The Disposition Dilemma Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities (2002) / Chapter Skim
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9 A Framework and Process for Decision Making
9 A Framework and Process for Decision Making
Pages 151-165
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From page 151... ...
The case-by-case applications for release produce additional workload and costs for the USNRC, but this burden appears manageable for the foreseeable future. From the licensees' perspective, the major concerns expressed to the committee were that this approach is unpredictable and costly, and creates undesirable operational impacts.
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From page 152... ...
The first choice is what kind of decision process to usefor 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.
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From page 153... ...
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 Amendments Act of 1985 (LLWPAA; 42 U.S.C.
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From page 154... ...
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 lowactivity radioactive materials.
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From page 155... ...
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 modifications)
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From page 156... ...
Therefore, source-based variants for clearance standards are not addressed further herein. Based on these and similar observations from its information gathering efforts, the committee focused on the following six policy alternatives and variants:
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From page 157... ...
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.
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From page 158... ...
The committee drew on these comments, together with the numerous statements of issues and concerns submitted in response to USNRC's June 1999 Federal Register notice (64 Federal Register 35090-35100; June 30, 1999) entitled "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)
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From page 160... ...
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 substantially lower than the cost at LLRW sites.
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From page 161... ...
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 desirable, even though it should not be the main reason for selecting an alternative.
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From page 162... ...
Under RCRA, the EPA establishes acceptable risk levels and then develops compound-by-compound standards through detailed calculations for each chemical and environmental medium. The EPA approach results in a detailed explanation of regulatory decisions, aspires to consistent application of risk, and elicits extensive public participation.
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From page 163... ...
FINDINGS Finding 9.1. The committee found no evidence that the problems with the current approach to clearance decisions require its immediate replacement.
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From page 164... ...
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From page 165... ...
Different stakeholders expressed preferences for different conditions for a dose-based conditional clearance standard: beneficial reuse in controlled environments, commercial reuse in low-exposure scenarios, or landfill disposal. Source-based standards and minor modifications of the existing case-by-case approach received limited support.
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