ML20044C680
| ML20044C680 | |
| Person / Time | |
|---|---|
| Issue date: | 05/03/1993 |
| From: | Parler W NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| References | |
| SECY-93-114, NUDOCS 9305060380 | |
| Download: ML20044C680 (40) | |
Text
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May 3, 1993 POLICY ISSUE srcr-93-11c The Commission (ersInformation) l FOR:
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William C. Parler General Counsel I
SUBJECT:
STATUS REPORT ON THE ENHANCED PARTICIPATORY RULEMAKING PURPOSE:
To provide the Commission with a summary of the status of the enhanced participatory rulemaking process to establish the radiological criteria for decommissioning.
SUMMARY
The Staff has recently completed the fifth of seven workshops designed to solicit early comments and recommendations on the radiological criteria for decommissioning of NRC-licensed sites.
This paper provides an interim status report of the workshop process.
BACKGROUND:
In its Staff Requirements Memorandum of October 28, 1992, the Commission approved the staff recommendation in SECY-92-249 to conduct an enhanced participatory rulemaking on the radiological criteria for decommissioning of NRC-licensed sites.
The heart of the enhanced rulemaking process is a series of workshops designed to obtain the early comments and recommendations of representatives of affected interests on the rulemaking issues.
These comments will be used by the NRC staff in the development of a draft l
proposed rule for Commission review.
In addition ~ to providing I
early comment on the rulemaking issues, the workshops were designed to provide an environment where the representatives of affected interests could effectively discuss their concerns and viewpoints on the rulemaking issues with each other, and with the NRC staff and the staff of the Environmental Protection Agency.
The staff has emphasized that the objectives of the workshops are early comment and discussion rather than attempting to reach a consensus l
Contacts: Francis X.
Cameron, OGC h(D b. eOCsWb._[,M/ A /T D if A 504-1642 Donald A. Cool, RES 140047
'Yzy Mh 492-3785 NOTE: TO BE MADE PUBLICLY AVAILABLE IN 10 WORKING D T
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on the issues.
The focus of the workshop discussions is a Rulemaking Issues Paper which describes the issues and alternative regulatory approaches that need to be addressed in the rulemaking.
The workshops completed to date have been effective in ventilating the issues and exploring the alternative approaches for developing decommissioning criteria, as well as NRC's process for involving the public in rulemakings and licensing.
The workshops are being facilitated by The Keystone Center, a nonprofit facilitation and mediation organization based in Keystone, Colorado. Workshops have been held in
- Chicago, Sar.
Francisco,
- Boston, Dallas, and Philadelphia. The remaining workshops are to be held in Atlanta on April 29 and 30, 1993; and Washington D.C. on May 6 and 7, 1993.
A final summary of the workshops will be submitted to the Commission in preparation for the Commission briefing on the enhanced participatory rulemaking scheduled for June 4, 1993.
DISCUSSION:
The workshops have included participants from the full spectrum of interests affected by the rulemaking, including representatives from state, local, and tribal interests, citizens groups, industry, and professional societies.
Participation in the workshops from citizens groups at the local level has been particularly strong.
The total number of participants at each workshop, as well as the mix of the various affected interests, has varied from workshop to workshop.
The level of technical expertise represented at each workshop has
- varied, with state government,
- industry, and professional society representatives being generally more well-versed in the technical and legal background of decommissioning, and with the citizen
- group, tribal, and local government representatives bringing the benefits of their experience and expertise in regard to individual sites and related policy issues.
Representatives from the staff of the Environmental Protection Agency's Office of Radiation and Indoor Air have jointly participated with the NRC staff at each workshop.
The staff also received excellent support and cooperation from the NRC and EPA regional personnel in preparing for each workshop.
The majority of workshop participants were drawn from the groups originally identified by the staff as candidates for participation in the workshops using the selection criteria set forth in SECY 249, i.e., representation of a wide range of viewpoints, ability of a participant to knowledgeably discuss the rule. making issues, and participation from organizations within the region encompassed by the workchops.
These initial invitations were supplemented significantly by The Keystone Center's efforts to determine who else should be invited to participate, primarily from the citizen group community. Participant lists from each workshop are included
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for the Commission's information at Attachment A.
The Keystone Center's support on this project has been outstanding in terms of assisting in workshop design, identifying workshop participants, j
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i arranging the logistical details for the workshops, and facilitating each of the workshops.
i Although the Rulemaking Issues Paper is the foundation for workshop discussions, the agenda for the workshops is the mechanism that was used to facilitate an effective discussion of those rulemaking 4
issue.s.
The agenda from the latest workshop in Philadelphia is included for the Commission's information at Attachment B.
The i
agenda approaches the rulemaking issues from the perspective of four " cross-cutting" issues that are relevant to each of the primary regulatory approaches identified in the Rulemaking Issues j
Paper.
These " cross-cutting" issues are health,
- safety, and i
environmental protection; waste management implications; relationship to the existing regulatory framework; and cost, technical capability and other implementation considerations.
The l
primary alternative regulatory approaches in the Rulemaking Issues risk limits, risk goals, best effort, and return to
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Paper background are comparatively discussed from each of these cross-cutting perspectives.
i The staff has made several adjustments to the workshop process based on the comments of workshop participants and the public. One i
comment concerned the lack of broader advance notice of the workshops. At the beginning of the workshop process, the staff had i
provided advance notice of the workshops through the publicatien of the entire workshop schedule in the Federal Register [57 FR 58727).
l This general notice was supplemented with a Federal Register Notice i
published in advance of each workshop.
The Office of Public i
Affairs distributed press releases announcing each workshop.
The staff also relied on the network of citizen groups in the region to broadcast notice of the workshops.
After receiving many comments on the notice issue et the San Francisco workshop, the staff made a number of efforts to expand the notice process.
This included j
i more active efforts to reach the print and electronic media in the region encompassed by the workshop.
It also included a broad
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advance mailing on the workshops to energy and environmental groups in the region identified through Commission public hearing records 4
and national mailing lists of the energy and environmental community.
Based on a comment at the Dallas workshop, the staff has further expanded the notification process to include a request
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to the major libraries in the workshop region to post notices of the workshops on the libraries' public information bulletin boards.
Again in response to workshop comments, the staff has initiated a public comment and information session the night before the workshop to provide an opportunity for participation for those members of the public who could not otherwise attend the workshop because of daytime commitments.
The staff initiated these night sessions beginning with the Dallas workshop and they have been very well-received. They have served to not only familiarize the public with the workshop process and decommissioning issues, but also to allow the exchange of information with the public on Commission
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activities and responsibilities generally.
These night sessions have drawn approximately thirty to fifty participants.
The EPA has oeen a full participant in workshop planning and implementation.
The joint participation by the NRC and the EPA staff has been very positively received by workshop participants, particularly the state government representatives.
Cooperation between the NRC and EPA staff on the NRC rulemaking, and on the anticipated EPA rulemaking on generally applicable standards for site cleanup, will facilitate the development of consistent NRC and EPA standards.
Under the framework of the NRC/ EPA Memorandum of Understanding (MOU), the EPA will make a determination on whether the NRC standards are sufficient to protect the public health and safety.
If the EPA finding is positive, the EPA rulemaking will exclude NRC licensees from its coverage and will focus on standards for Federal facilities.
The EPA plans to make its finding on the sufficiency of the NRC standards when it issues its proposed rule for public comment.
The staff is working with EPA to coordinate the schedules for the NRC and EPA rulemakings to ensure that the EPA has adequate time to evaluate the sufficiency of the NRC standards before it issues its proposed rule. In addition, the NRC and EPA staff are also working on the development of the technical underpinnings for the NRC and the EPA rulemakings, such as cost / benefit data and modeling strategies.
In response to a January 19, 1993 request from the Office of Management and Budget, the staff is also participating with EPA,
- DOE, and DOD in a high-level Steering Committee to ensure coordination of agency activities, timely progress and appropriate resources for the establishment of standards for the cleanup of contaminated sites and allowable levels of radioactivity in various materials.
The Committee's first meeting was on March 3, 1993 and was attended by the two NRC representatives on the Committee, Robert M.
Bernero and Francis X.
Cameron.
The summary of this meeting is provided in Attachment C.
NRC staff also participated in a subcommittee meeting on information and technical analysis on April 1,
1993.
The staff intends to participate fully in the activities of the Committee to ensure that the Committee's focus remains on residual radioactivity issues and that Committee activities facilitate the continued cooperation between EPA and NRC on the development of consistent standards.
Although a summary of the workshop comments on the substantive rulemaking issues will be compiled at the completion of the workshops, staff has identified a
number of preliminary observations about the workshop process.
The workshops have been very well received by workshop participants and the public.
Many positive comments have been made by workshop participants on the opportunity provided by the workshops for early participation in the rulemaking process, including the opportunity for participants to exchange information with one another about their views on the rulemaking issues.
The staff believes that the workshops have
i brought several significant issues to its attention, for example, the opposition to the concept of release of the site for unrestricted use as a general requirement for decommissioning, that may not have been fully developed in the normal process where the staff develops the draft proposed rule in relative isolation from the views of external interests.
The staff will provide a broad summary of the comments on the rulemaking issues in a paper to be submitted in preparation for the Commission briefing on the enhanced participatory rulemaking scheduled for June 4, 1993.
The participation at each workshop of the representatives of the many diverse interests affected by the rule has provided the staff with a
unique opportunity to explore the advantages and disadvantages of the various recommendations on the rulemaking issues.
Judging from the comments of the participants, the workshops are also valuable in helping participants to understand the information and concerns that formed the basis for other participants' views on the issues.
Although this communication among participants is far from a consensus on the rulemaking
- issues, it has been constructive in at least creating an understanding of the very real and significant concerns that underlie the different views.
In an area that is as fraught with controversy as decommissioning standards, this initial communication between the representatives of affected interests is a significant first step toward the development of an acceptable standard.
On another level, the workshop process is providing the Commission with a valuable network of contacts, particularly with citizen groups on the local level, that will the form the basis for future useful interactions on regulatory issues.
The full value of the workshops can perhaps best be seen whe.n contrasted with the strong expressions of distrust and lack of credibility directed towards the NRC by many citizen group participants in the workshops.
This lack of credibility was based on a number of previous NRC actions on a wide variety of issues.
The willingness of the Commission to involve the public early in the decisionmaking process and to engage in an open dialogue on the rulemaking issues is viewed by these participants as a significant first step towards re-establishing the trust and credibility necessary for acceptable regulatory decisions.
However, according to these participants, the willingness of the commission to provide meaningful opportunities for public participation also carries with it the responsibility to carefully consider the public comments on the rulemaking issues.
As many workshop participants noted, the ultimate credibility of the Commission will depend on the substantive outcome of the rulemaking and more importantly, on a demonstration that public comments on the rulemaking issues have been heard and seriously considered in arriving at the Commission's regulatory approach.
These participants also emphasized that re-establishing trust and credibility also depends on continued efforts to improve public participation in other areas of Commission decisionmaking.
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One other aspect of the workshop process that has received considerable comment is the scoping process for the Generic Environmental Impact Statement (GEIS) that will be developed for the rulemaking in accordance with the National Environmental Policy Act.
The staff had planned to conduct one public meeting in Washington D.C.
on the scope of the GEIS.
However, citizen groups at most workshops have emphasized not only the importance of the GEIS process but also that the rulemaking workshops should not be used as a substitute for the scoping process.
This was accompanied by a request that several scoping meetings be conducted, ideally at the same locations where the workshops were held.
The staff is evaluating the need for additional public meetings on the scope of the GEIS and the time and resource requirements for conducting such meetings.
Although a scoping meeting may not be necessary or practical in all workshop locations, a few meetings may be advisable.
It is anticipated that any scoping meetings would follow a fairly simple public hearing format.
Several other
" process" issues that have been raised at the workshops are the need for regional updates on the progress of the rulemaking, and the possibility of some type of review by workshop participants of the draft proposed rule before it is submitted to the Commission.
The staff will present its preliminary views on these issues, and the GEIS scoping process, in the paper to be submitted in preparation for the Commission briefing on June 4, 1993.
Other suggestions on public participation in general that were raised at the workshops were the need for more information and training for citizens groups on the regulatory and technical aspects of Commission activities; the convening of a forum involving a wide spectrum of scientific views on the health effects of low levels of radiation; the possibility of a national or regional citizens advisory groups to the Commission; and the need for periodic regional public forums on NRC activities. The staff will evaluate these suggestions, and develop future recommendations for the Commission, as appropriate.
COORDINATION:
This paper has been coordinated with the Exe u ive Director for Operations.
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- Ilam C.
Parler General Counsel Attachments:
A.
Participants list for each workshop.
B.
Agenda from Philadelphia workshop.
C.
Summary meeting notes from Steering Committee
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DISTRIBUTION:
Comissioners OGC OCAA OIG PA OPP DCD Central Files Regional Offices EDO l
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..,.>c r.u Attachment A NRC SITE Cl,EANUP CRITERI A WORKSHOPS January 27 28,1993 Chicago, Illinois Participant List Citizen / Environmental Or canizations Daniel Balocca Chris Trepal Co-Founder Co-Director Thorium Action Group Earth Day Coalition 29 W131 Blair 3606 Bridge Avenue West Chicago,IL 60485 Cleveland, OH 44113 708-293-7449 216-281-6468 Fax: 312-357 0323 c/o Annette Yeager Fax: 216-961-0004 Susan L. Hiatt Tribal Organizations Director Ohio Citizens for Responsible Energy, Inc.
Robert Holden 8275 Munson Road Project Director Mentor, OH 44060-2406 Nuclear Waste Project 216-255 3158 National Congress of American Indians Fax: 216-255-3158 (call first) 900 Pennsylvania Avenue, SE Washington, DC 20003 David A. Kraft 202 546-9404 President 301-808-5238 00 Nuclear Energy Information Services Fax: 202-546-3741 2773 Garrison Evanston,IL 60201 Local Government P.O. Box 1637 Evanston, IL 60204-1637 Erv Hall 708-869-7650 Supervisor Environmental Contingency Unit Carolyn Raffensperger Cuyahoga County Board of Health Illinois Environmental Council i Playhouse Square 930 Dunlop 1375 Euclid Avenue Forest Park,IL 60130 Cleveland, OH 44115 708-366-5535 216 443-7520 Fax: 708-366 5535 Fax: 216-443-7537 Mary P. Sinclair, Ph.D.
J. Donald Foster Co-Chair City Administrator Don't Waste Michigan City of West Chicago 5711 Somerset Drive P.O. Box 488 Midland, MI 48640 475 Main Street 517-835-1303 West Chicago,IL 60185 Fax: 517-835-7954 708-293-2212 Fax: 708-293-3028
T.
l State Government Mike C. Williams Manager, Nuclear Services j
David W. Minnar Union Electric Company l
Chief, Licensing and Registration Health P.O. Box 149 Division of Radiological Health 1901 Chouteau Avenue l
Michigan Department of Public Health St. I.ouis, MO 63166
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3423 North legan Street 314-554-3766 P.O. Box 30195 Fax: 314-554-3558 l.ansing, MI 48909 l
j Fax: 517-335-8706 l
517-335-8200 Fuel Cycle Industry j
Robert W. Sharkey i
j Richard Allen Manager of Radiological Protection l
Office Manager, Office of ABB Combustion Engineering l
Environmental Safety 100 Prospect Hill Road l
j Illinois Department of Nuclear Safety P.O. Box 500 1035 Outer Park Drive Windsor, CT 06095 Springfield,IL 62704 203-285-4721 l
217-782 1322 Fax: 203-285-4710 Fax: 217 524-4724 Jack E. Honey.
Robert E. Owen Regulatory Affairs Manager j
Chief Alliod-Signal Inc.
i Bureau of Radiological Health Metropolis Works j
Ohio Department of Health U.S. Route 45 Nonh l
35 Chestnut Sireet P.O. Box 430 i
l P.O. Box 118 Metropolis,IL 62960 i
Columbus, OH 43266-0118 618 524-6245 l
614 4 44 2727 Fax: 618-524 4239
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Fax: 614-644-1909 1
Medical Community and Non-Fuel Cvele Inductry
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Nuclear Utilities 1
Mark Doruff Frank Rescek Manager i
j Commonwealth Edison Environment & Safety Regulatory Affairs l
125 S. Clark Street Amersham Corporation -
12th Floor - Room 1248 2636 South Clearbrook Dnvc Chicago,IL 60603 Arli.ngton Heights,IL 60005 P.O. Box 767 708-593-6300 1
Chicago,IL 60603 Fax: 708-437-1699 I
312-294 3932 l
Fax: 312-294-4403 Henry D. Royal, M.D.
Asweiste Professor Washington University School of Medicine 510 South Kingshighway Boulevard l
St. Louis, MO 63110 l
314 362 2809 i
Fax: 314-362-2806 i
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J Qcantm Contractor il S. Nuclea Reculatmv Comminion i
Alfred N. Johnson Francis X. (Chip) Cameron Scientific Ecology Group (SEG)
Special Counsel for Public Liaison P.O. Box 2530 and waste Management 1560 Bear Creek Road Office of the General Counsel l
Oak Ridge, TN 37830 U.S. Nuclear Regulatory Commission 1
615 4 81-0222-11555 Ro:kville Pike Fax: 615-482-7206 Rockville, MD 20852 l
301-504-1642 Profession al Society / Standard Setting Fax: 301-504 1657 Orcanizations Donald A. Cool, Ph.D.
Herman Cember, Ph.D.
Branch Chief l
Health Physics Society Radiation Protecalca and Health Effects Branch De Technological Institute U.S. Nuclear Regulatory Commission 1
I Northwestern University Division of Regulatory Applications Evanston,IL 60208 DRA/RPHUB 5650 Nicholson Lane 708-491-4008 Mail Stop NLS139
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Fax: 708491 4011 Rockville, MD 20852 f
301-492 3785 Robert G. Romas, Ph.D.
Fax: 301-492 3866 American Nuclear Society ER-203 Michael F. Weber 9700 S. Cass Avenue Section Leader, Regulatory Issues Section Argonne,IL 60439 Low-Level Waste Management 708 252-4167 Decommissioning Fax: 708 252 2959 U.S. Nuclear Regulatory Commission
!!555 Rockville Pike U.S. Environmental Protection Agency Rockville, MD 20852 Mail Stop SE4 Allan C. Richardson Washington, DC 20555 l
3 Office of Radiation and Indoor Air 301-504-1298 t
U.S. Environmental Protection Agency Fax: 301-504-2260 MC-6602 3 401 M Street, SW Washington, DC 20460 202 233-9290
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Fax: 202-233-9629 l
Pamela Russell i
i Office of Radiation and Indoor Air U.S. Environmental Proter tion Agency MC-6603 J l
401 M Street, SW Washington, DC 20460 202 233-9340
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Fax: 202 233 % 50 i
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TxKeystone Center i
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Michael T. Lesnick, Ph.D.
I Senior Vice President l
i The Keystone Center j
P.O. Box 8606 Keystone, CO 80435-0643 r
j 303-468-5822 i
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Fax: 303-262-0152 i
Qonnie Lewis Senior Associate a
The Keystone Center l
t P.O. Box 8606
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i Keystone, CO 80435-0043
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i 303-468-5822 Fax: 303 262-0152 t
a Denise A. Siebert 1
Administrative Assistant
%e Xeystone Center i
P.O. Box 8606 Keystone CO 80435-0643 303-468 5822 Fax: 303 262 0152 Barbara L. Stinson it Associate he Keystone Center P.O. Box 8606 Keystone, CO 80435-0643 303-468 5822 4
Fax: 303-262-0152 j
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FRZ:EYSTOVE CENTER TO:
321 534 3725 f%R 2 1993 9:m em 9,
NRC Radiological Criteria Workhops February 23-24,1993 San Francisco, California l
Particinant List Citizen / Environmental Orcanizations James Adams Paige Knight Principal Consultant Northwest Environmental Advocates Redwood Alliance 133 Southwest Second Avenue P.O. Box 293 Suite 302 7618th Street Portland, OR 97204 3526 Suite 4 503 295-0490 Arcata, CA 95521 Fax: 503-295-6634 707-822-7884 or 707 826-7719 Fax: 707-822-7007 Marion Pack Executive Director Jacqueline Cabasso Alliance for Survival Western States Legal Foundation 200 North Main Street 1440 Broadway, Suite 500 Suite M-2 Oakland, CA 94612 Santa Ana, CA 92701 510-839 5877 714-547 4282 Fax: 510-839-5397 Fax: 714 547 4 322 Greg DeBruler Tribal Orannirations Columbia River United P.O. Box 667 Russell Jim BinEen, WA 98605 Yakima Indian Nation 509-493-2808 P.O. Box 151 Fax 503-386-2108 Toppenish, WA 98948 509 865-5121 Dan Hirsch Fax: 509-877-4101
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Committee ridge the Gap N'
1637 Bu r Avenue Local Government g
Suite 3
14 Angeler,, CA 90025 Commissioner Fran Bessermin 1(
0-478-0829 Stephens County Fax: 310-4784820 P.O. Box 191 Colville,WA 99114 Marylia Kelley 509 4 84-3757 Tri-Valley CARES Fax: 509 4 84-8310 5720 East Avenue Suite #116 1.!vermore, CA 94550 510-443-7148 Fax: 510 443 0177
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- FR:M: KEYSTONE CENTER TO:
321 534 3725 mR 2 1993 9:
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State Government Edgar D. Bailey E. Scott Medling i
California Radiologic Health Branch Southern California Edison Environmental Health Division 23 Parker Street j
State Department of Health Services Irvine, CA 92718 l
714/744 P Street 714-454-4550-P.O. Box 942732 Fax: 714-454-4475 Sacramento, CA 94234-7320 916-322-3482 Vernon Shockley 1
Fax: 916-324 3610 Washington Public Power Supply System P.O. Box 968 Ray D. Paris Richland, WA 99352 Manager 509 377-8375 i
Radiation Control Section Fax: 509-377-8097
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Oregon Health Division Department of Human Resources Fuel Cvele Industry l
800 N.E. Oregon Street l
Portland, OR 97232 Richard Burklin l
503 731-4014 Health Physicist j
Fax: 503-731-4081 Siemens Power Corporation 2101 Horn Rapids Road i
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David A. Stewart-Smith P.O. Box 130 l
Oregon Department of Energy Richland, W A 99352-0130 l
l 625 Marion Street, NB 509-375 8638 1
Salem, OR 97310 Fax: 509-375-8402 503 378-4649 Fax: 503-373-7806 Jay W. Davis 4
Senior Engineer T.R. Strong UMETCO Minerals Corporation Director 2754 Compass Drive, Suite 280 l
Division of Radiation Protection P.O. Box 1029 Department of Health, LE 13 Grand Junction, CO 81506 Airdustrial Center Building #5 303-245-3700 P.O. Box 47827 Fax: 303 245 7543 j
Olympia, WA 98504 7827 2
206-586-R949 Medical Communhv and Non-Fuel Cvele l
Fax: 206-753-1496 Industry i
Nuclear Utilities Robert E. Carretta, M.D.
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Director David Duke Nuclear Medicine Department PG&E Roseville Community Hospital 77 Beale Street, Room 1405 333 Sunrise Avenue San Francisco, CA 94106 Roseville, CA 95661 415-973-3251 916-781-1544 Fax: 415-972 2233 Fax: 916 781-1935 l
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331 534 3725 N
2, 1993 9:h am %
l Medient Community and Non-Fuel Cycle Industry (continued)
W[E Jan Kirsch, h Kenneth R. Kase, Ph.D.
/10 3085 Shas
. cad Department of Radiation Physics
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Berkely, CA 94708 Stanford Linear Acceleration Center 51 Y84-4903 P.O. Box 4349
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x: 510-784-2076 Stanford, CA 94309 415-926-2045 Cleanun Contractor Fax: 41S 9264 999 Richard Fasnacht U.S. Environmental Protection Acency Director of Projects NUS Eugene Durman 1411 Opus Place Deputy Director Downers Grove, IL 60515 Office of Radiation and door Air 705-769-1110 U.S. Environmental Pr ection Agency Fax: 708 769-1115 MC-6601J 401 M Street, SW Peter Straun Washington, DC 2 Senior Consultant 202-233-9320 MHB Technical Anociates Fax: 202 233-9651 1723 Hamilton Avenue Suite K Pamela Russell San Jose, CA 95125 Office of Radiatiop and Indoor Air 408-266 2716 U.S. Environmernal Protection Agency Fax: 408-266 7149 MC-6603-J 401 M Street, Professionni Societv/ Standard settine Washington, C 20460 Orcanirations 202-233-934 Fax: 202-23 9650 Joel Cehn American Nuclear Society Anthon 4o!barst Health Physicists Section ef Applied Sciences Company Office Radiation and Indoor Air 1036 Hubert Road U.S. Esvironmental Protection Agency Oakland, CA 94610 MC 6663 J 510-268 1571 401 M' Street, SW Fax: same as phone Washington, DC 20460 202 233-9392 Jerry Cohen Fax: 202 233-9650 American Nuclear Society Health Physicists SAIC Suite 310 4900 Hopyard Road Pleasonton, CA 94588 510463-8111 ext. 2101 Fax: 510416-2701
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NRC Site Cleanup Criteria Workshops March 12-13,1993 e
Cambridge, Massachusetts I
f Participant List i
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Citizen / Environmental Oreanizations 1
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- Robert A. Backus David Sles'mger -
J Attorney New England Clamshell Alliance l
Seacoast Anti-Pollution 1.cague.
P.O. Box 724 i
116 Lowell Street Portsmith, NH 03801 i
Box 516 2 Florence Street j
Manchester, NH 03105 Roslindale, MA 02131 1
j 603-668-7272 603-431-4163 i
Fax: 603-668-0730 Fax: 617-323-0115 i
r Beth Hildt Tribal CRMN Seabrook i
j P.O. Box 475 John Brown West Newbury, MA 01985 Tribal Council Member j
508-465-5916 Narrangansett Inthan Tribe Fax: 508-462-3959 4375 South Country Trail P.O. Box 268 j
Dale MacLeod Charlestown, RI 02813 l
Citizen's Awareness Network 401-364-1117 i
P.O. Box 83 Fax: 401-364-1104 i
L 25 Main Street Shelburne Falls, MA 01370 Local Govw - -r 413-625-9881 Fax: 413 425-6830 Col. Willard F. Boyle (retired)
Seabrook Decomminionmg Finance Committee James Perkins 463 New 7en1=nri Road Board President Seabrook, NH 03874 New England Coalition on Nuclear Pollution 603-926-2465 Route 1 Box 423 Wayne, ME 04284 Jane Flemmg 207 485-9604 Duxbury Nuclear Advisory Committee Fax: same as phone 8 Oceanwood Drive Duxbury, MA 02332 Judy Scotnicki 617-934-7451 Citizen Research and Environmental Watch Fax: 617-585-8201 52 Prairie Street Concord, MA 01742 508-369-7146 Fax: 508-369-0885 l
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State Government Fuel Cvele Industry 1
i Kevin T.A. McCarthy Alden R. Gihnan Director Vice President, Health / Safety Radiation Control Division Nuclear Metals, Inc.
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Department of Environmental Protection 2229 Main Street 165 Capitol Avenue Concord, MA 01742 4
Hartford, CT 06106 508-369-5410 ext. 296 l
203-566-5134 Fax: 508-369-5410 ext. 526 Fax: 203-566-6032
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Jack C. Moulton i
Diane E. Tefft Senior Consultant Administrator ABB Combustion Engineering -
New Hampshire Bureau of Radiological Health 1000 Prospect Hill Road Division of Public Health Services P.O. Box 500 Health & Welfare Building Windsor, CT 06095-0500 r
6 Hazen Drive 203-285-5200 Concord, NH 03301-6527 Fax: 203-285-5202 t
603-271-4588
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Fax: 603-225-2325 Medical Community and Non. Fuel Cvele Industry Robert T. Watkms Dennis O. Dumas l
Senior Radiation Scientist Manager, Safety; RPO j
Radiation Control Program du Pont Merck Pharmaceutical Company Massachusetts Department of Public Health 331 Treble Cove Road 305 South Street North Billerica, MA 01862-2897 l
7th Floor 508 4 71-8669
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Jamaica Plain, MA 02130 Fax: 508471-8812 617-727 4 214 i
Fax: 617-727-2098 Leonard R. Smith, Ph.D.
E.1. du Pont Nuclear Utilities 549 Albany Street Boston,MA 02118 John Kelly 617-350-9111 Director of Radiological & Environmental Support New York Power Authority Tom Winters, M.D.
123 Main Street Associate Clinical Professor of Medicine White Plains, NY 10601 University of Boston School of Medicine 914-681-6298 Director Medsite Occupation Health Center Fax: 914-681 4 256 1 Enterprise Drive i
North Quincy, MA 02171 Russ Mellor 617-472-9925 Yankee Atomic Electric Company Fax: 6"'4794483 580 Main Street Boston, MA 01740-1398
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508-7794711 ext. 2203 Fax: 508-7794711 ext. 6735 i
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FROM: KEYSTONE CENTER TO:
321 504 3725 t%R 2 1993 9:W m3ert p.m j
Nuclear Reculatory Commission The Keystone Center Staff Francis X. (Chip) Cameron Michael T. Lesni Ph.D.
Special Counsel for Publi laison Senior Vice President and Waste Management The Keystone C 'nter Omce of the General Counsel P.O. Box 8606 U.S. Nuclear Regulatf'y Commission Keystone, CO 0435-80435 11555 Rockville Pikp 303-46S-5822
)
Rockville, MD 2 2
Fax: 303-262 152 301 504-1642 l
Fax: 301-504-37 5 Connie Lewi j
Senior Asso ate j
Donald A. Co, Ph.D.
The Keysto Center 4
j Branch Chief P.O. Box Radiation Protection and Health Effects Branch Keystone, O 80435 80435 U.S. Nucles'r Regulatory Commission 303-468-5 2 4
Division of Regulatory Applications Fax: 303 2-0152 Washingtoh,DC 20555 301-492-3785 Denise 3. Siebert Fax: 301492-3866 Administrative Assistant The Ke stone Center Micha F. Weber P.O.
x 8606 Sectiod Leader, Regulatory Issues Section Keystone, CO 80435 80435 14wOvel Waste Management &
303
-5822 Deco /nmissioning Fax: 03-262-0152 U.S Nuclear Regulatory Commission M
Stop 5E4 Bar ara L. Stinson W hington, DC 20555 Ar ciate 3,1 504-1298 Th Keystone Center Fax: 301-504-2200 P.
. Box 8606 K ystone, CO 80435-80435 3 3-468-5822
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Cleanuo Contractors William J. Manion President Keith H. Dinger 2
Nuclear Energy Services, Inc.
Health Physics Society 44 Shelter Rock Road 23 Prospect Street Danbury, CT 06810 Somersworth, SH 03878 203 796-5220 207-438-1283 Fax: 203-743-2459 Fax: 207-438-1798 Professional Societv/ Standard Settine Dianne Quigley Orcanizations/ Academic Executive Director Childhood Cancer Research Institute Professor Herb Bernstein 747 Main Street Professor of Physics & Director of ISIS Concord, MA 01742 Institute for Science & Interdisciplinary Study 508-287-0023 Hampshire College Fax: 505-287-0025 Amherst, MA 01002 413-549-4600 ext. 573 U.S. Environmental Protection Acency Fax: 413-549-0707 Allan C. Richardson Joseph M. Cardito Office of Radiation and Indoor Air American Nuclear Society U.S. Environmental Protection Agency Stone & Webster Engineering Corporation MC-6602-J 245 Summer Street 401 M Street, SW Boston, MA 02210 Washington, DC 20460 617-589-6938 202-233-9290 Fax: 617-589-2156 Fax: 202-233- % 29 Pamela Russell Office of Radiation and Indoor Air U.S. Environmental Protection Agency MC-6603-J 401 M Street, SW Washington, DC 20460 202-233-9340 Fax: 202-233-%50
~
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l Nuclear Rerulatory Commission The Keystone Center Staff l
Francis X. (Chip) Cameron Michael T.12 snick, Ph.D.
l Special Counsel for Public Liaison Senior Vice President i
and Waste Management The Keystone Center l
Office of the General Counsel P.O. Box 8606 U.S. Nuclear Regulatory Commission Keystone, CO 80435-7998 I
11555 Rockville Pike 303-468-5822 Rockville, MD 20852 Fax: 303-262-0152 I
301-504-1642 i
Fax: 301-504-3725 Connie 12wis l
Senior Associate i
Donald A. Cool, Ph.D.
The Keystone Center i
Branch Chief P.O. Box 8606 i
Radiation Protection and Health Effects Branch Keystone, CO 80435-7998 U.S. Nuclear Regulatory Comnussion 303-468-5822 Division of Regulatory Applications-Fax: 303-262-0152 Washington, DC 20555 i
301-492-3785 Denise A. Siebert Fax: 301-492-3866 Administrative Assistant The Keystone Center i
Michael F. Weber P.O. Box 8606 Section Izader, Regulatory Issues Section Keystone, CO 80435-7998 Low-Level Waste Management &
303-468-5822 l
Decommissioning Fax: 303-26 0152 U.S. Nuclear Regulatory Commission j
Mail Stop SE4 Barbara L. Stinson
}
Washington, DC 20555 Associate 1
301-504-1298 The Keystone Center Fax: 301-504-2260 P.0, Box 8605 Keystone, CO 80435-7998 F
l 303-468-5822 i
Fax: 303-262-0152 l
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o NRC Site Cleanup Criteria Workshops March 23-24,1993 Dallas, Texas PARTICIPANT LIST l
Citizen / Environmental Orcanizations Mavis Belisle Janet Gordon Peace Farm Director, Citizens Call HCR 2 Box 25 Chair, National Committee for Radiation Victims Panhandle, TX 79068 126 South 1400 West 806-335-1715 Cedar City, UT 84720 l
Fax: 806-359-3284 801-586-4808 l
Fax: 801-586-8021 l
Betty Brink l
Citizens for Fair Utility Regulation Laraine Hofstetter l
7600 Anglia Drive Southwest Organizing Project l
Fort Worth, TX 76140 5018 Third Street, SW 817-478-6372 Albuquerque, NM 87105 l
Fax: 817-927-8939 505-247-8832 Fax: 505-247-9972 i
George Crawford Board Member Alva Morrison Citizens Association for Sound Energy Field Organizer 1426 South Polk The Water Information Network i
Dallas, TX 75225 P.O. Box %
214-946-9446 Tres Piedras, NM 87577 Fax: 214-946-9446 (call first) 505-758- % 52 i
Carrie Dickerson David Platerio Citi7en Action for Safe Energy Consultant 3609 East Blue Starr Drive Western Sho hone Claremore, OK 74017 1636 Sagebrush 918-341-3494 Elko, NV 89801 Fax: 918-341-1074 702-738-3618 Fax: 702-753-5439 Don Gardner Texas Campaign for Global Security Tribal Orranizations 13903 Murfm Road Austin, TX 78734 Dwayne Beavers 512-263-2586 Cherokee Nation OES P.O. Box 948 Tahlequah, OK 74465 918-458-5498 Fax: 918-458-5499 i
.. ew
i Joe Campbell Greta J. Dieus Assistant Secretary Treasurer Director 3
Mdewakanton (Prairie Island) Tribal Council Division of Radiation Control and j
5750 Sturgeon Lake Road Emergency Management i
Welch, MN 55089 Arkansas Department of Health 800-554-5473 4815 West Markham Street l
Fax: 612-385-0640 Slot 30 Little Rock, AR 72205-3867 Lance Hughes 501-661-2301 Director Fax: 501461-2468 Native Americans for a Clean Environment P.O. Box 1671 Lloyd A. Kirk Tahlequah, OK 74465 Environmental Kn,,
918-458-4322 Oklahoma State Department of Health 301-270-5518 (Counsel) 1000 N.E.10th Street L
i Fax: 918-458 4322 Oklahoma City, OK 73117-1299 405-271-5221 Merv Tano Fax: 405-271-3458 Council of Energy Resource Tribes i
1999 Broadway Ruth E. McBurney Suite 2600 l
Bureau of RaAntion Control Denver, CO 80202 Texas Department of Health 303-297-2378 1100 West 49th Street Fax: 303-296-5690 Austin, TX 78756-3189 512-834 4 688 local Government i
Fax: 512-8344690 4
Ray Wadas Roben M. Quillin Mayor Division Director s
102 J Avenue Radiation Control Division i
Johnstown, CO 80534 Colorado Department of Health 303-587-4664 4300 Cnerry Creek Drive, South Fax: 303-587-0141 l
(RCD-DO-BI) i Denver, CO 80222-1530 State Government 303 4 92-3030
' i Fax: 303-782-5083 Richard P. Brackin Program Manager Euchar Utilities Radiation Protection Division P.O. Box 82135 -
}
Howard W. Bergendahl Baton Rouge, LA 70884-2135 Technical Services 504-765-0115 Houston Lighting & Power Company Fax: 504-765-0220 MS-N2008 P.O. Box 289
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Wadsworth,TX 77483 512-972-7779 Fax: 512-972-7760 ~
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Dan Williams Donald A. Podoloff, M.D.
Entergy Operations, Inc.
Society of Nuclear Medicine Arkansas Nuclear One U.T. M.D. Anderson Cancer Center Route 3, Box 137G Department of Nuclear Medicine Russellville, AR 72801 1515 Holcombe Boulevard, Box 83 501-964-8628 Houston, TX 77030 Fax: 501-964-8679 713-792 4535 Fax: 713-792-3549 Fuel Cvele Industry Cleanuo Contractors Edwin T. Still Vice President & Director PhilGravcs Environmental Health Management Division Quadrex Recycle Center Kerr-McGee Corporation 109 Fut Road 123 Robert S. Kerr Avenue Oak Ridge, TN 37830-7033 McGee Tower, P.O. Box 25861 615-482-5532 Oklahoma City, OK 73125 Fax: 615-482-5605 405-270-2934 Fax: 405-270-3010 Ed Parsons Scientific Ecology Group John S. Dietrich 16805 Weld County Road 19%
Vice President, Regulatory Platteville, CO 80651 Affairs 303-620-1647 Sequoyah Fuels Corporation Fax: 303-260-1625 P.O. Box 610 Gore, OK 74435 Professional Societv/ Standard Settinc 918-489-3207 Orcanizations Fax: 918-489-2291 Frank P. Crum Anthony J. Thompson, Esquire American Nuclear Socie'ty American Mining Congress Ixckheed Environmental Systems & Technologies Perkirs Cole, 60714th Street, NT Company Washington, DC 20005 4010 Moorpark Avenue, Suite 104 202-628-6600 San Jose, CA 95117 Fax: 202-434-1690 408-554-8679 Fax: 408-554-8679 Medical Community and Non-Fuel Cvele Industry Leon West, Ph.D.
Lawrence D. Egben M.D., MPM.
Health Physics Society Department of Anesthesiology Mechanical Engineer Department i
Parkland Memorial Hospital University ef Arkansas Dallas, TX 75235-9068 Fayettevil!< AR 72701 214-590-8536 501-575-3449 Fax: 214-590-6945 Fax: 501-575-6982
j
^
I l
U.S. Envitenmental Protection Agency The Kn21pne Center Staff t
i Pamela Russell Michael T. Lesnick, Ph.D.
i Office of Radiation and Indoor Air Senior Vice President I
U.S. Environmental Protection Agency The Keystone Center MC-6603-J P.O. Box 8606 401 M Street, SW Keystone, CO 80435 4 643 i
Washington, DC 20460 303-468-5822 202-233-9340 Fax: 303-262-0152 Fax: 202-233-9651 l
i Connie 12wis Nuclear Reiulatory Commission Senior Associate The Keystone Center Francis X. (Chip) Cameron P.O. Box 8606 Special Counsel for Public Liaison Keystone, CO 80435-0643 l
and Waste Management 303-468-5822 Office of the General Counsel Fax: 303-262-0152 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Demse A. Siebert Rockville, MD 20852 Administrative Assistant 301-504-1642 The Keystone Center Fax: 301-504-3725 P.O. Box 8606 Keystone, CO 80435-0643 Donald A. Cool, Ph.D.
303-468-5822 Branch Chief Fax: 303-262-0152 4
i Radiation Protection and Health Effects Branch U.S. Nuclear Regulatory Commission Barbara L. Stinson 4
Division of Regulatory Applications Associate
]
Washington, DC 20555 The Keystone Center
{
301-492-3785 P.O. Box 8606 i
Fax: 301-492-3866 Keystone, CO 80435 4 643 303-468-5822 1
Michael F. Weber Fax: 303-262-0152 Section leader, Regulatory Issues Section f
Low-Level Waste Management &
.i
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Decommissioning U.S. Nuclear Regulatory Commission Mail Stop SE4 j
Washington, DC 20555 301-504-1298 Fax: 301-504-2260 4
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NRC Site Cleanup Criteria Workshops April 13-14,1993 King of Prussia, Pennsylvania Participant List Citizen / Environmental Orranizations Caspar W. Hiatt IH, Ph.D.
Joel Roth President Vice Chair Chesapeake' Environmental Protection NRC's Advisory Panel on Three Mile Island Association 254 Boas Street 861 Cumberstone Road Harrisburg, PA 17102 Harwood, MD 20776 717-236-6489 410-867-2436 Fax: 301-261-7954 Tribal Orcanizations Susan Griffin Robert Holden Don't Waste New York Project Director Box 303A Nuclear Waste Project South Plymouth, NY 13844 National Congress of American Indians 607-753-0106 900 Pennsylvania Avenue, SE Fax: 607-753-7257 Washington, DC 20003 202-546-9404 Judith Johnsrud, Ph.D.
Fax: 202-546-3741 Director Environmental Coalition on Nuclear Power Marvin Osborne 433 Orlando Avenue Community Response Coordinator State College, PA 16803 Shoshone-Bannock Tribe 814-237-3900 P.O. Box 306 Fax: 814-237-3900 (call first)
Fort Hall, ID 83203 208-238-3837 Carol Mongerson Fax: 208-237-0797 Coalition on West Valley Nuclear Wane 10734 Sharp Street Local Government East Concord, NY 14055 716-941-3168 Ernest Fuller Fax: 716-941-3168 Member, Bedford County Planning Committee Vice-Chair, Bedford-Fulton-Huntington Samuel E. Pinkard Solid Waste Authority Chairman RDI Box 216 Monteclair Radon Task Force Six Mile Run, PA 16679 P.O. Box 757 814-928-5416 Monteclair, NJ 07042 Fax: 814-928-4257 201-724-6059 Fax: 201-724-3909
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l Eric N. Johnson John A. Kadlecek, Ph.D.
Assistant Public Health Director Environmental Radiation Specialist D i
NYS CAC on LLRM Disposal Bureau of Radiation l
Cortland County Health Department Division of Hazardous Substances Regulation d
60 Central Avenue New York State Department of l
l P.O. Box 5590 Environmental Conservation Cortland, NY 13045 50 Wolf Road, Room 506 l
607-753-5034 Albany, NY 12233-7255 i
1 Fax: 607-753-5392 518-457-2225 I
l Fax: 518-485-8390 i
l Cindee Virostek Councilwoman Robert Stern Apollo Borough Council Chief, Radiation Protection Programs Citizens Advisory Committee Chairperson New Jersey Department of Environmental l
l 409 N 8th Street Protection
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Apollo, PA 15613 729 Alexander Road 412-478-2351 CN415 Fax: 412-567-7925 Trenton, NJ 08625-0415
[
609-987-2101 (beeper) l State Government Fax: 609-987-6390 J
Hal Brodie Nuclear Utilities Senior Counsel New York State Energy Research and Richard W. Dubiel Development Authority (NYSERDA)
Philadelphia Electric Company j
2 Empire State Plaza 52C-1, Nuclear Group Headquarters j
Albany, NY 12223 955-65 Chesterbrook Boulevard
[
j 518-465 4 251 ext. 280 Wayne, PA 19087-5691
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q Fax: 518-486-5246 215-640 4631 Fax: 215-640 4629 1
William P. Dornsife l
Bureau Director Michael J. Slobodien
.sureau of Radiation Protection Radiological Controls Director Pennsylvania Department of Environmental Oyster Creek Nuclear Station Resources General Public Utilities Sulton Building P.O. Box 388 a
Third and Iocust Streets; Box 8469 Forked River, NJ 08731-0388 I
Harrisburg, PA 17101-8469 609-971-4709 717-787-2480 Fax: 609-971-4627 Fax: 717-783-8%5 Roland G. Fletcher i
Administrator
- i l
Radiological Health Program l
Maryland Department of the Environment I
2500 Breening Highway Baltamore, MD 21224 410 431-3300 l
Fax: 410431-3198 L
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Fuel Cycle Industry Professional Societies / Standard Selling Orcanizatipa Don K. Sgarlata Supenisor, Nuclear Safety &
Sydney W. Porter, Jr.
Pagulatory Compliance Health Physics Society bhcock & Wilcox 125 Argyle Road Pennsylvania Nuclear Services Operations Ardmore, PA 19003 B & W Nuclear Environmental Services, Inc.
215-896-5353 R.D. I Box 355 Fax: 215 442-7804 Vandergrift, PA 15690 412-842-1412 Donald F. Schutz, Ph.D.
Fax: 412-842-1478 or 1499 American Nuclear Society c/o Teledyne isotopes A. Joseph Nardi 50 Van Buren Avenue Manager Westwood, NJ 07675 ES License Administration 201-664-7070 Westinghouse Electric Corporation Fax: 201 4 64-4617 P.O. Box 355 Pittsburgh, PA 15230-0355 U.S. Environmental Protection Acency 412-374-4652 Fax: 412-374-5738 Allan C. Richardson Office of Radiation and Indoor Air Medical Community and Non-Fuel Cvele Industry U.S. Environmental Protection Agency MC-6602-J Roy W. Brown 401 M Street, SW Manager, Regulatory Compliance Washington, DC 20460 Mallinckrodt Medical, Inc.
202-233-9290 2703 Wagner Place Fax: 202-233- % 29 Maryland Heights, MO 63043-3493 314-344-3977 Pamela Russell Fax: 314-344-3998 Office of Radiation and Indoor Air
.U.S. Environmental Protection Agency Cleanun Contractors MC-6603-J 401 M Street, SW Barry Koh, Ph.D.
Washington, DC 20460 l
President 202-233-9340 B. Koh and Associates, Inc.
Fax: 202-233-%51 j
10211A South Dolfield Road Owings Mills, MD 21117-3653 410-356-6612 Fax: 410-356-4213 1
1 I
j Nuclear Reculatory Commission
'Ihe Keystone Center Staff Francis X. (Chip) Cameron Michael T. Lesnick, Ph.D.
Special Counsel for Public Liaison Senior Vice President and Waste Management The Keystone Center Office of the General Counsel P.O. Box 8606 l
U.S. Nuclear Regulatory Commission Keystone, CO 80435 I1555 Rockville Pike 303-468-5822 l
Rot kville, MD 20852 Fax: 303-262 0152 l
301-504-1642 Fax: 301-504-3725 Connie Iewis
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Senior Associate J
Donald A. Cool, Ph.D.
The Keystone Center J
Branch Chief P.O. Box 8606 i
Radiation Protection and Health Effects Branch Keystone, CO 80435 U.S. Nuclear Regulatory Commission 303-468-5822 4
Division of Resilatory Applications Fax: 303-262-0152
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Washington, DC 20555 301-492-3785 Demse A. Siebert Fax: 301-492-3866 Admmistrative Assistant
'Ibe Keystone Center l
Michael F. Weber P.O. Box 8606 i
Section Leader, Regulatory Issues Section Keystone, CO 80435 Low-Level Waste Management &
303-468-5822 j
Decommissioning Fax: 303-262-0152 l
U.S. Nuclear Regulatory Commission Mail Stop SE4 Barbara L. Stinson i
Washington, DC 20555 Associate i
301-504-1298 The Keystone Center Fax: 301-504-2260 P.O. Box 8606 Keystone, CO 80435 1
303-468-5822 Fax: 303-262-0152 i
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Attachment B PageI NRC SITE CLEANUP CRITERIA WORKSHOP
]
King of Prussia, Pennsylvania l
April 13-14,1993 Agenda i
Tuesday. April 13.1993 l
f 8:30 a.m.
Coffee i
9:00 a.m.
Welcome and Background Enhanced Participatory Rulemaking and the Establishment of Site Cleanup Criteria - Chip i
Cameron, NRC
{
What is the Enhanced Participatory Rulemaking Process and why has NRC selected it?
e Why does NRC want to develop cleanup criteria?
l e
9:20 a.m.
EPA activities regarding the establishment of site cleanup criteria - Allan Richardson, EPA i
t What are the key EPA activities and timeframe?
l e
In what ways is EPA interactmg with NRC?
9:40 a.m.
Workshop Format - Michael Lesnick, Barbara Stinson and Connie Lewis, The Keystone Center 8
e What are the goals and objectives?
[
What are the groundrules for conducting the workshop and what is the role of the i
e facilitators?
e What is the agenda? -
9:50 a.m.
Participant Introductions i
e Name, affiliation, and location e
Two important issues for discussion in the workshop 10:30 a.m.
Break
\\
10:45 a.m.
Decommissioning Process - Michael Weber, NRC j
e What is decomnussion' g?
[
m o
What licensed facilities are affected? -
i 11:00 a.m.
Brief Review of the Issues Paper - Don Cool, NRC 1
A WMwdtcM !
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PDge 2 11:15 a.m.
Introductory Discussion l
The Rulemaking Issues Paper identifies four possible fundamental objectives which could serve as the basis for a regulatory approach to site cleanup standards. The four fundamental objectives reDect alternative regulatory approaches to the development of decommissioning standards, either separately or in some combination with one another.
What are the relative advantages and disadvantages of developing generic standards through rulemaking as opposed to continuing the present case-by-case approach?
i 12:15 p.m.
Public Comment I
12:45 p.m.
Lunch 1:45 p.m.
Cross-cutting Issues Discussion - a discussion of the cross-cutting issues that can be used to compare and contrast the alternative regulatory approaches for developing sleanup standards j
A.
In what ways do the alternative regulatory approaches protect human health. safety and the environment?
i l
How will populations (s) and individuals (s) be protected, in what locations, and over what timeframe? What are the relative merits and problems with use. of each alternative regulatory approach?
i What level (s) of health protection should be sought? What are the relative merits of each alternative regulatory approach in terms of achieving this level?
Should a separate set of standards be established to protect natural systems? If so, how?
e 3:15 p.m.
Public Comment d
1 3:30 p.m.
Break i
3:45 p.m.
Cross-Cutting Issues Discussion (continued) l R.
What are the waste manarement imolications of each alternative regulatory approach?
How do each of the alternative regulatory approaches relate to the quantity and types of e
wastes produced?
To what extent would each alternative regulatory approach transfer the risk to another e
medium or popult. tion?
How should each alternative regulatory approach apply to former waste disposals?
To what extent does each alternative regulatory approach address other options for waste e
management, including reduction, recycling, and reuse?
5:15 p.m.
Public Comment 5:45 p.m.
Summary and Adjournment t
4e
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Page 3 6:00 p.m.
Cash Bar 6:45 p.m.
Pathfinder Decommissioning Video Presentation (AneM-Optional)
Dinner on Your Own Wednesdar. April 14.1993 8:00 a.m.
Coffee 8:30 a.m.
Cross-Cutting Issues Discussion (continued)
C.
How do the alternative regulatory approaches relate to existine federal. rerlonal. state and local reculatory frameworks?
To what extent do the alternative regulatory approaches achieve long-term, regulatory stability?
What should be the effect of new standards or information on prior decommissioning actions?
Will there be cases where release for
- unrestricted use* may be difficult to achieve? How should these situations be addressed?
To what extent are the alternative approaches consistent with Superfund objectives? Do they need to be?
10:00 a.m.
Public comment 10:15 a.m.
Break 10:30 a.m.
Cross-Cutting Issues Discussion (continued) i D.
To what extent should costs. technical capabilities. and imniementation considerations.
Including nonradiological risks and costs, be considered in selecting a regulatory approach for the standards?
What are the implementation considerations, including cost, that relate to alternative regulatory approaches?
What technical capabilities are necessary to implement the alternative regulatory approaches (e.g., remediation, site characterization, modelling, and cleanup technologies for lands, structures, and groundwater)?
l If a cost-benefit approach is used, what cost and benefits should be considered? Should individual or population (or both) doses be considered? If costs are balanced against dose averted, what value should be used in evaluating the ratio?
12:00 p.m.
Public Comment 12:30 p.m.
Lunch
Page 4 1:45 p.m.
Other Key issues (remaining issues not already covered) f How should the standards address the effect of radon releases?
1 Should critria be established for protecting specific pathways or resources (e.g.,
e groundwater)?
2:30 p.m.
Break 2:45 p.m.
Public Comment 3:15 p.m.
Summary of Workshop Issues and Workshop Feedback 4:00 p.m.
Adjourn i
i j
239\\07\\06-054d. phi 4
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Attachment C j
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[ d'h 3
w 3 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C.
20460
- g,,,e lik e D 9 2 OFFCE Or AIR AND RADATON Chip Cameron Special Counsel for Public Liaison Nuclear Regulatory Commission l
Washington, DC 20555
Dear Mr. Cameron:
~
I would like to thank you for participating in the first meeting of the Interagency Steering Committee on Radiation Clean-up Standards held on March 3, 1993.
A summary of the meeting is enclosed for your information.
Also enclosed are the minutes and briefing from the November 25, 1992 EPA /NRC meeting on Risk Assessment Harmonization.
The interest and support shown from each Agency / Office is appreciated and indicates that we will be successful in developing a sound regulation in a timely manner.
Several important issues were raised at the Steering Committee meeting which will be examined further at the interagency workgroup level.
Of primary and immediate importance is the prompt sharing of data about sites contaminated with radionuclides.
Coordination and cooperation among all the Steering Committee members will ensure timely resolution of this and other issues which arise during the rulemaking process.
I look forward to working with you and continuing our discussions at the next Steering Committee meeting.
If you have questions or comments before that meeting, please feel free to call ne at (202) 233-9320.
Sincerely, M
Margo T. Oge Director, Office of Radiation and Indoor Air Enclosures Pet 1eedon RecydedPaper
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on EPA Radiation Clean-Up Standards Interagency Steering Committee j"
March 3, 1993 Meeting Summary (Agenda Attached)
- 1. Introduction /Doenina Remarks
.i 1
Marco Oce. EPA /ORIA:
j OMB is currently focused on EPA's need to develop standards.
This committee was formed at OMB's suggestion.- Committee's purpose is to set priorities, ensure adequate resources, and j
ensure sppropriate coordination.
i EPA /ORIA will coordinate closely with DOE, NRC, DOD and will actively involve state and local governments, industry, public interest groups, environmental groups, etc. in the rulemaking process.
1 4
Margo Oge has instructed staff to have clean-up standards to OMB s
l by early 1994.
l 4
EPA /ORIA is working with NRC and participating in decommissioning ~
standards workshops.
i EPA /ORIA is also working closely with the Superfund office.
l j
Working on baseline analysis for NPL sites with radioactive waste j
(includes federal and non-federal facilities).
i l
Gordon Davidson.-EPA /OFFE:
l l
OFFE meeting with DOE; new administration wants high degree of
{
team work between Federal agencies.
Matt Hale, EPA /OSW:
Supports Margo oge's schedule; important to involve public, states, and waste management companies.
Must convince waste management companies to accept waste.
Pat Whitfield. DOE:
Benefit should be commensurate with cost.
DOE facilities are
, {
l
)l different from NRC sites.
Need a de minimis concentration level.
Public must be part of the decision-making process (Keystone i
Center involvement).
Recycle is needed as a practical matter; i
DOE wants to gain approval to recycle contaminated material but i
i no acceptance yet.
\\
Jim Turi. DOE i
EM-30 office supports this rulemaking. - DOE /EM-30 active waste
[
streams, differ from EM-40.
1 Lee Stevens. DOE:
1 Public acceptance is important.
Section 2901 of 1992 Energy Bill says that states are allowed to regulate disposal or off-site incineration of low-level radioactive waste that NRC exempts.
States are ready to do this.
Need standards to avoid a patchwork of state regulations.
j 1
I l
. ~...
1 Bob Bernero, NRC:
~
Need a sound scientific basis and consistent judgement on residual radioactivity issues.
Addressing the de minimis concept early in the standard-setting process is very important.
For example, DOE cannot dispose of lead acid batteries containing one atom of added uranium at the Portsmouth Gaseous Diffusion Plant; this is unreasonable.
Chio Cameron. NRC:
Two key aspects of Enhanced Participatory Rulemaking for Decommissioning Standards: 1) obtain comments and advice from affected parties before NRC develops draft proposed rule, 2) encourage dialogue among affected parties.
EPA is actively participating in the NRC rulemaking, helped to develop the NRC issues paper, and is participating in and efaluating comments from the workshop.
NRC and EPA have agreed to exclude NRC-licensed facilities from the EPA cleanup standard if EPA determines, through a public rulemaking process, ti.at NRC's requirements provide a sufficient level of protection.
Generic EIS to be done on rulemaking; scoping meeting planned for June 1993.
Draft proposed rule will be available for NRC and EPA review in Fall 1993.
NRC to issue proposed rule in April 1994.
Lewis D. Walker. DOD:
Army is the executive agent for disposal of DOD's radioactive waste.
Average cost for disposal in 1992 was $164/ft.
For 3
8 1993, cost is $320/ft.
Costs are increasing, and volume of waste is growing also.
DOD is working with local community during clean up at Army Materials Testing Lab in MA.
Public wants zero detection after cleanup.
Future use of site / restricted use is an issue.
A need exists for a cleanup level related to health risk.
Communicating with the public, providing answers to questions, and explaining issues are important to ensure public acceptance of rule (medical experts can help provide answers).
Depleted uranium is a major problem that DOD.-is dealing with.
- 2. Federal Radiation Protection Guidance A"llan Richardson. EPA /ORIA:
i Described process for revising Federal guidance.
Old guidance has individual and source specific focus.
Discussion of harmonization of risk goals and assessment methodologies.
Action:
Distribute papers from NRC/ EPA November 1992 meeting on risk assessment harmonization (copy attached).
Pat Whitfield. DOE:
More risk from chemicals than radiation; but we know more about radiation risks than chemical risks.
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Lewis D. Walker. DOD:
Contact with UK, Canada, and Germany is important.
- 3. Overview of EPA Clean-uD Standards / Technical SuDDort Barbara Hostage and Nick Lailas, EPA /ORIA, presented overview.
Nick Lailas requested the following existing data from all agencies present by June 1, 1993:
site characteristics, dose and risk estimates, and cost for a representative set of sites.
Marco Oce. EPA /ORIA:
Use 2-3 sites as reference sites for cost / benefit analysis.
i Bob Bernero. NRC:
Implementability of recycle / reuse is a key issue in the waste i
management standards.
Gordon Davidson. EPA /OFFE:
Will waste management standards include treatment standards for mixed waste?
I Marco oce. EPA /ORIA:
Use existing NACEPT advisory committee that reports to EPA Administrator to get input from the stakeholders on issues associated with the standards.
-Pat Whitfield and Lee Stevens. DOE:
Objected to the use of the term " legally defensible data."
Stevens suggested use of data quality objectives instead.
Points-of-Contact for Radiation Site Data Collection:.
Nick Lailas, EPA /ORIA Bill Wisenbaker, DOE /EM-40 Jim Turi, DOE /EM-30 i
Andy Wallo, DOE /EH-23 Lewis D. Walker or Randall Morin, DOD c
Mike Weber, NRC j
Melanie Barger, EPA /OFFE Matt Hale, EPA /OSW Henry Longest, EPA /OERR.
- 4. Radiation Control Criteria for Hasardous Waste Andy Wallo. DOE:
Goal of this project is to determine if there is a level of radioactive material in permitted waste for which it can be demonstrated that RCRA (or TSCA) regulations provide an equivalent level of protection as that provided by regulations under.the AEA.
Project expected to be completed by Fall 1993.
l EH is waiting to receive data from EM.
NRC could issue general i
or specific license to TSD facilities and EPA could issue guidance or give data to states to develop criteria.
Margo Dge l
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.1 would like to include in waste management standards.
Bob Bernero
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raised two issues: 1) if radioactive content is low, treat as i
hazardous waste, 2) if radioactive and hazardous content is high, criteria for disposal of the two types of waste are not the same.
t Wallo has been working with the following people: Reid Rosnick (EPA /OSW), Tony Wolbarst (EPA /ORIA), Pam Russell (EPA /ORIA), Nick Orlando (NRC), and Bob Meck (NRC).
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conclusion 4
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Margo oge. requested formation of an interagency workgroup to i
look at issues and regulatory /non-regulatory options and l
report to steering committee.
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Federal Guidance workgroup is not the correct grcup to work
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with to collect site information or develop waste screening criteria.
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I Agencies will provide site data for a representative set of sites to EPA in timely manner for EPA use, after agreement on format and content of the needed information.
l Next meeting to take place in 3-4 months.
Agenda for next j
j meeting should include an overview of the NRC workshop d
comments and EPA workgroup comments on the EPA issues paper.
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INTERAGENCY STEERING COMMITTEE MEETING ON RADIATION CLEAN UP STANDARDS i
March 3,1993 10:00am - 12:00pm Environmental Protection Agency Office of Radiation and Indoor Air (ORIA)
Judiciary Square Building 5013rd Street, NW AGENDA:
a introduction (10 min.)
Margo Oge, Director, Office of Radiation and Indoor Air, EPA i
e a DOE Presentation (10 min.)
a NRC Presentation (10 min.)
e DOD Presentation (10 min.)
a Federal Radiation Protection Guidance (15 min.)
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Allan Richardson, Deputy Director, Criteria and Standards Division, ORIA I
a Overview of EPA Clean-up Standards for Radiation Contaminated Sites (15 min.)
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Barbara Hostage, Chief, Radiation Studies Branch, ORIA E
a Technical Support to Standard Development (15 min.)
e Nick Lailas, Chief, Radiation Assessment Branch, ORIA a Mixed Waste issues (15 min.)
~
o Andy Wallo, Director, Air, Water and Radiation Division, Office of Environmental Guidance, DOE a Open Discussion 4
s Next Steps / Conclusion i
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EXECUTIVE OFFICE OF THE PRESIDENT k
omCE OF MANAGEMENT AND BUDGET l
WASWGTON. D.C. 20503 j
l January 19, 1993 Mr. James M. Taylor Executive Director for operations Nuclear Regulatory Commission i
g Washington, D.C.
20555 i
Dear Mr. Taylor:
My staff has been consulting with NRC, EPA, and DOE about 3
the need for the Administration to establish a process to develop criteria for allowable residual radioactivity in various j
materials.
During July 1992, my staff met with DOE and EPA staff about j
the desirability for OMB to help with this issue.
We requested
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that DOE identify specific problems encountered in its j
j environmental restoration and waste management programs both because of the lack of appropriate criteria and standards in this i
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area as well'as the need for the Administration to give this area l
sufficiently high priority so that these criteria could be established expeditiously.
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i Based on these discussions, we understand that one near-ters priority for DOE is for EPA to address the feasibility of l
establishing criteria for trace levels of radioactivity in hazardous waste that are currently classified as mixed wastes.
The absence of a clear regulatory approach for treating, storing, I
and disposing of these. wastes (i.e., complying with dual regulatory systems when one system may be adequate to provide for protection of the public and environment) has resulted in significant budgetary costs to DOE.
Furthermore, we understand i
there is an additional need for DOE and other Federal agencies for EPA to establish generally applicable criteria for a broader i
~ class of residual radioactive material.
such criteria would 1
apply to standards developed for cleanup of contaminated sites, to the release of decontaminated material and equipment, and to l
the management of radioactive waste.
EPA expressed the need for 1
OMB to support sufficient budgetary resources in order that such
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criteria could be established in a timely fashion.
Both agencies agreed that NRC's' participation is important to any future discussions.on'this subject..In addition, we believe DOD also is 1
an affected agency with similar concerns regarding residual radioactive material and, therefore, should also participate in future discussions.
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In light of these considerations, this is to suggest that a high-level steering committee be established composed of membership from DOE, EPA, DOD, and NRC with OMB in an advisory role.
This committee's focus would be the establishment of 8
3 standards for allowable cleanup of contaminated sites and allowable levels of radioactivity.in various materials, including the feasibility of the development of'eriteria for trace levels of radioactivity in hazardous wastes.
The goal of this committee is to ensure that appropriate coordination has been established, l
that timely schedules have been agreed upon, and that appropriate budgetary resources have been identified.
We recognize the importance activities already underway within the EPA-chaired 1
Interagency Working Group on Federal Guidance and those of the t
)
NRC to establish cleanup standards for its licensees and do not l
~ want to deter accomplishments associated with these activities.
i The steering committee will. serve to coordinate these interagency activities and minimize unnecessary' duplication of effort.
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If you have any questions about this issue, please contact Kathy Peroff (202) 395-3404 ~or Ron Cogswell (202) 395-4586.
sincerely, L6Wf J
Paul Gilman l
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Associate Director l
Natural Resources, l
Energy and Science j
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Bernero Cys:
Taylor EXECUTIVE OFFICE OF THE PRESIDENT Sniezek I,
OFFICE OF MANAGEMENT AND BUDGET O son
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WASHINGTON. D.C. 23503 W
THE DIRECTOR April 8, 1993 (O p
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Mr. James M. Taylor Executive Director of Operations Nuclear Regulatory Commission Washington, D.C. 20555-0001
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Dear Mr. Taylor:
3 Thank you for your letter expressing support for establishing an Interagency Steering Committee to develop residual radioactivity standards. We are pleased that the Nuclear Regulatory Commission (NRC) is participating in this effort with i
representatives from the Department of Energy, the Environmental Protection Agency (EPA), the Department of Defense and the Office of Management and Budget.
As you know, the Committee convened March 3,1993 at EPA under the leadership of Margo T. Oge, Director of EPA's Office of Radiation and Indoor Air. Mr.
Robert M. Bernero, Director, Office of Nuclear Material Safety and Safeguards, presented NRC's perspective at this meeting, and we look forward to his active participation in the process.
I was particularly pleased to learn that you believe committee efforts could complement the NRC/ EPA participatory rulemaking process to develop radiological criteria for decommissioning that would be applicable to NRC licensees. We look forward to working with you on this issue.
Sincerely, W _-
Panetta l
ctor d