Radiation Protection of the Public and Environment

Draft 1/9/2006

Suggested lines of inquiry and review approach

Performance Objective 1: Contractor Program Documentation

Lines of Inquiry and Approach:

• How have potential radiological hazards to the public and the environment associated with radiological releases from DOE programs and activities been analyzed, and how have plans for the monitoring and assessment of these hazards been developed and reviewed?
• Is the documentation of the plans, practices, procedures and other actions to be used in complying with environmental radiation protection requirements in a manner commensurate with the radiation exposure hazards associated with the site's operations and activities? Are schedules for implementation of program elements necessary to achieve compliance identified?
• Does the documentation describe management systems used to maintain and keep current the plans, practices, and procedures for the environmental radiological protection program?

Performance Objective 2: Contractor Program Implementation

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.

Lines of Inquiry and Approach:

• How have all potential releases of radioactive material (i.e., hazards) been assessed and documented to ensure that they are managed in accordance with the ALARA policy and requirements?
• Is there evidence of a commitment to use the ALARA process? Is there a description of the means to be used to implement the ALARA process including appropriate involvement of interested parties? Identify specific examples and their strengths and weaknesses.
• Does the process for ALARA decisions involve consideration of appropriate options and their potential performance, to include appropriate quantitative and qualitative methods for estimating associated doses, costs, and other criteria or decision attributes? Identify specific examples and their inclusion of appropriate decision attributes.
• Is there a process for documenting ALARA decisions?
• Is there a training program for employees on implementation of the ALARA process?

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).

Lines of Inquiry and Approach:

• Has a system been established for evaluating the doses to the public and the environment considering relevant exposure modes and pathways from DOE activities? Are doses less than DOE's all-pathways limit of 100 mrem/year and ALARA?
• Is a system in place to ensure that dose evaluations are supported with updated and accurate information, which includes the documented justification of all parametric values used?
• Is a system in place for selecting and validating appropriate methods and models used for evaluating doses to the public and the environment?
• Is the information used to calculate doses to the public (e.g., including the extent and use of affected air, land, and water media data), as well as specific local or public interests or concerns identified, documented, reported, and periodically re-evaluated?

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).

Lines of Inquiry and Approach:

• Is there a program in place to characterize and assess the effects of DOE activities on onsite and offsite ambient air quality and to members of the public?
• Is the justification and rationale for the ambient air characterization program current and described in appropriate program plans, procedures, and protocols? Are stack monitoring methods and quality assurance requirements as specified in Subpart H implemented at the site and its facilities?
• Are demonstrations of compliance conducted using computer codes approved in accordance with 40 CFR Part 61 and through environmental measurements using EPA-approved techniques?
• Are there any variations to the site's Subpart H air monitoring program, and if so, have they been agreed to by EPA?
• Is the ambient air monitoring program considering minimum sensitivity, release conditions, and particle size?
• How are diffuse sources included into the site's air emissions program?
• Does radioactive air monitoring and results comply with DOE and appropriate federal, state, and local reporting requirements? Are annual Subpart H site emission reports submitted to EPA by June 30th per Subpart H reporting requirements?
• How are emissions of radon and from unplanned radionuclide releases, although not regulated by Subpart H, included in the site's reporting?
• How is collective dose to the population within 50 miles of the site represented in the site's reporting?

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.

Lines of Inquiry and Approach:

• Have DOE sites and contractors fully analyzed, controlled, and monitored for potential radiological releases from operational facilities and site restoration activities into the groundwater and soil column?
• Has selection of BAT been determined through a process that included several candidate technologies and that included an evaluation of factors related to technology, economics, technical and engineering aspects of the technology, safety, and public policy considerations?
• Are potential doses to the public from DOE operated drinking water systems, or from public or private systems downstream of DOE facilities, less than 4 mrem/year? Have dose estimates been determined through application of data and models of known pedigree and quality?
• Is there a program in place to characterize and assess the effects of DOE activities on onsite and offsite water quality and to members of the public and the environment?
• Is the justification and rationale for water quality characterization programs current and described in appropriate program plans, procedures, and protocols?
• Do water quality monitoring and results comply with DOE and appropriate federal, state, and local reporting requirements?
• Do radiological water quality and monitoring program areas for surface and groundwater incorporate, as appropriate, the concepts of a watershed approach for surface water protection and a site-wide approach for groundwater protection referenced in DOE Order 450.1?

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.

Lines of Inquiry and Approach:

• How are environmental measurement data and biota screening and dose assessment methods being applied to evaluate potential radiological impacts and to demonstrate compliance with requirements for radiological protection of biota?
• Are the DOE Graded Approach for Evaluating Radiation Doses to Aquatic and Terrestrial Biota (DOE-STD-1153-2002) and its companion software code RESRAD-BIOTA being applied as the preferred methods for assessing potential radiological impacts to biota, per the EH-41, March 24, 2005 Memorandum," Guidance for the Preparation of Department of Energy (DOE) Annual Site Environmental Reports (ASERs) for Calendar Year 2004?" If not then what other site-specified and technically peer-reviewed assessment approaches are being implemented and why?
• Are results from biota dose assessments in compliance with DOE's recommended dose rate guidelines of 1 rad/day for aquatic animals, 0.1 rad/day for riparian animals, 1 rad/day for terrestrial plants, and 0.1 rad/day for terrestrial animals as referenced in DOE-STD-1153-2002?
• Are results of biota dose assessments being properly documented and reported in the Annual Site Environmental Report as specified in DOE EH-41 annual format and content guidance?
• Based on lessons learned from previous biota screening and dose assessments, what refinements or modifications have been made to the design of the environmental monitoring program (e.g., addition of media sampling locations; greater frequency of media sample collections; co-location of water and soil/sediment media sampling stations; collection of indicator organism tissue data) have been made to allow for more realistic and representative biota dose assessment estimates?

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.

Lines of Inquiry and Approach:

• Are DOE and its contractors following DOE policies established through DOE Secretarial Memoranda issued in 2000 and 2001 that placed a moratorium on release of volumetrically contaminated metals; placed a suspension on scrap metal recycling from radiological areas; and provided key guidance that DOE sites should follow to improve their monitoring and release practices?
• How are DOE and its contractors clearly defining areas and activities that could potentially contaminate property?
• How are DOE and its contractors documenting clear process-knowledge-based procedures for those releases that have no potential to violate DOE radiological protection requirements?
• Has the property to be released been evaluated, radiologically characterized, and decontaminated as needed before release?
• Is the level of residual radioactive material in property released as near background levels as is reasonably practicable, as determined through DOE ALARA process requirements? Does it meet DOE authorized limits?
• How has DOE and its contractors involved the public in the analysis and discussion of candidate release options? Are they informing and reporting to the public regarding the authorized limits ultimately selected for property being released?
• How have property releases been appropriately certified, verified, documented, and reported? Have public involvement and notification needs been addressed? Are records of releases being maintained? Provide specific examples.
• How were appropriate DOE and other guidance for control and release of property applied in the evaluation of candidate release options and establishment of authorized limits?
• Does the final documentation for release of property contain the required specific elements per DOE Order 5400.5?
• Are radiological soil postings for areas contaminated with surface and volumetric radioactivity clear, consistent, and technically sound? Do they address both DOE Order 5400.5 and 10 CFR Part 835 requirements in cases where DOE retains control of the property? Provide specific examples.
• Have appropriate DOE line management approval authorities been applied to the release of property (e.g., for release of personal property through use of surface activity guides versus alternate ALARA/dose-based derived authorized limits; for release of open land and structures; exemptions for 10 CFR part 835 posting and access control) as specified in DOE Order 5400.5 and Guide 441.1-xx? Provide specific examples.

2.7 Waste Management

Lines of Inquiry and Approach:

To be added.

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.

Lines of Inquiry and Approach:

• Is there an integrated environmental monitoring and surveillance program and associated documentation in place? How is it systematically reviewed to ensure monitoring needs associated with specific program or site operations are being addressed in a holistic, cost-effective and efficient manner? How are program redundancies and gaps effectively identified and addressed?
• How are environmental monitoring and associated quality assurance and assessment data appropriately tracked, reviewed, and trended to ensure that changes in environmental conditions are fully identified and reported? Are procedural controls consistent with line management expectations established for trending and reporting anomalous conditions?
• How are environmental monitoring and surveillance data reviewed regularly to determine if modifications or improvements to the overall design (sampling methods, location, and analysis) are needed to meet data quality objectives or overall program performance?
• How are environmental sampling and analysis methods and approaches systematically reviewed and evaluated to ensure they are sufficient to demonstrate compliance with applicable limits and provide an adequate technical basis for the environmental monitoring program?
• Is there a program in place for evaluating unplanned releases and assessing the impacts of such releases on the public and the environment?
• What processes are employed in notifying responsible managers and stakeholders on environmental monitoring implementation and results?
• How is information gained through routine radiological monitoring and surveillance efforts used to support the ALARA process and evaluate its effectiveness?
• Are formalized reporting procedures and criteria for monitoring results in place?
• Are there programs in place to ensure the overall accuracy and precision of radiological effluent monitoring and environmental surveillance data?
• Are programs in place to ensure that representative samples are obtained and that all factors germane to proper sample collection are identified and incorporated into sampling activities?
• What systems are in place for performing and recording calibration and maintenance activities associated with field and laboratory instrumentation?
• Is a validated and consistent approach for sampling and analysis of radionuclide samples applied to ensure laboratory data meets program-specific needs and requirements within the framework of a performance-based approach for analytical work?
• What systems are in place to ensure corrective actions are implemented during malfunctions of field and laboratory instrumentation?
• Is there a program in place to conduct a preoperational assessment of all facilities coming on-line (new or modified) to determine the types and quantities of effluents to be expected?
• Is there a program in place to obtain representative meteorological data necessary to assess the impact of routine and accidental releases of radioactivity? How well does it provide the data needed to help determine the transport and fate of radionuclides released to the atmosphere or subsequently resuspended from surfaces, and the assessment of their impacts to public health and the environment?

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.

Lines of Inquiry and Approach

• Are dose assessments and data used to demonstrate compliance with DOE and other requirements documented in DOE Annual Site Environmental Reports, and in other environmental protection and compliance reports as requested or required by other Federal, state and local agencies?
• Are environmental data and compliance results documented in DOE Annual Site Environmental Reports consistent with DOE EH-41 annual format and content guidance?

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.

Lines of Inquiry and Approach:

• How does DOE line management exercise diligence in the trending and tracking of groundwater, air, soil, surface water, and biota monitoring and evaluation data to ensure that changes in environmental contamination conditions are fully identified and reported, and potential doses to the public and environment are adequately assessed and understood? Provide examples and their frequency.
• Has DOE line management provided for qualified environmental, health physics, and radiological science resources within environmental radiation protection program areas sufficient to ensure DOE radiological requirements and objectives are being met?
• How are environmental radiation protection program oversight assessments being routinely conducted using this and other media- or topic-specific Criteria and Review Approach Documents (CRADs)? Provide examples and their frequency.
• With respect to environmental radiation protection program elements, is there evidence that DOE line management is adequately interpreting and implementing DOE's Oversight Policy (DOE P 226.1)? Identify specific examples.
• Does the DOE line management oversight process include elements such as inspections, reviews, surveillances, surveys, operational awareness, and walkthroughs that evaluate the environmental radiation protection program and its integration within the overarching management system (e.g., ISMS; EMS)? Identify specific examples and their frequency.

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