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c Statement of Work The National Research Council committee formed to undertake this study will address the following tasks: (1) As part of its data gathering and understanding the technical basis for the Nuclear Regulatory Commission's (USNRC's) analyses of various alternatives for managing solid materials from USNRC-licensed facilities, the committee shall review the technical bases and policies and precedents derived therefrom set by the USNRC and other Federal agencies, by States, other nations and interna- tional agencies, and other standard setting bodies including the following. The review of the following will be contingent on the USNRC staff providing sum- maries with the salient issues of each document to the Research Council staff and committee, as well as copies of the documents, soon after project funds are received and before the first committee meeting. . . . The USNRC technical bases development, including ongoing and planned staff activities, to include the assessment of potential scenarios and path- ways for radiation exposure, survey and detection methodology, and an evaluation of the environmental impacts for a variety of solid materials. The 1997 Environmental Protection Agency Preliminary Technical Sup- port Document for its clean metals program and other studies on the environmental impacts of clearance of materials, exemption of materials containing naturally occurring radioactive material (e.g., coal ash), and development of guidelines for screening materials imported into the U.S. that contain radioactivity. The 1980 Department of Energy (DOE) petition to establish exemptions 196

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APPENDIX C . . . . . . 197 for small concentrations of technetium-99 and/or low enriched uranium as residual contamination in smelted alloys and the public comment on the proposed DOE rule. The 1990 USNRC Below Regulatory Concern (BRC) Policy setting a standard for release of solid materials for recycle. In 1991 the USNRC instituted a moratorium on the BRC Policy to allow more extensive public involvement, and the BRC policy was revoked by Congress in the Energy Policy Act of 1992. DOE criteria (e.g., DOE Order 5400.5) for release of solid materials and handbooks for controlling release of property containing residual radioac- tive material. DOE has established a task force to review its policies on release of materials for re-use and recycling that could have implications for USNRC licensees. Conference of Radiation Control Program Directors recommendations or policies on the control of solid materials from licensed facilities. Experience of individual states promulgating release criteria for solid materials in the absence of federal standards. For example, one state prohibits the disposal of radioactive material in municipal landfills and another state authorizes unrestricted release of volumetrically contami- nated materials. Methodologies states are using to survey and detect slightly contaminated materials. Basis and criteria states are using for approving the release of these materials. Approaches states are using for similar levels of naturally occurring radioactive materials. International Atomic Energy Agency and European Union experience, directives, recommendations or standards, especially as they pertain to international adoption of guidelines and criteria on international trade and import standards. Recommendations of the International Commission on Radiological Pro- tection (e.g., ICRP Report 60) and the National Council on Radiation Protection and Measurements (e.g., NCRP Report 116) and on-going ac- tivities evaluating clearance and criteria for release of slightly radioactive materials. American National Standards Institute Standard N13.12, "Surface and Volume Radioactivity Standards for Clearance." This standard contains criteria for unrestricted release of solid materials from nuclear facilities. Also, review of the National Technology Transfer and Advancement Act of 1995 and its implications for developing and implementing alternative release criteria. (2) The committee will review public comments and reactions received so far on current and former USNRC proposals to develop alternatives for control of solid materials. Again, this review will be contingent on the USNRC staff provid- ing the committee both with the comments and summaries of the public com-

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198 APPENDIX C meets and reactions received. The committee will explicitly consider how to address public perception of risks associated with the direct reuse, recycle, or disposal of solid materials released from USNRC-licensed facilities. The com- mittee should provide recommendations for USNRC consideration on how com- ments and concerns of stakeholders can be integrated into an acceptable approach for proceeding to address the release of solid materials. (3) The committee shall determine whether there are sufficient technical bases to establish criteria for controlling the release of slightly contaminated solid materials. This should include an evaluation of methods to identify the critical groups, exposure pathways, assessment of individual and collective dose, expo- sure scenarios, and the validation and verification of exposure criteria for regula- tory purposes (i.e., decision making and compliance). As part of this determina- tion, it should judge whether there is adequate, affordable measurement technology for USNRC-licensees to verify and demonstrate compliance with a release criteria. What, if any, additional analyses or technical bases are needed before release criteria can be established? (4) Based on its evaluation and its review, the committee shall recommend whether USNRC: (1) continue the current system of case-by-case decisions on control of material using existing, revised, or new (to address volumetrically contaminated materials) regulatory guidance, (2) establish a national standard by rulemaking, to establish generic criteria for controlling the release of solid mate- rials, or (3) consider another alternative approach~es). If the committee recommends continuation of the current system of case-by- case decisions, the committee shall provide recommendations on if and how the current system of authorizing the release of solid materials should be revised. If the committee recommends that USNRC promulgate a national standard for the release of solid material, the committee shall: (1) recommend an approach, (2) set the basis for release criteria (e.g., dose, activity, or detectability-based), and (3) suggest a basis for establishing a numerical limiters) with regard to the release criteria or, if it deems appropriate, propose a numerical limit. (5) The committee shall make recommendations on how the USNRC might consider international clearance (i.e., solid material release) standards in its imple- mentation of the recommended technical approach.