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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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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.