DOE-HDBK-1215-2014 Chg Notice 1 (Reaffirmed 2022), Optimizing Radiation Protection of the Public and the Environment for use with DOE O 458.1, ALARA Requirements

DOE HANDBOOK DOE-HDBK-1215-2014 October 2014 Change Notice 1 Reaffirmed September 2022 OPTIMIZING RADIATION PROTECTION OF THE PUBLIC AND THE ENVIRONMENT FOR USE WITH DOE O 458.1, ALARA REQUIREMENTS U.S. Department of Energy AREA ENVR Washington, D.C. 20585 DISTRIBUTION STATEMENT A. Approved for public release; distribution is unlimited. NOT MEASUREMENT SENSITIVE DOE HDBK-1215-2014 October 2014 Change 1: September 2022 ADMINISTRATIVE CHANGE TO DOE HDBK-1215, OPTIMIZING RADIATION PROTECTION OF THE PUBLIC AND THE ENVIRONMENT FOR USE WITH DOE O 458.1, ALARA REQUIREMENTS LOCATION OF CHANGES: Page Paragraph Changed To Ch.11 Bibliography Page 11-2 1st reference Updated 2011, 10 CFR 835 reference 2017, 10 CFR 835 reference Ch. 11 Bibliography Page 11-3 7th reference Corrected spelling of “optimization” in title of ICRP Publication 101. DOE-HDBK-1215-2014 ii PREFACE This Handbook provides information to assist Department of Energy (DOE) program and field offices in understanding what is necessary and acceptable for implementing the As Low As Reasonably Achievable (ALARA) provisions of DOE Order (O) 458.1, Radiation Protection of the Public and the Environment. It identifies the goals, requirements and issues that need to be addressed when developing ALARA analyses for optimization of various programs to support DOE’s diverse missions. Various case studies and examples are also provided to further assist in implementing the ALARA process. DOE’s ALARA process helps ensure that optimization techniques will be integrated into the design and analyses of programmatic options necessary for the protection of the public and the environment in accordance with the requirements of DOE O 458.1. As much as possible, DOE sites should consider using existing processes, programs or documentation for addressing the provisions of DOE O 458.1 in the development and implementation of the ALARA requirements. DOE-HDBK-1215-2014 iii TABLE OF CONTENTS Chapter 1. INTRODUCTION .................................................................................................... 1-1 Chapter 2. PURPOSE AND APPLICABILITY ....................................................................... 2-1 Chapter 3. ALARA REQUIREMENTS IN DOE DIRECTIVES ........................................... 3-1 3.1 ALARA Process. ............................................................................................... 3-1 3.1.1 ALARA Commitment ........................................................................... 3-2 3.1.2 Implementing ALARA ......................................................................... 3-3 3.1.3 Documenting ALARA Decisions ......................................................... 3-3 3.1.4 ALARA Training .................................................................................. 3-4 3.2 Factors to consider during the ALARA Process ............................................... 3-4 3.3 Compliance ....................................................................................................... 3-5 Chapter 4. ALARA PROCESS ANALYSIS ............................................................................. 4-1 4.1 Implementation ................................................................................................. 4-1 4.2 Determining the Level of ALARA Analysis .................................................... 4-4

4.2.1 Qualitative Analysis .............................................................................. 4-5 4.2.2 Semi-Quantitative Analysis .................................................................. 4-5 4.2.3 Quantitative Analysis ............................................................................ 4-6 4.3 General Steps in Quantitative ALARA Analysis .............................................. 4-6 4.3.1 Identify and Quantify the Sources of Radiation ................................... 4-7 4.3.2 Define Candidate Radiation Protection Systems .................................. 4-7 4.3.3 Quantify the Economic Factors (Costs) ................................................ 4-8 4.3.4 Quantify Exposures and Doses from DOE Activities ........................... 4-9 4.3.5 Estimate Health and Non-Health Detriments and Benefits ................ 4-10 4.3.6 Select a Candidate Radiation Protection Alternative as ALARA ....... 4-11 Chapter 5. EVALUATIONS AND ASSUMPTIONS ............................................................... 5-1 5.1 Cost of Radiation Protection Systems ............................................................... 5-1 5.2 Exposures and Doses ........................................................................................ 5-2 5.2.1 Exposure Location ................................................................................ 5-2 5.2.2 Receptors............................................................................................... 5-4 5.2.3 Collective Dose ..................................................................................... 5-4 Chapter 6. OTHER FACTORS AND ISSUES RELATED TO THE ALARA PROCESS .. 6-1 6.1 Resource Allocation .......................................................................................... 6-1 6.2 Uncertainties ..................................................................................................... 6-1 6.2.1 Source Terms ........................................................................................ 6-2 6.2.2 Dispersion Patterns ............................................................................... 6-2 6.2.3 Time Variations .................................................................................... 6-2 6.2.4 Release to the Atmosphere .................................................................... 6-2 6.2.5 Release to Surface Waterways .............................................................. 6-3 6.2.6 Releases to Ground Water .................................................................... 6-4 6.3 Exposures within Facilities ............................................................................... 6-5 6.4 Exposure Time .................................................................................................. 6-5 6.5 Discounting Cost ............................................................................................... 6-6 6.6 Perspectives....................................................................................................... 6-7 6.7 Other Factors and Criteria ................................................................................. 6-7 DOE-HDBK-1215-2014 iv Chapter 7. QUALITATIVE ALARA ANALYSIS ................................................................... 7-1 7.1 Environmental Restoration Case Study ............................................................ 7-1 7.2 Volumetric Release of Sediment for Off-Site Landfill Disposal ...................... 7-2 7.3 Pros and Cons Analysis .................................................................................... 7-5

Chapter 8. SEMI-QUANTITATIVE ALARA ANALYSIS..................................................... 8-1 8.1 Case Study #1: Colonie, New York .................................................................. 8-1 8.2 Case Study #2: Elza Gate Site, Tennessee ........................................................ 8-4 8.3 Case Study #3: Maywood, New Jersey ............................................................. 8-8 8.4 Case Study #4: Ventron, Massachusetts ......................................................... 8-12 8.5 Case Study #5: Weldon Spring Site, Missouri. ............................................... 8-15 Chapter 9. QUANTITATIVE ALARA ANALYSIS ................................................................ 9-1 9.1 Cost Benefit Analysis ....................................................................................... 9-1 9.1.1 Total Detriment Equations .................................................................... 9-2 9.1.2 Cost-Benefit Optimization .................................................................... 9-2 9.1.3 Detriment and Monetary Equivalent ..................................................... 9-4 9.1.4 Dose, Risk, and Health Detriment ........................................................ 9-4 9.1.5 Quantifying Risk of Radiation-Induced Serious Health Effects ........... 9-5 9.1.6 Monetary Considerations for Reduction in Collective Dose ................ 9-5 9.1.7 Non-Health Detriment .......................................................................... 9-6 9.1.8 Cost-Benefit Example ........................................................................... 9-8 9.2 Cost-Effectiveness Analysis ........................................................................... 9-12 9.3 Multi-Attribute Utility Analysis ..................................................................... 9-13 9.3.1 Additional Multi-Attribute Utility Analysis Example ........................ 9-18 9.4 Multi-Criteria Outranking Analysis ................................................................ 9-21 9.5 Kepner-Tregoe (K-T) Decision Analysis ........................................................ 9-22 9.6 Analytical Hierarchy Process Analysis ........................................................... 9-23 Chapter 10. ILLUSTRATIVE EXAMPLE OF ALARA APPLICATION .......................... 10-1 10.1 Input Data. ....................................................................................................... 10-1 10.2 Identity of the Optimum.................................................................................. 10-1 10.3 Graphical Illustration ...................................................................................... 10-1 10.4 Other Considerations ...................................................................................... 10-7 Chapter 11. BIBLIOGRAPHY ................................................................................................ 11-1 APPENDIX A. FINAL DISPOSITION OF PERSONAL PROPERTY .............................. A-1 APPENDIX B. OPTIMIZATION OF THE DESIGN OF LWR-RADWASTE TREATMENT SYSTEMS BY COST BENEFIT ANALYSIS ............................................. B-1 APPENDIX C. REMEDIATION OF THE WELDON SPRING CHEMICAL PLANT AND SELECTION OF TREATMENT METHOD FOR THE CONTAMINATED QUARRY WASTEWATER...................................................................................................................... C-1 APPENDIX D. CLEANUP OF CONTAMINATED SOILS AT THE NEVADA TEST SITE

................................................................................................................. D-1 APPENDIX E. BNL'S HAZARDOUS WASTE MANAGEMENT FACILITY (HWMF) E-1 DOE-HDBK-1215-2014 1-1 Chapter 1. INTRODUCTION For several decades, the position of the radiological protection community has been to keep exposures as low as reasonably achievable (ALARA). The International Commission on Radiological Protection (ICRP), following a review of past recommendations, reaffirmed this position in Publication 60 (1991) which recommended that the system of radiological protection for proposed and continuing practices be based on the following general principles: 1. Justification: No practice involving exposures to radiation should be adopted unless it produces sufficient benefit to the exposed individuals or to society to offset the radiation detriment it causes. 2. Optimization: The magnitude of individual doses, the number of people exposed, and the likelihood of incurring exposures where these are not certain to be received should be kept as low as reasonably achievable, economic and social factors being taken into account. 3. Dose limits: The exposure of individuals resulting from all relevant practices should be subject to dose limits such that no individual is exposed to radiation risks that are judged to be unacceptable from these practices in any normal circumstance. The National Council on Radiation Protection and Measurements (NCRP) made similar recommendations (NCRP 1987, 1993). The ICRP general principles of radiological protection for proposed and continuing practices have been adopted almost universally and DOE has implemented the recommendations through Orders such as DOE O 458.1, and regulations, such as 10 Code of Federal Regulations (CFR) Part 835, Occupational Radiation Protection. This Handbook focuses on the ALARA requirements in DOE O 458.1 to implement a process that ensures all exposures are kept as low as reasonably achievable. Since Department of Energy (DOE) programs and activities are established by Federal policy makers, and, for the most part, the justification part of the system is addressed through these policy decisions, this Handbook will not address Justification. Exposures of individuals will be managed in a manner that will ensure compliance with the dose limits for the individuals, regardless of the associated cost. For radiation protection purposes, Optimization considers the collective dose to the exposed population from radiation sources to be proportional to the number of radiation-induced health effects and evaluates the cost or detriment of measures that would reduce the dose below applicable dose limits or dose constraints. Optimization provides a basis for judging the reasonableness of the selection of a particular radiological protection system after considering several alternatives. This Handbook strives to be consistent with the ICRP and NCRP recommendations and to supplement other Federal regulations with that same intent. It should be stressed that optimization is not minimization. Optimization is the result of an evaluation that carefully balances the benefits from exposure reduction (e.g., health, regulator, and public goodwill, etc.) with the costs (e.g., economic, schedule, social, etc.). Thus, the best option is not necessarily the one with the lowest dose. DOE-HDBK-1215-2014 1-2 The importance of the ALARA concept was further stressed in DOE P 450.4A, Integrated Safety Management Policy (DOE, 2011), which states:

It is the Department’s policy that work be conducted safely and efficiently and in a manner that ensures protection of workers, the public, and the environment. To achieve this Policy, effective safety requirements and goals are established; applicable national and international consensus standards are adopted; and where necessary to address unique conditions, additional standards are developed and effectively implemented. Implementing Integrated Safety Management requirements for Federal organizations are established through directives, and for contractor organizations through contract clauses. The Department’s ultimate goal is zero accidents, work-related injuries and illnesses, regulatory violations, and reportable environmental releases. The Department expects that for all activities and phases in the lifecycle of missions (design, construction, research and development, operations, and decommissioning and decontamination), appropriate mechanisms are in place to ensure that exposures to workers, the public, and the environment to radiological and nonradiological hazards are maintained below regulatory limits. Furthermore, DOE expects that deliberate efforts are taken to keep exposures to radiation as low as reasonably achievable. The goals of this Handbook are: • To provide additional information on the ALARA requirements in DOE O 458.1; • To elaborate on the necessary elements of an ALARA process; • To assist DOE program and field offices in understanding what is necessary and acceptable for implementing the ALARA process for DOE activities that are conducted under DOE O 458.1; and • To aid decision makers by identifying acceptable approaches and methods for identifying and selecting the optimum radiation protection alternative from among several candidate radiation protection alternatives. Chapter 3 addresses the DOE ALARA requirements. Chapters 4 - 6 provide information on the various levels of ALARA analysis, assumptions and other factors related to the ALARA process. Chapters 7 - 10 provide information and case studies specific to qualitative, semi-quantitative and quantitative ALARA analyses, respectively. Chapter 10 and the appendices provide additional examples of historical ALARA analyses conducted throughout the Department to further help implement the ALARA process. 2-1 DOE-HDBK-1215-2014 Chapter 2. PURPOSE AND APPLICABILITY This Handbook addresses the development and use of a process to keep radiation exposures of the public and environment, and releases of radioactive material to the environment from DOE activities as low as reasonably achievable (ALARA), that is; an ALARA process to implement and comply with DOE O 458.1, Radiation Protection of the Public and the Environment. 10 CFR Part 835, Occupational Radiation Protection, prescribes regulations for occupational dose to general employees from exposure to ionizing radiation from DOE activities. 10 CFR Part 835 also includes dose limits for members of the public in a controlled area. ALARA requirements for general employees as well as definitions of the terms “general employee,” “occupational dose,” and “controlled area” are addressed in 10 CFR Part 835 and discussed in associated 10 CFR Part 835 guidance. The word “must” as used in this Handbook designates requirements from DOE O 458.1. The words “should” and “may” are used to denote optional program recommendations and allowable alternatives, respectively.

To achieve an adequate level of radiation protection, the degree of control, treatment, processing, remedial action, or other method limiting doses to workers and members of the general public should be determined by implementing a process that identifies and considers all factors important to decision-making. ALARA, as applied by DOE, is not a level or limit to be achieved in controlling radiation exposures or doses, but rather a process used to ensure that appropriate factors are considered in making decisions that could affect protection against radiation. KEY TERMS ALARA means “As Low As is Reasonably Achievable,” which is an approach to radiation protection to manage and control releases of radioactive material to the environment, and exposure to the work force and to members of the public so that the levels are as low as reasonable, taking into account societal, environmental, technical, economic, and public policy considerations. As used in DOE O 458.1, ALARA is not a specific release or dose limit but a process that has the goal of optimizing control and management of release of radioactive material to the environment and doses so that they are as far below the applicable limits of the Order as reasonably achievable. ALARA optimizes radiation protection. ALARA Process means a graded process for evaluating alternative operations, processes, and other measures, for optimizing releases of radioactive material to the environment, and exposure to the work force and to members of the public taking into account societal, environmental, technical, economic, and public policy considerations to make a decision concerning the optimum level of public health and environmental protection. A graded approach provides the flexibility to perform qualitative or quantitative ALARA analyses. For low doses, qualitative evaluations normally will suffice. An ALARA Program refers to the set of design specifications, operating procedures, techniques, monitoring and surveillance programs, records, instructions and other elements that have been used to implement the ALARA process. 2-2 DOE-HDBK-1215-2014 Doses to the public from effluents, emissions, and residual radioactive material must be maintained as low as reasonably achievable below the primary dose limits. Under DOE O 458.1 a documented ALARA process must be implemented to optimize control and management of radiological activities so that doses to members of the public (both individual and collective) and releases to the environment are kept as low as reasonably achievable. The ALARA process must be applied to DOE activities and the design or modification of facilities that expose the public or the environment, no matter how small the dose. In all cases, the scope and detail of the ALARA analysis should be commensurate with the potential benefit of the dose reduction. DOE O 458.1 requires that the ALARA process use a graded approach (e.g., a graded level of control and oversight) to ensure that doses to the public are low and any decisions made as a result of the process be both beneficial and cost-effective. DOE has defined the graded approach for nuclear safety management (10 CFR Part 830.3) as the process of ensuring that the level of analysis, documentation, and actions used to comply with a requirement are commensurate with: • The relative importance to safety, safeguards, and security; • The magnitude of any hazard involved; • The life cycle stage of a facility;

• The programmatic mission and characteristics of a facility; • The relative importance of radiological and non-radiological hazards; and • Any other relevant factor. This graded approach and these criteria generally are applicable to this Handbook, although other factors may modify how they are used. For example, a highly contentious issue may result in public concern and public policy becoming more consequential factors in the ALARA process. This Handbook describes a graded approach for applying the ALARA process. ALARA is a self-limiting system and thus the level of analysis should be commensurate with the estimated collective dose to the exposed population; higher estimated collective doses require more rigor in the analysis. In this sense, the cost of the analysis itself should be justified. For instance, DOE recommends the monetary value of a unit of collective dose be between $1,000 and $6,000 per person-rem (see Chapter 9). For an action that might cause a collective dose at the end of the qualitative range in Figure 2-1 (e.g., 10 person-rem/yr) to be reduced to zero (0 person-rem/yr), the averted dose value would be $60,000. In many cases, the cost of a quantitative ALARA analysis (e.g., Cost-Benefit Analysis) alone may significantly exceed this value. It is difficult to be prescriptive in setting guidelines for the level of ALARA analysis because many factors – both technical and societal in nature – can influence such an evaluation. A detailed quantitative ALARA analysis may only be necessary for major actions. DOE has therefore opted to provide flexibility in selecting the level of analysis. “Reference” dose levels have been established to help determine the level of effort required for an ALARA analysis, as illustrated in Figure 2-1. In general, if the dose to the maximally exposed individual (MEI), or the representative person of the critical group, is much less than 1 mrem (0.01 mSv) in a year and 2-3 DOE-HDBK-1215-2014 the collective dose to the exposed population is less than 10 person-rem in a year, only a qualitative1 ALARA analysis is warranted. When doses are near the reference levels, it may be necessary to evaluate the alternatives semi-quantitatively2. However, if individual doses are significant compared to the primary dose limit, e.g., tens of millirem in a year, or the collective dose exceeds 100 person-rem in a year, a quantitative ALARA analysis is recommended. Section 4.2 provides more detail on determining the level of ALARA analysis. ALARA applications to radiation protection may be reflected in decision-making among various options or alternatives such as design of a process system, performance criteria for the features or components of the system, selection of operating modes or other parameters, and other facility- specific or programmatic decisions that can affect the exposure of members of the public to radiation. The optimal decision may be reached through an ALARA process. The ALARA process should be applied to the control of routine doses and effluents, including those resulting from minor operational occurrences and anticipated off-normal operation. Although the ALARA process may be applied to accident-mitigating design features, that application is beyond the scope of this Handbook. While this Handbook includes some discussion of ALARA considerations for general employees, the 10 CFR Part 835 ALARA provisions must be incorporated into occupational ALARA considerations. Implementation of this Handbook does not constitute compliance with the ALARA requirements from 10 CFR Part 835.

1 A qualitative ALARA analysis is done by describing alternatives and comparing the costs and benefits without estimating their monetary or numerical values. A simple “pros and cons” analysis is an example of a qualitative type of analysis and is described further in Chapter 8 and in the Guidebook to Decision-Making Methods (Baker et al., 2001). 2 A semi-quantitative ALARA analysis develops alternative descriptions and estimates of the costs and benefits which can be enumerated readily but may lack a comprehensive numerical comparison employing all factors. Although numerical criteria (some subjectively assigned) may be used to help rank alternatives in the decision process. Examples of semi-quantitative analyses are presented in Chapter 9. 2-4 DOE-HDBK-1215-2014 FIGURE 2-1. General Guidance for Determining the Level of ALARA Analysis Required This Handbook: • Identifies a number of factors that should be considered in an ALARA analysis; • Presents a logical sequence for reviewing the factors important to decision-making; and • References techniques that may be used to quantify some of the factors. This Handbook also recognizes the difficulties in performing quantitative evaluations of alternative options using tools, such as cost-benefit analyses, and acknowledges that decisions inevitably involve technical and managerial judgment, regardless of the approach used. This Handbook goes beyond traditional quantitative ALARA tools such as cost-benefit analysis and optimization, recognizing the utility and efficiency of allowing different levels of detail in the ALARA process and further recognizing that other decision-making tools such as multi-attribute utility analysis may also be useful, particularly where non-quantifiable factors or attributes are concerned. Due to the complex nature of many DOE activities, a combination of radiological and non- radiological hazards may be encountered. DOE O 458.1 and this Handbook apply only to radiation exposures of the public and releases of radioactive material to the environment. However, identification of non-radiological hazards is critical to the ALARA process, because efforts to apply the ALARA process may inadvertently increase risks from non-radiological hazards. An integrated safety management approach that optimizes protection of the public and environment from all potential hazards should be considered in the ALARA process for a given DOE activity. MEI or Representative Person of the Critical Group dose 1 mrem/y Collective dose 10 person-rem/y 100 person-rem/y ALARA analysis type Qualitative………………Semi-quantitative ..................... Quantitative It is necessary to comply with the appropriate (individual) dose limit to any member of the public, whatever the cost. However, it is the collective dose that is used in the ALARA analysis to select a radiation protection alternative. DOE-HDBK-1215-2014 3-1 Chapter 3. ALARA REQUIREMENTS IN DOE DIRECTIVES The principal ALARA requirements for DOE actions in protecting the public and environment are contained in DOE O 458.1, paragraph 4.d [paragraph 2.d of the Contractor Requirements Document (CRD)]. However, specific references to the application of ALARA process appear throughout DOE O 458.1, including sections on the public dose limit, temporary dose limits, airborne radioactive effluents, liquid discharges, management, storage and disposal of radioactive waste, protection of drinking water and ground water, and release and clearance of property. Related directives such as DOE O 435.1, Radioactive Waste Management, also contain ALARA requirements. Application of ALARA is a broad, integral part of the overall implementation of DOE public, environmental and worker protection programs, and is not a limited or niche application.

3.1 ALARA Process In accordance with DOE O 458.1, a documented ALARA process must be implemented to control and manage releases of radioactive material to the environment and exposures of members of the public to radiation at levels as low as reasonably achievable. Likewise, the method for implementing the ALARA process is highly dependent on the complexity of the activity and should be commensurate with the potential radiological hazard associated with the DOE activity. For example, activities that use encapsulated radiation sources where there is essentially no likelihood of releasing source material with no potential for public or environmental exposures would only require addressing possible contamination from ruptured sources and potential external exposure. In contrast, if the activity included recovering the source material from ruptured capsules and re-encapsulation, the potential environmental exposure pathways for inhalation and ingestion would also be required in the ALARA process. An ALARA process should be reviewed by the DOE contractor or operating organization as necessary to maintain a current and effective program, but at least every three years, to identify: • Changes that have occurred in the facility, operations, or activities that could alter the relative importance of the releases or exposures; • Alternatives to operations or activities that were not considered previously; • Operational information on the performance of the selected equipment or process that could alter the decision on choice among alternatives; and • Changes in administration of the program, such as changes in mission or contractor. The ALARA process is an integral part of an environmental radiation protection program and should be reviewed and approved either separately or as part of other environmental protection documents such as those associated with the implementation of an Environmental Management System (EMS). The description of the ALARA process should be contained in, or summarized and referenced in, the DOE-approved plans, procedures, or other documentation. The degree of formality and the level of detail contained in these documents should be commensurate with the magnitude of the radiological hazard associated with the DOE activity. DOE-HDBK-1215-2014 3-2 Internal assessments or audits should be conducted to evaluate the effectiveness of the ALARA process and to ensure improvements are implemented to strengthen it, if justified. This is consistent with the approach in DOE G 441.1-1C, Radiation Protection Programs Guide for Use with Title 10, Code of Federal Regulations, Part 835, Occupational Radiation Protection (2011). The basis for ALARA decisions should be made available to the public. DOE encourages public participation in the process as well as coordination with appropriate external regulators that may be involved in related activities. This can be accomplished through existing site advisory groups, the National Environmental Policy Act (NEPA) process, or other public involvement programs that currently are being implemented in support of DOE actions. It is important to assure that the public understands DOE’s ongoing environmental protection activities. 3.1.1 ALARA Commitment

Management commitment to ALARA is a critical element in ensuring a successful ALARA program. DOE management retains the primary responsibility and accountability for the scope and implementation of ALARA. This commitment should take the form of a formal, written policy statement from a high-level manager responsible for DOE radiological activities committing to establish and to implement the ALARA process for activities that are sources of exposures to ionizing radiation. This commitment should hold all levels of management and personnel responsible for adhering to ALARA policy. All site personnel should know management’s commitment to ALARA, and appropriate personnel should be instructed on their ALARA responsibilities. Line management should demonstrate support for the ALARA program through direct communication, training, inspection of the workplace, and actions including: • Management decisions that incorporate ALARA considerations along with cost or schedule considerations; • Encouragement of, and praise for, employees who identify ALARA opportunities; • Support of the ALARA Committee; and • Publication of ALARA success stories. Also, it is essential that the public is aware of an organization’s commitment to ALARA. For example, the policy statement could be part of the public record. Management commitment is essential to implementing a successful ALARA process. DOE-HDBK-1215-2014 3-3 3.1.2 Implementing ALARA A description of how the ALARA process will be implemented, including appropriate involvement of interested parties, should identify: • The designated organizational responsibility, authority, and structure for implementing ALARA; • The systematic evaluation of the activities at the site to identify those activities that are responsible for the release of radioactive material and the exposures of the public and workers; and • A procedure to analyze the operations or activities to determine whether they are being performed in a manner that will ensure that the radiological impacts are ALARA. 3.1.3 Documenting ALARA Decisions DOE O 458.1 requires that a documented ALARA process be implemented however, as ALARA is a graded approach whose rigor and detail should be commensurate with potential benefit, documentation of the process can also be graded. In cases where no options exist to further reduce dose or dose reduction for all options are very small, minimal documentation (e.g. memorandum to file) may be adequate. Factors that should be considered and documented for any ALARA decision-making process are specified in Section 3.2. Records requirements are contained in DOE O 458.1, paragraph 4.l (paragraph 2.l of the CRD) and include: • Documentation of individual and collective dose to members of the public due to radiological activities. This includes documentation of site-specific information on radiation source dispersion patterns, location and demography of members of the public in the vicinity of the radiological activity and assumed default values or site-specific parameters used in calculations. • Documentation of actions taken to implement the ALARA process identified in the Order (CRD). Examples include records of cost-benefit or other analyses, and other factors considered important to the ALARA decision-making process. • Documentation of actions taken to implement the best available technology (BAT) selection process in regulating liquid discharges, including documentation of the analyses and factors considered to be important, including alternative processes.

ALARA evaluations and other activities and information considered in the selection of the alternative radiological protection option judged to be ALARA and in the rationale leading to the selection should be documented, to include referencing data utilized as part of NEPA or CERCLA requirements. Procedures should be established and implemented to assure that ALARA records are kept current, complete, and readily available for use. The records should be organized in such a way that appropriate sections can be located easily to demonstrate compliance with the ALARA requirements. The records should facilitate coordination and cooperation with other organizations in sharing information on analyses, performance of equipment, costs, operations, maintenance, identity, and evaluations of alternatives. DOE-HDBK-1215-2014 3-4 3.1.4 ALARA Training Personnel who plan, prepare, schedule, estimate, or engineer jobs that have the potential for radiological consequences should receive appropriate training to be knowledgeable of the ALARA process. The purpose of providing training in ALARA concepts and techniques is to ensure that personnel have the necessary knowledge and skills to conduct the needed analyses and evaluations. ALARA training should provide the basics of ALARA concepts and the use of ALARA-related equipment such as containment devices, shielding, ventilation, and special tools. Topics such as radiological waste minimization, application of decontamination efforts, and basic contingency planning for mitigation of accidental spills or releases may also be appropriate. The size, frequency, and content of the ALARA training should be commensurate with the size, complexity, and hazard potential of the DOE activity (i.e., a graded approach should be applied). Application of the ALARA process includes evaluations of: • Exposures and doses to individuals and populations; • Dispersions of radioactive material in the environment; • Cost-benefit and other economic evaluations; • Engineering evaluations of equipment performance and source determinations; and • Applications of other disciplines. As appropriate, such training may be integrated with other activities including ALARA-related training for 10 CFR Part 835 or DOE O 435.1. DOE has developed specialized training material in DOE HDBK 1110-2008, ALARA Training for Technical Support Personnel (DOE 2008b). 3.2 Factors to consider during the ALARA Process The ALARA process evaluates and documents the societal, environmental, technological, economic, and public policy factors considered in decisions where public exposures to radiation can occur from DOE activities. At a minimum, the following factors should be considered and documented as part of the ALARA process: • The maximum dose to an individual member of the public [termed MEI or representative person of the critical group]; • The collective dose to the exposed population; • Doses to workers; • Applicable alternative processes such as alternative treatments of discharge streams, operating methods, or controls; • Doses for each alternative evaluated; • Cost for each alternative evaluated; • An examination of the changes in cost among alternatives; and • Societal and environmental (positive and negative) impacts associated with alternatives. DOE-HDBK-1215-2014 3-5 These factors should be addressed whether the assessment is qualitative, semi-quantitative, or quantitative. If a specific factor(s) was not included in the evaluation, this should be noted and the justification documented.

No single best procedure exists for implementing the ALARA process for all DOE activities. This choice depends on the characteristics of the activity, the site, and the potential doses involved. 3.3 Compliance DOE requires application of the ALARA process in most activities addressed in DOE O 458.1. The exception is an activity regulated by a rule containing dose or other limits based on an ALARA determination. In that case, simply complying with the dose limit constitutes ALARA. Applicable requirements are specified in DOE Orders and rules as well as those of other Federal, State, and local agencies. Requirements do not originate in guidance documents. Demonstration of compliance with the ALARA requirements may be provided by: • A documented current description of the site ALARA process, reviewed and approved by the appropriate DOE Program or Field Office and a statement of commitment to implement the ALARA process; • A documented ALARA process describing procedures by which the individual ALARA evaluations and judgments will be made and the documentation of the procedures; • A description of the training program provided to ensure staff capabilities to perform ALARA evaluations; and • Records of all formal ALARA evaluations and decisions, including the rationale for the ALARA judgments, indicating that the ALARA process is being implemented. The records should demonstrate that sufficient information was assembled and considered to support the ALARA decisions. An ALARA process should identify general areas to be considered in making ALARA decisions: societal, technological, economic, and public policy considerations. Whether the ALARA analyses are qualitative, semi-quantitative, or quantitative, it is essential to document the analyses and decision. DOE-HDBK-1215-2014 4-1 Chapter 4. ALARA PROCESS ANALYSIS This Chapter provides additional information related to the implementation of the ALARA process and the analysis methods that may be used. The ALARA process is a management and decision-making tool designed to maximize the total benefits of the radiation protection provisions of a DOE activity that is likely to expose members of the public to ionizing radiation. The optimal radiation protection alternative can be selected from among several candidates by considering the radiation protection benefits, and, as appropriate, other benefits and detriments, along with the cost of implementing these protective measures. No single best method exists for implementing the ALARA process at all DOE activities. This choice depends on the characteristics of the activity or operation, the site, and the potential doses involved. Use of site-specific and activity- or operation-specific factors is encouraged for all ALARA analyses. 4.1 Implementation The basic question to be answered in the implementation of the ALARA process is “Has everything that reasonably can be completed to reduce the radiation doses been done?” Although the primary goal of ALARA is radiation dose reduction, hazardous non-radioactive materials also might be components of the waste stream effluent or could be introduced by some of the optional treatments used to reduce the radiological components. Therefore, risks associated with these materials should also be factored into the ALARA process and ALARA determinations. It is important to remain informed about the overall impacts and detriments of any alternatives or decision. The release of hazardous chemicals could be treated as a “β-factor” in a cost-benefit analysis or a non-radiological factor in a multi-attribute analysis (see Section 10.1.7). Other factors such as impacts or risks to natural or cultural resources can be addressed similarly.

There are a number of methods that can be applied to gather data for the ALARA process, ranging from quantified cost-benefit analysis to multi-attribute analysis with weighting and scaling factors that can be used in both quantitative and semi-quantitative analyses. Some may be rudimentary and based upon a fundamental understanding and commitment to the ALARA principle, “common sense,” or “sound judgment,” rather than on formal quantitative techniques – and that may be all that is necessary or justified. Activities that involve low doses are more likely to be based on judgmental decisions. In cases where dose increments are very low compared to the dose limits, the social and public policy considerations often will be the dominant factors in arriving at the ALARA decision. The goal of the ALARA process is to identify, from among candidate radiation protection alternatives, the alternative that would result in the maximum total benefit, considering the protective measures and their costs. Assumptions and parameters used in the ALARA evaluation should be realistic instead of overly conservative. Overly conservative choices of parameters may bias the ALARA analysis and could result in unjustified control expenditures or, in some cases, increased risk or detriment. DOE-HDBK-1215-2014 4-2 DOE’s application of Best Available Technology (BAT) under DOE O 458.1 may also be seen as a form of ALARA. However, it is important to distinguish that BAT focuses on reduction of concentration or quantity of contaminants rather than dose and may lead to controls being required for releases that have no receptor and hence no dose. From a cost-benefit perspective, it may require treatment that goes beyond ALARA. Site-specific societal values can be incorporated into the analysis through public input. Public input could be used: • To define values for use in the ALARA balancing decision; • For a comparative ranking of risks; and • To provide input regarding the adequacy of the data and decision processes. An example of incorporating societal values is the use of different food chain radiation exposure pathway models for estimating potential radiation doses to Native Americans and for ecological receptors. Table 4-1 presents a sequence of steps that could be followed in an ALARA (or BAT) evaluation. A sensitivity analysis is worthwhile in both types of evaluations because it can provide information on the robustness of the results. A sensitivity analysis also can identify information that is important to obtain as part of the monitoring and surveillance program. ALARA should be a flexible process, and the evaluation efforts should be proportional to the potential benefits. The boundaries between each of the steps in Table 4-1 may not always be clear-cut; some may proceed in parallel or may need to be repeated. The overall impact of the alternatives under consideration might also control the detail and level of effort assigned to individual steps. For example, if the difference in doses and costs associated with the various options is small, the cost of a detailed ALARA review may not be warranted. Similarly, if the difference in dose increments is large and the cost difference is small, or vice-versa, the choice of options could be straightforward and very detailed analyses may not be justified. However, when costs, doses, and other impacts vary significantly among options, more detailed analyses are needed.

The principal difference between the ALARA process and the BAT selection is that the ALARA process balances the cost and dose reduction and attempts to identify the optimal of several alternatives, whereas the BAT selection places more importance on the source term (rather than doses). As utilized in DOE O 458.1, BAT is a regulatory process applicable only to liquid effluents, but ALARA applies to all sources of radiation exposure. DOE-HDBK-1215-2014 TABLE 4-1. Implementing the ALARA Process Step 1: Define the Objective and Scope of the Issue to be Analyzed. State the objectives of the project or proposal in terms that do not prejudge the means by which the objective is to be achieved. Specify the radiation protection factors to be included and other factors to be considered. Step 2: Identify Radiation Protection Options. Generate several options for achieving the objective: the aim is to find options that are both practicable and environmentally acceptable. This step provides a strong incentive to consider not only obvious solutions, but also innovative alternatives. It also includes the elimination of impractical options. Step 3: Evaluate the Performance of the Radiation Control Options. Analyze these options to identify the advantages and disadvantages of each option. Use quantitative and qualitative methods when appropriate. Cost (for a cost-benefit analysis) each of the options for operation, maintenance, utilities, structures, equipment, labor, and collective dose. Incorporate judgment criteria explicitly. Identify other (non- radiological) impacts and other considerations. Evaluate the impact and cost of compliance with non-radiological requirements. Step 4: Screen Options. Present the results of the quantitative (or semi-quantitative) analysis of factors concisely and objectively and in a format that can highlight the advantages and disadvantages of each option. Do not combine the results of different measurements and forecasts if this would obscure information that is important to decision-making. Step 5: Order and Analyze. Include consideration of all relevant factors whether treated quantitatively, semi-quantitatively, or qualitatively, together with judgment or relative weighing and the results of sensitivity analyses to select the recommended radiological optimum. Step 6: Identify Optimal Alternative. Select the optimal option from the feasible options. The choice will depend upon the adequacy of the radiation protection, the weight given to the environmental impacts, the associated risks and the costs involved, and the importance of non- radiological factors. Step 7: Perform Sensitivity Analysis. The robustness of the decision to choose a particular alternative can be determined by varying the more important parameters and observing how the “bottom line” results are affected. If a particular parameter is seen to be capable of substantially affecting the results, the site-specific information should be scrutinized to ensure that the value of the parameter used in the study is representative for the site. Step 8: Decision. Take into account the results of optimization and any non-radiological factors and make the decision. Scrutinize closely the proposed detailed design or operating procedures to ensure that no pollution or hazards have been overlooked. It is good practice to have the scrutiny done by individuals who are independent of the original team. Decision makers should be able to demonstrate that the preferred option does not involve unacceptable consequences to the environment. Step 9: Implement and Monitor. Monitor the achieved performance against the desired targets, especially those for environmental quality. Do this to establish whether the assumptions in the design are correct and to provide feedback for future development of proposals and designs. The results of the sensitivity study can provide valuable input to planning a monitoring program for the activity. Throughout Steps 1 through 9: Record the bases for any choices or decisions through all of these stages: the assumptions used, the details of evaluation procedures, the reliability and origins of the data, the affiliation of those involved in the analytical work and a record of those making the decision. Record, if possible, the reasons for any departure from the recommended optimal candidate.

4-3 DOE-HDBK-1215-2014 4-4 Under DOE O 458.1 the ALARA process must be applied to the design or modification of facilities and conduct of activities that expose the public or the environment to radiation or radioactive material. (It should be recognized that when a new facility is being considered, the ALARA evaluation process needs to be used in those cases when the selection of processes, design of the facility, and setting operating parameters and procedures needs to be consistent with10 CFR Part 835). Early consideration of alternatives allows maximum flexibility in the choice of design options. When a new DOE activity is being designed, the initial source term should be characterized, and a “base case” alternative or system established. The condition that the base case needs to satisfy is that the radiation dose to the most exposed persons (workers or members of the public) must be within the appropriate dose limit. This base case system subsequently will be used as a basis for comparison of the cost- effectiveness of more sophisticated and more expensive alternative systems. The base case or some of the alternative cases may or may not be practical design candidates because of possible environmental or other impacts that may be judged to be undesirable or unacceptable, but these considerations would be evaluated at a later point in the decision-making. When the ALARA application is for an established, ongoing activity or facility (i.e., retrofitting), the practical alternatives are likely to be more limited. Retrofitting is considerably more costly (frequently by a factor of 2 to 3, or more) than the cost of the original design features, and the alternatives generally are limited to practical modifications of existing facility structures or operational procedures. In such cases, the “no action” case (i.e., the status quo) may be used as the base case. In some situations, the no action case may result in potential doses that exceed dose limits (e.g., a cleanup site), and as a result, may not be a viable alternative in the long term. However, it is helpful as a basis for comparison with other alternatives to assess risks and benefits and provide a perspective on the cost of various dose reductions. 4.2 Determining the Level of ALARA Analysis As a management tool, the resources expended to implement the ALARA process should be proportional to the potential benefits to the decision process. Although some level of evaluation is required for all actions that may affect doses to the public and environment, that level may vary from a “Memorandum to File” when the choice is obvious, to a very complex cost/benefit or multi-criteria decision analysis when there are multiple options with varied impacts. To assist in determining the necessary complexity of the analysis, DOE recommends “reference” dose levels to the MEI (or representative person of the critical group) and to the exposed population to assist in determining the level of detail needed in an ALARA analysis (See Figure 2-1). This Handbook provides the flexibility to perform qualitative, semi-quantitative, or quantitative ALARA analyses, depending on the dose expected to be received by the MEI (or representative person of the critical group) or the exposed population, and other influencing factors. The level of effort expended to estimate the initial dose level and to determine the level of ALARA analysis should be appropriate to the level of the activity. Professional judgment should be

The ALARA process can be most effective when applied in the design of new facilities that have potential to expose workers and members of the general public to radiation or radioactive material. DOE-HDBK-1215-2014 4-5 applied, and it should be considered an iterative process if the initial estimate seems too high or too low. In many cases, reasonable estimates of the radionuclide source term, site-specific meteorology, and dose screening factors should provide a reasonable dose estimate that allows the level of analysis to be determined. 4.2.1 Qualitative Analysis A qualitative ALARA analysis may be appropriate when the estimated doses are less than the reference dose levels and, in particular, when the collective dose is estimated to be less than 10 person-rem per year and individual doses are less than 1 mrem (0.01 mSv) per year. As for all analyses, several alternatives should be considered. All appropriate attributes or criteria of the alternatives should be identified, described, and compared but without assigning any numerical criteria to them. For example, the radionuclide emission level likely would be an important attribute of candidate airborne emission control systems, and could be described as low, medium or high. The cost of the candidate systems could be described similarly. In situations where there is only one obvious reasonable action, or there are a few alternatives all resulting in insignificant dose differences and one of the alternatives is clearly the favored approach based on one important attribute (e.g., cost, schedule, public acceptance), a simple memorandum explaining the options and the rationale for selecting one of the options may be adequate to satisfy DOE ALARA requirements. In other cases where doses are below the reference levels but there are multiple options with various risks or benefits, it may be appropriate to identify and qualitatively discuss multiple attributes, how each option addressed them, and qualitatively compare the options. 4.2.2 Semi-Quantitative Analysis A semi-quantitative ALARA analysis may be needed as the estimated doses from the alternative actions begin to approach or exceed the “reference” dose levels. Alternatives with collective doses between 10 and 100 person-rem per year are prime candidates for semi-quantitative analysis. In addition to the estimated dose the level of analysis also depends upon the complexity of the alternatives and the number and types of attributes. Semi-quantitative analysis may be necessary at lower levels if there are several attributes that are difficult to describe and compare qualitatively to show difference among alternatives. Useful tools for semi-quantitative analysis are multi-attribute analyses to rank and score attributes, with the level of analysis complexity following a sliding scale based on the estimated dose level. All significant attributes should be identified, characterized (rather than just described), weighted and scored, then compared and selected. More rigor is required to develop the attributes, their characteristics, and the relationships among attributes (e.g., uncertainty) for high-level multi-attribute analyses. The cost-benefit analyses generally will be partial analyses that are representative of the relative costs of each alternative, or surrogates may be used for dollars. For example, in a cleanup project, volume of material excavated may be assumed proportional to cost for the purpose of comparing alternative standards.

Resources allocated to the ALARA evaluation process should be commensurate with their potential benefits. DOE-HDBK-1215-2014 4-6 4.2.3 Quantitative Analysis A quantitative ALARA analyses may be justified for estimated doses that are above the “reference” dose levels. For example, if alternative actions produce individual doses that could cause the public dose to exceed or approach the all sources/all pathways dose limit [100 mrem (1 mSv) per year], or an associated source-based dose constraint such as the 25 mrem (0.25 mSv) per year for waste management or property control, or if collective dose exceeds 100 person-rem per year, a quantitative evaluation likely is warranted. However, dose is not the only attribute on which to base a decision to conduct a more rigorous evaluation. If there are several viable, alternative actions and their performance with respect to the various criteria is determined to be important to the decision (e.g., overall environmental performance, worker risk, cost, resource utilization), a quantitative evaluation may be needed. Similarly, if there are a large number of non-health factors to evaluate, it may be more appropriate to perform a quantitative analysis to determine which are more important to the decision. ICRP Publication 55 (ICRP 1989) presents a number of quantitative decision-aiding techniques that can be used such as: cost-effectiveness analysis, cost-benefit analysis, multi-attribute utility analysis, and multi-criteria outranking analysis. The process of quantitatively determining the alternative with the greatest total radiation protection benefit is formally called “optimization,” although all of the ALARA approaches discussed above seek the “optimal” radiation protection solution. “Optimization” should be used whenever decisions involve the implementation of a radiation protection practice that would be costly, complex, and/or involve significant dose savings (Munson 1988). 4.3 General Steps in Quantitative ALARA Analysis Quantitative analyses require the most effort and rigor and are the primary focus of much of this Handbook. Most of the information provided for quantitative analysis can be adapted for use in semi-quantitative and even qualitative analyses. The major steps in a quantitative ALARA analysis include the following: • Identify and quantify the sources of radiation; • Identify and define candidate radiation protection alternatives or systems (including waste stream treatment) that would reduce the exposure or doses; • Quantify economic factors (cost of systems, operations, maintenance, etc.); • Quantify exposures and doses to individuals and to populations in the vicinity of the DOE activity; • Estimate the health risk and identify non-health detriments (or benefits); and • Select one or more of the candidate radiation protection systems as ALARA. For semi-quantitative and quantitative analyses, it is important to avoid using very similar attributes to characterize the alternatives. Duplicative attributes result in unwarranted emphasis to a given impact area, manipulating the decision-making process and leading to bias. Duplication should also be avoided for qualitative analyses. DOE-HDBK-1215-2014 4-7 The above steps are based on a cost-benefit analysis, but they are generally applicable to other types of analyses, considering that cost-benefit analyses require benefits and detriments to be quantified in monetary or economic terms. The following subsections expand on these major steps of a quantitative ALARA analysis.

4.3.1 Identify and Quantify the Sources of Radiation A logical starting point for any ALARA analysis is to identify and characterize all anticipated radiation source terms, that is, sources of ionizing radiation from DOE activities. The source evaluation should quantify all parameters germane to the estimation of potential direct exposures of the workers and members of the public and internal exposures due to inhalation, ingestion, immersion, or absorption of radioactive material released to the environs by the DOE activity. For operational facilities, the “base case” source term used to compare with all alternative radiation protection systems is that which currently exists or a reasonable representation of the baseline source term. The data obtained from effluent sampling and/or monitoring, and environmental surveillance could be valuable when defining existing source terms from an ongoing activity and can provide exposure pathways and source data as well. The sampling, monitoring and surveillance data also may verify the adequacy of analytical models for dispersion of radioactive material in the environs and exposure pathways used to evaluate exposure conditions and dose estimates. Careful evaluations of facility design and operating conditions and measurements at a variety of locations in and around the facility or activity may reveal radiation sources and release and exposure pathways not previously identified or anticipated. Differentiation may have to be made between releases of radioactive materials as controlled airborne or liquid effluents and releases arising from pre-existing contamination (e.g., re-suspension). For facilities that are in the design stage, the base case is a radiation protection system that will meet the dose limits for postulated dose to the maximally exposed general employee or member of the general public. Although ALARA may be applied to the prevention of non-routine or accidental releases of radioactive materials, the application of this Handbook and the requirements of DOE O 458.1 are intended to apply to routine releases of radioactive material as airborne effluents and liquid discharges from normal operation. The ALARA process can also be used to set cleanup levels and authorized limits in the decontamination and decommissioning (D&D) of DOE facilities. 4.3.2 Define Candidate Radiation Protection Systems When the amount, physical characteristics, and location of the radiation sources are known, process systems can be designed to reduce the exposures of the workers and the public from the sources. The ALARA process should indicate how the activities and operation of the facility are analyzed systematically to identify existing and potential radiation sources and pathways for discharges or leakage of radioactive material that can be released to the environment where members of the public could be exposed. DOE-HDBK-1215-2014 4-8 For new facilities, or those being designed, source characterization likely would be based on: • Component performance data supplied by the manufacturer; • The design engineers; • Data from other installations that have used similar components; or • Laboratory tests. Source characterization also should consider life cycle costs and impacts of new facilities. The future cleanup or D&D costs should be considered as a criterion or attribute in selecting the appropriate environmental radiation protection approach for a new facility.

For operating facilities, the source characterization can be based on the results of survey, monitoring, and environmental surveillance data with supplemental studies or measurements, as necessary. Assuming that the sources of radiation and potential exposures are sufficient to justify the effort, several system design and operating options that would result in a range of release or exposure conditions and costs should be identified for each radiation source. Ideally, the design options would include several process technologies, combinations of process components, and operating conditions ranging from the most rudimentary (base case) to the most technologically sophisticated system. The ALARA process will identify the most favorable of the candidate design and operating options. The performance of the components of the radiation protection systems for reducing the exposures and associated doses should be estimated for each candidate system and option so that the modified source term, before and after treatment, can be estimated. Engineers, operators, and designers of other nuclear (and non-nuclear) facilities can provide extremely valuable data on alternative systems and components, cost, maintenance, and operating experience, particularly where the characteristics of the streams or processes are similar. Data should include system descriptions, performance and cost characteristics. 4.3.3 Quantify the Economic Factors (Costs) Two primary components of the cost associated with a radiation protection system are: • The system cost of purchasing, installing, operating, maintaining the equipment and D&D, and • The cost of the potential health effects. In ALARA applications, one is interested in the cost of providing various degrees of radiation protection for persons who are anticipated to be exposed to sources of radiation caused by a DOE activity, and in how these costs change with alternative systems. There also may be other costs associated with alternative systems that should be considered, such as those related to damage It is essential that several candidate process or radiation protection design options be evaluated so that the ALARA process can identify the best system(s). DOE-HDBK-1215-2014 4-9 (due to implementing an alternative) to a natural or cultural resource, or benefits to the protection of those resources from other alternatives. These factors also may be identified as part of the other “non-health detriments” discussed in Section 4.5.2. These analyses identify the candidate system with the least total (benefit [control] + detriment) cost in a cost-benefit analysis, hence the optimum system. The same types of factors help identify the optimum system in a multi- attribute analysis but are not quantified in monetary equivalents. It is important to recognize that cost is a metric used to compare alternatives. Alternative metrics may be used in multi- attribute analyses, but the goal is the same – to present the cost and benefits of the alternatives in common terms that can be easily compared. 4.3.4 Quantify Exposures and Doses from DOE Activities

The doses to occupationally exposed individuals and to the MEI (or representative person of the critical group) from a DOE activity are important because there are specific dose limits established by regulation or directive that must be met if the activity causing the exposures is to be permitted. The appropriate dose limit for an individual worker or member of the general public must be met regardless of cost. DOE also utilizes dose constraints for specific activities. In most cases, the constraints are treated like limits when evaluating options. If the constraint cannot be met, then the alternative is not viable. However, unlike limits, it is possible to consider an alternative that might exceed a constraint when other attributes of the ALARA analysis clearly override the benefit of meeting the constraint, as long as the dose limits are not exceeded. 10 CFR Part 835 regulates doses to workers. ALARA requirements for workers are addressed in that rule and its associated guidance. Collective dose is used as a surrogate for the potential radiological health impact on the population exposed to the radioactive material. DOE O 458.1, consistent with the ICRP, defines collective dose (S) as the sum of the total effective dose (TED) to all persons in a specified population received in a specified period of time. ICRP 103 recognized that this definition has led people in some cases to use the collective dose incorrectly to calculate radiation-related detriments by summing radiation exposures over a wide range of doses, over very long time periods and over large geographical regions. The following aspects should be considered and critically reviewed in order to assure that the collective dose is correctly calculated and applied as an instrument for optimization: • The radiation source geometry; • Quantity, type and energy of radiation emissions; • Exposure modes and pathways; • Number of exposed individuals and population distribution; • Age and sex of exposed persons; • Range of individual doses; • Location of the receptor with respect to the source location; • Duration of exposure and dose distribution in time; • Quantity of radioactive material released; DOE-HDBK-1215-2014 4-10 • Dispersion by natural forces; • Lifestyle of the receptors; and • Other parameters. There are no specific dose limits in DOE O 458.1 for collective dose from a DOE activity. As will be seen, if the health-detriment or health benefit can be quantified, a cost of the detriment or benefit may be postulated for cost-benefit assessment purposes. 4.3.5 Estimate Health and Non-Health Detriments and Benefits It is important to quantify the detriment (risk) or benefit (risk reduction) because, by doing so, a value can be placed on the amount of resources that may be committed for a radiation protection system to avoid a radiation-induced serious health effect. Again, the terminology of detriment and benefits is used principally in cost-benefit analysis, but the concepts are applicable to other ALARA process evaluations such as multi-attribute utility analyses. 4.3.5.1 Health Detriments

Serious health effects, such as cancer and genetic diseases, can be induced by exposures of humans to ionizing radiation. The effects have been observed only among populations subjected to doses greater than 10 rad delivered at a high dose rate. Whether these health effects occur at lower dose rates or by chronic exposure at low dose rates has not been determined due to the problems attendant to large epidemiological studies and to incomplete knowledge of the mechanisms of radiation-induced cancer causation. For radiation protection purposes, DOE assumes that there is proportionality between dose and risk (the probability of radiation-induced health effects) at dose levels encountered in the workplace and in the environment. To estimate radiation-induced health effects from low dose or low dose rate exposures, DOE recommends the use of cancer risk coefficients in the supplemental disk to Federal Guidance Report #13 update supplement, Cancer Risk Coefficients for Environmental Exposure to Radionuclides, EPA402-R-99-001, September 1999. However, this methodology requires estimates of radionuclide intake and may be too rigorous for many ALARA assessments. For estimating health effects from TED estimates, DOE recommends a mortality value of 6x10-4 fatal cancers/TED (rem) and a morbidity value of 8x10-4 cancers/TED (rem) based on use of technical guidance developed by the Interagency Steering Committee on Radiation Standards (DOE, 2003b). There are considerable uncertainties regarding radiation-induced health risks and, in general, DOE recommends ALARA analyses use dose and its monetary equivalents for comparative analysis rather than risk. The analyses conducted to support the ALARA process should consider all health detriments and benefits associated with the various alternatives evaluated. For example, one alternative control technology might reduce the collective dose (person-rem), by ∆S (detriment averted), but could significantly increase the risk to workers. The technology also might create a hazardous waste It is necessary to comply with the appropriate (individual) dose limit to any member of the public, whatever the cost. However, it is the collective dose that is used in the cost-benefit analysis to select a radiation protection system. DOE-HDBK-1215-2014 4-11 that could increase the public risk and present difficult disposal problems. These and similar factors need to be considered in the ALARA assessment. Reasonable measures should be taken to mitigate any additional risks caused by the technology. Due to the complex nature of many DOE activities, a combination of radiological and non-radiological hazards may be encountered. Identification of non-radiological hazards is critical to the ALARA process because efforts to apply the ALARA process inadvertently may increase risks from non-radiological hazards. An integrated safety management approach that optimizes protection from all hazards should be considered in the ALARA process for a given DOE activity. 4.3.5.2 Non-Health Detriments Non-health effects also can be experienced from activities that involve actual or potential exposures to radiation. Some of these effects are real and associated with environmental factors, such as temperature, noise, humidity, and other comfort considerations. Cost or other impacts and benefits may be accrued to a population other than the one receiving the exposure. It could include costs for purchasing property or other expenses to avoid litigation or demonstrations from stakeholders. Unlike the health detriment, the non-health detriment is not linearly related to dose, and might not be related to dose levels at all.

Because it is difficult to anticipate the cost of non-health detriments and the cost may not even be related to collective dose, they are difficult to include in a cost-benefit analysis and may need to be compared qualitatively. Multi-attribute analyses are useful analysis tools where non-health attributes may be important contributors to the decision-making and selection process. These techniques are particularly useful for factors that are difficult to quantify in the monetary terms that are required by a cost-benefit analysis. Multi-attribute analyses also are useful when sufficient quantitative information is not available to perform a cost-benefit analysis. 4.3.6 Select a Candidate Radiation Protection Alternative as ALARA In some cases, adequate information will be available to permit a cost-benefit analysis to quantify elements important in the decision-making process. In other cases, the information might not be available, or a quantitative cost-benefit analysis might not be practical to aid in a decision-making process involving ALARA exposures—in such cases, the decision should be based on less quantitative criteria. In these cases, other decision-making tools such as multi- attribute analyses may aid in alternative selection. In simplest terms, the radiation protection system selected by the ALARA process is the one that results in the maximum total benefit when all significant factors – either benefits or detriments – are considered. The prime factors crucial to ALARA decision-making in a cost-benefit analysis are the cost differential between candidate radiation protection systems and the differential in collective dose. These same attributes are likely the most important ones in a multi-attribute analysis; however, the inclusion of other attributes may change their relative significance. In the simplest case, the optimum system is that system with the maximum total benefit. In a cost-benefit analysis this is the system with the lowest total cost – including the monetary cost assigned to the health detriment. In a multi-attribute analysis, it is the highest ranked system. DOE-HDBK-1215-2014 5-1 Chapter 5. EVALUATIONS AND ASSUMPTIONS In any type of ALARA process evaluation, there are assumptions that need to be made and commonly used methods that should be followed. This Chapter addresses some of the areas commonly encountered for an ALARA analysis. 5.1 Cost of Radiation Protection Systems Cost projections for candidate radiation protection systems (including treatment systems) that alter the radiation source and operating cost may be expressed in terms of annual cost or total cost over the lifetime of the facility. Calculation of total cost for a facility or process typically should include, but not be limited to: 1. The system (capital) cost: • Equipment (description and quantity); • Labor (installation and operation); and • Other material. 2. The annual charge on capital (to the extent that this cost is applicable to Federal agencies). 3. The operation and maintenance (O&M) cost, that is: • A selected fraction of total capital cost equipment and piping cost; • Expendable material cost; • Electrical or other power cost; • Processing cost; • Collection and disposal cost; • Contingency allowance; and • Transportation cost. 4. The health detriment (cost for reduction).

It is essential to assess all of the alternatives on an equitable basis. Using conservative estimates for either system cost or detriment cost in one alternative but not in another will bias comparisons and should be avoided. Therefore, it is recommended that best estimates be used in all cases and for all attributes so that comparisons will be equitable. Standard engineering costing methods should be used in arriving at cost estimates for the systems. DOE-HDBK-1215-2014 5-2 5.2 Exposures and Doses Doses to occupationally exposed individuals (workers) and to the MEI (or representative person of the critical group) are important because there are specific dose limits that must be met, regardless of cost, if the activity causing the exposures is to be permitted. The primary dose limit is based on the TED and equivalent doses with few source-specific exceptions. Per DOE O 458.1, the primary dose limit for members of the public from all exposure modes is a TED of 100 mrem (1 mSv) in a year, an equivalent dose to the lens of the eye of 1500 mrem (15 mSv) in a year, or an equivalent dose to the skin or extremities of 5000 mrem (50 mSv) in a year. Dose limits for individuals are generally selected on the basis of 1) presumed health risk to the individual that is deemed acceptable, 2) feasibility of compliance, or 3) cost-benefit considerations. Several other individual dose limits that are source-specific or exposure-specific have been promulgated in DOE O 458.1. These include doses from airborne effluents (section 4.f.), liquid discharges (section 4.g.), radioactive waste and spent nuclear fuel (section 4.h.), drinking and ground water (4.i.), and release and clearance of property (4.k.). Thus, there may be multiple dose limits appropriate for an individual depending, in some cases, upon the exposure mode (direct exposure, ingestion, inhalation or absorption), the receptor status (occasionally exposed worker or incidentally exposed member of the public), and the source of the exposure (fuel cycle activity, exposure media such as drinking water, airborne source, etc.). If a DOE activity is subject to a dose limit that was based on cost-benefit considerations, and if it can be demonstrated that the dose from the activity is within that dose limit, a quantitative ALARA analysis will not be required for the part of the exposure subject to that dose limit. However, it may be worthwhile to perform a simple qualitative or semi-quantitative ALARA analysis to demonstrate that the exposures or resulting doses from that site-specific exposure mode are as low as reasonably achievable. There are many examples where non-radiological exposure limits have considered costs in their development: EPA permissible concentrations for contaminants in the environment, pesticide residual limits in food and feed stock, mercury limits in fish, EPA and FDA limits on cancer causing agents, maximum contaminant levels for public drinking waters supplies and effluent discharges for carbon-based power production, to name a few. There are several examples of radiological based exposure limits included throughout this handbook. 5.2.1 Exposure Location The magnitude of potential doses to individuals is dependent, among other things, on location during exposure. The location of the MEI, or representative person of the critical group, will depend on criteria such as: • The amount and characteristics of the radioactive source; • The release mechanism (through a stack, elevated vent, building leakage);

The maximum dose to individuals must be quantified to verify compliance with appropriate primary and supplemental dose limits. DOE-HDBK-1215-2014 5-3 • The site dispersal modes (wind roses, natural waterways) or environmental pathways; and • Exposure modes (direct exposure, intake of foodstuff). If the DOE activity can cause the release of airborne radioactive material, the location of the maximum potential exposure for that pathway is likely to be where the annual maximum time- integral of the air concentration exists. For example, the location of the highest annual average air concentration as a function of distance from the point of discharge may be determined by analytical modeling of meteorological data using joint wind-direction, wind-speed, and stability roses. The location of maximum potential dose is not necessarily where the highest concentration occurs. While the location of the maximum time-integral of the air concentration can be determined, the location might be uninhabited, and no person would be exposed. Further, it is unlikely for an individual to occupy any location for very extensive periods of time. Few people live in one location all of their lives; about two-three decades of living in one residence is more likely3. The doses at locations where there are homes, schools, and work locations should be evaluated. Therefore, even if people did occupy that location occasionally, adjustments for exposure duration would be necessary to estimate dose. Distance of the MEI or representative person of the critical group, from the point of discharge of the radioactive effluents can be taken as the location of the individual’s home, workplace, school, or other location where the individual remains for substantial periods of time. Doses to the MEI, or representative person of the critical group, from exposures to radioactive material in a waterway might depend on the concentration at the nearest location where access to the waterway is likely to occur. Although it is desirable (and recommended) to evaluate doses in a realistic manner, it is possible (and permissible) for economic savings to be realized to assume (conservatively) that the exposure of an individual occurs at the site boundary in the predominant wind direction. The advantage is that it is not necessary to collect data on actual locations of individuals. In this case, potential exposure pathways should be evaluated to confirm that greater potential doses are unlikely to occur at a location beyond the site boundary. This approach is less acceptable for estimating collective dose than for individual dose because overestimating doses can produce biased results and poor decisions. 3 A 1997 EPA survey found that about 95% of the population lives in a particular residence less than 30 years. The mean duration was about 7 years per residency. Realistic parameters should be used in estimating anticipated doses for ALARA purposes. The goal should be to ensure that the estimated doses will not substantially over- or underestimate the likely actual doses. To the extent practicable, the estimates should address anticipated doses to actual people, rather than maximum doses to hypothetical persons. DOE-HDBK-1215-2014 5-4 5.2.2 Receptors For most ALARA applications, the use of “average” or typical characteristics for evaluating potential doses to exposed populations is recommended. Irrespective of the age or gender of the persons exposed, average doses to organs or tissues, average risk coefficients, and typical values for food and drink intakes and metabolic parameters for “Reference Person” should be used.4

ALARA evaluations should be expressed in terms of TED, the sum of the effective dose from external exposures and the committed effective dose from radionuclides taken into the body during the same exposure time interval. There may be special circumstances where age or gender issues may be important considerations and the use of “Reference Person” or other standardized assumptions may not be applicable. This is clearly different from calculations for assessing compliance with individual dose limits or dose constraints. In such cases, the MEI (or representative person of the critical group) is likely to receive the highest dose, or the average dose to the “critical group” is calculated. This value should not be used to estimate collective dose. 5.2.3 Collective Dose By definition, collective dose (S) is the sum of the TED to all persons in a specified population received in a specified period of time. It can also be expressed as the product of the average dose to a specified population and the number of exposed persons within that population. It is important to the decision-making process that collective dose estimates be representative so that comparisons of alternatives can be conducted without bias. As with alternative cost estimates, collective dose estimates in quantitative ALARA assessments should be best estimates. Although the use of conservative dose estimates may be acceptable for screening assessments to determine if quantitative ALARA assessments are needed, average or representative dose estimates are needed for actual optimization assessments. The problem, therefore, is determining the average dose(s) and the number of persons that receive the dose. 4 It is noted that DOE uses the linear dose to risk assumption and average parametric assumptions for planning purposes and for evaluating potential exposure for use in the ALARA process and other environmental evaluations. However, these assumptions may not be applicable or appropriate when assessing the risks from actual exposures or the effects of exposures to accidental releases or conducting scientific studies (e.g., epidemiology). In this Handbook, the critical group may be considered to be individuals in the general vicinity of a DOE activity, facility, or site from which radioactive material is released or other sources of exposure occurs, which have relatively homogeneous physical and lifestyle characteristics that are likely to result in the maximum dose (and presumably the highest risk) compared to other groups in the exposed population. For example, the critical group might be infants who ingest milk from cows pastured on land in the predominant downwind direction from a facility that releases radioiodine to the atmosphere. Another critical group might be comprised of persons who ingest a substantial amount of fish taken from a local waterway downstream of a facility that releases radionuclides in liquid effluent. DOE-HDBK-1215-2014 5-5 To illustrate one method for estimating S, consider the release of radioactive material to the atmosphere. Various analytical models, generally in the form of diffusion equations, may be used to estimate the dispersion of the material at various distances from the source. Potential exposure conditions, e.g., integrated air concentration, can be evaluated as a function of distance and direction from the source. The population distribution of persons at the same distances and directions need to be determined. Within each compass direction-sector, a series of radial segments (of increasing distance from the release point, as Xi ± ΔX, or ΔRi) can be defined and representative (average) doses estimated for the centerline of the radial increment. The potential dose at distance Xi can be taken as the average dose, (Hi) for all persons, (N), located within a given radial segment ΔRi defined by Xi ± ΔX. Thus, the incremental collective dose (ΔS) is expressed as: N x Hi.

Similarly, additional incremental S values are estimated for all radial segments in that quadrant out to a distance of 50 miles (80 km) from the point of release or 50 miles beyond the site boundary when integration of doses beyond this point does not significantly affect data quality objectives. This process is repeated in all other sectors, each corresponding to one of the 16 compass points by which wind direction and wind speed are characterized in a wind rose. Site- specific meteorological data also combine atmospheric stability measurements with wind speed and direction to form a joint frequency file. The sum total of the incremental S values from all sectors is the collective dose for the release. Figure 5-1 provides a context for applying these concepts. DOE-HDBK-1215-2014 5-6 FIGURE 5-1. Concepts in Estimating Collective Dose from Airborne Radioactive Material Releases Figure 5-1 shows the release point, 0, surrounded by 16 equal sectors of 22.5 degrees, each centered on the points of the compass corresponding to a wind direction. Each compass sector is divided into radial segments, each designated as ΔRi where i defines the sector and distance Xi from the release point. The radial increments selected at various distances in a sector should be relatively small at locations where the concentration is decreasing rapidly with distance and larger at locations where the concentration is decreasing more slowly. This is necessary because the approximation is made that the average dose to all persons in the radial segment will be the dose calculated for the mid-point of the segment. For example, the radial increments might be no more than a mile apart out to 10 miles (16 km) and no more than 10 miles apart out to 50 miles (80 km). The actual division of sectors into radial segments depends on the site; many DOE sites are large and have unoccupied buffer areas between release points and the site boundary, so small radial segments near the release point are not necessary. When the release includes short-lived material, adjustments for decay en route may be necessary. N NNW NNE ---22.5o--- NW NE WNW ENE W 10 20 30 40 50 miles Xi WSW ∆Ri ESE SW SE SSW SSE S DOE-HDBK-1215-2014 5-7 The collective dose associated with the use of each alternative radiation protection system is needed for any semi-quantitative or quantitative ALARA analysis. Unless the characteristics (other than magnitude) of the source term are altered by the various systems, the collective dose will be proportional to the source term and can be determined readily by using ratios.5 Deposition of the airborne source on ground-level surfaces may be estimated using similar analytical models and estimated deposition velocities. When evaluating collective doses for release or clearance of property, defining the representative receptor is difficult. In comparing alternative actions collective dose estimates should consider the expected or likely use of the property. Where data are available for key parameters, models may use probabilistic assessment techniques to establish the average or representative dose for computing the collective doses. However, these dose estimates may not be acceptable for demonstrating compliance with the individual dose limits that require evaluations of MEIs as critical groups. When representative data are not available, it may be necessary to use generic values. However, overly conservative parameter selections will bias the ALARA analysis.

The collective dose to the exposed population is the measure used to evaluate the potential risk of serious radiation-induced health effects to the public and to identify the optimum radiation protection system among several alternatives. Actual and projected population distributions in the vicinity of the DOE activity or site are needed for this estimate. For practical reasons, such as availability of data, relatively small source term, or limitations of dispersion data, the availability of the population distribution should be limited to a distance of 50 miles (80 km) from the point of an atmospheric release unless integration of doses beyond this distance is suspected to be significant. Analytical models may be used for evaluating atmospheric releases and may assume sector-averaging and radial increments with the dose calculated at the center of the radial sectors and applied to the number of persons in that area, as discussed previously. For releases of radioactive materials to waterways, the method of release, such as through rakes or conduits, will determine the initial dispersal conditions. Releases may be evaluated using readily available analytical models, data on water usage, and the population data for activities involving the waterway and shoreline. The location of wells, water intakes for water processing plants, fishing, swimming, boating, shoreline, and other activities will be important parameters. In waterways, the dispersion is generally much more limited than releases to the atmosphere and evaluations of collective dose may require summations out to greater distances than for atmospheric releases. For example, discharges to a river may have few and very limited pathways of exposure within 50 miles (80 km) of the site. However, at some greater distance, such as 70 miles (110 km), a major drinking water system may extract water from the river. Potential collective doses associated with releases that might affect the system may be the major detriment associated with the alternative control systems. Therefore, unlike atmospheric releases where collective doses beyond 50 miles are typically not essential or significant to ALARA decisions, in this example, potential receptors 70 miles from the site are likely to be important to 5 Examples of situations where collective dose may not be proportional to source term include control systems that selectively affect certain radionuclides. For example, a containment facility may be used to delay releases for a period of time sufficient to significantly deplete (through decay) short-lived radionuclides. Such a control system may also increase worker dose while reducing public dose. In this example both public and worker doses must be assessed. DOE-HDBK-1215-2014 5-8 the decision-making process. Although in most instances such situations are not expected to occur when evaluating releases to the air, the 50-mile practical geography-based truncation of collective dose should be used cautiously. The truncation of collective dose calculations should occur only when there is a reasonable expectation that the additional calculations will not provide information important to the ALARA decision.

To summarize, there is essentially no de minimis for the application of the ALARA process. Theoretically, collective doses over all time and space may be considered in applying this decision-making tool. However, given that the ALARA process is used to help optimize benefit and make good decisions by balancing many factors such as dose reduction, economics and social factors, collective dose calculations should be constrained by practical considerations. Extending dose calculations inappropriately to include very long time periods, very large areas or very low individual doses could bias the data and analysis and is as likely to result in a poor decision as in a good decision. For example, integrating doses to infinity could produce results that diminish protection of workers but, given the uncertainty in the long-term projection, tend to provide little additional benefit to the non-worker populations. Therefore, quantitative ALARA analyses should only be conducted within periods or spaces where the collective dose data and differences between alternatives are meaningful. Temporal and geographical boundaries should be selected with care to minimize bias in results and uncertainty between alternatives. It is key to assess each alternative in a consistent, representative and comparable manner. With this in mind, as noted in the previous discussion: • Integration times for quantitative comparisons should be limited to time periods for which reasonable projections and comparisons can be made. For operational activities it is generally the expected life of the facility or operation. For cleanup and waste management it is typically a period up to a few hundred years but no more than 1,000 years. In special circumstances, such as deep geologic disposal, quantitative analyses beyond 1,000 years may be useful, but in most situations, analyses and data relating to such long periods should be assessed qualitatively, not quantitatively. • As a general rule, collective doses to populations need only be assessed to 50 miles (80 km) from the site boundary. There may be special circumstances where larger distances may be used (e.g., a large population is located just beyond the 50-mile radius, or the dispersion is sufficiently limited that larger distances can contribute collective dose that will be significant to the analyses). • Although DOE does not recommend dose-based value for truncating collective doses, specific analyses may truncate calculations when it is determined that the continued integration will be of little or no use in the comparison of alternative controls. It is expected that any such truncation will be at doses well below 1 mrem (0.01 mSv) in a year given that the median maximum individual dose associated with releases from DOE facilities is below 0.1 mrem (0.001 mSv) in a year. • The ALARA process must be applied and documented for all DOE radiological activities. However, DOE supports a graded approach to the process. A process for assessing the maximum resources appropriate for an ALARA assessment is discussed in the section on Resource Allocation in Chapter 7. As a general rule, quantitative assessments will not be necessary if potential individual doses from all alternatives DOE-HDBK-1215-2014 5-9 assessed are less than 1 mrem (0.01 mSv) in a year and collective doses are less than 10 person-rem. Quantitative comparisons of alternatives should always be considered when individual dose may exceed tens of mrem in a year and collective doses exceed 100 person-rem.

All of the above criteria constitute guidance, not rules. The goal of any ALARA analysis is to produce data that will be useful in supporting a good decision that fairly assesses the benefits and costs associated with the alternatives under consideration. Therefore, care should be taken to treat analyses of the alternatives equally and not compare conservative estimates for one alternative to realistic estimates for another. Similarly, varied uncertainties in data from different alternatives should be identified and to the extent possible, eliminated or, at least, be stated clearly. DOE-HDBK-1215-2014 6-1 Chapter 6. OTHER FACTORS AND ISSUES RELATED TO THE ALARA PROCESS This Chapter provides information to aid in optimizing resource allocations for radiation protection and to systemize and clarify “good ALARA practices.” ALARA applications are broad, ranging from day-to-day “routine” operations to those related to the design or modification of major facilities. The information in this Chapter can help determine how much analysis is necessary for the ALARA evaluations. DOE routine radiological activities are subject to the ALARA process. However, DOE O 458.1 requires that the ALARA process use a graded approach. The ALARA process should be commensurate with the complexity and hazard of the DOE activity. This Handbook provides practical benchmarks and criteria for ensuring that the level of effort associated with ALARA analyses is effective. 6.1 Resource Allocation To scope the effort necessary to comply with the ALARA requirements of DOE O 458.1, one may start by estimating the maximum amount of resources that can be justified for reductions of the dose. This can eliminate considerations of options that would exceed that amount. A suggested procedure would be: 1. Estimate the source term that would cause exposures of the public; 2. Estimate the potential S value (person-rem); and 3. Multiply S by the value of α (e.g., $6,000/person-rem).6 The resulting value, S x $6,000, is the maximum amount of resources that could be justified for health concerns because there is no process or system that can eliminate all exposures. If the collective dose is from annual exposure, the S x $6,000 value is the maximum cost. If the collective dose is over the lifetime of the activity, the S x $6,000 value is the maximum justifiable total cost associated with public dose. If no process or system can be identified that could be purchased, installed, operated, and maintained within this cost constraint, no further ALARA effort is needed other than to document the conclusion as part of the record. Such a finding does not foreclose on quantitative assessments and general good management practices that may decrease doses or potential doses. Nor does it eliminate the need to consider “non dose” factors that may indicate a need for quantitative review irrespective of the dose concerns. 6.2 Uncertainties A second basis for defining the scope of the ALARA applications is the uncertainty in the estimations of collective dose, even when using the best available models for making such estimates. Evaluations of collective dose generally involve estimating a radiation source term, estimating the dispersion patterns, characterizing exposure conditions, and summing the postulated resultant doses to members of the general public over all locations and times were

6 DOE recommends a range of $1,000 to $6,000 per person-rem be considered as possible monetary equivalents. Depending on circumstances, it may be appropriate to use a range or the $6,000 value for such screening assessments. DOE-HDBK-1215-2014 6-2 and when the exposures occur. It is instructive to briefly review some of the factors that contribute to uncertainties that are germane de minimis7 considerations; when uncertainties are extremely large relative to the value needed to quantify exposures and doses, it is not productive to continue the evaluation exercise. 6.2.1 Source Terms It is unusual to know, exactly, the identity, quantity, and physical/chemical characteristics of the radioactive source term that is the cause of exposures of the public. Sampling, monitoring, and environmental surveillance can provide a reasonable database for reasonably characterizing the sources if an effort has been made to do so. Sampling, collection, and analyses all have limitations and introduce their own uncertainties. In many cases, the source term can only be estimated on the basis of fragmentary information from operating experience or is completely based on speculation. Thus, the source terms are subject to considerable uncertainty. 6.2.2 Dispersion Patterns When radioactive material is released to the environment to be dispersed by natural forces, the concentrations generally decrease without limit until the radioactive material can no longer be measured. The ultimate fate of the material can be postulated, and analytical models can be found or developed in an attempt to describe the dynamics of the dispersion between the release and its ultimate fate. There are substantial uncertainties every step of the way. The collective dose is calculated using the estimated environmental concentrations at the locations where people reside. This calculation depends on demographic information, which can be highly uncertain. 6.2.3 Time Variations Essentially all of the parameters that determine exposure or dose vary with time. For example, source terms depend on equipment performance; dispersion patterns are affected by daily, monthly, seasonal, annual, and geologic fluctuations; and population numbers, locations, and lifestyles that affect exposure pathways and modes vary with time. 6.2.4 Release to the Atmosphere Consider a ground-level release of airborne material. As distance from the source increases, the dose rate generally decreases and one should decide how far to extend the dose estimate as some sources are dispersed widely, perhaps thousands of miles, or worldwide. Due to the inability of analytical models to precisely predict the dispersion pattern, or any of the other exposure parameters necessary for collective dose estimates, at distances beyond a few tens of miles, extreme caution should be exercised by the user. Further, the characteristics of the source term and the inability to predict its physical fate due, for example, to deposition or re-entrainment, are confounding factors in estimating collective dose. In view of the many uncertainties such as those discussed above, it does not appear rational to attempt to predict doses beyond a modest 7 De minimis refers to an impact or effect that is so small that it is insignificant and can be ignored in the decision- making process. DOE-HDBK-1215-2014 6-3

distance of 50 miles (80 km) from the DOE site boundary. In most instances, collective dose integrated for distance over 50 miles (80 km) provides minimal additional information necessary for the decision process and, therefore, truncation of the dose calculations at 50 miles is usually appropriate. Several DOE sites are very large – in some cases 10 or more miles from the release point to the site boundary. When several release points are present and they are all located at a considerable distance within the site boundary, they may be treated as a single point of release for purposes of calculating collective dose. However, the actual release points should be used where doses to individuals are evaluated to verify compliance with appropriate limits. 6.2.5 Release to Surface Waterways Releases to natural waterways generally undergo more limited dispersion than releases to the atmosphere. In both cases, dispersion is due to mixing by eddy currents, but natural waterways have much more finite dimensions than the atmosphere. This restricts the freedom for further mixing. Consequently, estimates of collective doses from releases to waterways may require including dose contributions beyond those associated with releases to the atmosphere. Further, if the waterway is a drinking water supply, many persons may be exposed. In this event, the 50- mile (80 km) distance constraint for atmospheric releases is not necessarily for releases to waterways. For smaller waterways, such as creeks, rivers, or ponds, the concentration becomes uniform over cross-sections of the waterway in a relatively short distance and decreases with distance only as further dilution from other water sources becomes available – generally slowly. In this case, the integration of doses may be required to be extended until the next collective dose increment to be added is less than about 1% of the total to that point. For larger waterways, such as large lakes, bays or oceans, the dimensions are generally greater and the water has fewer dimensional constraints, and the concentration is likely to decrease at a greater rate than is the case in smaller waterways. There could be less need for calculating dose contributions at the greater distances if the concentrations in the larger bodies of water are less than those in the smaller waterways. Site-specific conditions should be used to demonstrate that the collective dose has been adequately determined. The site of the receptor population is extremely important in these determinations. For example, a 0.1 mrem (0.001 mSv) per year dose 90 miles (145 km) downstream at a water treatment system serving a large population could be the most significant source of potential collective dose. DOE has no de minimis level on individual doses in the calculation of collective dose. However, the integration may be truncated when it is unlikely to significantly affect the decision process. In most instances, this is expected to occur when individual doses are a small fraction of 1 mrem in a year. DOE-HDBK-1215-2014 6-4 6.2.6 Releases to Ground Water Releases to the subsurface water, which typically undergoes less dispersion than releases to surface water, may or may not impact ground water quality, depending upon a number of factors which all contribute to overall uncertainty. These factors include: • Depth of the aquifer or water table; • Force that drives the released material toward the aquifer or water table (infiltrating water);

• Pathways in the subsurface that include physical barriers; and • Chemical processes that enhance or retard migration. If factors obtained at a particular site suggest that ground water will be impacted by a release, then additional factors related to the saturated zone become significant in determining the ultimate fate of the released material, and also contribute to overall uncertainty. Such additional factors include: • Transmissive properties of the hydrogeologic unit, including the hydraulic gradient, the size and dimensions of the unit, and soil particle distribution; • Geochemical processes that can vary significantly from one point to another in the same ground water unit, and can vary significantly over time; and • Chemical and physical properties of the released material. Further, understanding the current physical conditions of the subsurface is limited as a result of the high costs of subsurface investigations. While “at surface” and “above surface” conditions can be observed directly, “subsurface” conditions cannot. Generally, data from soil core samples, monitoring wells, and geophysical techniques are collected from a small number of observation points, and extrapolated to a much larger subsurface area, or to future time periods. Extrapolation, based on models and inference, adds uncertainty, due to the lack of uniformity in the subsurface (even considering small-scale investigations) and to the relatively long time periods needed to validate modeling analyses and predictions. One should also consider the uncertainty associated with long-term unknowns. Travel time of a conservative (that is, non-degrading) species in the ground water typically can be measured in tens of meters per year. At this rate of migration, human activities many generations into the future, as well as long-term geologic phenomena, can contribute further to uncertainty. Conceptual models of a site’s subsurface conditions should be designed to identify sources of uncertainty, and to include each source in any analysis performed – if only in a qualitative sense. Short-term (decades to centuries long) predictions of the fate of releases to the subsurface should be matched with ongoing monitoring of actual site conditions to reduce uncertainty, and to continually validate long-term predictions. DOE-HDBK-1215-2014 6-5 6.3 Exposures within Facilities Reduction in releases of radioactive material into the environment may be associated with increased amounts retained within the facility. This could lead to increases in the dose to both individual workers and the collective occupational dose. The detriment cost associated with these doses should be considered and the benefit due to the reduction in public dose should be reduced by this amount. 6.4 Exposure Time Among the more difficult issues to evaluate are those that deal with very low levels of exposure from man-made sources in the environment, and result in individual and collective doses that are a small fraction of those from naturally occurring sources. In some activities, widespread, chronic, very low dose levels might be delivered over very long-time intervals (such as several generations) to many people over a very large geographical area.

The dose from radiation sources depends on the dose rate and the duration of exposure. Possible duration of exposures to members of the public to radiation from some DOE activities could range from the duration of a cloud passage to a receptor’s lifetime. Estimates of the time- integrated air concentration and doses from airborne radioactive material in the cloud can be evaluated using available meteorological models describing atmospheric dispersion in the lower atmosphere for finite size clouds and for clouds of semi-infinite dimensions. Such calculations also can be used to estimate the intake of radioactive material by inhalation during cloud passage. In estimating the doses from finite exposure durations, the annual intake of radionuclides by inhalation or ingestion should be determined and appropriate dose coefficients used to estimate the annual (committed) dose and summed over the years of exposure. The average lifetime is about 70 years. However, it is highly unlikely that an individual would be exposed to one source for more than 20-30 years, because people usually do not live in one location more than 30 years. Most dose coefficients are based on 50-year time-integrals (dose commitments) after the intake. These factors are widely accepted and appropriate for DOE use regardless of the lifetime or period of exposure used. Another time-interval to consider is the time over which the public could be exposed. In some cases, chronic exposures presumably could occur over many years – perhaps several hundreds and possibly several thousands of years. Durations of these exposures are generally associated with applications involving very long-lived radionuclide materials that are assumed to be released to the biosphere at some point. The scenario usually ties the assumption of a release mechanism and a fraction of the existing inventory of material into a medium such as the water supply, and chronic exposure of the public. The results of such evaluations usually assume that a large number of people will receive relatively low doses for many generations. Such projections deserve critical examination to verify their credibility. Judgments on the acceptability of such doses usually are based on the dose to individuals, rather than on the collective dose, but the societal impact is related to collective rather than individual dose. The dose estimate can require the summation of annual dose over a lifetime and the total exposure is assumed to continue over DOE-HDBK-1215-2014 6-6 many generations. Further, the population density and distribution can be expected to differ substantially as compared to current distributions. Lifestyles, which determine exposure modes, also can be expected to change markedly over such a time span. For purposes of comparing ALARA alternatives for operational systems, the lifetime of the facility generally is a basis for truncating collective dose estimates, temporally. However, where cleanup, restoration, and waste management activities are necessary, the time frame of interest can be much longer. Where radionuclides have relatively short half-lives, decay over a few half- lives may be sufficient to determine the collective dose. For longer-lived radionuclides, integration times may be determined by the uncertainties in scenarios and due to the physical parameters affecting dose rates. These uncertainties make it difficult to determine and quantitatively assess the difference in alternatives beyond a few hundred years because the differences are based largely on assumptions rather than fact. Therefore, it is only appropriate to do quantitative comparisons to a few hundred years, or less.8 Although evaluating doses for periods of up to 1,000 years may provide useful information, periods beyond 1,000 years should not be used in quantitative ALARA assessments.

Due to the uncertainties and difficulty in quantifying these time-related factors, it is critical that knowledgeable persons are responsible for making ALARA judgments. As an example, the time and duration of exposures to the affected individuals or population and the likelihood or probability of occurrence of the exposure scenarios evaluated in the analyses should be considered and appropriately balanced when the alternatives are weighed. It may be appropriate for instance, to give more weight to likely near-term exposures than to plausible but unlikely future exposures. In general, it is reasonable to assign lower values to doses that are increasingly uncertain than to those that are not. Similarly, equal collective doses resulting from individual doses that are a significant fraction of the dose limit may be considered more important than collective doses resulting from individual doses that are very small compared to the dose limit. This is recommended because the linear non-threshold dose-risk assumption is generally believed to be conservative. 6.5 Discounting Cost One of the more controversial time-integral issues is associated with discounting cost when the expenditure is present and the health detriment that is being reduced is several hundreds or thousands of years in the future. From strictly an economics point of view, it is rational to discount cost projections based on postulated health effects centuries and eons in the future. Assuming all conservative assumptions in quantifying potential health effects are factual, if any finite discounting is applied, the present worth would be a small, even infinitesimal, fraction of 8 Administrator of the Office of Information and Regulatory Affairs of the Office of Management and Budget, January 11, 1996, Regulatory Planning and Review – Economic Analysis of Federal Regulations Under Executive Order 12866. The product of a very small annual dose to a very large number of people, over a very large area and over a very long period of time may aggregate information inappropriately and could be misleading when selecting protective actions. DOE-HDBK-1215-2014 6-7 the cost of the future detriment. Because of this, and the extreme uncertainties associated with very long projections of dose which limits the value in decision making, DOE recommends limiting quantitative assessments of collective dose to support ALARA efforts to a few hundred years. This is one method of weighting present collective doses greater than those that occur in the future. Conventional discounting is not recommended for analyses hundreds of years into the future (NAPA, 1997). However, without discounting, analyses of detriments over long periods typically are biased in favor of future generations at the expense of the present generation. 6.6 Perspectives A perspective of the dose analysis should be provided. It is often useful to compare estimated collective dose values from DOE activities with the collective dose to the same exposed population from natural (background) radiation sources. One such comparison would be the time required for the exposed population to receive a comparable collective dose from natural background radiation. Similarly, risks to populations can be compared to the normal incidence of cancers (fatal and non-fatal to the same population during the same exposure time). For example, about one-third of the population will contract cancer in their lifetime, and about half of those will be fatal. There are other comparisons that also can add perspective.

6.7 Other Factors and Criteria In many cases, particularly where multiple contaminants in multimedia situations occur, DOE ALARA requirements must be applied along with other criteria and requirements. The ALARA process is sufficiently flexible to incorporate such criteria into the process and in many cases, these factors or criteria are already parts of the process. For example, under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) regulations (40 CFR 300.430), selection of remedial actions must consider the criteria shown in Table 6-1. As noted above, all of these criteria are, or readily can be, addressed as part of the ALARA process and the CERCLA requirements to document that consideration of these factors is consistent with the ALARA documentation requirements. Although some of the CERCLA criteria may not be easily quantified through a monetary equivalent in the cost-benefit analysis, they all can be addressed with multi-attribute analysis approaches. Such approaches would weight each criterion and then score the alternatives for each criterion. The sum of these scores may be used to rank the alternatives. Although justifiable from economic considerations, the issue of discounting (like many other factors) is a policy consideration, and currently no discounting is likely to be considered. DOE-HDBK-1215-2014 6-8 TABLE 6-1. CERCLA Criteria That Can Be Addressed Using the ALARA Process Threshold Criteria Compliance with Applicable or Relevant and Appropriate Requirements (ARARs) – Addresses whether a remedy will meet the applicable or relevant and appropriate Federal and State standards or whether a waiver is justified. Overall protection of human health and the environment – Addresses whether a remedy provides adequate protection of human health and the environment and discusses how risks are eliminated, reduced or controlled through treatment, engineered controls or institutional controls. Both of these criteria are addressed in the ALARA process through the consideration of dose constraints and selection of alternatives that reduce doses (risks) to as low as reasonably achievable. The ALARA process may be useful in assessing the impact of specific ARARs with regard to implementable alternatives in cleanups under CERCLA. Primary Balancing Criteria Short-term effectiveness – Addresses the period of time needed to achieve and to determine any adverse impacts on human health and the environment that may be posed during the construction and implementation period, until remedial action objectives are achieved. Long-term effectiveness and permanence – Refers to expected residual risk and ability of a remedy to maintain reliable protection of human health and the environment over time. Reduction of toxicity, mobility, or volume through treatment – Refers to the performance of treatment technologies. Implementability – Refers to the technical and administrative feasibility of a remedy including the availability of materials and services to implement the alternative remedy. Cost – Includes estimated capital cost, annual operation and maintenance costs, and the net present value of capital and operational and maintenance costs. All of the primary balancing criteria are key factors in ALARA process assessments. Although the reduction of toxicity, mobility, or volume criterion is not addressed in detail, processes or techniques such as these that can reduce migration and possibly dose should be considered and addressed in the selection of alternatives.

Modifying Criteria State acceptance – Indicates whether the State concurs with, opposes, or has no comment on the preferred alternative, and State comments on ARARs or proposed waivers. Community acceptance – Summarizes the public’s response to the alternatives. As noted in this document, the analysis of the ALARA process factors requires judgment and as a result, input from interested groups (e.g., States, communities, Site Advisory Boards, unions, etc.) may be important when considering and evaluating the ALARA factors. The impacts of such input are discussed in some of the examples presented in the appendices of this Handbook for both CERCLA and non-CERCLA-related projects. DOE-HDBK-1215-2014 7-1 Chapter 7. QUALITATIVE ALARA ANALYSIS As previously expressed in Chapter 1, the goal of the ALARA process is to identify, from among candidate radiation protection alternatives, the alternative that would result in the maximum total benefit, considering the protective measures and their costs. Resources allocated to the ALARA evaluation process should be commensurate with their potential benefits. As illustrated in Figure 2-1, DOE recommends reference dose limits to the MEI (or representative person of the critical group) and to the exposed population to assist in determining the level of detail needed in an ALARA analysis. Qualitative analysis typically uses words to describe the magnitude of potential consequences and the likelihood that those consequences will occur. Scales or matrices are useful tools that can be adapted to suit the circumstances of the analysis. This type analysis is useful when reliable data for a more quantitative analysis is not available or necessary. A qualitative ALARA analysis may be appropriate when the estimated doses are less than the reference dose levels and, in particular, when the collective dose is estimated to be less than 10 person-rem per year and individual doses are less than 1 mrem (0.01 mSv) per year. 7.1 Environmental Restoration Case Study This case study is an example of using a Qualitative ALARA analysis for a small environmental restoration project to show that a complex analysis need not be performed to arrive at an optimum conclusion. This case study examined the options of removal of contaminated soil in a Radiological Materials Management Area (RMMA) to satisfy an industry land-use scenario and a residential land-use scenario. Site Description and History The RMMA is located immediately surrounding the outfall of an old industrial building and the former location of a trailer used for industrial operations. The industrial building was constructed in the late 1950s for explosive compounds synthesis and had also been used for animal experiments. A machine shop was opened in the mid-1960s and may have discharged solvents and acids to floor drains. There is currently no activity in the building and all floor drains had been sealed at some point in the past. The drains discharge to a central drain line east of the building to a surface outfall near the bottom of a small ravine, which is a tributary of a nearby stream. A thick mat of dead vegetation has built up around the discharge point. The area of the site is approximately 1000 m2 estimated to be 15-45 meters above the regional water table. Site Status A final status survey was conducted in accordance with Multi-Agency Radiological Survey and Site Investigation Manual (MARSSIM) guidelines. Surface radiation surveys did not detect any anomalies above background at the site. Subsequent soil sampling found one slightly elevated U-235 result but otherwise passed the MARSSIM statistical tests.

DOE-HDBK-1215-2014 7-2 Dose Assessments A dose assessment, using the Residual Radiation (RESRAD) computer code, was performed assuming both an industrial (most likely) and residential (assumes loss of active control measures) land-use scenarios. The assessment assumes that the only contamination will come from the U-235 concentration within the top 0.15 m of soil. As a conservative approach, this U-235 concentration was averaged over the entire site. The RESRAD dose assessment resulted in an annual TED to an MEI of 0.08 mrem (8.0 E-4 mSv) per year and 0.18 mrem (0.0018 mSv) per year for the industrial land-use and residential land-use scenario, respectively. Both values are much less than the numerical EPA guidance of 15 mrem (0.15 mSv) per year. ALARA Analysis for the Site Since only one slightly contaminated area of soil was found at the site, the ALARA cost analysis addresses only the expense of removing the soil and treating it as radioactive waste versus leaving it on the site. The disposal cost for 150 m3 of radioactive waste at this concentration would be approximately $108,000. Assuming an unlikely residential land-use scenario, where 0.18 mrem (1.8 E-3 mSv) per year is avoided by each of the projected 1 site resident (8 residents/acre * 0.04 acre) for each of the next 50 years, the projected cost per person-rem avoided would be $12 million ($108,000/(0.00018 rem/yr * 50yr * 1 person). By comparison, the cost to simply leave the soil untouched on-site would be $0. Therefore, further remedial actions or waste disposal expenses to reduce the already minimal radiation doses at this site are not reasonably justified. 7.2 Volumetric Release of Sediment for Off-Site Landfill Disposal This qualitative ALARA analysis was prepared in 1998 to evaluate the potential disposal of approximately 9 m3 (12 yd3) of sediments containing polychlorinated biphenyls (PCBs) and low levels of residual radioactive materials in accordance with DOE O 5400.5 and associated guidance. Site Description and History Sediments from a DOE facility containing PCBs at levels regulated under the Toxic Substances Control Act of 1976 (TSCA). Levels ranged from 52 to 450 ppm as compared to the TSCA criterion of 50 ppm. In addition, the sediments contained low levels of residual uranium at a maximum measured concentration of approximately 8 pCi/g. At the time of this evaluation, DOE requirements for release of real property were specified in Chapter IV of DOE O 5400.5. These requirements include: an evaluation to ensure that potential radiation doses to the public would not exceed 25 mrem (0.25 mSv) per yr with a goal of a few mrem per yr, in accordance with DOE’s requirements to reduce radiation exposures to ALARA; an evaluation of compliance with groundwater protection requirements; reasonable assurance that the proposed disposal is not likely to result in a future requirements for remediation of the landfill; and assurance that the materials proposed for disposal are acceptable to the owner/operator of the facility and regulators. DOE-HDBK-1215-2014 7-3 Disposal Alternatives Two primary disposal alternatives were available for this waste stream, an off-site, DOE-owned TSCA Incinerator or an off-site, commercial TSCA-permitted disposal facility. Utilization of the DOE-owned TSCA Incinerator would also require removed sediments be stored for an indefinite period of time until the then-current waste backlog be processed. In contrast, the commercial facility could provide permanent disposal of this waste immediately upon its generation.

Dose Assessment In accordance with DOE O 5400.5, dose assessments were conducted to determine: • Reasonable maximum worker dose during disposal • Reasonable maximum worker dose following disposal • Collective dose to facility workers • Long-term residential dose via ground water protection • Long-term remediation of disposal site Reasonable Maximum Worker Dose during Disposal Disposal workers were considered to be at greatest risk of exposure to radioactive materials during the disposal of the proposed waste stream. Three components of this work scope were identified as potential exposure periods: 1. Waste Transportation – Personnel involved in loading materials into trucks at the DOE site and driving loaded trucks to the disposal facility. 2. Waste Receiving – Personnel involved in receiving waste at the disposal facility, including inspection of the waste manifest, weighing the trucks, sampling and analysis of waste, and transferring the load to a staging area to await disposal. 3. Waste Disposal – Personnel involved in placement of waste in the disposal cell, including transfer from staging area, placement in the disposal cell, and placement of cover material as required by facility operating procedures. Estimated exposure times and characteristics for activities conducted by each of these hypothetical worker categories were derived in consideration of the specific characteristics of the waste stream. All parameter values and assumptions were also selected to be conservative. These parameters were combined with external dose factors developed for each scenario and appropriate internal dose conversion factors for inhalation and ingestion to estimate potential dose to each worker category. In all cases, the estimated annual dose to a hypothetical worker was less than 0.0003 mrem (3.0 E-6 mSv), which is more than five orders of magnitude below the primary DOE dose limit of 100 mrem per yr and far below the limit of 25 mrem (0.25 mSv) per yr specified for release of materials for disposal at an off-site landfill. DOE-HDBK-1215-2014 7-4 Reasonable Maximum Worker Dose following Disposal A hypothetical future worker employed full-time at the landfill facility following closure for site maintenance and surveillance was the basis of this dose assessment. The hypothetical future worker was assumed to spend 8 hours per day at the disposal facility for 250 hours per year in a position directly above the waste. This scenario and resulting dose estimate also represented a disposal worker involved in the placement of subsequent waste materials into the disposal cell during the active operating period of the facility. Under these conservative assumptions, the predicted dose to the future worker was 1 x 10-10 mrem (1 x 10-12 mSv) per year. In the event that a building was constructed over the disposal cell cover system, the potential concentration of radon decay products in indoor air was estimated at less than 2 x 10-7 working level, five orders of magnitude below the applicable limit of 0.02 working level. As indicated by these calculated levels, most potential exposure pathways are significantly restricted or eliminated due to the engineering of the disposal cell. Only external radiation, radon mitigation through the cap and cover system, and exposure to radiation in leachate would be active exposure pathways. Radionuclides of concern in this scenario are relative insoluble and immobile and not expected to be readily leached from the disposal material. As long as the cap and cover system retains its integrity, radiation exposures to any future receptor would be negligible for any future land use.

Collective dose to facility workers The following categories of workers, with varying potential for exposure to residual radioactive materials, were considered in this analysis: 1. Facility Worker/High-Exposure – Hypothetical worker population of 40 persons with high potential for exposure to waste or residual materials. 2. Facility Worker/Medium-Exposure – Hypothetical worker population of 60 persons with moderate potential for exposure to waste or residual materials. 3. Facility Worker/Low-Exposure – Hypothetical worker population of 80 persons with low potential for exposure to waste or residual materials (e.g. clerical workers). Dose assessment for this analysis utilized methodology and assumptions developed within the Complex for evaluating potential collective exposures at generic hazardous waste disposal facilities. Using these default parameters, the collective worker dose is estimated at approximately 2 x 10-5 person-rem during the active disposal operation for this waste stream. Similar methods and parameters were applied to estimate potential dose to the off-site public. The collective dose to this population would be negligibly small, due to the small volume and low radionuclide concentrations in the waste and the non-energetic dispersion mechanisms. Following placement in the disposal facility, there would be no plausible pathway for off-site exposures to the public. DOE-HDBK-1215-2014 7-5 Long-term residential dose via ground water protection For the selected facility, no breakthrough of contaminated groundwater was predicted during the 1,000-year period of analysis. Therefore, no impacts to groundwater were predicted. Even in the unlikely event that all design features and post-closure care requirements for the facility fail, no significant impacts to groundwater would be predicted due to the small volume of the waste stream and the very low concentrations of residual radioactive materials. Long-term remediation of disposal site Since the selected facility is permitted under RCRA and TSCA, closure and post-closure requirements are specified to control, minimize or eliminate the potential for future remediation at the site. The facility has a closure plan and perpetual fund established for future maintenance, monitoring and control of the site, to ensure care is provided. This will ensure that the facility will not be subject to future remediation under DOE Orders or other applicable requirements as a result of the disposal of this waste stream. ALARA Analysis for the Sediment Disposal of the materials at a commercial disposal facility was estimated to cost approximately $14,000 (including transportation and disposal) while disposal at the DOE-owned facility was estimated at $554,000 (not including interim storage costs). The results of this analysis clearly indicated that the disposal of these materials at the commercial facility would be protective of human health and the environment, while providing significant cost savings (approximately $540,000) and immediate disposal capacity for this waste. Evaluating the information readily available, a qualitative decision to select the commercial disposal option was made without having to perform a full quantitative ALARA analysis – further saving time and money. 7.3 Pros and Cons Analysis

A Pros and Cons Analysis is another example of a qualitative comparison method. As the name implies, positive and negative results are identified about each alternative. It requires no mathematical skill and can be implemented rapidly. Lists of the pros and cons, likely based on input from subject matter experts, are compared to one another for each alternative. The alternative with the strongest pros and weakest cons is preferred. A Pros and Cons Analysis is suitable for simple decisions with few alternatives and few discriminating criteria of approximately equal value. The following case study provides a simple example of this type analysis. Problem You must ensure the dose rate in a public area adjacent to a DOE facility is consistent with DOE guidelines. Approach to the problem To ensure public dose limits are consistent with DOE guidelines, you must determine the dose rates in the area adjacent to a DOE facility during routine facility operations. There are a number DOE-HDBK-1215-2014 7-6 of options available to determine the dose rates using resources commonly available at a DOE site. Three suggested options include: 1. Placing Thermoluminescent Dosimeters (TLDs) or Electronic Personnel Dosimeters (EPDs) in common area for 30 days to determine average dose rate in adjacent area; 2. Perform a survey using direct-reading radiation detectors to map the dose rate in the adjacent area; or 3. Use of a modeling code (e.g., Microshield) to estimate the dose rate at any point in the adjacent area. Applying the Pros and Cons Analysis You assemble a group of subject matter experts to provide comments on each alternative. Table 7-1 lists the generated Pros/Cons for each alternative: TABLE 7-1. Pros and Cons TLDs/EPDs Pro Con Easy to perform Delayed results (TLDs) Minimum time to employ Tampering of TLDs/EPDs DOECAP accredited Environmental Issues (e.g. weathering) Longer dwell time Instrumentation Pro Con Easy to perform Can be time intensive Immediate results Snap-shot in time Calibrated equipment Modeling Pro Con Immediate results Can be complex Model uncertainty Subjective Although all three options will provide the required information, a simple comparison of the Pros and Cons for each as they pertain to the particular circumstance will identify the best option to employ. DOE-HDBK-1215-2014 8-1 Chapter 8. SEMI-QUANTITATIVE ALARA ANALYSIS A semi-quantitative analysis is an approach that blends attributes of both qualitative and quantitative approaches. Where quantitative analyses can be both exhaustive and detailed, and typically performed by an outside third party, qualitative approaches lack the accuracy and transparency but usually result in high stakeholder buy-in as the level of involvement in the analysis is greater. A semi-quantitative approach is a mixture of the two. A semi-quantitative analysis attempts to match the thoroughness of a quantitative analysis with some of the simplicity of performing a qualitative analysis. The process is less costly and time- consuming than a quantitative analysis but the primary objectives are achievable at only a moderate loss in detail. A semi-quantitative ALARA analysis may be needed as the estimated doses from the alternative actions begin to approach or exceed the “reference” dose levels (i.e., collective doses between 10 and 100 person-rem per year) as illustrated in Figure 2-1. In addition to these dose levels, a semi-quantitative ALARA analysis, as compared to a quantitative ALARA analysis, is more appropriate when the number, types and complexities of alternative actions are not as substantive.

Five case studies are presented to explain the basis for derived standards applied to specific cleanups. The case study discussions are intended to provide examples of the impacts of cleanup criteria on waste volume, costs, and dose/risk avoided. These examples demonstrate various semi-quantitative evaluation processes used to satisfy ALARA process requirements when selecting Authorized Limits. The benefits or limitations to the approaches also are discussed. The comparisons also demonstrate that some knowledge of projected collective dose is important to the decision-making process. 8.1 Case Study #1: Colonie, New York Authorized limits for this case study were initially developed qualitatively, and post-activity analysis indicates the acceptability of the approach used. This case study demonstrates the importance of realistic assumptions in evaluating the benefits and assessing expected outcome. Site This site was a formerly-licensed (State and U.S. Nuclear Regulatory Commission (NRC)) facility that processed uranium largely for Department of Defense use. The facility operated for some period without functional stack controls. The State ultimately closed the facility, and Congress directed DOE to remediate the plant and residential properties around the plant. Vicinity properties have been remediated. This discussion deals primarily with the vicinity properties remediated in the late 1980s. Basis for Standard The cleanup standard or authorized limit used for cleanups at Colonie, New York, was 35 pCi/g for depleted uranium (U-238). This standard was derived using a process similar to that contained in DOE Order 5400.5, the predecessor to DOE O 458.1. DOE conducted dose DOE-HDBK-1215-2014 8-2 assessments that assumed a residential farmer scenario (a resident gets a significant fraction of food supplied from a home garden) and determined that a 120 pCi/g concentration of depleted uranium could result in a dose of 100 mrem (1 mSv) in a year. Based on a cost evaluation and through meetings with New York State and EPA officials, 35 pCi/g was determined to be an appropriate ALARA-based limit. At the time of the cost analysis, only 12 properties were known to be contaminated and the incremental cost between 35 pCi/g and other alternatives was on the order of a few thousand dollars per property. Therefore, the incremental costs were considered not to be significant. The supporting analysis was qualitative and included no systematic assessment of collective dose or waste volume-cost relationships. The standard ensured that maximum doses to residents would be less than 25 mrem (0.25 mSv) in a year assuming the contamination was uniformly spread over the property. For the most part, actual contamination was concentrated in areas such as near drain spouts, drip lines or run-off areas from pavement. Localized concentrations in these small areas exceed 100 pCi/g. Over 50 properties were cleaned up and many had only small areas of contamination. Results The final cleanup reduced maximum uranium concentrations on the properties to levels between 1.5 and 24 pCi/g. Post-remedial action dose assessments, conducted on the first 47 properties, indicated that the average maximum dose was 1 mrem (0.01 mSv) in a year (an average of the doses to the MEI from each of the properties evaluated). The maximum dose for any single property was 3.3 mrem (3.3 E-2 mSv) in a year. This dose is less than 15% of the dose used to select the authorized limits for uranium at this site.9

These dose estimates are generally conservative in that they are calculated assuming dose over the entire time period was equivalent to the dose at the time of maximum dose rate, and assume a significant portion of the resident’s diet is obtained from home gardening. In fact, the food grown may exceed the quantity that can be produced on the lots, although this is a minor contributor to dose, assuming a reasonably conservative mass loading factor used for inhalation (a major contributor to dose), likely overestimation of dose, and assuming that the residential scenario applied for all dose estimates, despite the fact that some properties were commercial or open areas. Doses from U-234 were not estimated; however, the site was contaminated with depleted uranium that is primarily U-238 and the contribution to dose from U-234 is expected to be low. Likewise, Ra-226 will eventually result from ingrowth; however, over the 1,000-year period evaluated, the contribution is insignificant. Table 8-1 presents a summary of the pre-remedial action doses, the post-remedial action doses, and the dose reduction resulting from the remedial action (Figure 8-1 presents pre- and post- remedial action doses by property). Pre-remedial action doses for these properties ranged from about 1 mrem (0.01 mSv) per year to less than 15 mrem (0.15 mSv) per year. In other words, although the generic dose assessment used to develop the standard assumed that the potential 9 This is not an uncommon situation – due to the field application of the ALARA principles and the precautions taken to account for uncertainties in field radioanalytical methods and excavation techniques, post-remedial levels actually achieved routinely surpass the authorized limit. However, this decrease cannot be predicted in advance and efforts to lower pre-remedial action limits to account for this phenomenon will likely cause significant increases in waste volume, costs and impact schedules. DOE-HDBK-1215-2014 8-3 dose on the contaminated properties could be as high as 25 mrem (0.25 mSv) in a year, given the actual use of the properties, the distribution of radionuclides, and the site-specific parameters, none of the 47 properties studied were likely to approach that dose even prior to remedial action.10 Annual individual risk of cancer, given residential use of the subject property, was reduced from 2x10-6 to 5x10-7. Assuming individuals spend 30 years at a property (EPA data suggest that most individuals spend, on average, seven years at a given property and 95% of the population spends less than 30 years at a given property), the lifetime incremental risk of fatal cancer was reduced from 6x10-5 to 1x10-5 (6 in 100,000 to 1 in 100,000). Assuming an average of four persons per household, collective doses for pre-remedial action conditions, post-remedial action conditions, and collective dose avoided by the action were estimated for 1 year, 50 years, and 200 years. Table 8-1 presents these doses. The estimated collective dose avoided over the 200-year period was 30 person-rem. At a cost of about $200,000 for vicinity property cleanup, this equates to about $6,700 per person-rem avoided, which is consistent with the upper end of the DOE recommended range of values for the monetary values for collective dose. The total number of health effects avoided, over a 200-year period, by these remedial actions is calculated to be 0.02 (this is effectively no cancers). The estimated cost per health effect averted for the project is about $10,000,000.

Authorized limits used for this remedial action were established at a concentration that provides assurance that doses would be less than 25 mrem (0.25 mSv) in a year. However, in this situation, it was developed using the worse plausible use scenario as the expected use scenario. Data from this site also demonstrate the importance of using dose estimates that are as realistic as possible in developing authorized limits. The results of modeling pre- and post-remedial action doses shows that the most conservative scenario and qualitative analysis used to derive the 25 mrem (0.25 mSv) per year-based authorized limits significantly overestimated actual doses. TABLE 8-1. Colonie, New York, Summary of Dose, Collective Dose, and Risk Averted Pre-Cleanup Post-Clean Reduction (Risk or Dose Averted) Average Maximum Individual Dose 4.2 mrem/y 1.0 mrem/y 3.2 mrem/y Hypothetical Annual Risk (cancer) 2 in 1,000,000 5 in 10,000,000 2 in 1,000,000 Hypothetical Lifetime Risk (30 yrs exposure) 6 in 100,000 1 in 100,000 5 in 100,000 Collective Integration time Person-rem Person-rem Person-rem Hypothetical Cancers Averted Annual 0.2 0.05 0.2 0.00008 50 year period 10 2 8 0.004 200 year period 40 10 30 0.02 10 Conservative assumptions routinely result in over-estimates of dose. Generic modeling conducted (in the early 1980s) to develop dose-based authorized limits for remediation of this site produced doses that were greater than those that were more firmly based on more site-specific data. DOE-HDBK-1215-2014 8-4 12 m 11 Residual Reduction r e m / y e a r 10 9 8 7 6 5 4 3 2 1 0 Properties FIGURE 8-1. Estimated Doses (Total Pre-cleanup, Residual and Reduction) by Property 8.2 Case Study #2: Elza Gate Site, Tennessee This is an example of applying the ALARA process to a small area with modest soil contamination. Authorized Limits for uranium were established based on a semi-quantitative evaluation using waste volume as a surrogate for costs. The selection of the ALARA-based authorized limit was made on the basis of cost-effectiveness rather than cost-benefit. The analysis also suggests that Authorized Limits developed separately for various radionuclides, when used together, likely will result in more dose reduction than projected. Site This site was a former storage site for waste and contaminated material. It was remediated and released to standards in effect in the 1970s. The property is now an industrial park that includes about 20 acres. The primary radionuclides of concern were Ra-226, Th-230, and U-238. The 5 pCi/g surface and 15 pCi/g subsurface criteria were used for Ra-226 and Th-230 based on a qualitative ALARA assessment because levels were not unlike the Uranium Mill Tailings Remedial Action (UMTRA) vicinity properties. A standard for uranium was derived using the DOE ALARA process. Basis for Uranium Standard The authorized limits for cleanup at Elza Gate were 35 pCi/g for U-238 and 5 pCi/g surface and 15 pci/g subsurface for the combined activities of Ra-226 and Th-230 isotopes. The uranium standard was developed independent of the radium11 standard. A dose assessment was completed for several scenarios, and a uranium concentration that would meet a dose limit of

11 The radium/thorium and uranium standards are not truly independent of each other. Selection of a lower or higher radium standard, for example, could impact the residual uranium levels and vice versa. In many cases, the standard development process deals with all radionuclides at once. However, because radium is treated separately in DOE standards (as low as reasonably achievable below the concentration limit) and all other radionuclides are dose-based (plus ALARA requirements), development is typically done separately, and dose analyses integrate the doses later. DOE-HDBK-1215-2014 8-5 100 mrem (1.0 mSv) in a year was calculated for each. The results are presented in Table 8-2. It was conservatively assumed that residual dose associated with cleanups to lower concentrations would be linearly related. This assumption ignores the benefits associated with additional clean fill necessary to replace the contaminated soil that was removed. Analysis of the relationship of the authorized limit (soil concentration of U-238) to volume of waste (a surrogate for cost) was completed (see Figure 8-2). This shows costs began to increase dramatically between concentrations of 30 and 40 pCi/g U-238. The estimated individual dose in this concentration range for the likely use of the site was about 4 mrem (0.04 mSv) in a year, which conforms with DOE guidance to remain well below the DOE constraint of 25 mrem (0.25 mSv) in a year. The worst-case future use scenario dose was about 15 mrem (0.15 mSv) in a year, well below the 100 mrem (1.0 mSv) in a year dose limit for all sources. A cleanup standard Authorized Limit of 35 pCi/g was selected for U-238 (about 70 pCi/g total uranium). TABLE 8-2. Uranium Concentrations representing 100 mrem/yr for Several Scenarios and Uranium Concentrations Industrial use (current and likely use) (if U-238 used as an indicator for measurement) - 1800 pCi/g (Uranium) - 880 pCi/g (U-238) Recreational use (U-238 as indicator) - 4000 pCi/g (Uranium) - 2000 pCi/g (U-238) Residential use12 (worst-case use) (U-238 as indicator) - 470 pCi/g (Uranium) - 230 pCi/g (U-238) 50000 40000 30000 20000 10000 0 0 20 40 60 80 100 120 Uranium‐238 Cleanup Guideline (pCi/gm) FIGURE 8-2. Elza Gate: Waste Volume vs. Uranium Concentration 12 Another residential scenario that was evaluated was rejected because the groundwater pathway was inappropriate [that is, inappropriate assumptions and parameters]. Even for the residential scenario results that were reported here, unrealistic assumptions were used for water use – it was assumed that an on-site pond provided drinking water and irrigation water despite the fact that the site is adjacent to a river and has a relatively steep slope. Volum e (cubic yards) DOE-HDBK-1215-2014 8-6 Results Table 8-3 presents pre- and post-remedial action concentrations (in pCi/g). Post-remedial action doses were estimated for the site using the Net Average residual concentrations of the above radionuclides and estimating U-234 &U-235 (and decay products) as a standard ratio to U-238. TABLE 8-3. Elza Gate, Tennessee, Site Pre- and Post-remedial Action Concentrations Pre-remedial Action Concentrations Radionuclide Measured (pCi/g) Average Background (pCi/g) Average Net (pCi/g) U-238* 146 1.0 145 Ra-226 8.9 1.3 7.6 Th-232 1.9 1.5 N/A Th-230 59 1.0 58 Post-remedial Action Concentrations Radionuclide Measured (pCi/g) Average Background (pCi/g) Average Net

(pCi/g) U-238* 5.9 1.0 4.9 Ra-226 1.0 1.3 N/A Th-232 1.3 1.5 N/A Th-230 2.5 1.0 1.5 * U-235 and U-234 were estimated on the basis of U-238 concentrations. The most likely use for this site will be industrial. Estimated dose for the maximum individual is shown in Table 8-4 and estimated dose for the individual risk is shown in Table 8-5. TABLE 8-4. Estimated Dose for the Maximum Individual Post-remedial Use Maximum Individual Dose Notes Industrial 1.5 mrem/yr less than 40% of the modeled dose13 Most likely use Recreational <1 mrem/yr Residential farmer 12 mrem/yr using an on-site pond for drinking water and irrigation14 TABLE 8-5. Estimated Dose for Individual Risk Post-remedial Use Potential Risk Factor Notes Industrial 7.5x10-7 Annually Industrial 2x10-5 (2 in 100,000) Lifetime, assuming 25 years working at the site Residential farmer 2x10-4 (2 in 10,000) Lifetime 13 Due to in-field ALARA applications and the uncertainties in radioanalytical methods and excavation techniques, post-remedial levels achieved routinely surpass the authorized limit for a site. However, because this reduction is highly dependent on field conditions, it cannot be predicted and pre-remedial action designation of this reduction as a specific goal would be likely to significantly increase volumes of waste. 14 An extremely unlikely assumption due to the slope and proximity to river. DOE-HDBK-1215-2014 8-7 Assuming a 20-acre industrial site could maintain a work force of 150 persons, the collective dose and estimated number of associated cancers for 1, 25, 50, and 200 years for continued use of the site under pre- and post-remedial action conditions were estimated and are presented in Table 8-6. TABLE 8-6. Elza Gate Site, Tennessee, Pre- and Post-remedial Action Conditions for Industrial Scenario INDUSTRIAL SCENARIO ANALYSIS Years Integrated Pre-remedial Action Collective Dose (person-rem) Estimated Cancers (fatal) 1 11 0.006 25 290 0.2 50 590 0.3 200 2340 1.2 Years Integrated Post-remedial Action Collective Dose (person-rem) Estimated Cancers (fatal) Collective Dose Averted (person-rem) Cancers Averted 1 0.2 0.0001 11 0.006 25 5 0.003 285 0.2 50 10 0.006 580 0.3 200 40 0.02 2300 1.2 Based on current use of the site (industrial/commercial) and assuming pre-remedial radiological conditions, dose to the reasonable MEI at the site was estimated to be about 78 mrem (0.78 mSv) in a year. An individual working at the facility and receiving this dose for 25 years would incur a potential incremental lifetime individual risk of about 1 in 1000 (about 1x10-3). It is highly unlikely that any individual would actually receive this dose for 25 years. Similarly, given the spotty and localized nature of the contaminant, it is highly unlikely, if not impossible, that a large number of the employees would be exposed to this dose; however, for the purposes of assessing collective dose, it was assumed that all 150 workers were exposed to this dose. The total cost of this remedial action was about $5,000,000. The cost per person-rem averted for this project is $2,200 ($5,000,000/2340 person-rem) for 200 years of operation and $18,000 ($5,000,000/290 person-rem) for the 25-year period. This equates to about $4,200,000 per potential cancer averted ($5,000,000/1.2 fatal cancers) over the 200 year integration period. This assessment ignores risks associated with worker dose and fatal accidents that would be expected to be less than 1. There were no fatal accidents on this project.

To illustrate the relationship between dose criteria and cost/benefit, consider Figure 8-2 that shows waste volume to uranium concentration relationships. It is apparent that increasing the uranium limit from 35 to 80 pCi/g would have decreased waste volume by less than 10% and would result in little cost savings. However, decreasing the authorized limit from 35 to 20 pCi/g would produce a 2.4 times increase in volume of the waste and a corresponding increase in costs. The collective dose reduction for this additional remedial action would be on the order of 17 person-rems over 200 years. This incremental action would have resulted in a cost per person- rem avoided on the order of $400,000 per person-rem (about $800,000,000 per fatal cancer averted) compared to the $2,200 per person-rem for the entire project. This indicates that more extensive remedial actions would not be reasonable. DOE-HDBK-1215-2014 8-8 8.3 Case Study #3: Maywood, New Jersey This case study represents a reasonable semi-quantitative assessment, although data to support volume estimates for the lower concentration alternatives were limited, producing significant uncertainty in the cost estimates at these levels. In addition to this semi-quantitative analysis, which used conservative but reasonable scenarios for exposure under all conditions, the results of a second analysis which used reasonable assumptions for the no-action option and worst-case exposure assumptions for cleanup alternatives are discussed. This comparison demonstrates the importance of using best-estimate scenarios for semi-quantitative evaluations. Mixing reasonable and worse-case assumptions can bias the results. Site This site includes a former thorium processing site and vicinity properties that contain residual radioactive material derived from the site. The site processed thorium and rare earth ores primarily for commercial uses. Many of the most contaminated properties have been remediated. This discussion addresses remedial action at the remainder of the vicinity properties and the site proper. Details on previous vicinity property cleanup are contained in the DOE certification docket for the Maywood remedial actions. The primary contaminant of concern is Th-232. Radionuclides present in lesser amounts include U-238, U-234 and Ra-226. The site is located in an industrial area and the vicinity properties include primarily neighboring residences. The site has since been remediated by DOE, transferred to the Army Corp of Engineers, and is on the CERCLA national priority list (NPL). Basis for Standards The cleanup criterion used for the action was the DOE Order 5400.5 guidelines for radium and thorium, that is to reduce the concentrations to levels at or below 5 pCi/g for the surface and 15 pCi/g for the subsurface radionuclides based on the ALARA process. At the time of the analysis, the project was in the “feasibility study” phase and DOE was working with EPA to develop the final remediation goals. Table 8-7 provides project costs, doses, and collective doses integrated over 200 years associated with no action and various cleanup goals (all of the alternatives except no action assume that post-remedial action concentrations on the soil surface are 5 pCi/g with the ratio of Th-232 and its progeny being four times the concentration of Ra-226 and its progeny). On the basis of these data, cost per dose and cost per cancer averted can be estimated.

As indicated in Table 8-7, the baseline costs for this project (indicated as the “No Action” alternative), cost $16M. Decontamination of these properties to 30 pCi/g will reduce collective doses by 11,000 person-rem at an additional cost of $61M (total of $77M). The incremental reduction to 15 pCi/g will avert an additional 440 person-rem and cost an additional $61M (total of $138M). Remediating to 5 pCi/g will avert an additional 280 person-rem in addition to that averted by the 15 pCi/g limit and cost between $30M and $120M15 additional (total between $168M and $258M). The incremental costs per person-rem avoided under each alternative 15 The cost of the 5 pCi/g alternative is uncertain because measurement on these radionuclides is sufficiently near to background that the actual volume of waste to be removed cannot be adequately defined with normal survey data. DOE-HDBK-1215-2014 8-9 cleanup level are $5,500, $140,000 and $110,000 to $430,000 for the 30 pCi/g, 15 pCi/g and 5 pCi/g cleanup alternatives. (See Table 8-7.) This equates to about $9M per hypothetical fatal cancer avoided at the 30 pCi/g level, $230M per hypothetical cancer averted for the 30 to 15 pCi/g increment, and between $180M and $270M for 15 to 5 pCi/g increment. TABLE 8-7. Predicted Costs, Radiation Doses, and Collective Doses for Various Criteria at Maywood, New Jersey Alternative Remedial Action Criteria Total Project Costa($M) Residual Dose to Exposed Individual (mrem/yr) Residual Collective Dose (person- rem) for 200 yearsb Remediation Worker Collective Dose (person- rem) No action 16 12-2800 12,000 — 30 pCi/g 77 3.6 (Resc) 8.2 (Comd) 880 18 15 pCi/g 138 1.8 (Res) 4.1 (com) 440 24 5 pCi/g 168 to 258 0.6 (Res) 1.4 (Com) 160 30 a. Detailed cost analysis is presented in the Feasibility Study for the No-Action alternative and Phased Action with 15 pCi/g subsurface criterion. The costs for 20 pCi/g and 5 pCi/g alternatives were scaled with the estimated change in waste volume. The waste volume for the 30 pCi/g criterion was estimated to be 56% of the waste from the 15 pCi/g alternative. The 5 pCi/g alternative was estimated to increase waste volume by 20 to 30%. The No Action alternative assumes continued environmental monitoring ($480,000 per year) and 5-year remedy reviews ($200,000 each) for 30 years. b. An integration period of 200 years is assumed in the estimate of collective dose from exposure to residual radioactive material (evaluations beyond this time would require assessments of waste disposal alternatives and associated collective doses); implementation times for remedial action workers were assumed to be 9, 12, and 15 years for the 36, 15, and 5 pCi/g alternatives, respectively. c. Estimated for expected conditions following remediation at residual properties (current use). d. Estimated for expected conditions following remediation at commercial/industrial properties (current use). As in the other examples, risks associated with the remedial actions had not been taken into account in the results stated above. Table 8-8 presents the risks of fatal accidents for remediation workers due to the transport of the waste as well as the risk averted in the analysis above. The incremental worker accident risk increases as expected with greater remediation volumes. The transportation related risks are insignificant at the 30 pCi/g criteria and lowering the criteria is shown to only result in minimal incremental increases to this risk. Depending on the volume of wastes resulting from the last increment (15 pCi/g to 5 pCi/g), the impact of the transportation and worker risks could range from that of reducing the benefits (0.14 cancers averted over the 200 years) by only a few percent to that of generating more risk than is averted by the incremental cleanup level.

DOE-HDBK-1215-2014 8-10 TABLE 8-8. Comparison of Risk Averted to Worker and Transportation Risk at Maywood, New Jersey Remedial Action Criteria Incremental Transportation Accident Riska (fatalities) Incremental Remediation Worker Accident Risk (fatalities) Incremental Excess Fatal Cancers due to Remediation Worker Exposureb Incremental Cancers Averted by Remedial Action to Criteria No action — — — — 30 pCi/g 0.004 rail 0.1 truck 0.005 0.009 5.5 15 pCi/g 0.002 rail <0.1 truck 0.009 0.003 0.22 5 pCi/g 0.002-0.003 rail <0.2 truck 0.001 — 0.01 0.003 0.14 a. Transportation risks include the risks associated with transport of the waste from the site to a commercial disposal site by rail, and transportation of borrow soil from an off-site borrow area to the site. (Risk associated with disposal or management of the waste at the disposal site are not included.) Both waste volume and borrow soil volume requirements are assumed to be proportional to the estimates of soil requiring excavation under each criterion. b. Fatal Cancers were estimated by multiplying the collective dose (person-rem) by a risk factor of 500 cancers per million person-rem. a factor of 600 cancers per one million person-rem was used for members of the public (that is, residential use scenarios). The data above are based on the Department’s assessment of the site and environs “expected conditions.” It considers likely use of the properties and takes credit for soil cover and shielding. In the Department’s negotiations with EPA to establish cleanup criteria for this phase of the Maywood project, EPA proposed that the analysis be conducted for the worst-case scenario and giving no credit for soil cover. Table 8-9 presents the average individual dose for residential and industrial/commercial uses and residual and averted collective doses for the worst-case scenario. The 30 pCi/g alternative was not assessed for the EPA scenario. For the EPA scenario, the cost per person-rem for the 15 pCi/g alternative was estimated to be between $24,000 and $55,000 per person-rem averted. This equates to between $41,000,000 and $92,000,000 per hypothetical cancer avoided.) Similar estimates for the 15 pCi/g to 5 pCi/g increment indicated that this additional cleanup would cost between $5,000 and $26,000 per person-rem averted (between $7,500,000 and $43,000,000 per hypothetical risk of fatal cancers). The decrease in the cost for collective dose (for health effects) between the 15 pCi/g criteria and the incremental reduction to 5 pCi/g may be an artifact of the assumptions. Under the scenarios used in the EPA estimates, material that was buried and not available to expose the public under the “No Action” alternative was assumed to be at the surface in the 15 pCi/g scenario despite the fact that it would be covered in that scenario as well. This artificially reduces the effectiveness of the first increment (that is, it compares a realistic no-action alternative scenario to a conservative scenario for the remedial action). It is extremely difficult to compare alternatives under such conditions and demonstrates the importance of using scenarios that are similar for all alternatives. DOE-HDBK-1215-2014 8-11 TABLE 8-9. Predicted Post-cleanup Dose, Collective Dose, and Collective Dose Averted by Criteria (Worst-case Exposure Assumptions for Cleanup Alternatives) Remedial Action Criteria Residual Individual Dose (mrem/year) Residual Collective Dose (person-rem)

Collective Dose Averted (hypothetical Cancers averted) 15 pCi/g 122 (Resa) 66 (Comb) 189 (Futurec) 9,800 7,000d 2,200 person-rem 5,000 person-rem (1.1 cancers) (2.5 cancers) 5 pCi/g 40 (Res) 22 (Com) 61 (Future) 3,200 2,400 8,200 person-rem 4,600 person-rem (4.1 cancers) (2.3 cancers) a. Estimate for worst-case conditions following remediation of residential properties. b. Estimate for worst-case conditions following remediation of commercial/industrial properties, assuming continued commercial/industrial use. c. Estimate for worst-case conditions following remediation of commercial/industrial properties, assuming residential use. d. Assumes all properties are residual in the future. In any case, the comparison of these two analyses (expected scenario analysis and worst-case analysis) demonstrates the need to clearly define the process for selecting comparable scenarios. Although in both analyses the cost per dose or health effect averted is relatively high, the use of one or the other of these analyses could very easily result in the selection of different cleanup criteria. It is critical that risk or dose assessments used in these types of comparisons represent the best estimates of expected risk that can be calculated. Bounding assessments can be of value when considering the uncertainty of best estimates. Although, if time and resources permit, a probabilistic risk assessment would be preferable for estimating uncertainty, because bounding estimates developed to quantify 95th percentile risks can significantly overestimate the risks. In general, worst-case scenarios should only be applied for screening purposes, and never in relative risk comparisons. They are prone to biasing the results in a manner that is not readily detectable and are difficult to compare to competing non-health risks or actuarial risks that are normally “best estimates.” This example also illustrates another important factor related to the need to define the process for selecting the comparative scenarios and evaluating the alternatives. Under the expected use scenario (as defined in the DOE analysis) all remediation criteria alternatives (30 pCi/g, 15 pCi/g, and 5 pCi/g) achieve the dose limit and constraints, and the 5 pCi/g criteria achieves the goal of a few mrem per year, or less, (although at great cost per person-rem averted). However, in the conservative assumptions (See Table 8-9), none of the alternatives are projected to achieve the “few mrem/y” goal. The waste volume data for the 5 pCi/g criteria are very uncertain because of the difficulty in adequately characterizing radium and thorium at these low concentrations. If the concentration limit was reduced by one third or one fourth to ensure compliance with a 15 mrem (0.15 mSv) per year limit (under the worst-case scenario) survey costs and remedial action costs would be further increased, not only as a function of waste volume, but also as a result of added survey costs, extensions of schedules to await verification of compliance from laboratory analyses, and possibly extra excavation to ensure compliance. DOE-HDBK-1215-2014 8-12 Although not considered in these analyses, it is not clear that some of these factors would not affect the cleanup costs under the 5 pCi/g criteria. This scenario illustrates the importance of communicating the results of an ALARA analysis with responsible parties (e.g. EPA) in determining final remediation goals. 8.4 Case Study #4: Ventron, Massachusetts

This case study represents another situation employing a semi-quantitative approach. However, it is a situation where a land use scenario other than industrial/commercial or suburban residential is the likely use. This is a good example of unrealistic and conservative exposure scenarios and assumptions used in many guidelines’ development efforts. The Ventron Site is a 3-acre site in a heavily developed area that directly abuts Massachusetts Bay (actually the mouth of the Danvers River) on two sides. The resident-farmer scenario was still evaluated assuming 100% of the milk/meat/fish and 50% of the produce was produced on site. These are extremely conservative assumptions. Site The former Metal Hydrides site in Beverly, Massachusetts, processed uranium compounds and scrap to produce uranium for the Manhattan Engineering District (MED) and Atomic Energy Commission (AEC). Operations contaminated portions of the buildings and grounds on site plus some of the properties around the site. The 3-acre site presently is used for industrial applications. Basis for Standard The authorized limit for cleanup of this site was developed consistent with DOE 5400.5 requirements and guidance. An assessment of potential doses was completed for industrial use, recreational use, and the resident farmer scenario. The analysis indicated that the 100 mrem (1.0 mSv) in a year dose limit would not be exceeded if total uranium concentrations were less than 1,800 pCi/g, 3,100 pCi/g, and 480 pCi/g for the industrial, recreational, and farmer scenarios, respectively. To select an authorized limit that was as far below the derived 100 mrem (1.0 mSv) in a year equivalent concentration guideline values as is reasonably achievable, an analysis of the relationship between concentration and waste volume (a surrogate for cost) was performed. This analysis indicated that waste volumes (and costs) generally were constant to about 60 pCi/g of U-238 (120 pCi/g total uranium). On this basis, an authorized limit of 100 pCi/g total uranium (about 48 pCi/g U-238 and U-234, and 4 pCi/g U-235) was approved. This limit would ensure that doses under the expected use of the property would be less than 5.5 mrem (5.5 E-2 mSv) in a year to the MEI or representative person of the critical group. Lifetime risk of a fatal cancer for a worker continuously exposed (for 25 years) to this dose would be about 7x10-5 (7 in 100,000). If the site were to continue to be operated as an industrial facility, residual collective dose would be less than 0.2 person-rem per year or about 8 person-rem and 33 person-rem integrated over 50 and 200 years, respectively. This assumes that the facility employed 30 persons for the entire integration period and all persons receive the 5.5 mrem (5.5 E-2 mSv) per year estimated for the MEI or representative person of the critical group. Assuming a linear no threshold relationship DOE-HDBK-1215-2014 8-13 between dose and health effects, the residual radioactive material on site after the cleanup would result in no radiation-induced cancers. The projected potential is 0.02 fatal cancers, or effectively zero, over 200 years of operation. However, it is expected that post-remedial action concentrations of uranium will be below the approved authorized limit and hence, potential doses and associated risks will be lower as well.

In the unlikely event that the site is used in a manner similar to the conditions set forth for the resident-farmer scenario, the maximum dose would be less than 21 mrem (0.21 mSv) in a year. This represents a 3x10-4 lifetime risk of cancer. Continuous exposure to such a dose (assuming the site could support six persons under the resident-farmer scenario) would produce a maximum collective dose of 0.1 person-rem/year or an integrated dose of about 25 person-rems over 200 years. Assuming the linear relationship between collective dose and health effects, 0.01 cancers over 200 years may be calculated. A more likely potential use for the site is a condominium complex, which is not unusual for this type of property in this region. Given a 3-acre lot, assuming a maximum of about 15 dwellings per acre and four residents per unit, the area could house a maximum of about 180 individuals. A reasonably conservative dose assessment indicates that the maximum dose to individuals living on the first floor of a condominium would be about 9 mrem (0.09 mSv) per year (individual lifetime cancer risk about 1.5 in 10,000) and for higher floors about 1.5 mrem (0.015 mSv) per year (individual risk of about 1.5 in 100,000) assuming the 3 acres were uniformly contaminated to 100 pCi/g total uranium (a very conservative assumption as average concentrations following cleanup are normally many times less than the standard). The annual collective dose would be 0.07 person-rem. Integration over a 200 year period would indicate less than 11 person-rem (hypothetical 0.06 fatal cancers in 200 years). Summary Table 8-10 presents the summary of collective doses from the various scenarios. This analysis was prepared prior to completion of remedial action; however, preliminary engineering estimates at the proposed uranium criteria indicated the cost of the project would be on the order of $20,000,000. This cost includes building remedial action and renovation as well as soil cleanup. As noted above, it was anticipated that residual levels of uranium at the site would be below those used in the dose assessments reported above and hence, the actual potential doses and associated risks also would be lower. TABLE 8-10. Ventron, Massachusetts, Exposure Scenario Collective Dose Analyses Years Residual Collective Dose person-rem Residual Risk Total Potential Cancers Industrial Use Scenario 25 200 4 33 0.002 0.02 Residential Farmer Use Scenario 25 200 3 25 0.002 0.01 Condominium Complex 25 200 18 144 0.009 0.07 DOE-HDBK-1215-2014 8-14 For the two likely use scenarios (Condominium and Industrial) evaluated, remedial action to the authorized limit is expected to reduce doses well below the dose constraint. If the residential- farmer scenario were assumed (the worst plausible use) the selected authorized limit is well below the primary dose limit. Table 8-11 reflects the impact of additional remedial measures implemented to reduce the potential maximum dose for the residential scenario. TABLE 8-11. Impact of Additional Remedial Measures – Residential Scenario Projected Dose Under Residential Scenario Uranium Criteria for Remedial Action Increase in Waste Volume Additional cost* 21 mrem/yr 100 pCi/g (48 pCi/g U-238) 15 mrem/yr 70 pCi/g (35 pCi/g U-238) 1,550 cubic yards (Figure 8-3) $530,000 *assuming $220/cu.yd. for disposal and $120/cu.yd. for transportation If the same reductions were taken for each of the likely use scenarios, Table 8-12 shows exposure reductions that would be anticipated (over the 200-year integration period).

TABLE 8-12. Anticipated Exposure Reductions Post-remedial Use Person-rem Reduction Cost per Person-rem Avoided Industrial 10 $53,000 Residential farmer 7 $76,000 Condominium 42 $12,000 This is equivalent to a cost per fatal cancer avoided of between $27,000,000 and $130,000,000, suggesting that the use of the semi-quantitative process employed to establish the authorized limit resulted in a decision that was reasonable. Further reduction of the authorized limit could not be justified solely on the basis of health considerations. However, a clear drawback of this semi-quantitative “cost-effectiveness-type” of process using waste volume and concentration as surrogates for cost and dose, respectively, is that there is no easy way to assess overall benefit between no action and alternative cleanup levels. DOE-HDBK-1215-2014 8-15 2 6 10 14 18 22 ‐ FIGURE 8-3. Alternative Concentration Limits vs. Estimated Waste Volume 8.5 Case Study #5: Weldon Spring Site, Missouri The Weldon Spring remediation was based on an application of the ALARA process and the CERCLA process. It is a large site containing a large industrial complex for processing uranium. The uranium contamination distribution in soil, buildings, and quarry varies widely and the remediation decisions included radiological and non-radiological considerations. Standard Approved Ra-226, Ra-228, Th-230, Th-232, and daughters in soil (0-60 cm) 5 pCi/g. U-238 in soil 30 pCi/g (natural U). Site This 226-acre AEC site (now DOE) was originally part of 17,000 acres of land acquired by the U.S. Army to construct an ordnance works. Uranium and thorium ore concentrates were processed from 1957 to 1966. Many buildings were constructed to house the processing equipment. Waste streams, including raffinates from the refinery and washed slag from the uranium recovery process, were piped to the raffinate pits and the decanted liquids were drained through sewers to the Missouri River via a 2.4-km natural drainage channel. The site contamination was extremely non-homogeneous, with a few highly concentrated areas that 15 14 13 12 W 11 S T E V O L U M E 10 9 8 7 6 5 4 3 2 1 0 T h o u s a n d s U‐238 pCi/g Cubic Yards c u b i c 10 20 35 50 100 230 13800 10800 6700 5150 4070 2370 y a r d s 0 20 40 60 80 100 120 140 160 180 200 220 240 Concentration (pCi/gram) DOE-HDBK-1215-2014 8-16 extend to a depth of a few tens of centimeters and the bulk of the soil area relatively lightly contaminated on the surface only. The sludge, in four raffinate pits and two ponds, was highly contaminated but confined. Contaminated surface water runoff was contained in a quarry. Table 8-13 presents the estimated volume of contaminated media. Basis for Standard The site was cleaned in compliance with CERCLA and NEPA. The standard was derived in 1991, using a site-specific process similar to that required by DOE Order 5400.5. Contaminated debris from buildings and equipment constitute the bulk of the volume (and cost) disposed and the soil, regardless of the level selected, comprised a relatively small fraction of the total. When the contamination is highly concentrated in the hot spots, there is relatively little difference in the volume of soil that has to be removed to reduce the residual contamination to a small fraction of the initial concentration. Hence, relatively more restrictive cleanup standards could be justified in this case through ALARA considerations. Nevertheless, the lifetime hypothetical risks could not be reduced to the EPA “target” range of 10-6 to 10-4, due to exposures to radon. A dose limit of 25 mrem (0.25 mSv) per year, which EPA has used for several source-specific regulations including management of U and Th by-product material, also was considered but could not be achieved for the residential site-specific scenario in all site locations.

Cleanup targets for radium and thorium (Ra-226, Ra-228, Th-230, and Th-232) concentrations in surface soil of 6.2 pCi/g (background is 1.2 pCi/g) and 16.2 pCi/g in subsurface soil were considered. Table 8-14 shows the relationship of target U-238 concentrations in soil to cost and dose. An ALARA goal of 5 pCi/g was selected for Ra-226, Ra-228, Th-230, Th-232, and daughters in soil at all depths, including background, because it is the lowest concentration that can be reasonably achieved without excavating significant quantities of clean soils and without incurring costs that are disproportionately high for the corresponding risk reduction. (The cost for excavation and disposal of soil is $55/yd3.) The EPA acceptable indoor radon level of 4 pCi/L was considered. The average U-238 concentration in soil was 190 pCi/g. The calculated annual dose to a farmer in the ash pond area is 42 mrem (0.42 mSv) per year, which represents a risk of 3 x 10-5/y. Doses were calculated for concentrations in soil of 120, 60, 30, and 15 pCi/g for U-238. Removal of contaminated soil and backfill with clean soil would reduce and delay the dose after remediation due to shielding and erosion. For uranium, a soil cleanup target of 120 pCi/g without backfill (that would yield a calculated dose of 25 mrem (0.25 mSv) per year) was selected, with an ALARA goal of 30 pCi/g. Table 8-14 shows that there is little incremental risk reduction associated with the significant cost increases beyond the proposed action level. Results The primary cleanup effort to date has been directed toward remediating buildings and equipment – the most expensive part of remediation. A water treatment facility was planned for decontaminating the water from the quarry prior to disposal in the river. The site is adjacent to a large recreational area and that is the most likely use for the property after remediation. The potential doses to persons who may use the site for a variety of purposes, including rangers, visitors, recreational, residential, farming, and intruders, were estimated. It is anticipated that the DOE-HDBK-1215-2014 8-17 ALARA goals for concentrations in soil will be achieved. The incremental radiological risk to a resident would range from 0 to 6 x 10-3 with a median of 8 x 10-6 across the site. Background for radium in soil is 1.2 pCi/g and a small increment of 0.075 pCi/g corresponds to a risk of 1 x 10-4. This reflects the difficulty in achieving either the target risk range or annual dose limit of 25 mrem (0.25 mSv) for residential scenarios for the areas of high contamination. However, the EPA acceptable indoor radon level of 4 pCi/L is likely to be met at all site locations. Dose projections for the site have focused on individual doses at various locations and times and not on collective doses to the population. State and EPA personnel have been involved with the proposed site cleanup plan. TABLE 8-13. Volume of Contaminated Media at Weldon Spring, Missouri Media Volume (yd3) Sludge 220,000 Sediment 119,800 Soil 339,000 Structural Material 169,600 Process Chemicals 3,960 Vegetation 30,650 Total 883,000 TABLE 8-14. Relationship of Target U-238 Concentrations in Soil to Cost and Dose at Weldon Spring, Missouri Concentration pCi U-238/g. Volume yd3 Backfill ft. Cost $M Annual dose Mrem >120 — 0.5 — 20 @ 400 y 120 11,000 0 0.58 25 @ present 60 26,000 1.0 1.4 6.7 @ 800 y 30 — 2.0 — 1.5 @ 10,000y 30 37,000 0 2.0 6.7 @ present 15 50,000 2.0 3.0 8.38 @ 10,000y

DOE-HDBK-1215-2014 9-1 Chapter 9. QUANTITATIVE ALARA ANALYSIS As discussed in Chapter 4, a quantitative ALARA analysis generally requires the most effort and includes the following major steps: • Identify and quantify the sources of radiation; • Identify and define candidate radiation protection alternatives or systems (including waste stream treatment) that would reduce the exposure or doses; • Quantify economic factors (cost of systems, operations, maintenance, etc.); • Quantify exposures and doses to individuals and to populations in the vicinity of the DOE activity; • Estimate the health risk and identify non-health detriments (or benefits); and • Select one of the candidate radiation protection systems as ALARA. Quantitative cost-benefit optimization methods are discussed in ICRP Publication 37, Cost- Benefit Analysis in Optimization of Radiation Protection (ICRP, 1982), and ICRP Publication 55, Optimization and Decision-making in Radiological Protection (ICRP, 1990). The most common quantitative ALARA analysis used is the cost benefit analysis and is discussed at length in this document. However, quantitative ALARA analyses can also be performed using a cost effect analysis, multi-attribute utility analysis, multi-criteria outranking analysis, Kepner-Tregoe (K-T) decision analysis, or analytical hierarchy process analysis. Each of these analyses are discussed further in this Chapter and applicable examples of optimization as applied to DOE occupational radiation protection issues are provided later in this Handbook and in Munson et al., 1988. 9.1 Cost Benefit Analysis Very complex or contentious issues may need a quantitative cost-benefit analysis16 to help decision-makers select among alternatives. Cost-benefit analysis is often a good approach to use when the primary basis for making a decision is the monetary cost vs. monetary benefits of the alternatives. This type of analysis describes benefits and detriments in terms of the economic or monetary cost and requires all attributes to be described in these terms. This is the most quantitative method described in this Handbook and requires the greatest amount of quantitative information. Selection of an appropriate cost-benefit factor for reducing dose involves a judgment of the relative values of dose, normally in terms of dollars per rem avoided. Additionally, guidance on optimization methodology will provide the basis for selection of collective dose values above which an ALARA review is appropriate. Numerical criteria for ALARA decision making should include types of radioactive effluent contamination levels, and exposure scenarios. 16 U.S. Office of Management and Budget, OMB Circular No. A-94, Guidelines and Discount Rates for Cost-Benefit Analysis of Federal Programs (October 29, 1992) presents general guidance on conducting cost-benefit analyses. OMB updates the discount rates for the methodology annually. DOE-HDBK-1215-2014 9-2 9.1.1 Total Detriment Equations Total detriment includes all deleterious effects, both health effects and non-health effects. These include real and imagined effects, perceived effects, anxiety, risk aversion, and any others associated with the radiation source. The Total cost, or the monetary equivalent of the total detriment (Y), can be written: Y = α S + ß Σj Nj ƒj(Hj) Equation 9-1 Where: α is the health detriment cost coefficient (dollars per person-rem), S is the collective dose (person-rem),

ß is the non-health detriment cost coefficient (dollars per person-rem), N is the number of individuals exposed, ƒ is a function of the individual doses, which would depend on risk aversion attitudes and regulations or company policies, and H is the mean total effective dose (rem) where j represents a particular group of individuals for N, ƒ, and H. In Equation 9-1, all components of the non-health detriment are taken together and assumed to depend on individual doses. This section will not address the non-health detriment portion of the cost-benefit analysis further, but rather will focus on the health detriment and specifically on the radiation-related health detriment.17 Thus, Equation 9-1 becomes: Y = αS Equation 9-2 9.1.2 Cost-Benefit Optimization The net benefit of an activity may be expressed mathematically in the following manner: B = V − (P + X + Y) Equation 9-3 17 Natural Resource Valuation: A Primer on Concepts and Techniques, July 1997, provides examples of related techniques for valuation of non-health detriments to support cost-benefit assessments. Two components of detriment are: 1) the assumed radiation-induced health effects that may be expressed in monetary terms through the use of the coefficient α ($/person-rem), and 2) a non-health coefficient ß ($/person-rem) that is related to societal considerations. Many ß “terms” are not predictable and can be strongly dependent on such factors as the local attitude and may be more suited for evaluation using multi-attribute type processes. Different values for the worth of the detriment might be warranted for workers and members of the public. DOE-HDBK-1215-2014 9-3   + = Where: B is the net benefit of the activity, V is the gross benefit of the activity, P is the basic production costs, X is the cost of achieving a selected level of protection, and Y is the cost of radiation detriment of the activity at a selected radiation protection level. The optimum level of radiation protection is obtained by maximizing the net benefit B of implementing an alternative. Assuming the collective dose (S) is the relevant independent variable; Equation 10-3 is differentiated with respect to S and set equal to zero: dV − dS  dP dX  dS dS dY  dS  0 Equation 9-4 The values of V and P are generally independent of S for a given activity, that is, the gross benefit worth and production cost of an activity generally are not affected by variations in S. Thus, components dV/dS and dP/dS are 0 and the optimum condition may be written as: dX = − dY dS dS = − = −α Equation 9-5 The optimum degree of radiation protection is obtained at a value of S such that the incremental increase in the cost of the radiation protection per unit of collective dose is equal to the incremental reduction in detriment per unit of collective dose. This is a differential cost-benefit equation18 and is used to optimize radiation protection efforts. This form is best-suited for applications where the exposures (and cost of health-detriment) can be associated with a release of radioactive material that can be described in an equation by a continuous variable. In most cases, exposures are not continuous variables; rather, the alternative radiation protection options result in finite incremental changes in exposures (and cost of the health-detriment). The equation may be written: (X 2 − X1 ) = (S2 − S1 ) (Y2 − Y1 ) (S2 − S1 ) = − α Equation 9-6

18 To select the optimum radiation protection system, it is necessary to define, cost, and evaluate the performance of several candidate systems which range from the most rudimentary to the more technologically sophisticated systems. When several candidate systems are considered, the ALARA process will identify the optimum system. If only two systems are evaluated, the only finding made is whether the change from the first system to the second system is cost-effective. There is a vast difference between the two applications, with economic savings favoring the optimization. A good example is a typical waste stream which will be discharged to the environment. The most rudimentary treatment can be expected to remove a significant fraction of the contaminant and cost relatively little. Further removal efforts will be less effective because there is less contaminant remaining in the waste stream and the more sophisticated removal components will be more and more costly. The ALARA process will indicate the choice of several candidate systems which will result in the minimum total cost, e.g., optimization. + DOE-HDBK-1215-2014 9-4 The subscripts ind