ML20155C327

Requests Attendance at Next Meeting of Iscors to Be Held on 981210 at Epa,Wa Info Ctr.Various Topics Re Radiation Protection Issues & Subcommittee Actions Will Be Discussed. Draft Agenda for & Minutes for 980910 Meeting,Encl

ML20155C327
Person / Time
Issue date:	10/22/1998
From:	Greeves J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Schaeffer M, Wallo A, Weinstock L DEFENSE, DEPT. OF, ENERGY, DEPT. OF, ENVIRONMENTAL PROTECTION AGENCY
References
REF-WM-3 NUDOCS 9811020194
Download: ML20155C327 (76)

Text

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October 22, 1998

Dear Members of the Interagency Steering Committee on Radiation Standards:

I am writing to invite you to attend the next meeting of the Interagency Steering Committee on l

Radiation Standards (ISCORS) to be held on December 10,1998, from 1:00 p.m. to 4:00 p.m.

The meeting will be at the U.S. Environmental Protection Agency, Washington Information Center, at the Waterside Mall (WIC Room 17;202-260-7200),401 M. Street, S.W., Washington, D.C. This facility is located at the Green Line Exit: Waterfront Station. The purpose of this meeting is to j

discuss ongoing efforts on various topics relating to radiation protection issues and discuss J

subcommittee actions.

J A draft agenda for the December 10th meeting is enclosed along with the minutes from the i

September 10th meeting. Several Action items are identified in the September 1998 minutes.

i Two action items of primary interest to the committee, include submittal of recommendations on activities for 1999 and comments or recommended changes to the enclosed ISCORS charter.

j Please send your comments on these two items to the ISCORS coordinators by November 13th, to allow distribution to all members prior to the December 1998 meeting.

j i look forward to meeting with you on December 10th. If you have any questions about the meeting, please call me at (301) 415-7437 or Pat Santiago of my staff at (301) 415-7269 (internet: pas 2@nrc. gov).

Sincerely,

[ original signed by:]

i John T. Greeves, Director Division of Waste Management Office of Nuclear Material Safety i

and Safeguards

Enclosure:

As stated cc: See attached distribution lists i

DISTRIBUTION:

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UNITED STATES j

NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20065-0001

1. o October 22, 1998

• • • • 4

Dear Members of the Interagency Steering Committee on Radiation Standards:

I am writing to invite you to attend the next meeting of the Interagency Steering Committee on Radiation Standards (ISCORS) to be held on December 10,1998, from 1:00 p.m. to 4:00 p.m.

The meeting will be at the U.S. Environmental Protection Agency, Washington Information Center at the Waterside Mall (WIC Room 17;202-260-7200),401 M. Street, S.W., Washington, D.C. This facility is located at the Green Line Exit: Waterfront Station. The purpose of this meeting is to discuss ongoing efforts on various topics relating to radiation protection issues and discuss subcommittee actions.

A draft agenda for the December 10th meeting is enclosed along with the minutes from the September 10th meeting. Several Action Items are identified in the September 1998 minutes.

Two action items of primary interest to the committee include submittal of recommendations on activities for 1999 and comments or recommended changes to the enclosed ISCORS charter.

Please send your comments on these two items to the ISCORS coordinators by November 13th, 4

to allow distribution to all members prior to the December 1998 meeting.

1 look forward to meeting with you on December 10th. If you have any questions about the meeting, please call me at (301) 415 7437 or Pat Santiago of my staff at (301) 415-7269 (internet: pas 2@nrc. gov).

Sincerely, b

9.,,

John T. Greeves, Director Division of Waste Management Office of Nuclear Material Safety and Safeguards

Enclosures:

As stated cc: See attached distribution lists

c -

n ISCORS Distribution List Dated: 10/22/98 Deborah Kopsick, EPA /ORIA Mary' Clark, EPA /ORIA Frank Marcinowski, EPA /ORIA Dennis O'Connor, EPA /ORIA Allan Richardson, EPA /ORIA John Karhnak, EPA /ORIA Vicky Lloyd, EPA /ORIA Julie Rosenberg, EPA /ORIA Stephen Luftig, EPA /OERR Chuck Sands, EPA /OERR Bruce Means, EPA /OERR Michael Shapiro, EPA /OSW Barry Breen, EPA /OFFE Craig Hooks, EPA /OFFE David Levenstein, EPA /OFFE Cynthia Dougherty, EPA /OGWDW Michael B. Cook, EPA /OWWM Bob Bastian, EPA /OWWM Jeffrey Phillips, EPA /OSWER Matt Hale, EPA /OSW Subijoy Dutta, EPA /OSW Nancy Hunt, EPA /OSW Carl Paperiello, NRC/NMSS Malcolm Knapp, NRC/NMSS Michael Weber, NRC/NMSS Cheryl Trottier, NRC/RES Donald Cool, NRC/NMSS Cynthia Jones, NRC/NMSS Raymond Fatz, DOD/ Army David Auton, DOD/DNA Muhammad Owais, DOD/DNA Colonel Robert Cherry, DOD/ Army Peter Brush, DOE /EH-1 Raymond Berube, DOE /EH-4 John Tseng, DOE /EH-6 Paul Seligman, DOE /EH-6 Mark Frei, DOE /EM-30 James Fiore, DOE /EM-40 Jim Owendoff, DOE /EM-40 Randal Scott, DOE /EM-60 James Antizzo, DOE /EM-70 Colleen Ostrowski, DOE /EH-412 l

Rick Jones, DOE Chia Chen, DOL / OSHA Rick Boyle, DOT / Room 8430 Fred Ferate, DOT /MS DHM-23 Phil Frappaolo, FDA Carrie Jelsma, OMB/ Room 8026 Miriam Forman, OSTP 1

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e ALSO DISTRIBUTE TO: Dated 10/22/98 Mr. Lawrence Weinstock, Director Ms. Norma Gonzalez Office of Radiation and Indoor Air (6601J)

Office of Management and Budget U.S. Environmental Protection Agency Room 10202 401 M Street, S.W.

New Executive Office Building Washington, DC 20460 Washington, DC 20503 Mr. Michael Schaeffer, Chairman Ms. Beverly Hartline U.S. Department of Defense Office of Science and Technology Policy Radiation Research and Policy Working 17th & Pennsylvania Avenue, N.W.

Group Washington, DC 20500 Defense Nuclear Agency'(DFRA) 6801 Telegraph Road Dr. Jill Lipoti, Assistant Director

~ Alexandria, VA 22310-3398 for Radiation Protection Programs Division of Environmental Safety, Health Mr. Andrew Wallo Ill, Director and Analytical Programs Air, Water and Radiation Division (EH-412)

Department of Environmental Protection U.S. Department of Energy CN 415 Washington, DC 20585 Trenton, NJ 08625-0415 Dr. Adam Finkel, Director Mr. Steven Collins Health Standards Programs, N-3718 Illinois Department of Nuclear Safey Occupational Safety and Health Office of Radiation Safety Administration 1035 Outer Park Drive 200 Constitution Avenue, N.W.

Springfield,IL 62704 Washington, DC 20210 Mr. Alan Roberts Associate Administrator for Hazardous Materials Safety Department of Transportation, Room 8422 400 Seventh Street, S.W.

Washington, DC 20590 Dr. Bruce Wachholz, Chief Radiation Effects Branch National Cancer institute Executive Plaza North, Suite 530 Bethesda, MD 20892 Dr. Marvin Rosenstein Center for Devices and Radiological Health Mail Code HFZ-60 Food and Drug Administration 16071 Industrial Drive Gaithersburg, MD 20877

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4 AGENDA INTERAGENCY STEERING COMMITTEE ON RADIATION STANDARDS

. December 10,1998.

d INTRODUCTIONS (1:00 - 1:15 pm)- John T. Greeves -

. Introduce Principal Meeting Attendees

' TOPICS FOR DISCUSSION (1:15 - 2:45 pm)

Discussion of ELI Report Discussion bf NAS Report on EPA NORM Guidelines Update on the NRC Clearance Rule Review of Recommended Changes to the ISCORS Charter Review of 1998 Planned Activities Review of Proposed 1999 Planned Activities SUBCOMMITTEE PROGRESS REPORTS (2:45 - 3:30 pm) i Federal Guidance Subcommittee

+

. Cleanup Subcommittee Mixed Waste Subcommittee Recycle Subcommittee Risk Harmonization Subcommittee Sewage Sludge / Ash Subcommittee NORM Subcommittee E ACTION ITEMS /NEXT STEPS (3:30 - 4 pm)

. Review of action items Date/ time / place of next meeting Topics for next meeting

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INTERAGENCY STEERING COMMITTEE ON RADIATION STANDARDS MEETING

SUMMARY

Date:

September 10,1998 Time:

9:00 a.m. to 1 p.m.

Location:

Department of Energy, Forrestal Bldg, Washington, D. C.

Attendees:

Total: 40 (Attachment 1)

Agenda:

See Attached Meeting Summary:

Larry Weinstock, EPA, welcomed the attendees to the September 1998 meeting of the ISCORS Committee and introduced new representatives Steve Collins, States, and Dr. Chia Chen, OSHA. The June 11,1998 minutes were approved and the members discussed the options for holding ISCORS Committee meetings open to the public. The membership consensus on holding public meetings was to continue to hold annual public meetings and reevaluate tha need for additional public meetings after a 2 year period. The committee

. members and subcommittee chairs were asked to develop a list of projected activities for 1999 to help guide the subcommittee activities.

Jackie Dziuban presented an overview of the 1994 GAO report, " Nuclear Safety and Health:

Consensus on Acceptable Radiation Risk to the Public is Lacking, and outlined the similarities and differences contained in the 1995 " White Paper on Risk Harmonization," developed by EPA and NRC. She also presented the recommendations developed by the Risk Harmonization Subcommittee in 1995 for addressing the differences identified in the white paper. The Risk Harmonization Subcommittee was tasked to review the white paper issues along with the Environmental Law Institute (ELI) report. As part of the review, the subcommittee will identify those issues that need higher level attention and those issues the subcommittee could work toward resolution of and provide recommendations to the ISCORS

. membership.

Dennis O'Connor discussed the status of the ELI report which should be available by September 30,1998. A presentation of the ELI report will be made from 12 to 2 pm on October 13,1998 at Ell,1616 P Street NW (near Dupont Circle), Washington, D.C.. The final proceedings will be available to the ISCORS membership at the December 1998 meeting.

Julie Rosenberg presented a draft charter for the proposed Federal Guidance subcommittee.

The membership consensus agreed that the Federal Guidance subcommittee was needed to focus and identify projects and provide recommendations to the ISCORS membership on issues related to federal guidance. The subcommittee was officially adopted. The ISCORS membership was asked to provide any objections to the proposed draft charter by September 25*

6rtc[ pre 2

o Cheryl Trottier, NRC, discussed the NRC Draft Regulatory Guide, DG-4006, " Demonstrating Compliance with the Radiological Criteria for License Termination" issued August 1998. In order to terminate an NRC license and release a site, an NRC licensee must demonstrate that the site is suitable for release in accordance with the criteria for decommissioning in Sobpart

1. E, " Radiological Criteria for License Termination," of 10 CFR Part 20. The guide describes acceptable methods for complying with the regulations, in addition, NRC will be developing a Standard Review Plan (SRP) for evaluating information submitted by licensees and other parties to support the decommissioning of materials facilities. The SRP will contain information on dose modeling, surveys, and other areas related to decommissioning and is scheduled for draft publication by FY 2000.

Robert Nelson, NRC, presented an overview of NRC Plans for the clearance rule. As directed by the Commission, the staff is proceeding independently to develop a dose-based regulation for clearance applicable to metals, equipment, and materials (soil, concrete) using an enhanced participatory rulemaking process. The NRC discussed plans with EPA and will be coordinating efforts on technical bases and briefing the ISCORS membership on project status.

]

Joseph Holonich, NRC, discussed NRC plans for the Uranium Recovery Decommissioning rule.

]

The decommissioning of uranium recovery facilities will use a radium benchmark approach for cleanup up of radionuclides other than radium. The top 15 centimeter soit level of uranium and thorium will be benchmarked to the site specific dose from 5 pCi/gm of radium-226. The As Low As Reasonably Achievable (ALARA) concept will be applied to the cleanup and the unity rule will be applied to areas with more than one residual radionuclide. Any benchmark dose exceeding 100 mrem /yr will require Commission review. Sites with approved decommissioning plans for soil and buildings will be grandfathered. Guidance for the benchmark dose assessment will be contained in the Standard Review Plan at the time the rule is published.

Martin Letourneau, doe, discussed the draft DOE Order 435.1 on " Radioactive Waste Management" and its accompanying manual. These address management of high-level waste, transuranic waste, and low-level waste (including the radioactive component of mixed wastes).

It does not address management of spent nuclear fuel. The revisions document the technical basis, update DOE's waste management and disposal practices, and implement directives requiring performance-based and risk-based requirements.

Ronald Thompson, FDA, presented the FDA's guidance, " Accidental Radioactive Contamination of Human Food and Animal Feeds: Recommendations for State and Local Agencies." The recommendations revise and replace the 1982 recommendations due to significant advancements related to emergency planning, scientific information, radiation protection philosophy, and international guidance. The recommendations provide guidance applicable to accidents at nuclear power plants und other types of accidents where a significant radiation dose could be received as a result of consumption of contaminated food. The recommendations advise that health risk to the public be averted by limiting the radiation dose received as a result of consumption of accidentally contaminated food. This is accomplished by: (1) setting limits, called Derived Intervention Levels (DILs) on the radionuclide activity concentration permitted in human food (apply during the first year after an accident), and (2) taking protective actions to reduce the amount of contamination. The current recommendations replace the preventiva and emergency Protective Action Guides (PAGs) with one set of PAGs for the ingestion pathways. The PAGs are 5 mSv (0.5 rem) for committed dose equivalent or 50 mSv (5 rem) committed dose equivalent to an individual tissue or organ, whichever is more limiting. (Attachment 2)

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Ben Hull, EPA discussed the status of the Multi-Agency Radiation Laboratory Protocols (MARLAP) manual. The manual will be guidance for radioanalyticallaboratories and will be a counterpart to the Multi-Agency Radiological Survey and Site Investigation Manual (MARSSIM).

The draft document is scheduled for internal agency review in April 1999 and for the public FY

]

2000.

)

Subcommittee Progress Reports:

.1 Cheryl Trottier, NRC, reported that the Cleanup Subcommittee met in August to discuss the issued NRC Regulatory Guide DG-4006, Demonstrating Compliance with the Radiological l

Criteria for License Termination and the proposed screening table for residual contamination.

Model parameters used by NRC, DOE, and EPA will be compared to better understand the differences between the various models. The subcommittee will provide recommendations to the ISCORS membership at the next meeting on issues the subcommittee should focus and complete.

Gus Vasquez, DOE, discussed the activities of the Mixed Waste Subcommittee, which continued to center on development of Radiological Control criteria for alternatives for disposal of mixed waste. EPA is proposing a document and it will be forthcoming to the subcommittee members for review, John Greeves, NRC, requested the subcommittee look into the difference in intruder scenarios between radioactive material waste disposal sites and RCRA disposal sites.

Deborah Kopsick, EPA, discussed tha activities of the Clean Metals Subcommittee. The subcommittee has an ongoing initiative to assist the states in disposing or recycling of orphaned radioactive sources. States heve been surveyed for orphaned sources and disposal will begin l

before the end of the year. EPA has funded a program, in partnership with the Conference of Radiation Control Program Directors (CRCPD) to implement a system to reuse or dispose of these sources. NRC and DOE, are participating in the orphan sourca program with CRCPD.

Dennis O'Connor, EPA discussed the activities of the Risk Harmonization Subcommittee, which j

completed fact sheets on institutional controls (Attachment 3). The subcommittee will review the ELI report and tabulate issues to identify those that the subcommittee believes it could provide recommendations on to the ISCORS membership. The National Research Council report, Health Effects of Exposure to Low Levels of lonizing Radiations: Time for Reassessment was issued August 1998. This was a preliminary scoping (BEIR Vil phase i study) to determine if reassessment of the health risks reported in BEIR V were needed.

Substantial new epidemiologic evidence, carcinogenesis studies, and animal models for carcinogenesis, and evidence on biological events that shape the dose-response curve at low dose is accumulating to require a study (phase-2).

The activities of the Sewage Subcommittee were presented by Bob Bastian, EPA. The subcommittee has been meeting frequently in conjunction with both the development of the Joint NRC/ EPA Guidance Document and conducting the survey of POTW sewage sludge and ash. OMB approval was granted on June 17th to go ahead with the full survey of 300 POTWs.

At OMB's direction representatives from two local POTWs have been added to the subcommittee and participating in our meetings, generally by conference call. The Subcommittee has been actively working on finalizing letters to update the states on the status of the survey and guidance document development effort and have both a Lab Report to the Subcommittee on the Nine Test Sites results and a more general report for the public that is

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going through final agency reviews. The report for the public will include a brief narrative along with a table that compares the radionuclide concentration results from the 9 test sites samples with other common materials such as soils, fertilizers, and construction debris to help provide a mean's of interpreting the results. The ISCORS Committee agreed that the normal agency concurrence process can be used to approve release of the document and that copies will be sent to subcommittee membership. The general issue of how to deal with FOIA requests was raised as a part of an ongoing FOIA appeal concerning the the Nine Test Sites Survey effort that is currently being addressed by EPA. A general agreement was reached by the ISCORS Committee and materials that are not " deliberative" will be placed in the NRC public docket.

Debbie Kopsick, EPA, discussed the activities of the NORM Subcommittee. Issues discussed included: 1) DOT's efforts to revise its regulations to conform to IAEA standards. A specific issue identified included the definition of radioactive materials which would be isotopic specific and not the current 0.002 uCi/g definition; 2) the National Academy of Sciences completed a report on EPA's Guidelines on NORM with recommendations and it will be available on the NAS website within the next few weeks. A report on Diffuse NORM will not be available for several months to allow incorporation of modeling and edits; 3) NRC advised that the Regulatory Guide DG 98-4006, License Termination Plan was available; 4) CRCPD indicated that a second stakeholder meeting on technically enhanced NORM (TENORM) would be held Sep 11 and 12 in Dallas, Texas; and 5) the National Park Service 6/12/98 letter requested the EPA NORM Subcommittee Chair provide information on occupational exposure regulations. The request is associated with work at mines by seasonal employees where radiation levels can be elevated. The next subcommittee meeting is scheduled for October 5,1998.

Action items:

1.

By September 25, the ISCORS members will provide any objections to the Federal Guidance subcommittee draft charter to Julie Rosenberg, EPA.

2.

By September 30,1998, agencies are invited to provide comment on the DOE Order 385.1 and manual to Martin Letourneau, DOE.

3.

By November 13,1998, ISCORS and its subcommittee membership will provide recommendations on activities for 1999 to the ISCORS coordinators (Pat Santiago, NRC or Debbie Kopsick, EPA). Each subcommittee should provide a summary paragraph for their 1998 activities. The information will be sent to the ISCORS members prior to the December meeting.

4.

By November 13,1998, ISCORS members will provide comments or recommended changes to the ISCORS Charter to P. Santiago, NRC or D. Kopsick, EPA.

5.

At the December 1998 ISCORS meeting, the Clean-Up subcornmittee will provide recommendations on issues to complete such as model validation.

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6.

The Risk Harmonization Subcommittee will tabulate issues from the ELI report and White Paper on Risk Harmonization and provide ISCORS a list of issues the subcommittee could address along with any next steps. The IC working group will

' identify similarities / differences in the fact sheets presented and provide topics to ISCORS on what issues the subcommittee could prepare recommendations. The subcommittee should also identify absent Parts or standards for which fact sheets should be developed. The subcommittee will provide an update at the December 1998 meeting.

J 7.

The Mixed Waste Subcommittee will consider different intruder scenarios (RCRA vs.

radioactive material waste sites).

Topics for the Next Meeting:

1.

Review of 1998 Activities and Planned 1999 Activities 2.

ELI Report 3.

NAS Report on EPA NORM Guidelines 4.

Status of External Regulation (doe /NRC) 5.

Review of ISCORS Charter 6.

Update on the NRC Clearance Rule Next Meeting:

The next ISCORS Committee meeting is scheduled for Thursday, December 10,1998, 1:00 to 4:00 pm, at :

U.S. Environmental Protection Agency HQ Room Washington Information Center (WlC) 401 M. Street, S. W.

Washington, D.C.

(Green Line: Waterfront station)

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ACCIDENTAL RADIOACTIVE CONTAMINATION OF HUMAN FOOD AND ANIMAL FEEDS:

RECOMMENDATIONS FOR STATE AND LOCAL AGENCIES l

U. S. Food and Drug Administration Guidance Document kf(l{Cl{/KEWl' 2 -

'b ASSIGNMENT OF RESPONSIBILITY e 1973 Defense Civil Preparedness Agency Notice ofInteragency Responsibilities Assigned DHEW preparation of planning actions for evaluation, prevention and control of radioactive contamination of foods and animal feeds.

1982 Food and Drug Administration Recommendations for State and Local Agencies

= 1982 Federal Emergency Management Agency 44 CFR Part 351 Final Regulations Assigned DHHS to develop and specify protective actions and guidance for human food and animal feed.

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3 1988 - FDA DECIDES ON NEED FOR UPDATED l

GUIDANCE J

1991,1994,1996 DRAFT REVIEWS -

Center for Food Safety and Nutrition, FDA l

Conference of Radiation Control Program Directors (E-6 Subcommittee)

Department of Energy Environmental Protection Agency l

Federal Emergency Management Agency Health Canada Nuclear Regulatory Commission U. S. Department of Agriculture

.p' FEDERAL REGISTER NOTICE OF AVAILABILITY FOR COMMENT FINAL DRAFT MAY 22,1997 Federal Radiological Preparedness Coordinating Committee State Radiation Control Programs

. Health Canada FEDERAL REGISTER NOTICE OF AVAILABILITY FINAL RECOMMENDATIONS AUGUST 13,1998

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FDA RECOMMENDATIONS

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= Protective Action Guides e Derived Intervention Levels

l Protective Actions e

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PROTECTIVE ACTION GUIDES (PAGs)

Projected dose commitment values to individuals in the general population that warrant protective action following a release of radioactive material.

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PAG VALUES ARE 5 mSv, committed effective dose equivalent (to whole body) or 1

j 50 mSv, committed dose equivalent (to an individual tissue or organ) 4 whichever is more limiting N

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DERIVED INTERVENTION LEVELS (DILs)

The limits on radionuclide concentrations permitted in human food.

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HOW DO NILS RELATE TO PAGs?

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i Food containing a DIL will deliver a dose equal to the t

PAG, provided:

e the concentration is equal to the DIL for the entire year I

i e the food is consumed by the most sensitive age group 4

i e no intervention occurs 4

PROTECTIVE ACTIONS AVOID OR LIMIT CONTAMINATION M

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OR REDUCE THE CONCENTRATIO.N IN FOOD OR DELAY OR LIMIT CONSUMPTION UNTIL FOOD IS EVALUATED

if USE OF FDA GUIDANCE

• STATES - can be employed in accident response plans e NRC - can be incorporated into Commission's Response Technical Manual 1

= FEMA - can be referenced in the Agency's Guidance Memorandum IN-1, and as the basis for REP publications 12 and 13 on the Ingestion Pathway e EPA - can be included in the Agency's Manual of Protective Action Guides e USDA - can be employed in the Department's emergency response plan

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5 ROLE OF FDA GUIDANCE IN STATE ACTIONS DURING EARLY PHASE Event Occurs State Preemptive Actions People, then Food Shelter, evacuation, prophylaxis Temporary embargo, shelter cows Release Occurs People Protection, then Food Measurements

> Limiting Concentrations Principal Radionuclides For Accident Type Intervention Levels

> DILs Protective Actions, Food

> Embargo Hold for decay Clean process Destroy

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o PAG (mSv)

DIL (Bq/kg) =

f x Food Intake (kg) x DC (mSv/Bq)

Where:

DIL

= Derived Intervention Level PAG

= Protective Action Guide f

= Fraction of food intake contaminated l

Food Intake

= Quantity of food consumed in period of time (kg)

I DC

= Dose coefficient (mSv/Bq) l l

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l TYPES OF ACCIDENTS i

Reactors i(13'I, 234Cs, '37Cs, '"3Ru,i6Ru)

I Fuel Reprocessing Plants (9 Sr, 237Cs, 239pg, 241Am) 4 Waste Storage Facilities t

(9 Sr, '37Cs, 239pu, 241Am)

Weapons (HE detonation only)

(239p,)

Power Sources in Space Vehicles (238po)

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l DERIVED INTERVENTION LEVELS (Bq/kg) i Principal Radionuclides by Age Group with Most Limiting Diet 8

l Strontium - 90 160 (15 years)

Iodine - 131 170 (1 year) l Cesium - 134 930 (adult)

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l Cesium - 137 1360 (adult) a l

Ruthenium - 103 6800 (3 months)

I Ruthenium - 106 450 (3 months)

Plutonium - 238 2.5 (3 months)

Plutonium - 239 2.2 (3 months)

Americium - 241 2.0 (3 months)

s.

j DERIVED INTERVENTION LEVELS (Bq/kg) l Recommended Derived Intervention Level (DIL) or Criterion for Each Radionuclide Group i

Radionuclide Derived l

Group Intervention Levels l

Sr-90 160 (15 years) l I-131 170 (1 year)

Cs-134 + Cs-137 1200 (adult)

Pu-238 + Pu-239 +Am-241 2 (3 months)

Ca,_1o3 Cao_io6 Ru-103 + Ru-106

+

<1 6800 450

a August 24,1998

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Resource Conservation and Recovery Act (RCRA), as amended by the Hazardpus and Solid Waste Amendments (HSWA) of 1984; 40 CFR Part 264.101; RCRA Corrective Action (CA) Statutory Authorities: 7003, 3004(u), {3004(v), 3008(h), and f3005(c)(3) in a Notice published May 1,1996, EPA stated that it is " committed to consistency of results between the RCRA corrective action and Superfund remedial programs" and stated expectations for corrective action that were based on those published in the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), National Oil and Hazardous Substances Pollution Contingency Plan (NCP).

Accordingly, the expectation for the use ofinstitutional controls in corrective action are the same as those under the CERCLA NCP.

Applicability Any facility regulated by RCRA engaged in the management, storage and disposal of hazardous waste.

i RCRA CA applies to the control and cleanup of releases of hazardous waste and hazardous constituents from these facilities into the environment.

Approach The purpose of the Corrective Action Program is to implement remedies that eliminate, reduce, or control risks to human health and the environment. The remedy selection process includes the evaluation of remedies that: (1) remove or destroy hazardous substances (if possible), eliminating the need for long-term management; (2) prevent exposures by containing the hazardous substances using engineering controls; and (3) prevent exposures by institutional controls.

Institutional Controls EPA expects to use institutional controls such as water use and deed restrictions to supplement engineering controls as appropriate for short-and long-term management to prevent or limit exposure to i

hazardous waste or hazardous constituents. Institutional controls may be used during the RCRA Facility Investigation, Co.Tective Measures Study / Implementation; and where necessary as a component of the completed corrective action. The use ofinstitutional controls does not substitute for active response measures (e.g., treatment and/or containment of source material, restoration of ground waters to the beneficial uses) as the sole remedy unless such active measures are determined not to be practical, based on the balancing of trade-offs among alternatives.

Examples ofinstitutional controls, which generally limit human activities at or near RCRA facilities where contamination remains on-site, at greater than residential concentrations, include land and resource (e.g., water) use and deed restrictions, well-drilling prohibitions, building permits, and well use advisories and deed notices.

Documentation The decision to use the institutional controls in a corrective action remedy is documented in the HSWA Corrective Action Permit, Enforcement Order, or other Enforceable Agreement. Also, institutional controls should be documented in the Administrative Record for the facility. The type ofinstitutional control will determine the type documentation necessary to implement it.

pisct.ri m a f

RCRA-1 t

Waste form requirements DOE is required to show that it considered waste form alternatives.

Documentation ' Considerable documentation is required. DOE must provide a recertification document on a five-year basis.

DISCtAIMER These fact sheets were prepared by the l'.S. Ensironmental Protection Agency (EPA)in orde r.o provide a clear understanding of the existing institutional controls la serious EPA programs These fact sheets are primarily intended for the interagency (NRC, DOE,IX)T etc.) omelais. EPA does not mal 6e any warranty or representation. express or implied with respect to the accuracy, completeness or neefulness of the information contained in these fact sheets. EPA does not assume any liability with respect to the use of, or for damages resulting from the ese of, any information, apparatus method or process disclosed in these fact sheets. Information presided in these fact sheets are not latended, nor can they be relied upon, to create any rights enforceable by any party in litigation with the tinited States. EPA onicials may decide to follow the information presided in these fact sheets, or to act at sariance with them, based on an analysis of specific site circamstances. The Agency also reserses the right to change / update these fact sheets at any time without public notice.

4,4 WIPP - 1

d,

.SEPA August 24,1998 Atomic Energy Act (AEA -5) 40 CFR 192 Health and Environmental Protection Standards for Uranium and Thorium Mill Tailings; Subpart E - Standards for Management of Thorium Byproduct Materials Pursuant to Section 84 of the Atomic Energy Act of 1994, as Amended Applicability Thorium byproduct materials at facilities licensed by the NRC under Section 84 of the AEA.

Approach Similar to Subpart D, but with the following additional provision:

Operations conducted in a manner that provides assurance that annual doses do not exceed 25 mrem to the whole body,75 mrem to the thyroid, and 25 mrem to any other organ of any member of the public from planned discharges, not including Rn-220 and its progeny.

In addition, provisions in Subpart D applicable to Radon-222 also apply to radon-220, provisions applicable to uranium also apply to thorium, and provisions applicable to Ra-226 also apply to Ra-228.

Institutional Control Identical to Subpart A Time Period Identical to Subpart A Point of Compliance Identical to Subpart A Groundwater Protection Identical to Subpart A Intruder Assumptions identical to Subpart A Waste-Form Requirements Identical to Subpart A Documentation Identical to Subpart A

.5 AEA-5

f.

SEPA

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August 24,1998 1992 WIPP Land Withdrawal Act (as amended)(WIPP 1) 40 CFR 194 Criteria for the Certification and Re-Certification of the Waste Isolution Pilot Plant's Compliance With the 40 CFR Part 191 Disposal Regulations Applicability By WIPP Land Withdrawa! Act, EPA certines, by rule, DOE compliance with 40 CFR Part 191 at WIPP.

Approach Part 194 was promulgated based on the requirements of the 1992 WIPP Land Withdrawal Act, revised by the Defense Appropriations Act of 1996. DOE raust submit a Compliance Certincation Application for approval by EPA. EPA then certines, by rule, whether WIPP will comply with 40 CFR Parts 191 and 194. Thereafter until repository closure, DOE must submit documentation to EPA that demonstrates the WIPP's continued compliance.

Institutional Controls

~

This facility is under permanent Federal government and ownership.

Part 194 requires DOE to implement two types ofinstitutional controls at the WIPP (defined in Part 191)

Active controls (e.g. signs, fencing, and site patrols).

Passive controls (e.g. site markers, record archival, government ownership of the site, and other measures intended to ward offintrusion for the long term). These controls must be designed to be as permanent as practicable.

Time period Time of compliance is specified in 40 CFR 191.

Point-of-compliance Point ofcompliance is specified in 40 CFR 191. Compliance with 191.15 (individual protection requirements) shall assume that an individual resides at the single geographic point on the surface of the accessible environment where that individual would be expected to receive the highest dose from radionuclide releases from the disposal system. For compliance with 191 subpart C, all underground sources ofdrinking water in the accessible environment that are expected to be affected by the disposal system over the regulatory time frame shall be considered.

Groundwater protection Addressed in 40 CFR 191. All significant modeling parameters must be treated in a probabilistic manner.

Intruder assumptions Performance assessments must consider activities occurring near the WIPP prior to and soon after closure, including existing boreholes and development of existing leases. Events with less than a one in 10,000 chance of occurring need not be considered. Mining must be assumed to occur once every century, and may be limited to changes in hydraulic conductivity. DOE may propose that institutional controls will reduce human intrusion for up to several hundred years after closure, intrusion must be considered as follows:

As long as passive institutional controls endure and are understood, they may reduce the likelihood ofinadvertent, intermittent human intrusion. An implementing agency may not assume that passive controls entirely eliminate human intrusion.

Performance ant :sments shall examine deep drilling and shallow drilling that may potentially affect the disposal system during the regulatory time frame.

,9 WIPP - 1

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Waste-Form Requirements: N/A Documediation: Plan for remedial action DISCLAIMER These fact sheets were prepared by the U.S. Environmental Protection Agency (EPA)in order to proside a clear understanding of the existing

}

institutional controls in various EPA programs. These fact sheets are primarily intended for the interagency (NRC, DOE, DOT etc.) omcials.

EPA does not make any warranty or representation, express or implied with respect to the accuracy, completeness or usefulness of the information contained in these fact sheets. EPA does not assume any liability with respect to the use of, or for damages resulting from the use of, any information, apparatus. method or process disclosed in these fact sheets, Information provided in these fact sheets are not intended. nor l

can they be relied upon, to create any rights enforceable by any party in litigation with the United States. EPA omeials may decide to follow I

the information provided in these fact sheets, or to act at variance with them. based on an analysis of specific site circumstances. The Agency also reserves the right to change / update these fact sheets at any time without public notice.

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AEA-3

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SEPA August 24,1998

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Atomic Energy Act (AEA -4) 40 CFR 192 Health and Environmental Protection Standards for Uranium and Thorium MillTailings; Subpart D - Standards for Management of Uranium Hyproduct Materials Pursuant to Section 84 of the Atomic Energy Act of 1994, as Amended Applicability Tailings and wastes produced by the extraction or concentration of uranium by Title 11 facilities (i.e., facilities licensed by the NRC under Section 84 of the AEA)

Approach Identical to Subpart A except:

The alternative of complying with 0.5 pCill concentration standard in lieu of the 20 pCi/m2-sec design flux standard available at Title i sites is not permitted.

Title II sites are required to perform measurements to confirm that the design flux for radon has been attained.

Institutional Controls Identical to Subpart A Time Period Identical to Subpart A Point of Compliance Identical to Subpart A Groundwater Protection Identical to Subpart A Intruder Assumptions identical to Subpart A Waste-Form Requirements identical to Subpart A Documentation Identical to Subpart A AEA-4

3 *

'6 s.

Intruder assumptions:

Intruder could come onto site, after institutional controls fail, and take up residence without a time limit. More specific guidance on exposure scenarios is being developed in staff guidance documents. " Intruder"(or average member of the critical group that becomes exposed when the institutional controls fail) cannot receive dose of greater than 100 mrem /yr, or 500 mrem /yr under certain circumstances.

Waste form requirements:

No waste form requirements apply. The rule applies to residual radioactivity in soil, slag, building surfaces, etc. left at site.

Documentation:

Licensee must submit a decommissioning plan that provides all of the dose analyses, scenario assumptions, etc. An environmental report may also be required, and NRC may have to prepare an EIS.

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2 NRC Restrk ted Release of Decommissioned Sites (Subpart E of 10 CFR Part 20)

Applicability: To provide for termination of NRC licenses at facilities with some residual radioactive material remaining onsite. Institutional controls would be relied on to limit doses to j

control land use and thereby limit doses to members of the public. Applies to residual source, byproduct and special nuclear material.

l Approach: Two tiered approach. Dose limit from all pathways of 25 mrem /yr to average member of critical group, assuming that institutional controls are functioning. Compliance with higher dose limit of 100 mrem /yr or 600 mrem /yr (under certain specified circumstances) assuming that institutional controls fail. ALARA also applies. Compliance demonstration similar

]

to Part 61 in NRC LLW disposal regulation, and involves use of a performance assessment of the site to determine compliance with dose limits in future, for up to 1000 years.

The 100 mrem /yr cap applies when institutional controls are assumed to fail. A 500 mrem /yr cap could apply if:

l a) licensee demonstrates that further reductions in residual radioactivity to comply with the 100 mrem /yr limit are not technically achievable, would be prohibitively expensive, or would result in net public harm.

i b) Licensee makes provisions for durable institutional controls.

c) Licensee sets aside sufficient financial assurance to enable a responsible third party to carry out controls and 5 year rechecks of the site.

Institutional controls:

3 i

Controls must be legally enforceable. Details on types of controls are being developed by NRC staff in a Regulatory Guide. At this time, the controls are generally passive, land-use controls.

l 4

Time period:

l' A 1000 year time period is specified in the rule.

Point-of-compliance:

Both on-site and offsite. For sites that have a restricted release (i.e. that rely on institutional controls to limit doses), a 25 mrem /yr dose limit applies onsite and offsite when the controls are functioning. These controls could, for example, prohibit certain land uses on-site, such as farming or excavating soil, but would permit members of the public to be on-site for authorized uses of the property. For the restricted release scenario, the NRC rule requires that the institutional controls be postulated to fail and that the resulting dose to a member of the public be no more than 100 mrem / year, or 500 mrem /yr in unusual site-specific circumstances. This dose would be expected to be for an onsite member of the public.

Groundwater protection:

As in other NRC regulations, ground water protection is provided for by the all pathways standard, in this case both 25 mem/yr and 100 or 500 mrem /yr. No specific ground water j

provisions are specified.

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proposal, NRC will need to evaluate the merits, feasibility, and relative uncertainties associated with applying a quantitative limit to risks incurred at time frames considerably longer than those used for assessing acceptable risk for other hazards.

Point of Compliance:

NAS recommended that dose should be assessed for the average member of a hypothetical critical group expected to be at highest risk and defined based on present knowledge, using cautious, but reasonable, assumptions (including those with regard to the group's location). The critical group risk, calculated for purposes of comparison with the overall system performance objective, should be the mean risk to the members of the group. Proposed regulations for Yucca Mountain will specify the location and characteristics of the critical group.

Ground water protection:

e i

NAS did not recommend inclusion of separate criteria for ground water as being necessary to limit risks to individuals. The Commission has directed the NRC staff to oppose inclusion of separate groundwater criteria and the staff has no plans at this time to implement separate i

groundwater criteria.

k Intruder Assumptions:

NAS recommended that it is not possible to make scientifically supportable predictions of the probability that a repository's engineered or geologic barriers will be breached as a result of human intrusion over a period of 10,000 years. NAS also concluded that, while passive controls may be helpful in reducing the risk of intrusion, there exists no technical basis for making forecasts about the long-term reliability of passive institutional controls, such as markers, monuments, and records. Although it cannot be proven, however, NAS stated its belief that a collection of prescriptive requirements, comprising both active and passive controls, will help reduce the risk of intrusion, at least in the near term. According to NAS, it is not reasonable to q

attempt to protect the intruders themselves or the public from material brought to the surface by the inadvertent intruder, other than through the use of controls discussed above. For purposes of compliance, a separate analyses should focus on the consequences of inadvertent intrusion on repository performance arising from modification of the repository's engineered and geologic barriers to perform their intended function.

't NRC Yucca Mountain HLW Disposal Regulation,10 CFR Part 63 [In preparation]

Appli'cability:

Separate, site-specific criteria are being developed (at 10 CFR Part 63) to implement new dose-or risk-based standards for Yucca Mountain that will be established, consistent with the requirements of the Energy Policy Act of 1992 (EnPA). On March 6,1998, the Commission directed its staff to commence development of new Yucca Mountain-specific regulations. These new regulations at Part 63 are being developed to implement dose-or risk-based standards, consistent with the EnPA and generally consistent with the August 1,1995 recommendations of the National Academy of Sciences made pursuant to that act.

Approach:

NRC expects to develop regulations that will rely on the results of predictive performance assessment of the Yucca Mountain repository system. Reasonable assurance of compliance with the applicable overall repository system performance objective (expressed in terms of dose or risk to the average member of the critical group) will be the basis for licensing. In addition, the robustness of the repository system design must be estimated by assessing the performance of the repository system when subjected to a prescribed, stylized intrusion scenario (e.g. a single borehole of specified diameter, drilled from the surface through a single waste canister to the underlying aquifer). NAS recommended that.."the estimated risk calculated from such the assumed intrusion scenario be no greater than the risk limit adopted for the undisturbed-repository case because a repository that is suitable for long-term disposal should be able to continue to provide acceptable waste isolation after some type of intrusion."

institutional Controls:

Under Section 801(c) DOE is required to continue to oversee the site after permanent closure to prevent any activity at the site that poses an unreasonable risk of breaching the repository's engineered or geologic barriers; or increasing the exposure of the public to radiation beyond allowable limits.

NAS recommended that it is not reasonable to assume that such a system for postclosure oversight, based on active institutional controls, can be developed, that will prevent such risks, or increased exposures.

Although DOE is clearly required, under statute, to provide active controls in perpetuity, it is unclear, at this time, how the effectiveness of such controls will be considered in assessing compliance of the repository system with the overall performance objective. Nonetheless, the consequences of an assumed intrusion will be evaluated under the current approach.

Time period:

The NAS recommended that " compliance assessment be conducted for the time when the greatest risk occurs, within the limits imposed by long-term stability of the geologic environment". The NAS found no scientific basis for limiting the time period for an individual risk standard to 10,000 years. NRC recognizes that selection of a compliance period involves not i

only scientific considerations, but policy considerations as well, in formulating a rulemaking

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A rule " construct" is that a exposure of an intruder (i.e. a person who intrudes directly into a disposal cell, by building a house foundation, e.g.) and exposure of a member of the general public (a resident farmer, e.g.) outside of the boundaries of the site occur independently, and not simultaneously or sequentially.

Waste form requirements: In addition to minimum requirements pertaining to worker safety considerations (e.g., cardboard boxes are prohibited, as is free-standing liquid above 1%

volume), higher activity (Class B and C) wastes must be disposed in a manner providing structural stability. Performance requirements for structural stability are specified.

Documentation: Operations take place in accordance with a licence developed from an application that includes a Safety Analysis Report and an Environmental Report.

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(

i NRC LLW Disposal Regulation,10 CFR 61 Appli~ ability: Radioactive waste not HLW, spent nuclear fuel, TRU waste,11(e).2 byproduct c

material, NORM waste, or accelerator-produced material (small quantities of 11(e).2 byproduct material are acceptable in LLW disposal facilities).

Approach: Combines performance assessment and specified design approach. Requires performance assessment of projected doses to public. As used here, performance assessment is a type of systematic analysis that addresses, among other things, what can happen and what the resulting impacts (i.e., radiation dose) might be. It includes the site, engineered features, and scenarios that could cause radiation doses to humans. For all pathways except direct exposure, the performance objective (design) limit is 75 mrem /yr to thyroid and 25 mrem /yr to whole body or any other organ. Reduce effluents to ALARA levels. Direct exposure pathway is subject to 10 CFR 20 limits (100 mrem (ede)/yr plus ALARA). Also requires acceptance and disposal of waste based on specified waste classification limits and procedures and waste form requirements.

A principal objective for waste disposal is to ensure long-term stability of the disposal site to eliminate to the extent practicable the need for ongoing active maintenance following closure.

I A monitoring program is required and will be established on a site-specific basis.

l Institutional controls: State or Federal government must own site land. Rule indicates that monitoring and other active measures would be replaced after 100 years by passive institutional control measures. Owner of facility could continue active controls for longer periods, if desired.

However, as noted below, no credit is allowed for active institutional controls after 100 years in the demonstration of compliance with the dose limit in the rule.

PA assumptions--assume "no credit for active institutional controls after 100 years."

Draft guidance recommends reasonable extrapolation of current processes and events to future.

Time period: Not stated in rule, but draft PA guidance has recommended consideration up to 10,000 years, and beyond if needed. No final guidance is available.

Point-of-compliance: Draft PA (and earlier) guidance recommends a point of compliance 1

outside of a buffer zone around waste. The buffer zone is to be specified on a site-specific basis but would normally be only a few hundred yards wide.

Groundwater protection: No specific Part 61 requirement to protect groundwater as a separate entity. Groundwater is a pathway considered in pas for assessment of 25/75/25-mrem /yr design objective. NRC considers this and other Part 61 requirements including those for long-term disposal facility stability, institutional controls, monitoring, and waste form to be adequate for groundwater protection.

Intruder assumptions: Rule includes a performance (design) objective to protect an inadvertent intruder. In most cases, no analysis need be performed. Intrusion protection results from generic waste classification system including requirements for waste form, limits on concentrations of specific radionuclides, and requirements for segregation and deeper disposal of highest-activity (Class C) wastes. An intruder barrier may be substituted for deeper disposal.

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a archives remain intact and are accessible for several hundreds of years.

Docu' mentation: Extensive documentation is required including: a site characterization plan, a license application, an environmental impact statement, license application updates, and permanent records in local, national, and international archives and land record systems.

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9 NRC HLW Disposal Regulation,10 CFR Part 60 Appli'cability: Disposal of high-level radioactive wastes (and spent nuclear fuel) in a geologic repository. Will most likely not apply to Yucca Mountain. Separate, site-specific criteria are being developed [at 10 CFR Part 63] to implement new dose-or risk-based standards for Yucca Mountain that will be established, consistent with the requirements of the Energy Policy Act of 1992.

Approach: Uses both predictive performance assessments and currently measurable design and siting criteria. Reasonable assurance of compliance with applicable EPA containment standards (none currently in effect for NRC-licensed repositories sited and characterized under the NWPA) plus substantially complete containment and gradual release requirements require predictive analysis. Siting criteria based on historical and current conditions are potentially measurable. Some design criteria are currently determinable and others require predictive analysis.

Institutional controls: The repository is to be sited, marked, and documented to discourage intrusion. Land is required to be permanently withdrawn and reserved for repository use. DOE is required to exercise any jurisdiction and controls over surface and subsurface estates (i.e.

passive controls), as necessary to prevent adverse human actions. However, effectiveness of active controls may not be assumed for longer than 100 years following permanent closure for purposes of compliance demonstration. Monuments and records are required to prevent activities which could impair long term isolation and to assure that information is preserved for future generations.

Time period: Compliance with applicable EPA standards (none currently in effect for NRC-licensed repositories sited and characterized under the NWPA) is required. Containment is to be substantially complete for a period of between 300 and 1,000 years. Following this containment period, any releases are required to be gradual; no time period is specified for this requirement. Other siting and design requirements are generally dependent on past or current conditions.

Point of compliance: As defined by applicable EPA standards (none currently in effect for NRC-licensed repositories sited and characterized under the NWPA). The substantially complete containment requirement is evaluated at the exterior of the waste packages. The gradual release requirement is evaluated at the outer boundary of the engineered barrier system. Siting criteria are applied both within the controlled area and in its general vicinity.

Ground water protection: There is no separate ground water protection requirement.

Intruder assumptions: The repository will be sited, marked, and documented to discourage intrusion. Inadvertent human intrusion into the repository must be addressed. Processes and events initiated by human activities are to be considered as part of quantitative performance assessments for sufficiently credible scenarios, subject to specified assumptions. These assumptions include: (a) required monuments are sufficiently permanent to serve their intended purpose; (b) value of resources to future generations can be adequately assessed; (c) institutions will continue to exist that retain knowledge of radiation and its hazards; (d) institutions will exist that can assess risk and take remedial action at the same, or superior level of technological competence as that which initiated the intrusion; and (e) relevant records and ffy?7leHM(&K3

=._

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Use of permanent markers and other passive measures to indicate dangers of the waste and waste locations.

Maintenance of records pertaining to disposal facility (e.g., location, design, contents, etc.

Federal government ownership of disposal sites and regulations regarding future land / resource use.

Time Period Active institutional controls over a disposal site should be maintained for as long a period of time as is practicable after disposal.

Performance assessments that evaluate isolation of wastes from the accessible environment shall not consider any contributions from active institutional controls for more than 100 years after disposal.

Point of Compliance Implementing agencies must demonstrate compliance with containment standard and exposure limits, and the individual and groundwater standards.

Ground-Water Protection: The disposal system must provide a reasonable expectation that 10,000 years of undisturbed performance after disposal shall not cause the levels of radioactivity in any underground source of drinking water in the accessible environment to exceed the limits specified in 40 CFR 141 as they existed on January 19,1994.

Intruder Assumptions-Site selection criteria that avoid sites with known minerals, petroleum, gas, water, or other natural exploitable resources; waste form requirements; containment requirements; and permanent markers to alert potential future intruders to the presence of hazardous materials.

Intrusion must be considered for the containment standard as follows:

1 The potential for inadvertent intrusion is reduced by site selection criteria that avoid sites

=

with known minerals, petroleum, gas, water, or other natural exploitable resources.

As long as passive institutional controls endure and are understood, they may reduce the likelihood ofinadvertent, intermittent human intrusion. An implementing agency may not assume that passive controls entirely eliminate human intrusion.

Drilling of exploratory wells need not exceed 30 boreholes per square kilometer of repository area over the 10,000-year period for repositories in sedimentary rock formations, or more than 3 lx>reholes per square kilometer of repository area in other geologic formations.

Waste-Form Requirements: Waste form as defined in this standard means the materials comprising the radioactive components of waste and any encapsulating or stabilizing matrix.

Waste materials include spent nuclear fuel, high-level waste, and transuranic waste.

4 AEA-1

.A a.

SEPA August 24,1998 Atomic Energy Act (AEA - 1)

Subchapter F Radiation Protection Programs

. 40 CFR 191 Subpart A - Environmental Standards for Management and Storage, Subpart B - Environmental Standards for Disposal, and Subpart C - Environmental Standards for Ground-Water Protection Applicability Any facility regulated by the NRC or Agreement State, other than Yucca Mountain, engaged in the management, storage, and/or disposal of spent nuclear fuel or high-level, transuranic radioactive waste.

Any disposal facility operated by DOE, other than Yucca Mountain, engaged in the management, storage, and disposal, of spent nuclear fuel, high-level or transuranic radioactive waste.

Approach The standard incorporates limits for (1) radioactive releases to the accessible environment (2) contamination of ground water in the vicinity of the disposal system, and (3) radiation doses to members of the public.

Subpart A of the standard limits the annual radiation dose equivalent to members of the public during facility management and storage phase to 25 mrem whole body,75 mrem thyroid, and 25 mrem to any organ from the combined (1) discharges of radioactive materials and direct radiation from waste management and storage and (2) all operations covered by 40 CFR 190.

Subpart B establishes requirements for the disposal of waste materials that include (1) facility siting criteria, (2) engineering designs for waste containers, and (3) a geophysical barrier system.

The regulations specify a set of six qualitative assurance reauirements that provide confidence that containment requirements will be met and reasonable expectations that exposures to individual members of the public for a period of 10,000 years from all potential pathways are not likely to exceed 15 mrem / year.

The standards incorporate limits for Radioactive releases to the accessible environment for 10,000 years after disposal less than 1/10 chance of exceeding specified quantities less than 1/1000 chance of exceeding 10 times the specified quantities Contamination of ground water in the vicinity of the disposal system (see below) a Institutional Controls (Do not apply to facilities regulated by the NRC - see 10 CFR Part 60 for comparable provisions)

Monitoring and assessment of waste isolation by engineered and natural barriers to detect substantial and detrimental deviations from expected performance.

M AEA-1

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OEPA August 24,1998 Atomic Energy Act (AEA -2) 40 CFR 192 Health and Environmental Protection Standards for Uranium and Thorium Mill Tailings; Subpart A - Standards for the Control of Residual Radioactive Materials from Inactive Uranium Processing Sites Applicability Designated inactive uranium processing / depository sites.

Approach The standard incorporates limits for Releases ofradon-222 from uranium byproduct materials to the atmosphere (on average will not exceed 20 pCi/m -s), or 2

The radon concentration at any location outside the disposal area (will not increase by more than 0.5 pCi/t).

See ground-water protection (below).

The objectives of this standard are achieved by constructing the facility in accordance with specific design and location controls.

L Institutional Controls Federal or State governments are required to acquire and retain control of Title 11 sites. The Federal government is required to retain control of Title I sites under the general NRC license.

Regulations require Ground-water monitoring.

e Long-term stabilization and isolation of waste material that control releases of radon to air and inhibits misuse and spreading of residual radioactive materials.

This is achieved by Eliminating free liquids in waste piles.

Stabilizing the wastes.

Engineering designs that include a permanent radon barrier.

Time Period Disposal areas must provide reasonable assurance of control of radiological hazards for 1,000 years and in any case for at least 200 years, for the design of the engineered barriers.

Ground-water monitoring is done for a duration which is adequate to demonstrate that future performance of the disposal system can be expected to comply with the concentration limits.

Point of Compliance Upon emplacement of a permanent radon barrier, the licensee must conduct appropriate monitoring and analyses of radon-222 releases that demonstrate compliance with regulatory standards using the methodology defined in 40 CFR 61, Appendix B, Method 115.

j AEA-2

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SEPA August 24,1998 Atomic Energy Act(AEA-2) 40 CFR 192 Health and Environmental Protection Standards for Uranium and Thorium Mill Tailings; Subpart A - Standards for the Control of Residual Radioactive Materials from Inactive Uranium Processing Sites Applicability Designated inactive uranium processing / depository sites.

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_ Approach The standard incorporates limits for Releases of radon-222 from uranium byproduct materials to the atmosphere (on average e

will not exceed 20 pCi/m -s), or 2

The radon concentration at any location outside the disposal area (will not increase by

=

more than 0.5 pCi/f).

See ground-water protection (below).

=

The objectives of this standard are achieved by constructing the facility in accordance with specific design and location controls.

Institutional Controls Federal or State governments are required to acquire and retain control of Title Il sites. The Federal government is required to retain control of Title I sites under the general NRC license.

l Regulations require Ground-water monitoring.

Long-term stabilization and isolation of waste material that control releases of radon to i

air and inhibits misuse and spreading of residual radioactive materials.

I This is achieved by Eliminating free liquids in waste piles.

a Stabilizing the wastes.

Engineering designs that include a permanent radon bamer.

Time Period Disposal areas must provide reasonable assurance of control of radiological hazards for

. 1,000 years and in any case for at least 200 years, for the design of the engineered

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barriers.

Ground-water monitoring is done for a duration which is adequate to demonstrate that future performarme of the disposal system can be expected to comply with the concentration lirr,its.

Point of Compliance Upon emplacement of a permanent radon barrier, the licensee must conduct appropriate monitoring and analyses of radon-222 releases that demonstrate compliance with i

regulatory standards using the methodology defined in 40 CFR 61, Appendix B, Method 115.

j AEA-2 i

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,t Documectation: None specified, DISCLAIMER These fact sheets were prepared by the U.S. Environmental Protection Agency (EPA)in order to provide a clear understanding gf the existing

' institutional controls in various EPA programs. These fact sheets are primarily intended for the interagency (NRC, IX)E, DOT etc.) officials.

EPA does not make any warranty or representation, express or implied with respect to the accuracy, completeness or usefulness of the information contained in these fact sheets. EPA does not assume any liability with respect to the use of, or for damages resulting from the use of, any information, apparatus, method or process disclosed in these fact sheets. Information provided in these fact sheets are not intended, nor can they be relied upon to create any rights enforceable by any party in litigation with the United States.' EPA officials may decide to follow the information provided in these fact sheets, or to act at variance with them, based on an analysis of specific site circumstances. De Agency also reserves the right to change / update these fact sheets at any time without public notice.

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DOE LLW Disposal Reauirements. Order DOE 5820.2A

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Appucabiety: DOE requrements for deposal of loM weste (LLW), which le radioactive weste not HLW, spent nbcieer fuel, TRU weste, or 11(e).2 byproduct metenal LLW includes NORM and accelerator-produced weste secept for large quantdies of NORM weste which are addressed under DOE 5400.5. Requrements are pnwided in DOE 5820.2A (plus DOE 5400.1 and DOE 5400.5, and eventually 10 CFR 834), which was leeued under the authonty of the Atomic Energy Act of 1954, se amended Interpretshon of DOE 5820.2A is bened on DOE guidance issued 1 November 1996. This order is being revised and wlR be re-issued as Order 435.1.

Approach: Predictive performance aseeeement (PA) approach. Resoonable awpM=han of protected comphence with performance (design) objectmee, for weste disposed aRor 26 September 1988:

o 25 mrom (ode) In a year from as pathways, suctuding Rn and progeny reisseed to air.

o 10 mrom in a year from er pathway alone, escludmg Rn and progeny o For Rn, either 20 pCi/m2-s at surface or 0.5 pCi/L at comphance point for au sources.

o Memtam reiosees of radioectmty in affluents to the general envwenment as low as is reasonably achievable o inadvertent intrueson: 500 mrom/yr for acute exposures and 100 mrern/yr for chronic (few years) exposures 4

o Groundwater protechon targets coneastent wsh site groundwater protechon management program plan.

Plus, a predictwo compcode analyses (CA) must be propered for other sources of radioactwo metenal that might contnbute to calculated does, using 100 mrom/yr as an upper bound plus ALARA analysis (target: <30 mrom/yr), and consistent with Aprd 1996 DOE guidant.e For CA and PA, aneume that current envronmental processes and events, and reasonable vertebons, may be entrapolated to future.

Mondor to ensure public protechon standards (DOE S400.5 and 10 CFR 834 when issuod) are met throughout DOE control (indefindely long oversaght).

4 InstitutionalControls: Agly81 DOE mentams control of a raiapa==8 see for as long as the weste is hazardous (AEA/NWPA responsitWhtles). Morutor and memtein constatent with redlanon protection requirements (e.g., DOE 5400.1, DOE 5400.5,10 CFR 834 when leeued). PA assumobons. Design to meet intrusion design cejectives soeumeng temporary lepees in actrve control after 100 j

years. Undisturbed performance is assumed for other design objectnes. Site maintenance (agemet burrowmg arumats, =*=riance, etc.) is assumed to be lees than perfect.

1 Time Period. DOE guidance rubcates that design should provide reasonable awpar+=Han of comphence for 1000 years of undisturbed performance Longer penods may be sessened for comparing attemetwee. This time pened does not signal en end to sde control.

Oversight and morutonng are requred (DOE S400.5 and eventually 10 CFR 834) until ede meets appropnete reisese entene.

i Point of Compliance For pas, a distence of 100 m from the weste deposal und is the pont of departure for aseeeement. May be closer or forther if justified (but must be within DOE controlled property). For CAs, recogruze that land to be controNed by DOE may shnnk in the future. Assume poets of comphance consistent with ade specdic piene required by DOE policy for land and facaldy use.

Groundwater Protection: Based on assumption of no human intervenbon to preclude reisees or human does (not the actual planned or supacted ceae), a PA must provide a reasonable awpachewin that ground water wiu be protected uomg the DOE groundwater protection management program plan to define sde specific design obgoctrves. Mondonng md other controle are required to ensure that exposures are averted intruder *-.

Temporary intruder events evaluated as part of PA process to establish desagn, operabng, and especially waste acceptance cntene.

Weste Form Requirements: Among others, minimize voids and liquids. Using the PA, CA, and other considershons such as the Safety Analysm Report, determme addtsonal requirements for sde specific use including weste arcar*=nce entena.

Oocumentation: Use CA and PA to denve HQ-issued deposal authonzation statements Field Offices review and approve Safety Analyse Reports. Also: PA and CA memtenance and re-review, and annual DOE site armronmental reports and worker dose reports.

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For the purposes of groundwater protection, the intersection of a vertical plane with the e

uppermost aquifer underlying the site, located at the hydraulically downgradient limit of the disposal area plus the area taken up by any liner, dike, or other barrier designed to contain the residual radioactive material.

Ground-Water Protection Monitor for constituents contained in Appendix I of 40 CFR 192 and determine a

background levels, Disposal system designed to meet ground water standard in uppermost aquifer underlying a

the site beyond the point of compliance.

For any constituent lived in Appendix I to Patt 192, concentration limits must not exceed a

background levels or Subpart A Table i valu :s.

Allows use of supplemental standards if greuer harm to workers, public health, or a

environment; unreasonably high cost; no kruwn remedial action; GW restoration is technically impracticable; GW is " limited use"; or presence of other radionuclides; Supplemental standards must be as close to primary standards as possible; must apply a

ALARA; must protect human he:hbid the environment; and, must preserve reasonably expected future use of ground water.

Intruder Anumptions f

Engineering design and government land control and management are deemed adequate and intruder analysis is not required.

Waste-Form Requirements Waste in the fonn of tailings from the processing of uranium or thorium must be dewatered and sufficiently stabilized to a bearing capacity sufficient to support a permanent cover.

Documentation A remediation olan(s) for disposal and cleanup of residual radioactive materials associated with a processing site that incorporates the results of(1) site characterization studies, (2) environmental i

assessments or impact statements, and (3) engineering assessments so as to satisfy the requirements of Subparts A and B.

A closure ple that documents (1) ground water monitoring and (2) radon emissions and demonstrates compliance with applicable star.dards.

DISCLAIMER These fact sheets were prepared by the U.s. Environmental Protection Agency (EPA)in order to provide a clear understanding of the existing institutional controls in various EPA programs. These fact sheets are primarily intended for the interagency (NRC, DOE. dot etc.) omcials.

EPA does not malte any w,irranty or representation. espress or implied with respec to the accuracy, completeness or usefulness of the information contained in these fact sheets. EPA does not assume any liability with respect to the use of, or for damages resulting from the use of, any information, apparatus, method or process disclosed in these fact sheets. Information provided in these fact sheets are not intended. nor can they be relied upon, to create any rights enforceable by any party in lirg? ion with the United states. EPA omcials may decide to follow the information provided in these fact sheets, or to act at vnriance with thes bued on an analysh of specific site circumstances. The Agency also reserves the right to change / update these fact sheets at any time withc3 public notice.

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y OEPA August 24,1998 Atomic Energy Act(AEA-3) 40 CFR 192 Health and Environmental Protection Standards for Uranium and Thoriurn Mill Tailings; Subpart B - Standards for Cleanup of Land and Buildings Contaminated with Residual Radioactive Materials from inactive Uranium Processing sites Applicability Land and buildings that are part of any inactive uranium processing site.

Approach The standard incorporates limits for The concentration of radium-226 in " land" (i.e., any surface or subsurface land that is not part of the disposal site) shall not exceed the background level by more than 5 pCi/g in the first 15 cm of soil and 15 pCi/g more than 15 cm below the surface.

Occupied or habitable buildings shall not yield annual average concentrations in excess of 0.02 WL (including background) and a gamma radiation dose rate of 20 uR/hr above background.

Groundwater protection standard (see below).

Institutional Controls Must meet the following criteria for contaminated groundwater.

Have a high degree of permanence.

Effectively protect public health and the environment.

Satisfy beneficial uses of groundwater during the extended period (up to 100 years).

Be enforceable by the administrative orjudicial branches of government entities, Be instituted and maintained, as part of the remedial action, at the processing site and wherever contamination by listed constituents from residual radioactive materials is found in groundwater, or is projected to be found.

Time Period Remediation is performed for as long as is necessary to meet the standard. Natural flushing, if used, must result in the standard being met in less than 100 years.

Point of Compliance Uppermost aquifer and throughout the contaminant plume, that is not beneath the disposal site and its cover.

Ground-Water Protection Monitor to define backgroundwater quality and the areal extent and magnitude of groundwater contamination by constituents listed in Subpart A.

Natural flushing may more reasonably achieve the standard; Concentration limits will be achieved within 100 years; Institutional controls are established; and.

Ground water is not a Underground Source of Drinking Water.

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. These fact sheets t ere prepared by the ti.S. Ealronmeltil Protection Agency (EPA)la order to preside a clear understanding of the

• ' esisties laatitutional controls is various EPA programs. These fact 8'

• ts are primarily latended for the lateragency (NRC. DOE,IMIT etc.) omelais. EPA does not make any warranty or representation, e

% plied with respect to the accuracy. completeness or usefoleena of the leformation costaleed is these fact sheets. EPA...

e a e any liability with respect to the use of or for damages resulting from the ese of, any information, apparatus, method or ;w +ss si.iti ed in these fact sheets. leformation provided la these fact sheets are not latended, nor can they be relied upon, to create any ebe..~ orceable by any party la litigation with the l'alted States. EPA ofileista may decide to follow the information provided in these fact sheets, or to act at variance with them, based on an analysis of specille site circumstances. The Agency also reserves the right to change / update these fact sheets at any time without public notice.

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NRC HLW Disposal Regulation,10 CFR Part 60

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Applicability: Disposal of high-level radioactive wastes (and spent nuclear fuel) i,n a geologic repository. Will most likely not apply to Yucca Mountain. Separate, site-specific criteria are being developed [at 10 CFR Part 63) to implement new dose-or risk-based standards for Yucca Mountain that will be established, consistent with the requirements of the Energy Policy Act of 1992.

Approach: Uses both predictive performance assessments and currently measurable design and siting criteria. Reasonable assurance of compliance with apolicable EPA containment standards (none currently in effect for NRC-licensed repositories sited and characterized under the NWPA) plus substantially complete containment and gmdual release requirements require predictive analysis. Siting criteria based on historical and currer.t conditions a e potentially measurable. Some design criteria are currently determinable and others require predictive analysis.

Institutional controls: The repository is to be si'.ed, marked, and documented to discourage intrusion. Land is required to be permanently withdrawn and reserved for repository use. DOE is required to exercise any jurisdiction and controls over surface and sul, surface estates (i.e.

passive controls), as necessary to prevent adverse human actions. However, effectiveness of active controls may not be assumed for longer than 100 years following permanent closure for purposes of compliance demonstration. Monuments and records are required to prevent activities which could impair long term isolation and to assure that information is preserved for future generations.

Time period: Compliance with applicable EPA standards (none currently in effect for NRC-licensed repositories sited and characterized under the NWPA) is required. Containment is to be substantially complete for a period of between 300 and 1,000 years. Following this containment period, any releases are required to be gradual; no time period is specified for this requirement. Other siting and design requirements are generally dependent on past or current conditions.

Point of compliance: As defined by applicable EPA standards (none currently in effect for NRC-licensed repositories sited and characterized under the NWPA). The substantially complete containment requirement is evaluated at the exterior of the waste packages. The gradual release requirement is evaluated at the outer boundary of the engineered barrier system. Siting criteria are applied both within the controlled area and in its general vicinity.

Ground water protection: There is no separate ground water protection requirement.

Intruder assumptions: The repository will be sited, marked, and documented to discourage intrusion. Inadvertent human intrusion into the repository must be addressed. Processes and events initiated by human activities are to be considered as part of quantitative performance assessments for sufficiently credible scenarios, subject to specified assumptions. These assumptions include: (a) required monuments are sufficiently permanent to serve their intended purpose; (b) value of resources to future generations can be adequately assessed; (c) c:iscors3.new h

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institutions will continue to exist that retain knowledge of radiation and its hazards; (d) institutions will exist that can assess risk and take remedia! action at the same, or superior level of technological competence as that which initiated the intrusion; and (e) relevant records and archives remain intact and are accessible for several hundreds of years.

Documentation: Extensive documentation is required including: a site characterization plan, a license application, an environmental impact statement, license application updates, and permanent records in local, national, and international archives and land record systems.

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NRC LLW Digposal Regulation,10 CFR 61 Applicability: Radioactive waste not HLW, spent nuclear fuel, TRU waste,11(e).2 byproduct material, NORM waste, or accelerator-produced material (small quantities of 11(e).2 byproduct material are acceptable in LLW disposal facilities).

Approach: Combines performance assessment and specified design approach. Requires performance assessment of projected doses to public. As used here, performance assessment is a type of systematic analysis that addresses, among other things, what can happen and what the resulting impacts (i.e., radiation dose) might be. It includes the site, engineered features, and scenarios that could cause radiation doses to humans. For all pathways except direct exposure, the performance objective (design) limit is 75 mrem /yr to thyroid and 25 mrem /yr to whole body or any other organ. Reduce effluents to ALARA levels. Direct exposure pathway is subject to 10 CFR 20 limits (100 mrem (ede)/yr plus ALARA). Also requires acceptance and disposal of waste based on specified waste classification limits and procedures and waste form requirements.

A principal objective for waste disposal is to ensure long-term stability of the disposal site to eliminate to the extent practicable the need for ongoing active maintenance following closure.

A monitoring program is required and will be established on a site-specific basis, institutional controls: State or Federal govemment must own site land. Rule indicates that monitoring and other active measures would be replaced after 100 years by passive institutional control measures. Owner of facility could continue active controls for longer periods, if desired.

However, as noted below, no credit is allowed for active institutional controls after 100 years in the demonstration of compliance with the dose limit in the rule.

PA assurnptions-assume "no credit for active institutional controls after 100 years."

Draft guidance recommends reasonable extrapolation of current processes and events to future.

Time period: Not stated in rule, but draft PA guidance has recommended consideration up to 10,000 years, and beyond if needed. No final guidance is available.

Point-of e.ompliance: Draft PA (and earlier) guidance recommends a point of compliance outside of e buffer zone around waste. The buffer zone is to be specified on a site-specific basis but would normally be only a few hundred yards wide.

Groundwater protection: No specific Part 61 require nent to protect groundwater as a separate entity, Groundwater is a pathway considered n pas for assessment of 25/75/25-mrem /yr design objective. NRC considers this and other Part 61 requirements including those for long-tenn disposal facility stability, institutional controls, monitoring, and waste form to be adequate for groundwater protection.

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4 Intruder assumptions: Rule includes a performance (design) objective to protect an inadvertent intruder. In most cases, no analysis need be performed. Intrusion protection results from generic waste classification systeri: including requirements for waste form, limits on

- concentrations of specific radionuclides, and requirements for segregation and deeper disposal of highest-activity (Class C) wastes. An intruder barrier may be substituted for deeper disposal.

A rule " construct" is that a exposure of an intruder (i.e. a person who intrudes directly into a disposal cell, by building a house foundation, e.g.) and exposure of a member of the general public (a resident farmer, e.g.) outside of the boundaries of the site occur independently, and not simultaneously or sequentially.

Waste form requirements: In addition to minimum requirements pertaining to worker safety considerations (e.g., cardboard boxes are prohibited, as is free-standing liquid above 1%

volume), higher activity (Class B and C) wastes must be disposed in a manner providing structural stability. Performance requirements for structural stability are specified.

Documentation: Operations take place in accordance with a licence developed from an application that includes a Safety Analysis Report and an Environmental Report.

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Applicability:

Separate, site-specific criteria are being develcped (at 10 CFR Part 63] to implement new dose-or risk-based standards for Yucca Mountain that will be established, consistent with the requirements of the Energy Policy Act of 1992 (EnPA). On March 6,1998, the Commission directed its staff to commence development of new Yucca Mountain-specific regulations.

These new regulations at Part 63 are being developed to implement dose-or risk-based standards, consistent with the EnPA and generally consistent with the August 1,1995 recommendations of the National Academy of Sciences made pursuant to that act.

Approach:

NRC expects to develop regulations that will rely on the resuits of predictive performance assessment of the Yucca Mountain repository system. Reasonable assurance of compliance with the applicable overall repository system performance objective (expressed in terms of dose i

or risk to the average member of the critical group) will be the basis for licensing. In addition, the robustness of the repository system design must be estimated by assessi:

• 0 performance of the repository system when subjected to a prescribed, stylized ; s scenario (e.g. a single borehole of specified diameter, drilled from the surface t - @ a single waste canister to the underlying aquifer). NAS recommended that.. "the estimateu.uk calculated from such the assumed intrusion scenario be no greater than the risk limit adopted for the undisturbed-repository case because a repository that is suitable for long-term disposal should be able to continue to provide acceptable waste isolation after some type of intrusion."

Institutional Controls:

Under Section 801(c) DOE is required to centinue to oversee the site after permanent closure to prevent any activity at the site that poses an unreasonable risk of breaching the repository's engineered or geologic barriers; or increasing the exposure of the public to radiation beyond allowable limits.

NAS recommended that it is not reasonable to assume that such a system for post-closure oversight, based on active institutionai controls, can be developed, that will prevent such risks, i

or increased exposures.

Although DOE is clearly required, under statute, to provide active controls in perpetuity, it is unclear, at this time, how the effectiveness of such controls will be considered in assessing compliance o' the repository system with the overall pedormance objective. Nonetheless, the consequences of an assumed intrusion will be evaluated under the current approach.

Time period:

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6 The NAS recommended that " compliance assessment be conducted for the time when the,

greatest risk occurs, within the limits' imposed by long-term stability of the geologic environment". The NAS found no scientific basis for limiting the time period for an individual risk standard to 10,000 years. NRC recognizes that selection of a compliance period involves not only scientific considerations, but policy considerations as well. In formulating a rulemaking proposal, NRC will need to evaluate the merits, feasibility, and relative uncertainties associated with applying a quantitative limit to risks incurred at time frames considerably longer than those used for assessing acceptable risk for other hazards.

Point of Compliance:

NAS recommended that dose should be assessed for the average member of a hypothetical critical group expected to be at highest risk and defined based on present knowledge, using cautious, but reasonable, assumptions (including those with~ regard to the group's location).

The critical group risk, calculated for purposes of comparison with the overall system performance objective, should be the mean risk to the members of the group. Proposed regulations for Yucca Mountain will specify the location and characteristics of the critical group.

Ground water protection:

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NAS did not recommend inclusion of separate criteria for ground water as being necessary to limit risks to individuals. The Commission has directed the NRC staff to oppose inclusion of i

separate groundwater criteria and the staff has no plans at this time to implement separate groundwater criteria.

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r1 Intruder Assumptions:

NAS recommended that it is not possible to make scientifically supportable predictions of the probability that a repository's engineered or geologic barriers will be breached as a result of j

human intrusion over a period of 10,000 years. NAS also concluded that, while passive controls may be helpful in reducing the risk of intrusion, there exists no technical basis for making forecasts about the long-term reliability of passive institutional controls, such as markers, monuments, and records. Although it cannot be proven, however, NAS stated its belief that a collection of prescriptive requirements, comprising both active and passive controls, will help reduce the risk of intrusion, at least in the near term According to NAS, it is not reasonable to attempt to protect the intruders themselves or the public from material brought to the surface by the inadvertent intruder, other than through the use of controls discussed above. For purposes of compliance, a separate analyses should focus on the consequences of inadvertent intrusion on repository performance arising from modification of the repository's engineered and geologic barriers to perform their intended function.

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4 NRC Restricted Release of Decommissioned Sites (Subpart E of 10 CFR Part 20)

Applicability: To provide for termination of NRC licenses at facilities with some residual radioactive material remaining onsite. Institutional controls would be relied on to limit doses to control land use and thereby limit doses to members of the public. Applies to residual source, byproduct and special nuclear material.

Approach: Two tiered approach. Dose limit from all pathways of 25 mrem /yr to average member of critical group, assuming that institutional controls are functioning. Comp!iance with higher dose limit of 100 mrem /yr or 500 mrem /yr (under certain specified circumstances) assuming that institutionM controls fail. ALARA also applies. Compliance demonstration similar to Part 61 in NRC LLW oisposal regulation, and involves use of a performance assessment of the site to determine compliance with dose limits in future, for up to 1000 years.

The 100 mremlyr cap applies when institutional controls are assumed to fail. A 500 mrem /yr cap could apply if:

a) licensee demonstrates that further reductions in residual radioactivity to comply with the 100 mremlyr limit are not technically achievable, would be prohibitively expensive, or would result in net public harm.

b) Licensee makes provisions for durable institutional controls.

c) Licensee sets aside sufficient financial assurance to enable a responsible third party to carry out controls and 5 year rechecks of the site.

Institutional centrols:

Controls must be legally enforceable. Details on types of controls are being developed by NRC staff in a Regulatory Guide. At this time, the controls are generally passive, land-use controls.

Time period:

A 1000 year time period is specified in the rule.

Point-of compliance:

Both on-site and offsite. For sites that have a restricted release (i.e. that rely on institutional controls to limit doses), a 25 rnrem/yr dose limit applies onsite and offsite when the controls are functioning. These controls could, for example, prohibit certain land uses on-site, such as farming or excavating soil, but would permit members of the public to be on-site for authorized uses of the property. For the restricted release scenano, the NRC rule requires that the institutional controls be postulated to fail and that the resulting dose to a member of the public be no more than 100 mrem / year, or 500 mremlyr in unusual site-specific circumstances. This dose would be expected to be for an onsite member of the public.

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i Groundwater protection:

As in other NRC regulations, ground water protection is provided for by the all pathways standard, in this case both 25 mem/yr and 100 or 500 mrem /yr. No specific ground water provisions are specified.

Intruder assumptions:

Intruder could come onto site, after institutional controls fail, and take up residence without a time limit. More specific guidance on exposure scenarios is being developed in staff guidance documents. " Intruder"(or average member of the critical group that becomes exposed when the institutional controls fail) cannot receive dose of greater than 100 mrem /yr, or 500 mrem /yr under certain circumstances.

Waste form requirements:

No waste form requirements apply. The rule applies to residual radioactivity in soil, slag, building surfaces, etc. left at site.

Documentation:

Licensee must submit a decommissioning plan that provides all of the dose analyses, scenario assumptions, etc. An environmental report may also be required, and NRC may have to prepare an EIS.

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CHARTER FOR INTERAGENCY STEERING COMMITTEE ON RADIATION STANDARDS Purooce of Committee The purpose of this committee is to foster early resolution and coordination of regulatory issues associated with radiation standards.

Membershio 1.

Agencies represented on the committee include the U.S. Environmental Protection Agency, U.S. Nuclear Regulatory Commission, U.S. Department of Energy, U.S. Department of Defense, U.S. Department of Transportation, the Occupational Safety and Health Administration of the U.S. Department of Labor, the U.S. Department of Health and Human Services, and any successor agencies.

2.

The Office of Science and Technology Policy and the Office of Management and Budget will be invited as observers at meetings because of their responsibilities for coordination of science policy and regulation policy, respectively.

3.

The committee will be co-chaired by the EPA and NRC representatives for the first two years, after which the committee will determine whether the chairmanship should be rotated among additional agencies, or whether the chairmanship should be held by a single. agency.

4.

Other departments and agencies will be invited to participate in forming consensus for specific issues as voting members when their interests and responsibilities are involved.

Ob.iectives The objectives of the committee include the following:

1.

Facilitate a consensus on allowable levels of radiation risk to the public and workers.

2.

Promote consistent and scientifically sound risk assessment and risk management approaches in setting and 3mplementing standards for occupational and public protection from ionizing radiation.

3.

Promote completeness and coherence of Federal standards for radiation protection, j

4.

Identify interagency radiation protection issues and coordinate their resolution.

Imolementation 1

The committee will conduct its activities in accordance with the attached understandings and procedures.

Ert&oSMC)

Attachment UNDERSTANDINGS AND PROCEDURES FOR THE INTERAGENCY STEERING COMMITTEE ON RADIATION STANDARDS Participation 1.

Various offices and agencies within each agency may participate in the committee meetings.

Each agency will develop a unified position and present that position at committee meetings.

Each agency representative is responsible for developing their coordinated agency position in preparation for reaching committee consensus.

2.

Agencies will be represented at the meetings by senior level, career government employees, who are engaged in policy matters for the agency.

3.

Official agency representatives will be identified in writing to the co-chairpersons by the Assistant Administrator, Secretary, or Commissioner, as appropriate.

4.

Committee meetings involve pre-decisional intragovernmental discussions and, as such, are not open for observation by members of the public or media.

5.

The committee may, from time to time, revise the charter based on the consensus views of the committee, including such items as membership, responsibility for chairing the committee, and objectives.

Decisions 1.

The committee has not been delegated any authorities established by law, regulation, Executive Order, or other administrative mechanism to act in lieu of formal agency action. The objectives of the committee are described in the committee charter.

2.

The committee will make every effort to base decisions on consensus.

Consensus reflects acceptance among the voting agencies.

3.

Each agency will have a single vote in reaching consensus on specific issues.

If a consensus cannot be reached, committee recommendations will reflect the lack thereof and include the opportunity for agencies to attach minority views to any documentation of the recommendations.

4.

Recommendations on specific issues will be provided to the heads of member agencies, OMB, and OSTP.

Meetinas 1.

Responsibility for hosting the meetings will rotate among the agencies.

The host agency is responsible for developing a mutually agreeable meeting date and time, informing the agencies at least two weeks in advance of the

meeting date, distributing a draft agenda for the meeting, arranging for a meeting facility, and documenting and distributing summary meeting notes.

2.

Summary meeting notes will be provided by the host agency to designated representatives of each of the member agencies, OMB, OSTP, and, as appropriate, Congressional contacts and other groups.

The host agency will distribute draft notes within one week of the committee meeting and final meeting notes at least two weeks before the next committee meeting.

NRC will also place a copy of the summary meeting notes in the Public Document Room.

3.

The committee will establish a plan for approximately a six-month period.

Specific agendas will be developed for each meeting based on the general plan.

4.

The committee will meet approximately once each calendar quarter, with more frequent meetings, as needed to address specific issues.

Lubcommittees 1.

The committee may create subcommittees to focus on specific issues or activities (e.g., recycling criteria, risk harmonization, cleanup standards).

Subcommittees will follow the same understandings and procedures as the full committee.

2.

Subcommittees will meet at a frequency and location as determined necessary by the subcommittee.

2:

1

y, FOR THE V.S. NUCLEAR REGULATORY COMMISSION, Li 11 # 2 ll-/(~ 9 V Hug ( y. Thompson, f. /'f Date DepKy Executive mrecter for Nuclear Materials Safety, Safeguards and Operations Support FOR THE

.E IR0 NTAL PROTECTION AGENCY, p

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MaryAicWols Date Assistant Administrator Offii:e of Air and Radiation FOR T

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DEPARTMENT OF ENERGY, s~ oG

>blu Tara O'Toole, M.D., M.P.H.

Date Assistant Secretary for Environment, Safety and Health FOR THE U.S. DEPARTMENT OF DEFENSE, fa g, Jul. I 21996 Paul G. Kaminski Date Under Secretary of Defense (Acquisition & Technology)

FOR THE U.S. DEPARTMENT OF TRANSPORTATION, h.k,

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Dr. Dharmendra K. Sharma Date Administrator Research and Special Programs Administration FOR THE U.S. DEPARTMENT OF LABOR,

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-l^ !D Greg Wa@hman Datei Acting Assistant Secretary for Occupational Safety and Health A& ministration

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FOR THE US DEPARTMENT OF HEALTil AND HUMAN SERVICES

[- Iv. 9 7 Jo Ivey Boufig M.D.

Date Acting Assistant Secretary for Health

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t NRC HLW Disposal Regulation,10 CFR Part 60 Applicability! Disposal of high-level radioactive wastes (and spent nuclear fuel) in a geologic repository. Will most likely not apply to Yucca Mountain. Separate, site-specific criteria are being developed [at 10 CFR Part 63] to implement new dose-or risk-based standards for Yucca Mountain that will be established, consistent with the requirements of the Energy Policy Act of 1992.

Approach: Uses both predictive performance assessments and currently measurable design and siting criteria. Reasonable assurance of compliance with applicable EPA containment standards (none currently in effect for NRC-licensed repositories sited and characterized under the NWPA) plus substantially complete containment and gradual release requirements require predictive analysis. Siting criteria based on historical and current conditions are potentially measurable. Some design criteria are currently determinable and others require predictive analysis.

Institutional controls: The repository is to be sited, marked, and documented to discourage intrusion. Land is required to be permanently withdrawn and reserved for repository use. DOE is required to exercise any jurisdiction and controls over surface and subsurface estates (/.e.

passive controls), as necessary to prevent adverse human actions. However, effectiveness of active controls may not be assumed for longer than 100 years following permanent closure for purposes of compliance demonstration. Monuments and records are required to prevent activities which could impair long term isolation and to assure that information is preserved for future generations.

Time period: Compliance with applicable EPA standards (none currently in effect for NRC-licensed repositories sited and characterized under the NWPA)is required. Containment is to be substantially complete for a period of between 300 and 1,000 years. Following this containment period, any releases are required to be gradual; no time period is specified for this i

requirement. Other siting and design requirements are generally dependent on past or current conditions.

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1 Point of compliance: As defined by applicable EPA standards (none currently in effect for NRC-licensed repositories sited and characterized under the NWPA). The substantially complete containment requirement is evaluated at the exterior of the waste packages. The gradual release requirement is evaluated at the outer boundary of the engineered barrier system. Siting criteria are applied both within the controlled area and in its general vicinity.

Ground water protection: There is no separate ground water protectior. aquirement.

j intruder assumptions: The repository will be sited, marked, and documented to discourage intrusion. Inadvertent human intrusion into the repository must be addressed. Processes and events initiated by human activities are to be considered as part of quantitative performance assessments for sufficiently credible scenarios, subject to specified assumptions. These assumptions include: (a) required monuments are sufficiently permanent to serve their intended purpose; (b) value of resources to future generations can be adequately assessed; (c) institutions will continue to exist that retain knowledge of radiation and its hazards; (d) institutions will exist that can assess risk and take remedial action at the same, or superior level of technological competence as that which initiated the intrusion; and (e) relevant records and ffflicH/f9K 3

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archives remain intact and are accessible for several hundreds of years.

Docur' entation: Extensive documentation is required including: a site characterization plan, a n

license application, an environmental impact statement, license application updates, and permanent records in local, national, and international archives and land record systems.

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NRC LLW Disposal Regulation,10 CFR 61 Applicability':~ Radioactive waste not HLW, spent nuclear fuel, TRU waste,11(e).2 byproduct material, NORM waste, or accelerator-produced material (small quantities of 11(e).2 byproduct material are acceptable in LLW disposal facilities).

Approach: Combines performance assessment and specified design approach. Requires performance assessment of projected doses to public. As used here, performance assessment is a type of systematic analysis that addresses, among other things, what can happen and what the resulting impacts (i.e., radiation dose) might be. It includes the site, engineered features, and scenarios that could cause radiation doses to humans. For all pathways except direct exposure, the performance objective (design) limit is 75 mrem /yr to thyroid and 25 mrem /yr to whole body or any other organ. Reduce effluents to ALARA levels. Direct exposure pathway is subject to 10 CFR 20 limits (100 mrem (ede)/yr plus ALARA). Also requires acceptance and disposal of waste based on specified waste classification limits and procedures and waste form requirements.

A principal objective for waste disposal is to ensure long-term stability of the disposal site to eliminate to the extent practicable the need for ongoing active maintenance following closure.

A monitoring program is required and will be established on a site specific basis.

Institutional controls: State or Federal government must own site land. Rule indicates that monitoring and other active measures would be replaced after 100 years by passive institutional control measures. Owner of facility could continue active controls for longer periods, if desired.

However, as noted below, no credit is allowed for active institutional controls after 100 years in the demonstration of compliance with the dose limit in the rule.

PA assumptions-assume "no credit for active institutional controls after 100 years."

Draft guidance recommends reasonable extrapolation of current processes and events to future.

Time period: Not stated in rule, but draft PA guidance has recommended consideration up to 10,000 years, and beyond if needed. No final guidance is available.

Point-of-compliance: Draft PA (and earlier) guidance recommends a point of compliance outside of a buffer zor.e around waste. The buffer zone is to be specified on a site-specific basis but would normally be only a few hundred yards wide.

Groundwater protection: No specific Part 61 requirement to protect groundwater as a separate entity. Groundwater is a pathway considered in pas for assessment of 25/75/25-mrem /yr design objective. NRC considers this and other Part 61 requirements including those for long-term disposal facility stability, institutional controls, monitoring, and waste form to be adequate for groundwater protection.

Intruder assumptions: Rule includes a performance (design) objective to protect an inadvertent intruder. In most cases, no analysis need be performed. Intrusion protection results from generic waste classification system including requirements for waste form, limits on concentrations of specific radionuclides, and requirements for segregation and deeper disposal of highest-activity (Class C) wastes. An intruder barrier may be substituted for deeper disposal.

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Q A rule " construct" is that a exposure of an intruder (i.e. a person who intrudes directly into a disposal cell, by building a house foundation, e.g.) and exposure of a member of the general public'(a resident farmer, e.g.) outside of the boundaries of the site occur independently, and not simultaneously or sequentially.

Waste form requirements: In addition to minimum requirements pertaining to worker safety considerations (e.g., cardboard boxes are prohibited, as is free standing liquid above 1%

volume), higher activity (Class B and C) wastes must be disposed in a manner providing structural stability. Performance requirements for structural stability are specified.

Documentation: Operations take place in accordance with a licence developed from an application that includes a Safety Analysis Report and an Environmental Report.

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NRC Yucca Mountain HLW Disposal Regulation,10 CFR Part 63 [In preparation]

4 Applicability!

Separate, site-specific criteria are being developed (at 10 CFR Part 63] to implement new dose-or risk-based standards for Yucca Mountain that will be established, consistent with the requirements of the Energy Policy Act of 1992 (EnPA). On March 6,1998, the Commission directed its staff to commence development of new Yucca Mountain specific regulations. These new regulations at Part 63 are being developed to implement dose-or risk-based standards, consistent with the EnPA and generally consistent with the August 1,1995 recommendations of the National Academy of Sciences made pursuant to that act.

Approach:

NRC expects to develop regulations that will rely on the results of predictive performance assessment of the Yucca Mountain repository system. Reasonable assurance of compliance with the applicable overall repository system performance objective (expressed in terms of dose or risk to the average member of the critical group) will be the basis for licensing. In addition, the robustness of the repository system design must be estimated by assessing the performance of the repository system when subjected to a prescribed, stylized intrusion scenario (e.g. a single borehole of specified diameter, drilled from the surface through a single waste canister to the underlying aquifer). NAS recommended that..*the estimated risk calculated from such the assumed intrusion scenario be no greater than the risk limit adopted for the undisturbed-repository case because a repository that is suitable for long-term disposal should be able to continue to provide acceptable waste isolation after some type of intrusion."

institutional Controls:

Under Section 801(c) DOE is required to continue to oversee the site after permanent closure to prevent any activity at the site that poses an unreasonable risk of breaching the repository's engineered or geologic barriers; or increasing the exposure of the public to radiation beyond allowable limits.

NAS recommended that it is not reasonable to assume that such a system for post-closure oversight, based on active institutional controls, can be developed, that will prevent such risks, or increased exposures.

Although DOE is clearly required, under vatute, to provide active controls in perpetuity, it is unclear, at this time, how the effectiveness of such :ontrols will be considered in assessing compliance of the repository system with the overall performance objective. Nonetheless, the consequences of an assumed intrusion will be evaluated under the current approach.

Time period:

The NAS recommended that " compliance assessment be conducted for the time when the greatest risk occurs, within the limits imposed by long-term stability of the geologic 1

environment'. The NAS found no scientific basis for limiting the time period for an individual risk standard to 10,000 years. NRC recognizes that selection of a compliance period involves not only scientific considerations, but policy considerations as well, in formulating a rulemaking

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proposal, NRC will need to evaluate the merits, feasibility, and relative uncertainties associated with applying a quantitative limit to risks incurred at time frames considerably longer than those used f'or assessing acceptable risk for other hazards.

Point of Compliance:

NAS recommended that dose should be assessed for the average member of a hypothetical critical group expected to be at highest risk and defined based on present knowledge, using cautious, but reasonable, assumptions (including those with regard to the group's location). The critical group risk, calculated for purposes of comparison with the overall system performance objective, should be the mean risk to the members of the group. Proposed regulations for Yucca Mountain will specify the location and characteristics of the critical group.

Ground water protection:

NAS did not recommend inclusion of separate criteria for ground water as being necessary to limit risks to individuals. The Commission has directed the NRC staff to oppose inclusion of separate groundwater criteria and the staff has no plans at this time to implement separate groundwater criteria.

Intruder Assumptions:

NAS recommended that it is not possible to make scientifically supportable predictions of the probability that a repository's engineered or geologic barriers will be breached as a result of human intrusion over a period of 10,000 years. NAS also concluded that, while passive controls may be helpfulin reducing the risk of intrusion, there exists no technical basis for making forecasts about the long-term reliability of passive institutional controls, such as markers, monuments, and records. Although it cannot be proven, however, NAS stated its belief that a j

collection of prescriptive requirements, comprising both active and passive controls, will help J

reduce the risk of intrusion, at least in the near term. According to NAS, it is not reasonable to attempt to protect the intruders themselves or the public from material brought to the surface by the inadvertent intruder, other than through the use of controls discussed above. For purposes of compliance, a separate analyses should focus on the consequences of inadvertent intrusion on repository performance arising from modification of the repository's engineered and geologic barriers to perform their intended function.

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f NRC Restricted Release of Decommissioned Sites (Subpart E of 10 CFR Part 20)

Applicability: To provide for termination of NRC licenses at facilities with some residual radioactive material remaining onsite. Institutional controls would be relied on to limit doses to control land use and thereby limit doses to members of the public. Applies to residual source, byproduct and special nuclear material.

Approach: Two tiered approach. Dose limit from all pathways of 25 mrem /yr to average member of critical group, assuming that institutional controls are functioning. Compliance with higher dose limit of 100 mrem /yr or 500 mrem /yr (under certain specified circumstances) assuming that institutional controls fail. ALARA also applies. Compliance demonstration similar to Part 61 in NRC LLW disposal regulation, and involves use of a performance assessment of the site to determine compliance with dose limits in future, for up to 1000 years.

The 100 mrem /yr cap applies when institutional controls are assumed to fail. A 500 mrem /yr cap could apply if:

a) licensee demonstrates that further reductions in residual radioactivity to comply with the 100 mrem /yr limit are not technically achievable, would be prohibitively expensive, or would result in net public harm.

b) Licensee makes provisions for durable institutional controls.

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c) Licensee sets aside sufficient financial assurance to enable a responsible third party to carry out controls and 5 year rechecks of the site.

Institutional controls:

Controls must be legally enforceable. Details on types of controls are being developed by NRC staff in a Regulatory Guide. At this time, the controls are generally passive, land-use controls.

Time period:

A 1000 year time period is specified in the rule.

Point-of-compliance:

Both on-site and offsite. For sites that have a restricted release (i.e. that rely on institutional controls to limit doses), a 25 mrem /yr dose limit applies onsite and offsite when the controls are functioning. These controls could, for example, prohibit certain land uses on-site, such as farming or excavating soil, but would permit members of the public to be on-site for authorized uses of the property. For the restricted release scenario, the NRC rule requires that the institutional controls be postulated to fail and that the resulting dose to a member of the public be no more than 100 mrem / year, or 500 mrem /yr in unusual site-specific circumstances. This dose would be expected to be for an onsite member of the public.

Groundwater protection:

As in other NRC regulations, ground water protection is provided for by the all pathways standard, in this case both 25 mem/yr and 100 or 500 mrem /yr. No specific ground water provisions are specified.

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Intrud,er assumptions:

Intruder could come onto site, after institutional controls fail, and take up residence without a time limit. More specific guidance on exposure scenarios is being developed in staff guidance documents. " Intruder" (or average member of the critical group that becomes exposed when the institutional controls fail) cannot receive dose of greater than 100 mrem /yr, or 500 mrem /yr under certain circumstances.

Waste form requirements:

No waste form requirements apply. The rule applies to residual radioactivity in soil, slag, building surfaces, etc. left at site.

Documentation

• Licensee must submit a decommissioning plan that provides all of the dose analyses, scenario assumptions, etc. An environmental report may also be required, and NRC may have to prepare an E!S.

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CHARTER FOR INTERAGENCY STEERING COMMITTEE ON RADIATION STANDARDS Purpose of Comittee The purpose of this comittee is to foster early resolution and coordination of regulatory issues associated with radiation standards.

Membershio i

1.

Agencies represented on the comittee include the U.S. Environmental Protection Agency, U.S. Nuclear Regulatory Comission, U.S. Department of Energy, U.S. Department of Defense, U.S. Department of Transportation, the Occupational Safety and Health Administration of the U.S. Department of Labor, the U.S. Department of Health and Human Services, and any successor agencies.

2.

The Office of Science and Technology Policy and the Office of Management and Budget will be invited as observers at meetings because of their responsibilities for. coordination of science policy and regulation policy, respectively.

3.

.The comittee will be co-chaired by the EPA and NRC representatives for the first two years, after which the comittee will determine whether the chairmanship should be rotated among additional agencies, or whether the chairnanship should be held by a single agency.

4.

Other departments and agencies will be invited to participate in forming consensus for specific issues as voting members when their interests and responsibilities are involved.

Qb.iectives The objectives of the comittee include the following:

1.

Facilitate a consensus on allowable levels of radiation risk to the public and workers.

2.

Promote consistent and scientifically sound risk assessment and risk management approaches in setting and implementing standards for occupational and public protection from ionizing radiation.

3.

Promote completeness and coherence of Federal standards for radiation protection.

4.

Identify interagency radiation protection issues and coordinate their resolution.

Imolementation The committee will conduct its activities in accordance with the attached understandings and procedures.

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Attachment UNDERSTANDINGS AND PROCEDURES FOR THE INTERAGENCY STEERING COMMITTEE ON RADIATION STANDARDS Participation 1.

Various offices and agencies within each agency may participate in the committee meetings.

Each agency will develop a unified position and present that position at committee meetings.

Each agency representative is responsible for developing their coordinated agency position in preparation for reaching committee consensus.

2.

Agencies will be represented at the meetings by senior level, career government employees, who are engaged in policy matters for the agency.

3.

Official agency representatives will be identified in writing to the co-chairpersons by the Assistant Administrator, Secretary, or Commissioner, as appropriate.

4.

Committee meetings involve pre-decisional intragovernmental discussions and, as such, are not open for observation by members of the public or media.

5.

The committee may, from time to time, revise the charter based on the consensus views of the committee, including such items as membership, responsibility for chairing the committee, and objectives.

Decisions 1.

The committee has not been delegated any authorities established by law, regulation, Executive Order, or other administrative mechanism to act in lieu of formal agency action. The objectives of the committee are described in the committee charter.

2.

The committee will make every effort to base decisions on consensus.

Consensus reflects acceptance among the voting agencies.

3.

Each agency will have a single vote in reaching consensus on specific issues.

If a consensus cannot be reached, committee recommendations will reflect the lack thereof and include the opportunity for agencies to attach

-minority views to any documentation of the recommendations.

4.

Recommendations on specific issues will be provided to the heads of member agencies, OMB, and OSTP.

Meetinas 1.

Responsibility for hosting the meetings will rotate among the agencies.

The host agency is responsible for developing a mutually agreeable meeting date and time, informing the agencies at least two weeks in advance of the

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_g"a-4i meeting date, distributing a draft agenda for the meeting, arranging for a meet,ing facility, and documenting and distributing summary meeting notes.

2.

Summary meeting notes will be provided by the host agency to designated representatives of each of the member agencies, OMB, OSTP, and, as appropriate, Congressional contacts and other groups.

The host agency will distribute draft notes within one week of the committee meeting and final meeting notes at least two weeks before the next committee meeting. NRC will also place a copy of the summary meeting notes in the Public Document Room.

3.

The committee will establish a plan for approximately a six-month period.

Specific agendas will be developed for each meeting based on the general plan.

4.

The committee will meet approximately once each calendar quarter, with more frequent meetings, as needed to address specific issues.

Subcommittees 1.

The committee may create subcommittees to focus on specific issues or activities (e.g., recycling criteria, risk harmonization, cleanup standards).

Subcommittees will follow the same understandings and procedures as the full committee.

l 2.

Subcommittees will meet at a frequency and location as determined necessary by the subcommittee.

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FOR THE U.S. NUCLEAR REGULATORY COMMISSION, 1

1. 2 lb '/['9 V Hugh V. Thompson, 8. &

Date DepKy Executive Directefr for Nuclear Materials Safety, Safeguards and Operations Support

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FOR THE

.E IRO NTAL PROTECTION AGENCY,

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Mary /NicHols Date

- Assistant Administrator Office of Air and Radiation FOR T

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DEPARTMENT OF ENERGY, noCL Mu Ta'ra O'Toole, M.D., M.P.H.

Date Assistant Secretary for Environment, Safety and Health FOR THE U.S. DEPARTMENT OF DEFENSE, f

g JUI.1 21996 Paul G. Kaminski Date Under Secretary of Defense (Acquisition & Technology)

FOR THE U.S. DEPARTMENT OF TRANSPORTATION, h.f. l % Lt.~ f-Dr. Dharmendra K. Sharma Date Administrator Research and Special Programs Administration FOR THE U.S. DEPARTMENT OF LABOR, b

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,D Greg Wa( haan Date.

Acting Assistant Secretary for Occupational Safety and Health Administration m

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'l~7 Jo Ivey BoufigM.D.

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