a year.
2. Request reviewed and approved by DOE field
elements in coordination with program office and
submitted to EH-4 at least 45 working days prior to
implementation. Submittal to EH-4 is mandatory.
The authorized limits may be considered approved
by EH-1 if EH-4 does not notify the field as to the
status of the review and potential concerns within
30 working days following receipt of request.
3. Alternate ALARA/dose-based derived
authorized limits for surfaces or activity in
mass or volume where potential doses are less
than the 25-mrem dose constraint but in excess
of 1 mrem or 10 person-rem in a year.
3. Request reviewed and approved by DOE field
elements in coordination with program office.
It is mandatory that field elements provide
authorized limits to EH-4 for review and approval
prior to implementation.
EH-1 provides written approval if authorized limits
are acceptable and field elements implement limits.
Approval of authorized limits for open land (soil
criteria); does not include waste or soil-like wastes
for disposal in a landfill or other disposition.
Request reviewed and approved by DOE field elements
consistent with Sections 5.2 and 5.3.
Field elements coordinate with program offices.
EH provides technical assistance upon request.
Approval of authorized limits for structures.
See Sections 5.4 and 5.5 of this Guide. Organizational
functions are the same as for 1-3 above under "personal
property," except that for surface activity on structures,
submittal of authorized limits to EH-4 is voluntary and
EH-1 approval is not required.
Exemptions for 10 CFR part 835 posting, access
control.
Exemption requests submitted to EH-1 consistent with
10 CFR part 820. Request should use documentation for
authorized limit to justify exemption and will be
approved or rejected by EH-1 within 45 days of receipt.
EH Office of Environment, Safety and Health
EH-1 Assistant Secretary for Environment, Safety and Health
EH-4 Office of Environment, Safety and Health, Office of Environment
8. REFERENCES
1. 10 CFR 20, "Standards for Protection Against Radiation," subpart E, "Radiological Criteria
for License Termination;" Washington, D.C.
2. 10 CFR 61, "Licensing Requirements for Land Disposal of Radioactive Waste;"
Washington, D.C.
3. 10 CFR 830, "Nuclear Safety Management;" Washington, D.C.
4. 10 CFR 834, "Radiation Protection of the Public and the Environment" (proposed);
Washington, D.C. Notice of availability published in the Federal Register (FR), August
31, 1995 [FR 60, 45381]; proposed March 25, 1993, [FR 58, 16268].
5. 10 CFR 835, "Occupational Radiation Protection;" Washington, D.C.
6. 40 CFR 192, "Health and Environmental Protection Standards for Uranium and Thorium
Mill Tailings;" Washington, D.C.
7. ANSI (American National Standards Institute), 1999. Surface and Volume Radioactivity
Standards for Clearance; ANSI/N13.12-1999; New York; August 31, 1999.
8. DoD-DOE-EPA-NRC (Department of Defense, Department of Energy, Environmental
Protection Agency, Nuclear Regulatory Commission), 2000. Multi-Agency Radiation
Survey and Site Investigation Manual (MARSSIM), Rev. 1; NUREG 1575; Washington,
D.C.; August 2000.
9. DOE, 1984. Guidance Memorandum: Unrestricted Release of Radioactively
Contaminated Personal Property; Washington, D.C.; DOE Office of Nuclear Safety;
March 15, 1984.
10. DOE, 1988. General Environmental Protection Program; DOE 5400.1; Washington,
D.C.; November 9, 1988.
11. DOE, 1989. Manual for Implementing Residual Radioactive Material Guidelines A
Supplement to the U.S. Department of Energy Guidelines for Residual Radioactive
Material at FUSRAP and SFMP Sites; DOE/CH-8901; Washington, D.C.; June 1989.
12. DOE, 1990. Radiation Protection of the Public and the Environment; DOE 5400.5;
Washington, D.C.; February 8, 1990.
13. DOE, 1991a. DOE Guidance on the Procedures in Applying the ALARA Process for
Compliance with DOE 5400.5; Washington, D.C.; DOE Office of Environmental Policy
and Assistance.
14. DOE, 1991b. Recommended Tritium Surface Contamination Release Guides; Washington,
D.C.; DOE Tritium Surface Contamination Limits Committee.
15. DOE, 1991c. Environmental Regulatory Guide for Radiological Effluent Monitoring and
Environmental Surveillance; DOE/EH-0173T; Washington, D.C.; January 1991.
16. DOE, 1992. DOE Radiological Control Manual; DOE/EH-0256T; Washington, D.C.
17. DOE, 1994. Public Participation; DOE P 1210.1; Washington, D.C.; July 29, 1994.
18. DOE, 1995. Guidance Memorandum: Application of DOE 5400.5 Requirements for
Release and Control of Property Containing Residual Radioactive Material; Washington,
D.C.; DOE Office of Environment; Air, Water and Radiation Division; November 17,
1995.
19. DOE, 1996a. Information Management Program; DOE O 200.1; Washington, D.C.;
September 30, 1996.
20. DOE, 1996b. Environment, Safety, and Health Reporting; DOE O 231.1; Washington,
D.C.; November 7, 1996.
21. DOE, 1997a. Applying the ALARA Process for Radiation Protection of the Public and
Environmental Compliance with 10 CFR Part 834 and DOE 5400.5 ALARA Program
Requirements (DOE draft ALARA standard); 2 vols.; Washington, D.C.; April 1997.
22. DOE, 1997b. Environmental Implementation Guide for Radiological Survey Procedures
(draft report for comment); Washington, D.C.; February 1997.
23. DOE, 1997c. Guidance Memorandum: Establishment and Coordination of Authorized
Limits for Release of Hazardous Waste Containing Residual Radioactive Material;
Washington, D.C.; DOE Office of Waste Management; January 7, 1997.
24. DOE, 1999. Radioactive Waste Management; DOE O 435.1; Washington, D.C.; July 9,
1999.
25. DOE, 2000a. Department of Energy Press Release: Energy Secretary Richardson Blocks
Nickel Recycling at Oak Ridge; Press Release R-00-008; Washington, D.C.; January 12,
2000.
26. DOE, 2000b. Secretarial Memorandum: Release of Surplus and Scrap Materials;
memorandum from Bill Richardson to heads of all departmental elements; Washington,
D.C.; July 13, 2000.
27. DOE, 2000c. Fact Sheet: Frequently Asked Questions on the Suspension on Release for
Recycling of Metal from Radiation Areas. Office of Environmental Policy and Guidance.
Air, Water and Radiation Division. July 2000.
28. DOE, 2000d. Records Management Program; DOE O 243.X (draft); Washington, D.C.
29. DOE, 2001. Secretarial Memorandum: Managing the Release of Surplus and Scrap
Materials; memorandum from Bill Richardson to heads of departmental elements;
Washington, D.C.; January 19, 2001.
30. NRC, 1974. Termination of Operating Licenses for Nuclear Reactors; Regulatory
Guide 1.86; Washington, D.C.; June 1974.
31. NRC, 1987. Guidelines for Decontamination of Facilities and Equipment Prior to Release
for Unrestricted Use or Termination of License for Byproduct, Source, or Special Nuclear
Material, Washington, D.C., August 1987.
32. Pfingston, M., et al.; 1997. TSD Dose: A Radiological Dose Assessment Model for
Treatment, Storage, and Disposal Facilities; ANL/EAD/LD-4; Argonne, IL; Argonne
National Laboratory; March 1997.
33. Wang, Y., et al.; 1993. A Compilation of Radionuclide Transfer Factors for the Plant,
Meat, Milk, and Aquatic Food Pathways and the Suggested Default Values for the
RESRAD Code; ANL/EAIS/TM-103; Argonne, IL; Argonne National Laboratory; August
1993.
34. Yu, C., et al.; 1993. Data Collection Handbook to Support Modeling the Impacts of
Radioactive Material in Soil; ANL/EAIS-8; Argonne, IL; Argonne National Laboratory;
April 1993.
35. Yu, C., et al.; 1994. RESRAD-BUILD: A Computer Model for Analyzing the Radiological
Doses resulting from the Remediation and Occupancy of Buildings Contaminated with
Radioactive Material; ANL/EAD/LD-3; Argonne, IL; Argonne National Laboratory;
November 1994.
36. Yu, C., et al.; 2000. RESRAD-RECYCLE: A Computer Model for Analyzing the
Radiological Doses and Risks Resulting from the Recycling of Radioactive Scrap Metal
and the Reuse of Surface-Contaminated Material and Equipment; ANL/EAD-3; Argonne.
IL; Argonne National Laboratory; November 2000.
37. Yu, C., et al.; 2001. User's Manual for RESRAD Version 6; ANL/EAD-4; Argonne, IL;
Argonne National Laboratory; July 2001.
This page intentionally left blank. SECRETARIAL MEMORANDUMS REGARDING POLICY AND GUIDANCE FOR
MANAGING THE RELEASE OF DOE SURPLUS AND SCRAP MATERIALS
This page intentionally left blank. OVERVIEW OF SUPPORTING GUIDANCE AND TOOLS
This appendix lists many of the guidance documents and tools available for implementing the
process for release and control of property with residual radioactive material. Many of these
guidance documents and tools can be downloaded from the Office of Environmental Policy and
Guidance's main Web site (http://tis.eh.doe.gov/oepa), from the Office's Dose and Risk
Assessment Web site (http://tis.eh.doe.gov/oepa/risk), or from the RESRAD Web site
(http://web.ead.anl.gov/resrad/home2/).
B.1 DOSE MODELING TOOLS
1. DOE (Department of Energy), 1989. Manual for Implementing Residual Radioactive
Material Guidelines A Supplement to the U.S. Department of Energy Guidelines for
Residual Radioactive Material at FUSRAP and SFMP Sites; DOE/CH-8901; Washington,
D.C.; June 1989.
2. Pfingston, M., et al.; 1997. TSD Dose: A Radiological Dose Assessment Model for
Treatment, Storage, and Disposal Facilities; ANL/EAD/LD-4; Argonne, IL; Argonne
National Laboratory; March 1997.
3. Wang, Y., et al.; 1993. A Compilation of Radionuclide Transfer Factors for the Plant,
Meat, Milk, and Aquatic Food Pathways and the Suggested Default Values for the
RESRAD Code; ANL/EAIS/TM-103; Argonne, IL; Argonne National Laboratory; August
1993.
4. Yu, C., et al.; 1993. Data Collection Handbook to Support Modeling the Impacts of
Radioactive Material in Soil; ANL/EAIS-8; Argonne, IL; Argonne National Laboratory;
April 1993.
5. Yu, C., et al.; 1994. RESRAD-BUILD: A Computer Model for Analyzing the Radiological
Doses resulting from the Remediation and Occupancy of Buildings Contaminated with
Radioactive Material; ANL/EAD/LD-3; Argonne, IL; Argonne National Laboratory;
November 1994.
6. Yu, C., et al.; 2000. RESRAD-RECYCLE: A Computer Model for Analyzing the
Radiological Doses and Risks Resulting from the Recycling of Radioactive Scrap Metal
and the Reuse of Surface-Contaminated Material and Equipment; ANL/EAD-3; Argonne.
IL; Argonne National Laboratory; November 2000.
7. Yu, C., et al.; 2001. User's Manual for RESRAD Version 6; ANL/EAD-4; Argonne, IL;
Argonne National Laboratory; July 2001.
B.2 DOE ALARA GUIDANCE
1. DOE, 1991a. DOE Guidance on the Procedures in Applying the ALARA Process for
Compliance with DOE 5400.5; Washington, D.C.; DOE Office of Environmental Policy
and Assistance.
2. DOE, 1997a. Applying the ALARA Process for Radiation Protection of the Public and the
Environmental Compliance with 10 CFR Part 834 and DOE 5400.5 ALARA Program
Requirements (DOE draft ALARA standard); 2 vols.; Washington, DC.; April 1997.
B.3 GUIDANCE MEMORANDUMS
1. DOE, 1984. Guidance Memorandum: Unrestricted Release of Radioactively
Contaminated Personal Property; Washington, D.C.; DOE Office of Nuclear Safety;
March 15, 1984.
2. DOE, 1995. Guidance Memorandum: Application of DOE 5400.5 Requirements for
Release and Control of Property Containing Residual Radioactive Material; Washington,
D.C.; DOE Office of Environment; Air, Water and Radiation Division; November 17,
1995.
3. DOE, 1997c. Guidance Memorandum: Establishment and Coordination of Authorized
Limits for Release of Hazardous Waste Containing Residual Radioactive Material;
Washington, D.C.; DOE Office of Waste Management; January 7, 1997.
B.4 SURVEY, MEASUREMENT, ENVIRONMENTAL MONITORING, AND
RADIOLOGICAL CONTROLS GUIDANCE
1. DOD-DOE-EPA-NRC (Department of Defense, Department of Energy, Environmental
Protection Agency, Nuclear Regulatory Commission), 2000. Multi-Agency Radiation
Survey and Site Investigation Manual (MARSSIM), Rev. 1; NUREG 1575; Washington,
D.C.; August 2000.
2. DOE, 1991c. Environmental Regulatory Guide for Radiological Effluent Monitoring and
Environmental Surveillance; DOE/EH-0173T; Washington, D.C.; January 1991.
3. DOE, 1992. DOE Radiological Control Manual; DOE/EH-0256T; Washington, D.C.
4. DOE, 1997b. Environmental Implementation Guide for Radiological Survey Procedures
(draft report for comment); Washington, D.C.; February 1997.