Radiation Protection of the Public and Environment

Draft 1/9/2006

FUNCTIONAL AREA GOAL: The Department of Energy (DOE) and its contractors are operating their facilities and conducting their activities according to DOE and other appropriate federal and state requirements, policies and guidance for protecting members of the public and the environment against undue risk from radiation.

The Department of Energy is providing effective federal oversight to ensure it fulfills environmental radiological protection responsibilities within its programs and operations.

REQUIREMENTS::

DOE P 226.1, Department of Energy Oversight Policy
DOE P 450.4, Safety Management System Policy
DOE P 450.2A, Identifying, Implementing, and Complying with Environment, Safety and Health Requirements
DOE P 454.1, Use of Institutional Controls
10 CFR Part 835, Occupational Radiation Protection
48 CFR 970.5223-1, Integration of Environment, Safety and Health into Work Planning and Execution
40 CFR Part 61, Subpart H, National Emission Standard for Radionuclide Emissions from Department of Energy Facilities
40 CFR Part 141, National Primary Drinking Water Regulations
DOE Order 5400.5, Radiation Protection of the Public and the Environment
DOE O 450.1, Environmental Protection Program
DOE O 435.1, Radioactive Waste Management
DOE O 231.1A, Environment, Safety and Health Reporting
DOE M 435.1-1, Radioactive Waste Management Manual
DOE M 231.1-1A, Environment, Safety and Health Reporting Manual

GUIDANCE:

EH-41, November 17, 1995, Guidance Memorandum on Application of DOE 5400.5 Requirements for Release and Control of Property Containing Residual Radioactive Material
EH-41, March 24, 2005, Guidance for the Preparation of Department of Energy (DOE) Annual Site Environmental Reports (ASERs) for Calendar Year 2004
DOE/EH-0173T, Environmental Regulatory Guide for Radiological Effluent Monitoring and Environmental Surveillance
EPA 520/1-88-020, Federal Guidance Report No. 11
Residual Radioactivity (RESRAD) Family of Codes for Dose and Risk Assessment, accessible through the RESRAD Web Site (http://web.ead.anl.gov/resrad/home2/)
Guide 441.1-XX, Implementation Guide for Control and Release of Property with Residual Radioactive Material
DOE-STD-1153-2002, A Graded Approach for Evaluating Radiation Doses to Aquatic and Terrestrial Biota
DOE/EH-0676, RESRAD-BIOTA: A Tool for Implementing a Graded Approach to Biota Dose Evaluation, User's Guide, Version 1
EPA 402-B-04-001A-C, Multi-Agency Radiological Laboratory Analytical Protocols Manual (MARLAP)
NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)

Performance Objective 1: Contractor Program Documentation

Environmental radiation protection program elements for assessing potential impacts to public health and the environment are documented and described in sufficient detail to demonstrate that requirements and expectations are translated into program and procedural description documents.

Department of Energy (DOE) and other federal, state, and local requirements and commitments are appropriately addressed.

Organizational structure and program content, roles and responsibilities, levels of authority, accountability, and interfaces for those managing, planning, performing, and assessing work are clearly defined and documented as appropriate.

Criteria:

DOE requirements and expectations for environmental radiological protection programs are clearly understood and fully defined in all areas, and invoked as appropriate in DOE contracts. [DOE Order 5400.5; 48 CFR 970.5223-1]
The management of environmental radiation protection functions and activities are an integral and visible part of the contractor's work planning and execution processes. [48 CFR 970.5223-1]
Environmental Management Systems (EMSs) contained within contractor Integrated Safety Management Systems (ISMSs) include the systematic planning for addressing and demonstrating compliance with DOE environmental radiation protection policies and requirements, and with applicable public health and environmental protection laws and regulations. [DOE O 450.1]

Performance Objective 2: Contractor Program Implementation

Environmental radiological protection programs and activities are being successfully implemented within DOE operations in accordance with appropriate DOE and other federal and state requirements, policies and guidance.

Implementation of programs and activities is meeting the requirements and expectations presented and referenced in program and procedural description documents, contracts, and compliance agreements.

An effective environmental radiation protection program includes systems to provide for compliant utilization, storage, and disposal of radioactive materials, minimizes radiation exposure to the public and environment, accurately characterizes radiological releases to the environment, and formally documents that all exposures and releases are maintained ALARA.

2.1 As Low as is Reasonably Achievable (ALARA) Program: Releases and exposures of radioactivity to the public and the environment are controlled to ensure they are maintained at levels that are ALARA below applicable dose limits. Releases and exposures of radioactivity are assessed in a manner consistent with the ALARA analysis process.

Criteria:

The ALARA principle and options analysis process is being systematically applied to environmental radiological protection programs and activities in monitoring and assessing the potential radiological hazards to the public and the environment. [DOE Order 5400.5]
An ALARA program, developed and documented by DOE Field Elements, is being implemented by the contractor for all operations, facilities, and activities that could cause doses to the public and the environment. [DOE Order 5400.5]

2.2 Doses to the Public and Environment: Potential exposures to the public and the environment and resultant doses are as far below dose limits as is reasonably achievable (ALARA).

Criteria:

Exposure of members of the public as a consequence of all routine DOE activities (e.g., all pathways and sources) is ALARA and does not cause an effective dose equivalent of greater than 100 mrem in a year. Doses from all exposure modes that could contribute significantly to the total dose are considered for evaluation. [DOE Order 5400.5]
Compliance with dose limits is demonstrated by documentation of an appropriate combination of measurements and calculations to evaluate potential doses and the results of the evaluations. Demonstrations of compliance are performed employing monitoring and surveillance data, modeling and dose conversion factors, and parametric considerations identified in DOE Order 5400.5 and supporting guidance from DOE and other agencies. [DOE Order 5400.5]

2.3 Radiological Impacts from Air Emissions: Exposures to the public and the environment and resultant doses attributable to air emissions from DOE activities are as far below air pathway-specific dose limits and requirements as is reasonably achievable (ALARA).

Criteria:

Exposure of members of the public to radioactive materials released to the atmosphere as a consequence of routine DOE activities are ALARA and do not cause members of the public to receive greater than 10 mrem in a year. Facilities exceeding 1 % of the dose limit to an offsite member of the public are continuously monitored. Facilities that are less than 1 % of the dose limit are sampled periodically for confirmation. [DOE Order 5400.5; 40 CFR Part 61, Subpart H; state air emission regulations]

2.4 Radiological Impacts from Liquid Discharges: Exposures to the public and the environment and resultant doses attributable to liquid discharges from DOE activities are as far below water pathway-specific dose limits and requirements as is reasonably achievable (ALARA). Liquid discharges to surface waters, aquifers, and sanitary sewerage, and their contamination of soils and drinking and groundwater exposure pathways are quantified and assessed.

Criteria:

A program has been established to review all operational changes, facilities, and facility modifications to determine if they will increase discharges of radioactively contaminated liquids to soil columns, create new soil column discharge areas or discharge uncontaminated liquid to an inactive soil column release area. [DOE Order 5400.5]
Contaminated soil column, drainage systems, and groundwater to which radiologically contaminated liquid discharges have been discontinued have been identified and are being managed or decontaminated pursuant to appropriate requirements. [DOE Order 5400.5]
Best Available Technology (BAT) and ALARA selection processes are applied as necessary regarding effluent discharges to surface waters or soil columns. [DOE Order 5400.5]
Doses to the public from public drinking water supplies operated by DOE or its contractors are ALARA and less than 4 mrem in a year. Combined radium-226 and radium-228 does not exceed 5 x 10-9 uCi/ml and gross alpha activity (including radium-226 but excluding radon and uranium) does not exceed 1.5 x 10-8 uCi/ml. Liquid effluents from DOE activities are ALARA and do not cause private or public drinking water systems downstream to exceed 4 mrem. [DOE Order 5400.5; 40 CFR Part 141]

2.5 Radiological Impacts to Biota: Environmental radiological protection programs include planning and implementation of approaches to demonstrate radiation protection of biota (plants and animals) and ecosystems.

Criteria:

As part of integrating EMSs into their ISMSs, DOE and its contractors should include, as appropriate, approaches for demonstrating protection of biota (plants and animals) from radiological impacts associated with DOE activities. [DOE O 450.1]
Doses to aquatic animals do not exceed 1 rad/day from exposures resulting from liquid wastes discharged to natural waterways. [DOE Order 5400.5]

2.6 Release of Property Containing Residual Radioactive Material: Authorized releases of property suspected of containing residual radioactive material meet DOE and other federal, state and local radiation protection policies and requirements.

Criteria:

An authorized limit for release of property should not exceed a dose constraint of 25 mrem/year and should be as far below 25 mrem/year as is practicable determined through an ALARA release options analysis process. [DOE Order 5400.5]
Any property known or suspected to have residual radioactive material must be appropriately surveyed or characterized. Surveys must be adequate to demonstrate that authorized limits are met. [DOE Order 5400.5]
Releases must also be in compliance with other applicable federal or state requirements, such as NRC or Agreement State licenses. [DOE Order 5400.5]
Final documentation supporting the release of property should meet DOE Order 5400.5 records requirements, and should be publicly available. [DOE Order 5400.5]

2.7 Waste Management

Criteria:

DOE and DOE contractor radioactive waste management programs and activities are systematically planned, documented, executed, and evaluated in a manner that protects the public, workers, and the environment from exposure to radiation. [DOE O 435.1]
DOE and DOE contractor waste management programs and activities comply with the requirements of DOE M 435.1-1, Radioactive Waste Management Manual. [DOE O 435.1]
Exposure of the public to direct radiation or radioactive material released from DOE management and storage activities at a disposal facility for spent nuclear fuel (SNF), high level waste (HLW), or transuranic waste (TRU) not regulated by NRC should be ALARA and less than 25 mrem/year. [DOE Order 5400.5]

2.8 Effluent Monitoring and Environmental Surveillance: A program is in place for monitoring and quantifying releases of radioactivity to the environment, and that provides for the credible assessment of their potential impacts to public health and the environment.

Criteria:

DOE contractors have the capabilities, consistent with the types of operations conducted, to monitor routine and non-routine releases that provide for the assessment of doses to members of the public and the environment. [DOE Order 5400.5; DOE O 450.1]
As part of integrating EMSs into their ISMSs, contractors ensure the early identification of, and appropriate response to, potential adverse environmental impacts associated with DOE operations, including as appropriate preoperational characterization and assessment, and effluent and surveillance monitoring. [DOE O 450.1]
Contractors shall conduct environmental monitoring, as appropriate, to support the site's ISMSs, to detect and characterize releases from DOE activities; assess impacts; estimate dispersal patterns in the environment; characterize the pathways of exposure to members of the public; and characterize the exposures and doses to individuals, and to the population; and to evaluate the potential impacts to the biota in the vicinity of the DOE activity. [DOE O 450.1]

2.9 Reporting Results of Environmental Radiation Protection Programs: Results of environmental radiation protection program elements for assessing potential impacts to public health and the environment are appropriately reported and disseminated to DOE stakeholders consistent with DOE and other reporting requirements.

Criteria:

Environmental monitoring and surveillance data, dose assessments, and demonstrations of compliance with DOE environmental radiological protection program requirements and with other federal, state, or local requirements and commitments are appropriately reported. [DOE Order 5400.5; DOE O 231.1A; DOE M 231.1-1A]

Performance Objective 3: DOE Line Management Oversight

Programs, protocols, resources, and commitments are in place for assuring that DOE site and headquarters elements are providing adequate management and oversight of environmental radiological protection programs and activities.

Criteria:

PSOs are implementing DOE public and environmental radiation protection policy and requirements in their respective programs. [DOE Order 5400.5]
DOE Heads of Field elements and contractors are maintaining appropriate capabilities for monitoring and assessing routine and unplanned releases of radioactive materials, with respect to the characteristics of radioactive material released and the release modes, consistent with the types of operations conducted. [DOE Order 5400.5; O 450.1]
Sufficient resources (to include budget and professional radiological expertise) are being applied to environmental radiological protection programs. [DOE O 450.1; 48 CFR 970.5223-1]

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