Improving the Regulation and Management of Low-Activity Radioactive Wastes (2006) / Chapter Skim
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4 Implementing Risk-Informed Practices
4 Implementing Risk-Informed Practices
Pages 67-88
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From page 67... ...
These considerations led the committee to conclude that gradual, stepwise implementation of risk-informed practices is the best way to proceed. Implementation will require the participation of regulators, waste generators and facility operators, and public stakeholders.
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From page 68... ...
Changes to licenses and permits of individual waste generators or disposal facility operators seeking solutions for specific wastes, waste streams of a given type, or unique wastes that are infrequently generated. 1Such a stepwise approach is consistent with other National Academies advice on managing high-level waste and spent nuclear fuels (NRC, 2001c, 2003b)
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From page 69... ...
By focusing on a waste's actual hazard and potential risks of a proposed solution for dealing with that waste, rather than on regulatory complexities, risk-informed decision making within the four-tiered approach can increase the ability of public stakeholders to participate effectively. The Tiered Approach in Practice This section provides examples of how each tier of the four-tiered approach has been applied to manage and dispose of wastes in ways that appropriately recognize their radiological hazards.
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From page 70... ...
Tier 1: Changes to licenses and permits of individual waste generators or disposal facility operators seeking solutions for specific wastes, waste streams of a given type, or unique wastes that are infrequently generated. Changes to license and permit conditions are generally considered a part of doing business in the commercial world.
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From page 71... ...
Tier 2: Changes to guidance documents issued by federal and state agencies that provide interpretations and technical resolutions for specific regulatory issues. This may require the development of MOUs to better align and clarify requirements where there is a shared regulatory responsibility among agencies.
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From page 72... ...
Part 10 CFR 61.58 states: The Commission may, upon request or on its own initiative, authorize other provisions for the classification and characteristics of waste on a specific basis, if, after evaluation of the specific characteristics of the waste, disposal site, and method of disposal, it finds reasonable assur ance of compliance with the performance objectives in subpart C of this part. This gives the USNRC significant authority and flexibility to use a riskinformed approach to waste classification, while maintaining public health and safety, for LLW or LAW.
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From page 73... ...
MARSSIM's objective is to "describe a consistent approach for planning, performing, and assessing building surface and surface soil final status surveys to meet established dose or risk-based release criteria, while at the same time encouraging an effective use of resources." Tier 3: Changes to regulations that more formally codify requirements for specific management practices and are promulgated by federal or state agencies under their legislated authority. Examples of regulatory changes that can lead toward risk-informed LAW practices are the EPA's Advance Notice of Proposed Rulemaking for disposing of certain wastes in RCRA Class C landfills and the USNRC's proposed rule on alternative disposition pathways, both of which were discussed in Chapter 2.
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From page 74... ...
Previously the committee noted that the definition of "low-level waste" in the Nuclear Waste Policy Act, which is reflected in the AEA, is not risk-informed. The definition is a "catchall" that includes AEA wastes that do not have another statutory definition (e.g., high-level waste, transuranic waste)
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From page 75... ...
In a recent USNRC workshop on decommissioning, industry officials said they would like to see more flexibility in where to send their waste, consistency in regulations between the USNRC and EPA, and finality of closing a site once the required decommissioning work is complete. Fuel Cycle Facilities Forum Chairman David Culberson stated that "waste disposal is typically the largest single cost component of decommissioning, and frequently licensees are left with only one commercial disposal alternative.
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From page 76... ...
This internal accounting strategy has been associated with substantial pollution prevention activity (Rondinelli and Berry, 2000)
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From page 77... ...
The practice requires identifying "conventional waste zones," where there are no radioactive materials, and "nuclear waste zones" in and around the facilities. Zoning helps ensure that conventional wastes are not contaminated by radioactive materials.
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From page 78... ...
Increasingly there is interest in establishing comprehensive environmental performance measurement schemes such as the Global Reporting Initiative, which will allow quantitative comparisons within sectors and across organizations; pollution prevention efforts are at the center of measurement schemes as well. Characterizing and reporting on LAW is consistent with several trends in corporate responsibility and can be accomplished without government regulatory action.
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From page 79... ...
Industries generating LAW will benefit from sharing a range of best practices, including waste characterization and waste minimization techniques. Act in Advance of Regulatory Requirements Institutions have articulated several reasons for acting in advance of regulatory action, including · Enhanced reputation among customers and other stakeholders; · Greater control over timing of action, particularly when capital investments are required; and · Increased likelihood that when regulations are implemented, regulators will codify elements of successful practice, conferring a competitive advantage on the organizations already following those practices.
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From page 80... ...
By working with regulators, public authorities, and local citizens to implement risk-informed practices, industry can increase the costeffectiveness of its LAW disposal; increase its options for such disposal; and by moving away from the ad hoc nature of the current origin-based system, increase the predictability of its disposal options. Given the degree of public concern associated with radioactive waste, institutions taking
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From page 81... ...
In parallel with the previous section's discussion that risk-informed practices are good business practices, this section develops the thesis that risk-informed practices provide effective new opportunities for involving stakeholders and reducing mistrust. Currently there are a number of LAW issues that worry public stakeholders, and any action that appears to lessen regulatory control of lowlevel radioactive wastes is a major one.
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From page 82... ...
He said the decision-making process for the proposed rule was open and reflected "extensive stakeholder input from citizens and environmental groups, metals and concrete industries, nuclear industry representatives and other state and federal agencies, representing a broad-based and diverse set of views." He called this process "enhanced participatory rulemaking" (Diaz, 2005b)
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From page 83... ...
Currently, there are a number of public outreach programs in the federal government to gather information about nuclear issues from, and provide it to, public stakeholders, although not all of them put stakeholders in a central decision-making role. According to the USNRC (2002, p.
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From page 84... ...
In France in the late 1990s, when results from epidemiological studies raised causal questions about cases of leukemia in residents living in the vicinity of La Hague, a nuclear reprocessing plant, a group of stakeholders, including members of the public, were brought together to review the situation. In Sweden, a site investigation for developing a high-level nuclear waste repository has carefully taken into account local stakeholder concerns and positions.
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From page 85... ...
Network members exchange information about their experiences to analyze local involvements in national decision processes and issue recommendations for improving those processes. Besides outreach, another way in which a few government organizations in Europe and the United States have helped public stakeholders become more central in risk decision-making processes is by helping them hire their own technical experts.
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From page 86... ...
While a risk-informed system might not solve all the problems involved in LAW public participation efforts, offering public stakeholders' a central role early in the decision-making process should increase trust and add important dimensions to public input into radiation decision making. A risk-informed system by its very definition would ensure that more information than just scientific risk assessment would be used when evaluating LAW issues.
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From page 87... ...
Both interested and affected publics need to be active and central partners in a riskinformed decision process. CONCLUSIONS Government agencies, nuclear waste managers, and public stakeholders all play an important role in effectively implementing riskinformed processes for managing and regulating LAW.
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From page 88... ...
88 LOW-ACTIVITY RADIOACTIVE WASTES not only in the process but also in the government agency and waste management personnel making radiation risk decisions. Because the process is transparent, understandable, and guarantees that a variety of views will be heard and evaluated, implementing a risk-informed decision process would be an important step in building public trust in the LAW regulatory process.
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