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OCR for page 151
9
A Framework and Process
for Decision Making
PROBLEMS WITH THE CURRENT APPROACH
The current approach for releasing radioactive materials from facilities li-
censed by the U.S. Nuclear Regulatory Commission (USNRC) is based on Regu-
latory Guide 1.86 (AEC, 1974), USNRC guidance memoranda, and the case-by-
case application of section 2002 of 10 CFR Part 20 by USNRC and its agreement
states. Several problems with this approach were pointed out in presentations to
the study committee (see details in Chapters 2 and 8~. From an administrative
perspective, the major concerns expressed were that this approach does not handle
volume contamination generically and that the case-by-case approach may lead
to inconsistent determinations from one case to another. Another point made was
that this approach and the acceptable surface contamination levels in Table I of
Regulatory Guide 1.86 are 27 years old; they have not kept up with international
developments of release standards, many of which are risk based (see Chapter 7~.
Also, the regulatory guidance was not adopted through rulemaking and hence
was not submitted for public comment or review. The case-by-case applications
for release produce additional workload and costs for the USNRC, but this bur-
den appears manageable for the foreseeable future.
From the licensees' perspective, the major concerns expressed to the com-
mittee were that this approach is unpredictable and costly, and creates undesir-
able operational impacts. Licensees also expressed concern about future liabili-
ties if materials released under Regulatory Guide 1.86 are later suspected to have
caused harm.
151
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152
THE DISPOSITION DILEMMA
From the perspective of environmental groups and some members of the
public, a major concern with the current case-by-case approach is that it allows
unrestricted uses of slightly radioactive solid material (SRSM) once it clears the
surface contamination limits. However, representatives of this perspective typi-
cally do not favor dose-based standards as a remedy; they prefer a no-release
approach. In addition, environmental groups criticized the current approach as
being largely administrative and precluding the possibility of public scrutiny or
external review.
For the above reasons and more, various stakeholders, including licensees,
and other interested parties have argued for modifying or replacing the current
approach. Their proposals for an alternative approach differ widely, ranging from
a strict no-release policy favored by some to a dose-based standard for uncondi-
tional release favored by others. Given these different and strongly held views,
the development, evaluation, and implementation of a regulatory approach will
likely create substantial controversy and debate. It will take significant time and
effort to develop an acceptable solution.
The committee recognizes that there are problems with the current approach
and that a new approach is needed for many of the reasons stated by the stake-
holders. However, the committee has not found any evidence that the problems
with the current approach cause significant health effects or amount to an imme-
diate crisis. The committee therefore concludes that it is possible for the USNRC
to conduct, with deliberate speed, a thorough analysis and evaluation of several
alternative approaches to the disposition of SRSM including a broad-based stake-
holder involvement process.
THE DECISION-MAKING PROCESS
The USNRC has two important choices when considering a decision on the
disposition of SRSM. The first choice is what kind of decision process to use-
for example, a regular rulemaking process or an enhanced participatory process.
The second choice is which alternatives for the disposition of SRSM it should
study and evaluate. This section discusses process options. The next section
describes a systematic framework for developing, analyzing, and evaluating dis-
position alternatives within this process.
The USNRC has various process options for making the decision about the
disposition of SRSM. One possibility is to follow a variation of the National
Environmental Policy Act (NEPA) process. NEPA provides a widely accepted
structure for the announcement of a proposal by an agency, for solicitation of
public input as to the appropriate range of alternatives and impacts to analyze
through a scoping process, and for subsequent review of environmental analyses
with public input. In addition, the NEPA concept of tiering will allow the USNRC
to obtain input on issues of broad scope first and later move to NEPA review of
· · ~ · ret ~
Increasingly specific options.
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A FRAMEWORK AND PROCESS FOR DECISION MAKING
153
The USNRC used a scoping NEPA process in parallel with its enhanced
participatory rulemaking process during 1992-1997, while developing its License
Termination Rule, 10 CFR Part 20, Subpart E. The USNRC might reconsider that
experience, and the experience with the below regulatory concern (BRC) policy
statement that preceded it, to evaluate a tiered NEPA approach overall. The BRC
process did not use an enhanced open approach and had severe difficulties. The
enhanced participatory process for the License Termination Rule was an open
NEPA approach and appeared to have achieved consensus until the USNRC's
process changed, following the issuance of the proposed rule.
As explained in Chapter 2, the BRC policy statement was required of USNRC
in response to Section 10 of the Low-Level Radioactive Waste Policy Amend-
ments Act of 1985 (LLWPAA; 42 U.S.C. §2021j), which was specifically di-
rected at defining a release standard for radioactive material that was at such a
low level that it would be "below regulatory concern." The BRC policy statement
addressed this statutory provision with an overarching dose-based or risk-based
policy. The policy would have provided guidance for setting BRC standards for
radioactive waste, residues at license termination, exemption of radioactivity in
consumer products, and general release of materials for recycle or reuse.
If a tiered NEPA process had been followed, the USNRC might have begun
by developing a draft policy statement, with full public input and participation.
Then it would have proceeded with separate NEPA processes for each of the
subsequent decisions. Instead of this tiered NEPA process, the USNRC devel-
oped and published the BRC policy statement in 1990 but turned to public con-
sensus building only after receiving severe negative reactions to the policy. Pub-
lic acceptance was not built step by step, nor was the policy developed in an
iterative manner. The consensus process failed, and the BRC policy was first put
on hold (56 Federal Register 36068; July 30, 1991) and then rescinded (58 Fed-
eral Register 44610; August 24, 1993~. Since that failure to establish a broad
policy, the lack of a top tier an overarching policy appears to have signifi-
cantly hindered progress with the subsequent License Termination Rule and the
development of standards for release of SRSM.
The USNRC decision processes can be improved by including a broad range
of affected groups and individuals. Administrative appeals processes and admin-
istrative guidelines may have to be altered to ensure greater access to the
USNRC's decision-making process by a broader range of affected individuals,
industries, and interested parties. The goal should be to develop a process that
solicits input broadly, while remaining flexible, open, transparent, and fair.
In addition, compared to some of the more recent national health and safety
legislation (such as the Resource Conservation and Recovery Act [RCRAj; the
Comprehensive Environmental Response Compensation and Liability Act
[CERCLAj; the Clean Air Act, and the Clean Water Act) the USNRC's funda-
mental legislation, the Atomic Energy Act (AEA) provides a somewhat less
extensive legal basis for citizens' suit challenges or public review. However, the
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154
THE DISPOSITION DILEMMA
legal basis is fully adequate if used properly. Whatever the AEA's shortcomings
might be in this regard, the USNRC can and must employ the appropriate mecha-
nisms to reach out to develop stakeholder participation, acceptance, and (eventu-
ally) support.
It is vital that any decision process for developing policies on clearance of
SRSM begins from a broad set of alternatives. Among the alternatives could be
options beyond just clearance of materials from licensed sites. In particular, the
committee believes that it would be useful to consider alternatives beyond a
clearance standard by looking at issues concerning the broader range of low-
activity radioactive materials. For example, a broad-based scoping process could
also include consideration of whether the USNRC should regulate naturally oc-
curring and accelerator-produced radioactive material (NARM) and naturally
occurring radioactive material (NORM) by some national standards rather than
continuing with state-only regulation of these categories of radioactive materials.
The USNRC might consider supplementing its decision process with en-
hanced and expanded use of public advisory committees. Many federal agencies
include members of the broader public not just highly technical experts on
their advisory committees. The result of using NEPA, a broad scoping process,
more iterative development of proposals, and broader participation on advisory
committees would be greater and broader public participation in the USNRC
decision-making process.
As the regulatory body, the Commission holds the statutory decision-making
authority. Some concerned groups perceive the Commission and USNRC staff as
nonresponsive to public input. In addition, many observers perceive the Commis-
sion and staff as not operating cohesively. Unless confidence and trust in the
USNRC increase, acceptance by the public and Congress of a clearance or condi-
tional clearance standard is unlikely.
Any process to develop a release standard might be enhanced by using
professional facilitators. During the BRC process, the Commission called on one
of the USNRC staff to lead the attempt at building consensus for BRC. The staff
then recruited a professional facilitator, who worked on BRC and other matters.
For the enhanced participatory rulemaking effort, the USNRC engaged the ser-
vices of the Keystone Center, a group of professional facilitators. In the long run,
the USNRC might benefit from further pursuit of facilitated participation pro-
cesses to increase the likelihood of productive public involvement.
A SYSTEMATIC DECISION FRAMEWORK
Several alternatives exist for the disposition of SRSM: the current case-by-
case approach, a no-release (from regulatory control) alternative, clearance, and
conditional clearance. In addition, there are many combinations, types, and levels
of possible standards and several possible clearance conditions worth consider-
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A FRAMEWORK AND PROCESS FOR DECISION MAKING
155
ing. Impacts to be considered include public health, costs and benefits, consis-
tency with existing national and international analysis and regulations, and public
perceptions and acceptance. This section first defines a logical set of alternatives
for disposition of SRSM, ending with the finding that for practical purposes, only
a few alternatives merit further consideration. It then develops a list of impacts
that should be examined when evaluating these alternatives.
Alternatives
In its statement of work (see Appendix C), the study committee was asked to
consider the following alternatives for the disposition of SRSM from USNRC-
licensed facilities:
1. Continue the current system of case-by-case decision;
2. Establish a national standard by rulemaking or other approaches; and
3. Consider other alternative approaches.
After gathering information and deliberating on the range of possible ap-
proaches, the committee decided to address two "other" approaches in some
detail:
1. A no-release policy, and
2. Establishment of a national standard with conditions on the uses of released
materials.
At the general level, there are thus four policy alternatives to address:
1. Case-by-case approach (the USNRC or an agreement state approves specific
license conditions in accordance with Regulatory Guide 1.86 or modifica-
tions);
2. Clearance standard (unrestricted release of materials that meet the standard);
3. Conditional clearance standard (restricted release of materials that meet the
standard); and
4. No releases of licensed material.
There are many possible variants for some of these alternatives. Box 9-1
illustrates some of these variants.
Not all of the alternatives in Box 9-1 merit detailed consideration here. For
example, the committee found little support for minor modifications of the cur-
rent approach. One such modification would be to develop additional criteria for
volume contamination, based on a dose assessment, and apply these criteria on a
case-by-case basis. As a second example, stakeholders who prefer a national
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156
THE DISPOSITION DILEMMA
standard (for unconditional or conditional clearance) typically argue for a dose-
based standard rather than a source-based standard. Therefore, source-based vari-
ants for clearance standards are not addressed further herein.
Based on these and similar observations from its information gathering ef-
forts, the committee focused on the following six policy alternatives and variants:
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A FRAMEWORK AND PROCESS FOR DECISION MAKING
157
1. Case-by-case approach (pursuant to Section 2002 of 10 CFR Part 20 or
possible modifications);
2. Dose-based clearance standard (unrestricted reuse, including commercial
recycling);
3. Dose-based conditional clearance standard (beneficial reuse in controlled
environments, e.g., shield blocks at Department of Energy [DOE] facili-
ties);
4. Dose-based conditional clearance standard (commercial reuse for low-
exposure scenarios, e.g., concrete rubble base for roads);
5. Dose-based conditional clearance standard (landfill disposal); and
6. No release (all SRSM is disposed of at licensed low-level radioactive
waste [LLRW] sites).
The current case-by-case approach can be improved by developing addi-
tional criteria for volume contamination, possibly based on a dose assessment,
using coefficients similar to those currently under development for the draft
NUREG- 1 640.
Several possible dose limits for use in a dose-based standard have been
discussed, including annual doses of 1 ,uSv (0.1 mrem), 10 ,uSv (1 mrem), or 100
,uSv (10 mrem). Placing conditions on clearance has the effect of limiting the
potential exposure scenarios. For example, suppose SRSM is cleared under a
dose-based standard of 10 ,uSv/yr (1 mrem/yr) for landfill disposal only. If the
same secondary activity standard were kept, the maximum individual dose would
be lowered for most radionuclides, because the highest doses without the landfill
restrictions apply to transport and factory workers, who would no longer be
exposed on the job.1 On the other hand, if the secondary activity standard is
adjusted upward under a landfill restriction to allow the primary dose standard to
be reached in the new critical group, then it would be possible to release SRSM
with higher concentration under a conditional clearance standard than it would
under an (unconditional) clearance standard.
The following discussion provides a few examples of the range and type of
policy alternatives that the committee recommends to the USNRC. It may even
be reasonable to consider alternative dose standards for different conditional
clearance conditions. For example, if the restriction is beneficial reuse in con-
trolled environments, a dose standard of 100 ,uSv/yr (10 mrem/yr) may be reason-
able since exposure limits for nuclear workers are typically much higher (50,000
,uSv/yr or 5,000 mrem/yr).
1 The committee notes that modeling of exposed groups in draft NUREG-1640 (USNRC, 1998b)
specifically rules out residential use of postclosure property. Had such a restriction not been made,
landfills would become the critical group for some radionuclides and hence would already represent
the maximum dose for these radionuclides.
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158
THE DISPOSITION DILEMMA
Impacts of Alternative Regulatory Approaches
Many participants in the study committee' s information-gathering meetings
expressed concerns, issues, preferred outcomes, and objections in response to
some of the alternatives discussed above. As discussed in Chapter 8, the USNRC
has not gained widespread public trust in its recent rulemakings. For example,
environmental groups objected to any standard that allowed the release of SRSM
into commerce. They argued that this would create an unnecessary health risk
with unknown cumulative effects. Some licensee representatives expressed con-
cerns about liability risks and economic costs of regulation. Representatives from
the steel and concrete industries worried about the possible stigmatization of their
products if it became known that some of their materials might include radioac-
tive contamination, no matter how slight.
The committee drew on these comments, together with the numerous state-
ments of issues and concerns submitted in response to USNRC's June 1999
Federal Register notice (64 Federal Register 35090-35100; June 30, 1999) en-
titled "Release of Solid Materials at Licensed Facilities: Issues Paper, Scoping
Process for Environmental Issues and Notice of Public Meetings" and public
hearings in the fall of 1999 (see Appendix F), to create a generic list of impacts
for consideration when evaluating alternatives for disposing of SRSM. This list is
shown in Box 9-2 and discussed below.
Health Impacts
The primary objective of any alternative for the disposition of SRSM is to
ensure that there are minimal health impacts for any individual and the public at
large. Much of the work on dose-based standards (e.g., draft NUREG-1640) has
focused on specific scenarios for individuals with the potentially highest doses
from released materials. However, the committee also heard concerns about the
potential for multiple exposures and collective doses, especially cumulative doses
from multiple commercial products containing SRSM. To address these con-
cerns, risk assessments must consider not only maximally exposed individuals
and direct health impacts from a single source, but also the potentially exposed
population and cumulative impacts from multiple sources.
There may also be indirect and unintended impacts from implementing alter-
native approaches. For example, under the current approach, radioactive materi-
als must be shipped over long distances, usually by truck. One waste broker
(Duratek, Inc.) estimated that its trucks drive about 6 million miles per year. With
increased decommissioning activities, these shipment miles will increase sub-
stantially, thus increasing the probability of accidents, however low the probabil-
ity per mile might be.
The conditional clearance option, by allowing disposal of SRSM in Subtitle
C or D landfills, would reduce both the transportation miles and the associated
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A FRAMEWORK AND PROCESS FOR DECISION MAKING
159
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160
THE DISPOSITION DILEMMA
transportation risks. The greater number of such landfills in the United States,
relative to the three LLRW disposal facilities, means a much greater likelihood of
a landfill being in close proximity to the power reactor that is undergoing decom-
. . .
mlsslomng.
Environmental Impacts
Alternative approaches to the disposition of SRSM will have different envi-
ronmental impacts. For example, if conditional clearance is chosen, the use of
landfill disposal at sites near nuclear power plants will reduce transportation and
associated vehicle emissions. These impacts may be small relative to the poten-
tial radiation-related impacts on health and the economic impacts, but they must
be examined to ensure that any regulation does not produce worse environmental
impacts as an unintended consequence.
Direct Costs
The main direct cost impact of alternative approaches is likely to be the
licensees' disposal costs for SRSM. A no-release policy means, in practice, that
all low-level radioactive materials would have to be sent to a site licensed to
accept LLRW for disposal. If conditional clearance is chosen, the cost of disposal
of metals at a landfill site, even a Subtitle C hazardous waste landfill, is substan-
tially lower than the cost at LLRW sites. The committee's preliminary calcula-
tions (Chapter 4) indicate that disposal of decommissioning wastes under a strict
no-release policy would cost billions of dollars, whereas Subtitle D landfill dis-
posal would cost a few hundred million dollars.
The committee reviewed available cost data but found only limited informa-
tion. The current cost estimates of disposal vary widely, both among LLRW sites
and between LLRW sites and landfill disposal options. Because cost will be a
major factor in selecting an approach for disposing of SRSM, it is very important
that the USNRC conduct a thorough cost analysis that accounts for the differ-
ences among disposal options and the uncertainties in cost estimates caused by
regulations and by supply and demand.
Other waste management costs will include transportation and operational
(e.g., material preparation and sample analysis) costs. These are likely to be much
lower than disposal costs. Regulatory costs also have to be considered. These
include the cost of staff at the USNRC and in agreement states to manage which-
ever regulatory approach is taken.
Indirect Costs
Indirect costs of alternative approaches include the potential liabilities of
licensees and other waste handlers. Although the study committee has not heard
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A FRAMEWORK AND PROCESS FOR DECISION MAKING
161
of any cases where such liabilities were invoked, some industry representatives
clearly expressed concerns about this possibility. However an approach is fash-
ioned, it must consider the liability of generators in a variety of circumstances,
including continuing liability, erroneous free release, and unapproved reuse.
As noted above, representatives from the steel and concrete industries have
expressed particular concern about the impact of releasing slightly radioactive
steel and concrete into commerce. They believe that the presence of released
material in their feed streams could stigmatize their products, reducing sales and
revenue. Representatives of these industries made it quite clear that their policy is
to reject any materials identified as radioactive by detection equipment at their
gates when the material arrives at their facilities. They emphasized that their
companies will continue to exercise vigilance in this area.
Direct Benefits
Alternatives allowing clearance would create opportunities for commercial
benefits for example, through the sale of SRSM. One example is the sale being
contemplated by the DOE of $30 million worth of slightly radioactive nickel on
the commercial market. The committee did not hear much evidence for potential
direct benefits (other than the nickel example), but it would be useful to deter-
mine the net value associated with releasing these materials into commerce.
These net value calculations should consider both the market value of the materi-
als and the cost of processing and shipping them. Another direct benefit is the
reduction of licensees' operational expenses. For example, licensees expressed
concern about the paperwork and cost of releasing equipment to be moved from
one controlled site to another, but they did not comment on additional potential
labor costs associated with further categorization of waste materials.
Consistency with Existing Regulations
Consistency with international, national, state, and local regulations is desir-
able, even though it should not be the main reason for selecting an alternative. In
Chapter 7, the committee discusses the efforts under way in the European Union
(KU) to establish consistent standards for free release of SRSM. There may be
economic advantage to the United States in establishing a clearance standard for
SRSM, particularly if it were consistent with international standards. Consistency
would make import-export and control of materials easier and, if monitored
properly, of no consequence to public health. An international agreement on such
trade not only must include the levels of residual radioactivity allowable for
clearance for shipment, but also must specify standard methodologies of mea-
surement at both the point of export and the point of import. Standard measure-
ment methods are particularly important for ensuring detection, and preventing
the shipment, of materials in which orphan sources are present.
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162
THE DISPOSITION DILEMMA
The committee believes that the USNRC may wish to evaluate the various
technical considerations employed by the EU and other countries in reaching
clearance standards. However, as stated elsewhere in this report, the committee
believes that many other factors should be considered in any U.S. approach.
Consistency with other federal regulations is also important. For example,
the rulemaking process employed by the Environmental Protection Agency (EPA)
results in lengthy explanation of all comments in the preamble to the Federal
Register announcement of the rule. Under RCRA, the EPA establishes acceptable
risk levels and then develops compound-by-compound standards through de-
tailed calculations for each chemical and environmental medium. The EPA ap-
proach results in a detailed explanation of regulatory decisions, aspires to consis-
tent application of risk, and elicits extensive public participation. It also includes
extensive responses and analyses of public comments in Federal Register an-
nouncements as well as in administrative records.
Similarly, if the USNRC were to choose a dose-based approach to setting a
national standard, consistency with the regulation of other radioactive materials
would be important. For example, the committee is concerned about inconsisten-
cies with the current regulatory approaches to NORM, technologically enhanced
naturally occurring radioactive material (TENORM), and NARM wastes. The
issue of consistency within USNRC guidelines and regulations should be ad-
dressed as well.
Implementation and Enforcement
To be effective, any approach to clearance of SRSM must be implementable
and enforceable. Of special relevance in this case is the ability to detect, measure,
and monitor very small amounts of radiation with few false alarms. Another
concern is the ability to track the chain of custody of conditionally cleared mate-
rials, especially if the uses of these materials are restricted by conditions on their
release. Hence, to establish confidence in any approach to clearance of SRSM,
there must be adequate procedural guidance, oversight, and reporting require-
ments.
Enforceability is crucial for ensuring broad-based compliance with a stan-
dard. Both enforceability and a standardized, accessible measurement methodol-
ogy are crucial for uniform implementation. Enforceability requires penalties
(such as fines) for failure to meet the standard or failure to implement the stan-
dard properly. Enforcement by regulatory agencies is an integral part of gaining
public trust as well.
Public Perception
The USNRC faces perhaps no greater challenge than winn
.
1ng widespread
public acceptance of any regulation for release of SRSM. As discussed in the next
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A FRAMEWORK AND PROCESS FOR DECISION MAKING
163
section of this chapter, there are many challenges, opportunities, and options for
the USNRC in seeking public acceptance. Acceptance does not equate directly
with consensus or unanimous agreement. Rather, the likelihood of acceptance is
increased first by adhering faithfully to an announced process that engages all
responsible stakeholder representatives and viewpoints. Second, this process
must be perceived by participants as fair and open. Third, the process should
bring out all advantages and disadvantages of the alternative approaches in an
even-handed way. Fourth, participation throughout the process by informed and
knowledgeable persons, as well as openness to a broad and creative range of
alternatives, will increase public acceptance.
The USNRC could use many mechanisms to attain public acceptance. The
committee believes that the degree of trust (or mistrust) of the USNRC has been
and will remain a major factor in the public's response to issues involving
SRSM. The USNRC should consider substantial changes that would open its
decision-making process (for details, see "Stakeholder Involvement" in Chap-
ter 2 and all of Chapter 8~.
Decision Impact Matrix
Figure 9-1 shows, in the form of a two-dimensional matrix, the committee's
view of how alternative approaches and their possible impacts should be ana-
lyzed and evaluated. A thorough and systematic analysis and evaluation of these
approaches would address each cell of this matrix. Additional columns and rows
might emerge from a thorough stakeholder involvement process.
Most of the work to date on evaluating alternatives has focused on health
impacts. Although this is an important issue when setting a standard, other
impacts may be significant as well. The committee has done some preliminary
work on some of these other impacts. For example, the relative costs for a
conditional clearance standard and a no-release alternative are discussed in Chap-
ter 4. However, there clearly is much more work to be done to provide a satisfac-
tory assessment for all of the alternatives and impacts represented in Figure 9-1.
FINDINGS
Finding 9.1. The committee found no evidence that the problems with the
current approach to clearance decisions require its immediate replacement. The
committee concludes that there is sufficient time to conduct a thorough and
systematic analysis and evaluation, including a sound process of stakeholder
participation and involvement, of alternative approaches to the disposal of
SRSM.
Finding 9.2. Although there are many possible alternatives for the disposal of
SRSM from USNRC-licensed facilities, the committee heard substantial support
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164
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OCR for page 165
A FRAMEWORK AND PROCESS FOR DECISION MAKING
165
from stakeholders for only a few. In general terms, the supported alternatives are
a dose-based clearance standard, a dose-based conditional clearance standard,
and a no-release policy. Different stakeholders expressed preferences for differ-
ent conditions for a dose-based conditional clearance standard: beneficial reuse
in controlled environments, commercial reuse in low-exposure scenarios, or land-
fill disposal. Source-based standards and minor modifications of the existing
case-by-case approach received limited support.
Finding 9.3. There are many possible impacts of the approaches that the USNRC
might select for the clearance of SRSM. Potentially important impacts include
the degree of public protection against exposure from radioactive materials, envi-
ronmental impacts, direct costs (e.g., for disposal), indirect costs (e.g., through
product stigmatization), consistency with existing regulations, implementation
and enforcement, and public perception. To date, the USNRC has focused its
analyses of alternative approaches fairly narrowly on protecting the public from
exposure to SRSM. The USNRC has done very little analysis of the other impor-
tant impacts on this list.
Representative terms from entire chapter:
clearance standard
