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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
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Dr. Bruce M. Alberts is president of the National Academy of Sciences.
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achievements of engineers. Dr. Wm. A. Wulf is president of the National Academy of
. ~ . .
. ~ nglneerlng.
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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
