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THE DISPOSITION DILEMMA Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities Committee on Alternatives for Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities Board on Energy and Environmental Systems Division on Engineering and Physical Sciences National Research Council NATIONAL ACADEMY PRESS Washington, D.C.
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National Academy Press · 2101 Constitution Avenue, N.W. · Washington, DC 20418 NOTICE: The project that is the subject of this report was approved by the Governing Board of the National Research Council, whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the Insti- tute of Medicine. The members of the committee responsible for the report were chosen for their special competences and with regard for appropriate balance. This report and the study on which it is based were supported by Grant No. NRC-04- 00-050. Any opinions, findings, conclusions, or recommendations expressed in this publi- cation are those of the authorts) and do not necessarily reflect the view of the organizations or agencies that provided support for the project. International Standard Book Number: 0-309-08417-2 COVER: Image adapted from a photograph of the decommissioned Big Rock Point nuclear plant near Charlevoix, Michigan, available at
National Acaclemy of Sciences National Acaclemy of Engineering Institute of Meclicine National Research Council The National Academy of Sciences is a private, nonprofit, self-perpetuating society of distinguished scholars engaged in scientific and engineering research, dedicated to the furtherance of science and technology and to their use for the general welfare. Upon the authority of the charter granted to it by the Congress in 1863, the Academy has a mandate that requires it to advise the federal government on scientific and technical matters. Dr. Bruce M. Alberts is president of the National Academy of Sciences. The National Academy of Engineering was established in 1964, under the charter of the National Academy of Sciences, as a parallel organization of outstanding engineers. It is autonomous in its administration and in the selection of its members, sharing with the National Academy of Sciences the responsibility for advising the federal government. The National Academy of Engineering also sponsors engineering programs aimed at meeting national needs, encourages education and research, and recognizes the superior achievements of engineers. Dr. Wm. A. Wulf is president of the National Academy of . ~ . . . ~ nglneerlng. The Institute of Medicine was established in 1970 by the National Academy of Sci- ences to secure the services of eminent members of appropriate professions in the exami- nation of policy matters pertaining to the health of the public. The Institute acts under the responsibility given to the National Academy of Sciences by its congressional charter to be an adviser to the federal government and, upon its own initiative, to identify issues of medical care, research, and education. Dr. Kenneth I. Shine is president of the Institute of Medicine. The National Research Council was organized by the National Academy of Sciences in 1916 to associate the broad community of science and technology with the Academy's purposes of furthering knowledge and advising the federal government. Functioning in accordance with general policies determined by the Academy, the Council has become the principal operating agency of both the National Academy of Sciences and the National Academy of Engineering in providing services to the government, the public, and the scientific and engineering communities. The Council is administered jointly by both Acad- emies and the Institute of Medicine. Dr. Bruce M. Alberts and Dr. Wm. A. Wulf are chairman and vice chairman, respectively, of the National Research Council.
COMMITTEE ON ALTERNATIVES FOR CONTROLLING THE RELEASE OF SOLID MATERIALS FROM NUCLEAR REGULATORY COMMISSION-LICENSED FACILITIES RICHARD S. MAGEE, Chair, Carmagen Engineering Inc., Rockaway, New Jersey DAVID E. ADELMAN, University of Arizona, Tucson JAN BEYEA, Consulting in the Public Interest, Lambertville, New Jersey JACK S. BRENIZER, JR., Pennsylvania State University, University Park LYNDA L. BROTHERS, Sonnenschein, Nath & Rosenthal, San Francisco, California ROBERT J. BUDNITZ, Future Resources Associates, Inc., Berkeley, California GREGORY R. CHOPPIN, Florida State University, Tallahassee MICHAEL CORRADINI, NAT, University of Wisconsin, Madison JAMES W. DALLY, NAE, University of Maryland, College Park EDWARD R. EPP, Harvard University (retired), Cambridge, Massachusetts ALVIN MUSHKATEL, Arizona State University, Tempe REBECCA R. RUBIN, Businesses of Adams, Hargett and Riley Inc., Alexandria, Virginia MICHAEL T. RYAN, Medical University of South Carolina, Charleston RICHARD I. SMITH, Pacific Northwest National Laboratory (retired), Kennewick, Washington DALE STEIN, NAE, Michigan Technological University (retired), Tucson, Arizona DETLOF VON WINTERFELDT, University of Southern California, Los Angeles Liaison from the Board on Energy and Environmental Systems GERALD L. KULCINSKI, NAE, University of Wisconsin, Madison Liaison from the Board on Radioactive Waste Management ROBERT M. BERNERO, Nuclear Safety Consultant, Gaithersburg, Maryland Project Staff MARTIN OFFUTT, Study Director JAMES ZUCCHETTO, Director, Board on Energy and Environmental Systems RICK JOSTES, Program Officer, Board on Radiation Effects Research PANOLA GOLSON, Project Assistant, BEES SHANNA C. LIBERMAN, Project Assistant, BEES (until September 2001) iNAE = member, National Academy of Engineering. ~v
BOARD ON ENERGY AND ENVIRONMENTAL SYSTEMS ROBERT L. HIRSCH, Chair, RAND, Arlington, Virginia RICHARD E. BALZHISER, NAE, ~ Electric Power Research Institute, Inc. (retired), Menlo Park, California (term expired September 30, 2001) DAVID L. BODDE, University of Missouri, Kansas City PHILIP R. CLARK, NAE, GPU Nuclear Corporation (retired), Boonton, New Jersey WILLIAM L. FISHER, NAE, University of Texas, Austin CHRISTOPHER FLAVIN, Worldwatch Institute, Washington, D.C. (term expired August 3l, 2001) HAROLD FORSEN, NAE, Foreign Secretary, National Academy of Engineering, Washington, D.C. ROBERT W. FRT, Resources for the Future, Washington, D.C. WILIAM FULKERS ON, Oak Ridge National Laboratory (retired) and University of Tennessee, Knoxville MARTHA A. KREBS, California Nanosystems Institute, Los Angeles, California GERALD L. KULCINSKI, NAE, University of Wisconsin, Madison JAMES MARKOWSKY, NAE, American Electric Power (retired), North Falmouth, Massachusetts EDWARD S. RUBIN, Carnegie Mellon University, Pittsburgh, Pennsylvania PHILIP R. SHARP, Harvard University, Cambridge, Massachusetts ROBERT W. SHAW, JR., Arete Corporation, Center Harbor, New Hampshire JACK SIEGEL, Energy Resources International, Inc., Washington, D.C. ROBERT SOCOLOW, Princeton University, Princeton, New Jersey KATHLEEN C. TAYLOR, NAE, General Motors Corporation, Warren, Michigan JACK WHITE, The Winslow Group, LLC, Fairfax, Virginia JOHN J. WISE, NAE, Mobil Research and Development Company (retired), Princeton, New Jersey Staff JAMES ZUCCHETTO, Director RICHARD CAMPBELL, Program Officer ALAN CRANE, Program Officer MARTIN OFFUTT, Program Officer SUSANNA CLARENDON, Financial Associate PANOLA GOLSON, Project Assistant ANA-MARTA IGNAT, Project Assistant (until October 5, 2001) SHANNA LIBERMAN, Project Assistant (until September 22, 2001) 1 NAE = member, National Academy of Engineering. v
Preface and Acknowledgments Statutory responsibility for the protection of health and safety related to civilian nuclear facilities rests with the U.S. Nuclear Regulatory Commission (USNRC). The basic standard for protection against radiation is 10 CFR Part 20, which was first issued in final form by the Atomic Energy Commission in 1957 and was subject to a major revision that was finalized in 1991. Part 20 includes limits on quantities or amounts of radionuclides released in gaseous and liquid effluents below which the effluent would not be subject to further regulatory control, but it does not contain similar regulatory limits applicable to slightly radioactive solid material (SRSM). Absent such limits, the USNRC does have guidance documents regarding how slightly radioactive solid materials are cleared from regulatory control (a practice that licensees make use of routinely), and Section 2002 of Part 20 allows licensees to apply to the USNRC and its agree- ment states for clearance of solid materials on a case-by-case basis where the guidance documents do not apply. This policy issue could become increasingly important in the future as the eventual decommissioning of nuclear power plants generates large amounts of SRSM. The USNRC has attempted without success to update and formalize its poli- cies on disposition of SRSM. In 1990, it issued a policy, as directed by the Low Level Radioactive Waste Policy Amendments Act of 1985, that declared materi- als with low concentrations of radioactivity contamination "below regulatory concern" (BRC) and hence deregulated. However, Congress intervened to set aside the BRC policy in the Energy Policy Act of 1992, following the USNRC's own suspension of the policy. In 1999, the USNRC again examined the issue of disposition of SRSM and published a Federal Register notice examining several . . via
. . . vile PREFACE AND ACKNOWLEDGMENTS policy options. In neither case was the USNRC able to convince consumer and environmental groups that clearance of SRSM could be done safely or to con- vince some industry groups that clearance is desirable. In August 2000, the USNRC asked the National Research Council to form a committee to provide advice in a written report. The National Research Council established the Com- mittee on Alternatives for Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities to address this task and recommend approaches for the clearance of solid materials from USNRC-licensed facilities (Appendix A contains biographical sketches of the committee members). It became clear to the committee that radioactive waste is generated by many different industries and controlled by several government agencies under the terms of different regulations. This compounded the committee's task. During open information gathering sessions, the committee heard from stakeholders such as the U.S. Department of Energy (DOE) whose concerns focused on wastes that are not controlled by the USNRC; however, these stakeholders feared that any USNRC rulemaking or policy change might influence the disposition of these materials. Other large volumes of waste e.g., naturally occurring radioactive materials (NORM) or technically enhanced NORM, which is known as TENORM are not regulated under any specific federal statute. Finally, since the current case-by-case approach seems to be working, there is not a strong, unified impetus for change. I wish to gratefully acknowledge the hard work of the committee members, who served as volunteers and who provided all the expertise necessary to carry out this difficult task. I am especially appreciative of the many hours they spent at the two writing sessions, which enabled us to complete the task on schedule. The assistance and contributions of the committee's two liaisons, Robert M. Bernero and Gerald L. Kulcinski, greatly enhanced the committee's efforts. The presentations by U.S. Nuclear Regulatory Commission Chairman Rich- ard A. Meserve; staff from the USNRC, the Environmental Protection Agency, and DOE; stakeholder organizations; nuclear industry representatives; represen- tatives from the European Union and the International Atomic Energy Agency; and a host of other organizations, provided the committee with valuable informa- tion and insights into the issue of the disposition of SRSM from USNRC-licensed facilities. The contribution of these presenters is greatly appreciated (see Appen- dix B for a complete list of presentations). Robert Meck at the USNRC was our principal point of contact; he ensured the constant flow of written information to the committee in response to our numerous questions and requests for additional information. Special thanks are owed to Al Johnson and Doug Jamieson, Duratek, Inc., for arrangements and a guided tour of Duratek's Bear Creek Operations (Oak Ridge, Tennessee) and Gallaher Road Facility (Kingston, Tennessee) and to Richard Grondin for a tour of the ATG, Inc., facility (Richland, Washington).
PREFACE AND ACKNOWLEDGMENTS MIX A study such as this requires extensive support; we are all indebted to the National Research Council staff for their assistance. I would particularly like to acknowledge the close working relationship I had with the National Research Council study director, Martin Offutt, and the support I received from him. The logistic support that enabled us to concentrate on our task was ably provided by Shanna Liberman and Panola Golson. The efforts and contributions of the con- sulting technical writer, Robert Katt, greatly enhanced the clarity and sharpness of the report. The committee was also assisted by Alan Fellman, who provided technical consulting. This report has been reviewed in draft form by individuals chosen for their diverse perspectives and technical expertise, in accordance with procedures ap- proved by the National Research Council's Report Review Committee. The pur- pose of this independent review is to provide candid and critical comments that will assist the institution in making its published report as sound as possible and to ensure that the report meets institutional standards for objectivity, evidence, and responsiveness to the study charge. The review comments and draft manu- script remain confidential to protect the integrity of the deliberative process. We wish to thank the following individuals for their review of this report: Vicki M. Bier, University of Wisconsin; Philip R. Clark (NAB), General Public Utilities, Nuclear Corporation (retired); Kenneth Eger, Jacobs Engineering Group; Ann Fisher, Pennsylvania State University; Gordon Geiger, University of Arizona; Richard Guimond, Motorola, Inc.; Ivan Itkin, former Director, Office of Civilian Radioactive Waste Management, U.S. Department of Energy; David Lochbaum, Union of Concerned Scientists; Claudio Pescatore, Organization for Economic Cooperation and Development, Nuclear Energy Agency; John J. Taylor (NAB), Electric Power Research Institute, Inc.; and Chris C. Whipple (NAB), Environ, Inc. Although the reviewers listed above have provided many constructive com- ments and suggestions, they were not asked to endorse the conclusions or recom- mendations, nor did they see the final draft of the report before its release. The review of this report was overseen by Frank Parker (NAB) of Vanderbilt Univer- sity. Appointed by the National Research Council, he was responsible for making sure that an independent examination of this report was carried out in accordance with institutional procedures and that all review comments were carefully consid-
x PREFACE AND ACKNOWLEDGMENTS Bred. Responsibility for the final content of this report rests entirely with the authoring committee and the institution. Richard S. Magee, Chair Committee on Alternatives for Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities
Contents EXECUTIVE SUMMARY INTRODUCTION Historical Context, 14 Radiation Protection Standards Developed by Organizations Other Than the USNRC, 20 The U.S. and Global Contexts of Radioactive Waste Generation, 20 Status of the Current USNRC Process for Clearing Solid Materials, 25 The Study Task and Approach, 28 THE REGULATORY FRAMEWORK Mechanics of Existing and Former Standards Governing Releases of Radioactively Contaminated Material, 33 Historical Evolution of the Regulatory Framework for Controlling Radioactively Contaminated Solid Materials, 39 Comparative Assessment of Existing Regulations in the United States, 44 Stakeholder Involvement, 52 Findings, 53 3 ANTICIPATED INVENTORIES OF RADIOACTIVE OR RADIOACTIVELY CONTAMINATED MATERIALS Inventories of Contaminated Materials Arising from Decommissioning of USNRC-Licensed Facilities, 56 x~ 13 33 55
Xil CONTENTS Inventories of Radioactive Waste from Other Licensed and Unlicensed Sources, 61 Findings, 71 4 PATHWAYS AND ESTIMATED COSTS FOR DISPOSITION 72 OF SLIGHTLY RADIOACTIVE MATERIAL Disposition System Decisions, 73 Relative Costs for Disposition Alternatives, 75 Finding, 79 REVIEW OF METHODOLOGY FOR DOSE ANALYSIS Key Technical Assessments of Annual Doses Associated with Clearance of Solid Materials, 81 USNRC Studies, 86 Environmental Protection Agency Documents on Dose Factors, 91 American National Standards Institute and Health Physics Society Standard N13.12-1999, 92 International Atomic Energy Agency Documents, 93 European Commission Documents, 95 Comparison of Clearance Studies, 96 Detailed Comments on NUREG-1640, 107 Findings, 112 6 MEASUREMENT ISSUES Levels of Detectability, 117 Measurement Cost, 120 Current Measurement Practices of a Waste Broker, 122 The MARSSIM Methodology, 122 Findings, 124 7 INTERNATIONAL APPROACHES TO CLEARANCE The Global Context, 125 Clearance Standards in the European Union, 131 Findings, 135 8 STAKEHOLDER REACTIONS AND INVOLVEMENT Past USNRC Efforts at Stakeholder Involvement, 136 Risk Communication and Its Role in the Rulemaking Process, 144 Stakeholder Involvement: Methods and Successes, 147 Findings, 150 80 115 125 136
CONTENTS . . . Xti! 9 A FRAMEWORK AND PROCESS FOR DECISION MAKING 151 Problems with the Current Approach, 151 The Decision-Making Process, 152 A Systematic Decision Framework, 154 Findings, 163 10 FINDINGS AND RECOMMENDATIONS Major Findings, 167 Recommendations, 171 REFERENCES APPENDIXES A Biographical Sketches of Committee Members B Presentations and Committee Activities C Statement of Work D Standards (Limits) Proposed by Other Organizations E Radiation Measurement F Stakeholder Reactions to the USNRC Issues Paper G Acronyms and Glossary 166 175 183 192 196 199 212 218 230
Tables and Figures TABLES Table 1-2 Table 1-3 Table I-l Average Annual Amounts of ionizing Radiation to Which Individuals in the United States are Exposed, T-S Common Source of Radiation to Which the Public is Exposec3, 1-8 Risk Assessment Based on a Linear, No-ThreshoIc! Mode] With a Probability of Developing a Fatal Cancer of Sxio~2 /Sv (5x I0~4/rem), l-16 Table 3-l Volume of Materials Arising Rom Power Reactor Decommissioning, 3-4 Table 3-2 Weights of Slightly Radioactive Solid Material from Power Reactors, 3-5 Table 3-3 Decommissioning Materials Inventory from the Population of U.S. Research Reactors, 3-7 Table 3-4 Decommissioning Materials Inventory from the Population of U.S. Uranium Hexafluoride Conversion Plants, 3-9 Table 3-5 Decommissioning Materials Inventory from the Population of U.S. Fuel Fabrication Plants, 3-10 Table 5-2 Table 5-3 .!, .~ Table 5-4 Table 6-1 Table 6-2 Table 6-3 Table 7-] Table 3-6 Sites Containing Radioactively Contaminated Soils, 3-14 Table 3-7 Sources, Quantities, and Concentrations of TENORM, 3-15 Table 4-l Approximate Costs for Disposal of Solict Material as Low-Level Radioactive Waste, 4-7 Table 4-2 Estimatect Costs for Alternative Dispositions of Slightly Radioactive Solict Material, 4-7 Table 5-1 Technical Analyses Supporting Numerical Coefficients for Deriving Secondary Activity Standards from Primary Dose Standards, 5-6 NUREG-1640 Uncertainty Factors Averaged Across Radionuclides, 5-S Comparison of Dose Factor Estimates Made to Support Clearance Proposals, 5-17 Ratio of NUREG-1640 Dose Factors to Other Estimates, Averaged Across Raclionuclides, 5-~S Comparison of Derived Screening Levels and Laboratory MDCs for Selected Raclionuclides (Based on ~ mrem/Yr), 6-4 Detectability of Selectec! Ractionuclides by Laboratory Analysis Relative to Derived Screening Level (DSL) from TSD97, 6-5 Estimates! Number of Analyzed Samples Per Metric Ton of Waste at Break- Even Between Clearance ant! Low-leve! Radioactive Waste Disposal, 6-6 International Clearance Status as of May 2001, 7-4 Table S-l Matrix of Stakeholder Perspectives, S-5 x~v
Tables and Figures TABLES Average Annual Amounts of Ionizing Radiation to Which Individuals in the United States Are Exposed, 21 Common Sources of Radiation to Which the Public Is Exposed, 21 1-3 Risk Assessment Based on a Linear, No-Threshold Model with a Probability of Developing a Fatal Cancer of 5 x 10-2/Sv (5 x 10~/rem), 30 3-4 Volume of Materials Arising from Power Reactor Decommissioning, 58 3-2 Weights of Slightly Radioactive Solid Material from Power Reactors, 59 Decommissioning Materials Inventory from the Population of U.S. Research Reactors, 62 Decommissioning Materials Inventory from the Population of U.S. Uranium Hexafluoride Conversion Plants, 64 Decommissioning Materials Inventory from the Population of U.S. Fuel Fabrication Plants, 64 3-6 Sites Containing Radioactively Contaminated Soils, 68 3-7 Sources, Quantities, and Concentrations of TENORM, 70 Approximate Costs for Disposal of Solid Material as Low-Level Radioactive Waste, 77 4-2 Estimated Costs for Alternative Dispositions of Slightly Radioactive Solid Material, 79 Technical Analyses Supporting Numerical Coefficients for Deriving Secondary Activity Standards from Primary Dose Standards, 84 xv
xv! 6-2 TABLES AND FIGURES NUREG-1640 Uncertainty Factors Averaged Across Radionuclides, 88 Comparison of Dose Factor Estimates Made to Support Clearance Proposals, 98 Ratio of NUREG-1640 Dose Factors to Other Estimates, Averaged Across Radionuclides, 100 6-1 Comparison of Derived Screening Levels and Laboratory Minimum Detectable Concentrations (MDCs) for Selected Radionuclides, 118 Detectability of Selected Radionuclides by Laboratory Analysis Relative to Derived Screening Level (DSL) from TSD 97, 119 6-3 Estimated Number of Analyzed Samples per Metric Ton of Waste at Breakeven Between Clearance and Low-Level Radioactive Waste Disposal, 121 7-1 8-1 D-1 International Clearance Status as of May 2001, 128 Matrix of Stakeholder Perspectives, 142 Exempt Quantities Established by Council Directive 96/29/ EURATOM, 206 D-2 Derived USNRC Clearance Levels Assuming a 10 ,uSv/yr Primary Dose Standard (All Metals), 210 E-1 Radiation Sources and Their Activities, 217 FIGURES ES-1 Time distribution for generation of slightly radioactive solid material from U.S. power reactor decommissionings, 5 3-1 Time distribution for generation of slightly radioactive solid material from U.S. power reactor decommissionings, 60 4-1 Decision points and disposition pathways, 73 5-1 Points at which technical information and judgments can inform rulemaking decisions related to clearance of slightly radioactive solid material, 82 Illustration of scenario pathways following SRSM clearance and hypothetical affected critical groups, 85 Dispute resolution techniques, 148 Decision impact matrix, 164
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