The Disposition Dilemma Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities (2002) / Chapter Skim
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Appendix F Stakeholder Reactions to the USNRC Issues Paper
Appendix F Stakeholder Reactions to the USNRC Issues Paper
Pages 218-229
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From page 218... ...
policy was discussed 10 years earlier. USNRC EFFORTS AT STAKEHOLDER INVOLVEMENT Background As the initial step in this process, the USNRC solicited comment on its June 30, 1999, issues paper (64 Federal Register 35090-35100; "Release of Solid Materials at Licensed Facilities: Issues Paper, Scoping Process for Environmental Issues and Notice of Public Meetings")
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From page 219... ...
Both efforts adequately provide the reader with the range of responses to the issues paper categories, but they do not offer a sense of the intensity of the views expressed. In addition, both SECY-00-0070 and the ICE Kaiser report tie comments and analyses back to the preexisting issues paper categories (process alternatives and technical approach categories)
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From page 220... ...
The gradations identified are the following: · Cannot support release (clearance) for recycle or disposal; · Cannot engage in a dialogue with the USNRC because the dialogue process is itself tainted; · Recommend delaying a decision on whether to conduct a rulemaking until public comments can be integrated into the USNRC's decision framework; · Recommend restricted release (conditional clearance)
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From page 221... ...
May 9, 2000. 2Oral testimony of Wenonah Hauter, Public Citizen, Rockville public meeting.
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From page 222... ...
The USNRC and the National Academy of Sciences (NAS) through the National Research Council both mistakenly believe the primary issues to be technical issues involving formulation, in the abstract, of some notional dose that ensures public health and safety, whereas the real issue is that the USNRC has an "empirical record of institutional incompetence"3 that shows a startling incapacity to technically abide by public protection standards."4 The real task is for the NAS to undertake a thorough public review of whether the Department of Energy (DOE)
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From page 223... ...
" Dan Guttman Recommend Delaying a Decision on Whether to Conduct a Rulemaking Until Public Comments Can Be Integrated into the USNRC's Decision Framework Illustrative stakeholders in this category include groups as diverse as the scrap recycling industry, the Natural Resources Defense Council (NRDC) , the Association of Radioactive Metals Recyclers (ARMR)
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From page 224... ...
Jeff Deckler,Department of Human Health and Environment for the State of Colorado, representing ASTSWMO "If you were going into end uses that were very clear and controlled, and we had confidence in how the material was being surveyed and how measurements were being made, what you're proposing is something we might consider." Natural Resources Defense Council Recommend Restricted Release (Conditional Clearance) Illustrative stakeholders in this category included the metals and concrete industries.
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From page 225... ...
· Free release could also add substantially to costs by forcing steel mills to go to extremes to protect against volumetrically contaminated materials that could cause a radioactive melt; recycling is viewed by the industry as a way for DOE to shift responsibility to the mills; and if sensor alarms go off too frequently, they may be ignored by employees even if the alarm is truly warranted. No unrestricted release of any contaminated radioactive steel or other metals should be permitted from USNRC-licensed facilities, even if the steel meets dose-based release levels that the committee might recommend and the USNRC adopt.
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From page 226... ...
The concept of concrete framed buildings across the United States being made with radioactive materials housing millions of people exposing them to potential radioactive material greater than background exposure is contrary to the charter of the NRC." Robert A Garbini, National Ready Mixed Concrete Association Recommend Continuing Case by Case, but with Uniform National Dose-Based Criteria Several individual states and the Organization of Agreement States (OAS)
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From page 227... ...
Recommend Setting a Specific Clearance Standard, but with Some Exceptions for Special Groups Such as the Metals Recycling Industry Illustrative stakeholders in this category included the Health Physics Society, the Nuclear Energy Institute, the American Nuclear Society' s Special Committee on Site Restoration and Cleanup Standards, and the CRCPD E-23 Committee on Resource Recovery and Radioactivity. These stakeholders generally shared in the following perceptions: Lack of a consistent acceptance criteria provides inconsistent public protection, undermines public confidence, wastes resources, and perpetuates liability.
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From page 228... ...
"We continue to advocate for the eventual promulgation of clear, consistent and enforceable regulations based upon a one millirem annual dose criterion and nuclide specific concentration guidelines." Kathleen McAllister, Committee on Resource Recovery and Radioactivity Options Beyond Those Originally Envisioned by the USNRC Have to Be Identified and Considered in Any Further Stakeholder Involvement Process. As can be seen from the matrix in Table 8-1, all stakeholder opinions do not neatly line up with process and technical alternatives initially envisioned by the USNRC in its issues paper, notably the section of the matrix that refers to "other" alternatives.
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From page 229... ...
The USNRC had expected to receive comments on the issues paper that would offer new options and alternatives. In this light, the discussion of stakeholder views above and the matrix of options in Chapter 8 may be of some value in framing other options and alternatives.
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