The U.S. Department of Energy's (DOE's) environmental cleanup activities will generate large amounts of non-real (personal) property over the next few decades. Although much of this material does not contain above-background concentrations of residual radioactive material, some does contain above-background concentrations. In many cases, property containing or potentially containing above-background concentrations of residual radioactive material has been disposed of by burial. However, some of the property may be expensive equipment or devices that are still useful, and the incentive to recover them for reuse is high. Other property may be valuable metals, such as nickel, copper, or high-quality stainless steel, which can easily be recycled. Yet another category of property that will be involved is bulky material, such as concrete and carbon steel, which will require considerable space for burial. Although the values of these latter materials may not be significant, recycling presents an attractive option for alleviating limited burial capacity and ever-increasing disposal costs at licensed or authorized disposal facilities. Authorized release provisions for non-real property are contained in Order DOE 5400.5, which DOE has proposed to be codified in Title 10, Part 834, of the Code of Federal Regulations (10 CFR 834), and in related guidance. The Department has also issued (for use and comment) the Draft Handbook for Controlling Release for Reuse or Recycle of Property Containing Residual Radioactive Material. As described in the handbook, authorized release can be accomplished using a step-by-step process. The process emphasizes application of the as-low-as-reasonably-achievable (ALARA) concept to derive release limits. This process involves identifying viable alternatives, followed by dose calculations and an optimization (cost/benefit) analysis to arrive at a preferred release alternative. Demonstration that a release alternative is ALARA does not have to be elaborate if the individual and collective doses are small (on the order of a few mrem and person-rem per year). The approach outlined in the handbook also addresses stakeholder participation and the need to coordinate with the U.S. Nuclear Regulatory Commission or the responsible Agreement State to ensure that DOE-approved releases will not result in an unlicensed release of properly that is subject to NRC licensing requirements.
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