Accelerator Safety WorkshopSLAC

Scott L. DavisAccelerator Safety Program Manager – SC- 31.1Office of Science, U.S. Department of Energy

Progress on Metals Moratorium InitiativeAugust 17-19, 2010

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Background

Since July 13, 2000, DOE/SC has been prohibited from releasing materials such as scrap metal from radiation areas into general commerce.

The Secretarial Moratorium and Suspension was originally to be in place for 6 months, the prohibition was extended indefinitely on January 19, 2001 until improvements were made to radiological clearance processes associated with the release of personal property.

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Background

Improvements Better definition, control and minimization of areas that

can contaminate property.

Clear and consistent definition and management of process knowledge used to support clearance of property from radiological control.

Independent (e.g., federal) verification of the integrity of site radiological clearance programs.

Incorporation of public input and better inform the public on radiological clearance programs.

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Background

All NNSA Sites have been reviewed

EM has conducted one site review

Two SC Sites have been reviewed to date, SLAC and TJ

Each Site has consistently implemented the prohibition with a conservative approach

Both demonstrated they had encumbered metal and equipment that could be ultimately be introduced into the reuse/scrap stream

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ImpactsHigher costs for operations, research and

development with no increased benefit Stockpile of encumbered materials is increasing No budget to manage or disposition as waste Material at some sites does not qualify for disposal at

EM on-site cells. Must be disposed of locally as industrial or sanitary waste or sent to Nevada Test Site.

Some communities specifically prohibit disposal of recyclables.

Management of newly generated encumbered material increases estimated total costs

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Impacts

Lost revenue Scrap including radiologically clean precious metals

cannot be sold and materials currently encumbered cannot be used as a revenue source

TJ and SLAC materials have an estimated value of $5M and $11M

Cost to manage this material is a tax on operations and research budgets

Disposal of accumulated inventory as a legacy problem and is funded through site overhead accounts.

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Current Status

Review of site radiological clearance practices System-wide review of NNSA sites SC participated in several NNSA reviews SC joined NNSA initiative in August 2009 with

endorsement of NLDC TJNAF and SLAC sites reviewed NNSA and SC Assistance teams consisted of personnel

from; NA-50, NA-17 and HSS, each provided subject matter experts.

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Current Status

Site Reviews

Site Reviews focused on identifying improvements to radiological and property management clearance processes since July 2000

Review Reports provided site proficiencies and observations with recommendations for improvement, where needed

SC Site reviews are not complete.

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Current Status

Radioactive Materials Workshop

NNSA and SC combined efforts culminated in an integrated site workshop to develop consensus approach to management of radiological clearance programs consistent with Secretarial mandates.

Workshop established a set of “Principles for Management and Operation of Radiological Clearance Programs”

Sites agreed to use these Principles of Operation to resume clearance operations

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Principles of Operation

Program offices and sites commit to an active and continuous process of validating radiological postings

Sufficient information should be gathered, managed and preserved as process knowledge to support validation of the clearance decision by a third, independent party.

Site office personnel are responsible for independent verification and oversight of the integrity of radiological clearance programs.

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Principles of Operation

Sites will use the Annual Site Environmental Report as the primary conduit to report the amount and type of personal property cleared. Site public affairs offices will be the primary contact with members of the public.

For accelerator facilities, items determined to be indistinguishable from background radiation levels are not impacted by accelerator operations. Material meeting established criteria may be cleared.

To the extent possible, sites will model their radiological clearance programs according to the processes defined in the MARSAME manual.

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Approach to Resumption of Clearance Operations

■ Develop an Action Memorandum for the Secretary, requesting delegation of authority to the Under Secretaries, to manage their site radiological clearance processes.

■ Once delegated to SC-1, SC-3 staff can:

Offer recommendations to the Under Secretary regarding SC sites deemed ready to restart clearance operations.

Provide assistance, guidance, clarification and oversight for the Under Secretary of Science to ensure site compliance with Principles of Operation.

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Path Forward for Radioactive Material Initiative

Action Memo (AM) to Secretary Options in AM Permit clearance of currently encumbered materials if “Principles of Operation”

are adopted and institutionalized. Permission can be granted by the Under Secretary (preferred option).

Same as #1, but clearance of encumbered materials must wait until an EA is completed and a FONSI issued.

Lift the suspension without any enhancements. Make suspension permanent. Direct program offices to budget for and dispose of

encumbered materials. Current Status of AM

The action memorandum to the Secretary is being drafted concurrently. NNSA, SC and EM, are working on the AM and public notification that GC wants

to precede any change in the suspension policy. AM is drafted to come from ALL THREE of the Under Secretaries; Assuming they

concur, memo will be given to the Secretary for consideration.

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Recommendations1. Request the Secretary to delegate, to the Undersecretaries the

authority to manage radiological clearance and release of all material.

2. In support of delegation, each Under Secretary would promulgate the Principles of Operation as guidance to field sites. Acceptance of these principles is a condition to resume radiological clearance operations.

3. Establish a headquarters steering group should be assigned the responsibility to:

a. Provide an appropriate level of oversight and assistance to field elements;

b. Provide guidance and support as requested;c. Coordinate with relevant HQ organizations as necessary;d. Monitor the Occurrence Reporting System (ORPS) for issues related to

release of items from radiological control;e. Report on performance trends periodically.

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Backup Slides

Accelerator Working Group Release Criteria Process Improvements

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Process Improvement & OpportunityInstitute an SC Investment Recovery Process with

emphasis on improved operations:■ Processing obsolete, scrap, surplus, or waste material in a manner

that maximizes the ROI while minimizing costs and liabilities

■ Coordinate management of surplus materials across all SC sites.

■ Integrate site operations to include: Environmental requirements for dispositioning actions Improve communications and save resources Recycle and reuse options to address GHG initiatives (EO

13514).

■ Leverage high value items within SC complex.

■ Partner with NNSA to: Engage private sector capabilities. Use their interfaces with DoD

Accelerator Working Group Release Criteria Indistinguishable from Background (IFB): Materials that are IFB can

have unrestricted release and are not subject to further regulatory control.

Greater that IFB but less that ANSI N13.12: The ANSI N13.12 Clearance Level (based on an annual dose criterion of 1 mrem/yr) should be considered as DOE pre-approved Authorized Limits for materials that may be volumetrically activated. This provides for a consistent technical basis on which to base release protocols and allows for effective regulation of those protocols.

Greater than ANSI N13.12: Materials with induced activity above the ANSI N13.12 Clearance Levels may be released through the current DOE Order 5400.5 Derived Authorized Limit process. This is consistent with requirements in the DOE Order 5400.5 and DOE Order 458.1 draft for volumetric