EM Program Expectations on Implementation of DOE O 458: Radiation Protection of Public/Environment - 19553
DOE Order 458.1, Radiation Protection of the Public and Environment, was issued in 2011. DOE sites were given 18 months to implement. The revised Order promulgates requirements for property clearance actions and independent verification. DOE Order 458.1 allows for preapproved authorized limits for the clearance of property. However, when property with the potential to contain residual radioactive material does not meet preapproved authorized limits, an authorized limits package must be developed. The Order contains a range of requirements for demonstrating with reasonable assurance that dose constraints are met for any actual or likely future use of the property to be released. EM has developed a draft guidance document that provides the elements of an authorized limits package. These elements are used to review all authorized limits packages that are submitted to EM. Expected elements include property description and process knowledge documentation, current and likely future use, the conceptual site model, dose modeling methodologies, specific authorized limits, dose- or concentration-based constraints, collective dose estimate to the potentially exposed population, stakeholder communications, description of the As Low As Reasonably Achievable (ALARA) analysis, implementation plan, evaluation of difficult to assess surfaces, and independent verification plan. The draft guidance document also provides further explanation of the desired elements of an independent verification (IV) plan. An IV plan should describe the planning phase, implementation phase, assessment phase, and decision phase of an activity. The planning phase includes scope and cost, concurrent with cleanup contractor procurement, and review and approval of site radiological survey clearance program and IV program plans. The implementation phase assures sufficient collection of data and adjustment can be made as necessary. During the assessment phase, data and reports are reviewed, and coordination between the clean-up contractor and IV personnel occurs. A decision of whether or not the clearance actions need to be altered occurs during the decision phase. IV certification that the clearance action is complete also occurs during the decision phase. Issuance of the final guidance document is meant to improve the consultation process and minimize iterative interactions with EM. Standardizing and formalizing property clearance and IV actions also helps assure that cleanup actions are transparent and sustainable for future scrutiny. (authors)