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LFRG DOE Order 435.1

Chapter 4 of the DOE Manual on Order 435.1, Low-level Waste Requirements, addresses the procedures whereby Department of Energy LLW Disposal Facilities will operated and maintained. Section P and Section Q describe the Performance Assessment and Composite Analysis documents that each DOE disposal facility will submit to the LFRG.

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P. Disposal. Low-level waste disposal facilities shall meet the following requirements.

(1) Performance Objectives. Low-level waste disposal facilities shall be sited, designed, operated, maintained, and closed so that a reasonable expectation exists that the following performance objectives will be met for waste disposed of after September 26, 1988:

(a) Dose to representative members of the public shall not exceed 25 mrem (0.25 mSv) in a year total effective dose equivalent from all exposure pathways, excluding the dose from radon and its progeny in air.

(b) Dose to representative members of the public via the air pathway shall not exceed 10 mrem (0.10 mSv) in a year total effective dose equivalent, excluding the dose from radon and its progeny.

(c) Release of radon shall be less than an average flux of 20 pCi/m2/s (0.74 Bq/m2/s) at the surface of the disposal facility. Alternatively, a limit of 0.5 pCi/1 (0.0185 Bq/l) of air may be applied at the boundary of the facility.

(2) Performance Assessment. A site-specific radiological performance assessment shall be prepared and maintained for DOE low-level waste disposed of after September 26, 1988. The performance assessment shall include calculations for a 1,000 year period after closure of potential doses to representative future members of the public and potential releases from the facility to provide a reasonable expectation that the performance objectives identified in this Chapter are not exceeded as a result of operation and closure of the facility.

(a) Analyses performed to demonstrate compliance with the performance objectives in this Chapter, and to establish limits on concentrations of radionuclides for disposal based on the performance measures for inadvertent intruders in this Chapter shall be based on reasonable activities in the critical group of exposed individuals. Unless otherwise specified, the assumption of average living habits and exposure conditions in representative critical groups of individuals projected to receive the highest doses is appropriate. The likelihood of inadvertent intruder scenarios may be considered in interpreting the results of the analyses and establishing radionuclide concentrations, if adequate justification is provided.

(b) The point of compliance shall correspond to the point of highest projected dose or concentration beyond a 100 meter buffer zone surrounding the disposed waste. A larger or smaller buffer zone may be used if adequate justification is provided.

(c) Performance assessments shall address reasonably foreseeable natural processes that might disrupt barriers against release and transport of radioactive materials.

(d) Performance assessments shall use DOE-approved dose coefficients (dose conversion factors) for internal and external exposure of reference adults.

(e) The performance assessment shall include a sensitivity/uncertainty analysis.

(f) Performance assessments shall include a demonstration that projected releases of radionuclides to the environment shall be maintained as low as reasonably achievable (ALARA).

(g) For purposes of establishing limits on radionuclides that may be disposed of near-surface, the performance assessment shall include an assessment of impacts to water resources.

(h) For purposes of establishing limits on the concentration of radionuclides that may be disposed of near-surface, the performance assessment shall include an assessment of impacts calculated for a hypothetical person assumed to inadvertently intrude for a temporary period into the low-level waste disposal facility. For intruder analyses, institutional controls shall be assumed to be effective in deterring intrusion for at least 100 years following closure. The intruder analyses shall use performance measures for chronic and acute exposure scenarios, respectively, of 100 mrem (1 mSv) in a year and 500 mrem (5 mSv) total effective dose equivalent excluding radon in air.

(3) Composite Analysis. For disposal facilities which received waste after September 26, 1988, a site-specific radiological composite analysis shall be prepared and maintained that accounts for all sources of radioactive material that may be left at the DOE site and may interact with the low-level waste disposal facility, contributing to the dose projected to a hypothetical member of the public from the existing or future disposal facilities. Performance measures shall be consistent with DOE requirements for protection of the public and environment and evaluated for a 1,000 year period following disposal facility closure. The composite analysis results shall be used for planning, radiation protection activities, and future use commitments to minimize the likelihood that current low-level waste disposal activities will result in the need for future corrective or remedial actions to adequately protect the public and the environment.

(4) Performance Assessment and Composite Analysis Maintenance. The performance assessment and composite analysis shall be maintained to evaluate changes that could affect the performance, design, and operating bases for the facility. Performance assessment and composite analysis maintenance shall include the conduct of research, field studies, and monitoring needed to address uncertainties or gaps in existing data. The performance assessment shall be updated to support the final facility closure. Additional iterations of the performance assessment and composite analysis shall be conducted as necessary during the post-closure period.

(a) Performance assessments and composite analyses shall be reviewed and revised when changes in waste forms or containers, radionuclide inventories, facility design and operations, closure concepts, or the improved understanding of the performance of the waste disposal facility in combination with the features of the site on which it is located alter the conclusions or the conceptual model(s) of the existing performance assessment or composite analysis.

(b) A determination of the continued adequacy of the performance assessment and composite analysis shall be made on an annual basis, and shall consider the results of data collection and analysis from research, field studies, and monitoring.

(c) Annual summaries of low-level waste disposal operations shall be prepared with respect to the conclusions and recommendations of the performance assessment and composite analysis and a determination of the need to revise the performance assessment or composite analysis.

(5) Disposal Authorization. A disposal authorization statement shall be obtained prior to construction of a new low-level waste disposal facility. Field Elements with existing low-level waste disposal facilities shall obtain a disposal authorization statement in accordance with the schedule in the Complex-Wide Low-Level Waste Management Program Plan. The disposal authorization statement shall be issued based on a review of the facility's performance assessment, composite analysis, performance assessment and composite analysis maintenance, preliminary closure plan, and preliminary monitoring plan. The disposal authorization statement shall specify the limits and conditions on construction, design, operations, and closure of the low-level waste facility based on these reviews. A disposal authorization statement is a part of the radioactive waste management basis for a disposal facility. Failure to obtain a disposal authorization statement by the implementation date of this Order shall result in shutdown of the disposal facility.

(6) Disposal Facility Operations. The disposal facility design and operation must be consistent with the disposal facility closure plan and lead to disposal facility closure that provides a reasonable expectation that performance objectives will be met. Low-level waste shall be disposed in such a manner that achieves the performance objectives stated in this Chapter, consistent with the disposal facility radiological performance assessment. Additional requirements include:

(a) Operating procedures shall be developed and implemented for low-level waste disposal facilities that protect the public, workers, and the environment; ensure the security of the facility; minimize subsidence during and after waste emplacement; achieve long-term stability and minimize the need for long-term active maintenance; and meet the requirements of the closure/post-closure plan.

(b) Permanent identification markers for disposal excavations and monitoring wells shall be emplaced.

(c) Low-level waste placement into disposal units shall minimize voids between waste containers. Voids within disposal units shall be filled to the extent practical. Uncontainerized bulk waste shall also be placed in a manner that minimizes voids and subsidence.

(d) Operations are to be conducted so that active waste disposal operations will not have an adverse effect on any other disposal units.

(e) Operations shall include a process for tracking and documenting low-level waste placement in the facility by generator source.

(7) Alternate Requirements for Low-Level Waste Disposal Facility Design and Operation. Requirements other than those set forth in this Section for the design and operation of a low-level waste disposal facility may be approved on a specific basis if a reasonable expectation is demonstrated that the disposal performance objectives will be met.

Q. Closure. The following requirements are in addition to those in Chapter I of this Manual.

(1) Disposal Facility Closure Plans. A preliminary closure plan shall be developed and submitted to Headquarters for review with the performance assessment and composite analysis. The closure plan shall be updated following issuance of the disposal authorization statement to incorporate conditions specified in the disposal authorization statement. Closure plans shall:

(a) Be updated as required during the operational life of the facility.

(b) Include a description of how the disposal facility will be closed to achieve long-term stability and minimize the need for active maintenance following closure and to ensure compliance with the requirements of DOE 5400.5, Radiation Protection of the Public and the Environment.

(c) Include the total expected inventory of wastes to be disposed of at the facility over the operational life of the facility.

(2) Disposal Facility Closure. Closure of a disposal facility shall occur within a five-year period after it is filled to capacity, or after the facility is otherwise determined to be no longer needed.

(a) Prior to facility closure, the final inventory of the low-level waste disposed in the facility shall be prepared and incorporated in the performance assessment and composite analysis which shall be updated to support the closure of the facility.

(b) A final closure plan shall be prepared based on the final inventory of waste disposed in the facility, the plan implemented, and the updated performance assessment and composite analysis prepared in support of the facility closure.

(c) Institutional control measures shall be integrated into land use and stewardship plans and programs, and shall continue until the facility can be released pursuant to DOE 5400.5, Radiation Protection of the Public and the Environment.

(d) The location and use of the facility shall be filed with the local authorities responsible for land use and zoning.