US Department of Energy Implementation of Pre-Approved Volumetric Authorized Limits in Environmental Management - 22049

For several decades, the US Department of Energy (DOE) has had pre-approved authorized limits in place for the clearance of materials based on surface contamination thresholds. These surface contamination thresholds were previously published in DOE Order 5400.5, Radiation Protection of the Public and Environment Reference. When the Order was revised in 2011 with the issuance of DOE Order 458.1, Radiation Protection of the Public and Environment, the surface contamination threshold tables were removed from the Order with the intention of moving them to a technical standard Reference. In the absence of a technical standard, the Order allowed for the continued use of the pre-approved authorized limits for surface contamination. However, no volumetric authorized limits had ever been approved. Additionally, pre-approved authorized limits for surface contamination for Group 1 radionuclides (transuranics, I-125, I-129, Ra-226, Ac-227, Ra-228, Th-228, Th-230, and Pa-231) were not specified in DOE Order 5400.5. Pre-approved authorized limits for surface contamination for Group 1 radionuclides were included in the draft DOE Guide 441.1-XX, Implementation Guide: Control and Release of Property with Residual Radioactive Material for use with DOE 5400.5, Table 2, DOE Total Residual Surface Activity Guidelines: Allowable Total Residual Surface Activity (dpm/100 cm²) Reference. Although the pre-approved surface contamination limits in Table 2 of the draft guide were approved for use, the guide itself was never formally published. In March 16, 2021, the Associate Undersecretary for Environment, Health, Safety and Security issued a memorandum titled: Pre-Approved Authorized Limits for Release and Clearance of Volumetric Radioactivity of Personal Property at the Department of Energy Field Elements and reaffirmed that the January 2000 moratorium on the release of volumetrically contaminated metals and the related July 2000 prohibition on unrestricted release of volumetrically contaminated metal into commerce remains in place Reference. The memorandum authorized the use of volumetric screening levels from American National Standards Institute (ANSI)/Health Physics Society (HPS) N13.12-2013, Surface and Volume Radioactive Standards for Clearance, for the volumetric clearance of personal property, as defined in DOE Order 458.1, for US DOE activities Reference. Pre-approved authorized limits for surface contamination remained unchanged and were re-affirmed in an Operating Experience (OE) level 3 bulletin, OE-3: 2021-01, Implementation of Pre-Approved Authorized Limits for Release and Clearance of Volumetric Radioactivity of Personal Property at DOE Field Elements Reference. Prior to approval of the ANSI/HPS N13.12-2013 volumetric clearance limits, clearance activities involving potentially contaminated personal property were approved on a case-by-case basis. With the approval of the ANSI/HPS N13.12 volumetric clearance limits, DOE field elements are now able to more efficiently implement the recommendations of a national consensus standard across the DOE Complex. Previously approved authorized limits are unaffected by the March 16, 2021 memorandum. DOE field elements would expected to conduct a gap analysis. The newly issued pre-approved volumetric authorized limits only apply to personal property as defined by DOE Order 458.1. Real Property, defined as 'Land and anything permanently affixed to the land such as buildings, fences and those things attached to the buildings, such as light fixtures, plumbing and heating fixtures, or other such items, that would be personal property if not attached' must still be approved on a case-by-case basis. The Acting Assistant Secretary for Environmental Management (EM) further clarified in an April 9, 2021 memorandum that EM sites must notify EM Headquarters for proposed use of pre-approved authorized limits for off-site reuse or recycle, excluding metals covered by the January 2000 moratorium on the release of volumetrically contaminated metals and the related July 2000 prohibition on unrestricted release of volumetrically contaminated metal into commerce Reference. Several questions regarding implementation of the pre-approved volumetric authorized limits have arisen in the DOE EM Complex since the issuance. This paper will focus on implementation of the new pre-approved volumetric release criteria for personal property at DOE field elements. (authors)