Metal Suspension and Exemption Planning

1. Metal Suspension and Exemption Planning Sayed Rokni, Jim Allan, James Liu, Olga Ligeti, Amanda Sabourov, Joachim Vollaire ES&H Radiation Protection Department

2. Outline • Overview of Material Disposition • DOE Moratorium and Suspension • Regulations • Pantex experience • SLAC Conditions • SLAC proposed protocol • Conclusion

3. Overview of Material Disposition All paths governed by SLAC ES&H requirements Recycle SLAC-Hold (DOE Metal Suspension) Non-Rad Metal Non-Rad Non-Metal SLAC Protocol Rad Non-Metal Rad Metal Recycle SLAC-Hold (DOE Metal Moratorium) Waste Waste SLAC RWM

4. DOE Moratorium and Suspension • Jan. 2000, DOE Metal Moratorium prohibits the release of all volumetrically contaminated metals at DOE facilities … into commerce • July 2000, DOE Metal Suspension suspends the unrestricted release for recycling of scrap metals from radiation areas within DOE facilities • Radioactive or not

5. DOE Order 5400.5, Draft Guide 441.1-XX • DOE Order 5400.5 is the primary radiation protection standard used to protect the public and the environment from undue risk of radiation • Establishes requirements and framework for the release of property with residual radioactivity from DOE control • Last revised in 1993, it remains effective • DOE G 441.xx: Guide for Control and Release of Property with Residual Radioactive Material • DOE allows sites to apply for specific permission, Authorized Limits, to release items with volumetric contamination

6. DOE Order 5400.5: Authorized Limits • Authorized Limits govern the control and clearance of personal and real property. They are radionuclide concentrations or activity levels approved by DOE to permit the clearance of property under DOE radiological control for either restricted or unrestricted use, consistent with DOE’s radiation protection framework and standards for workers, the general public, and the environment.

7. Clearance of Property: Principal Requirements • Authorized limits must meet DOE dose limit & constraint • Derived through ALARA analysis • Property must be radiologically characterized or surveyed • Public involvement and notification • Comply with applicable federal and state requirements • Independent verification prior to property release • Final documentation approved by DOE to demonstrate all requirements have been met; specifying any restrictions • Records maintenance and reporting

8. Scrap Metal Management at Pantex • Pantex revised radiation area posting procedures that limited the extent of previously defined radiation areas. New posting procedures resulted in reclassification of the status of previously encumbered scrap in storage. • Independent Review Conducted September 2008 with participation of HSS and EM. Findings: • Compliant with DOE Order 5400.5 • Complaint with 10 CFR 835 posting requirements • Compliant with DOE Policy

9. SLAC Conditions PEP II was a Radiological Area and all metal and metal containing objects within the accelerator tunnel (including BaBar) are subject to: • METAL MORATORIUM • METAL SUSPENSION For beneficial reuse/recycling as well as alleviating storage needs and disposal costs, SLAC needs to release some of the BaBar/PEP II components containing metals for recycling.

10. Materials: Concrete blocks Electronic copper cables of various diameters and lengths Iron and steel plates Electronic components and crates including PMTs Rubber and plastic hoses Aluminum piping, cable plant, and components Non-Radioactive metals largest volume of items generated in the dismantling Isotopes: In Copper: Co-60, Fe-55, Mn-54 In Plastic: Na-22, Si-32, H-3 In Lead: Bi-207, Tl-204, Hg-194, Pt-193, Ta-179 In Stainless Steel: Co-60, Fe-55, Mn-54, Co-57, V-49, Ni-63, Nb-91, Ar-39, Ti-44 Expected Materials and Isotopes

11. SLAC’s Path Forward for DOE Suspension Relief • Pantex materials had mainly surface contamination • SLAC materials are volumetrically activated SLAC proposed protocol: • Evaluation • Release Criteria • Assurance that property meets requirements

12. Path Forward for Suspension Relief: 1. Evaluation • Process knowledge • Identify areas and activities that can potentially activate materials • FLUKA calculations • BaBar detector model • Similar to LEP D&D at CERN • Identify areas with induced activity above the MDA • zoning concept • Confirmatory measurements • Measurement and survey protocols that follow MARSSIM guidance • Gross beta-gamma field surveys • Gamma spectroscopy surveys • Portal monitor surveys

13. Total Induced Activity (from B0B0 events) • Total induced activity after 10 years of irradiation and 1 year of cooling

14. Path Forward for Suspension Relief: 2. Release Criteria • Screening levels for clearance • DOE Order 5400.5 • Guidance for surface contamination (based on 25 mrem/yr) • Case-by-case approval for volumetrically contaminated materials • ALARA principle be observed • ANSI N13.12-1999 • Guidance for volumetrically activated materials (based on 1 mrem/yr) • 30 pCi/g for most beta-gamma isotopes at SLAC such as Co-60, Na-22, etc. Only items without radioactivity, i.e., below MDA, would be released for recycling

15. Path Forward for Suspension Relief:3. Assurance that Property Meets Requirements • Personnel will ensure that the calculations and surveys, project documentation, and component inventory and tracking process are of sufficient quality to meet proposed requirements. • Use lessons learned from Pantex: • Detailed and thorough documentation • Training on procedures • Independent verification • Working in close partnership with DOE site office, HQ, EM

16. Conclusion • SLAC possesses the competencies, programs, systems and processes for managing Radioactive, Mixed, and Hazardous Wastes • SLAC has developed a protocol for relief from the DOE Metal Suspension and is completing technical basis documents and implementation procedures