ML20217M854

Forwards Summary of Atlanta Meeting Held on 991005-06 Re Control of Solid Matls

ML20217M854
Person / Time
Issue date:	10/08/1999
From:	Patricia Holahan NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Tracy G NRC
References
NUDOCS 9910280060
Download: ML20217M854 (16)

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October 8,1999 Note to: Glenn Tracy e From: Patricia K. Holahan, IMNS/NMS i '" NLIC C0CMNT Rccn

SUMMARY

OF ATLANTA MEET NG ON CONTROL 00 SOUD;MATERJALS Attached is a brief summary of the Atlanta meeting held on October 5-6,1999. Tilese are the highlights that were raised in the discussions during each session. We have only provided the key points but further details will be provided in a summary being prepared by Meridian Institute. A draft of the summary will be submitted to NRC in two weeks. In addition, the staff is prepanng a Commission item of interest regarding the meeting.

I am also providing you with hard copies of the slides used and a letter signed by 125 citizen groups and individuals that was read into the transcript at the meeting.

The staff is continuing to prepare for the next meeting to be held in Rockville, MD on November 1-2,1999, t  :

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. . 1 g 4 Summary of Major Points raised at NRC Workshop on Control of Solid Materials I October 5-6,1999 Atlanta, Georgia l l

For each of the sessions we have briefly described the focus of the session, followed by some of the key points that were raised by attendees. This is not intended to be a comprehensive summary. These ideas will be more fully characterized in the detailed  ;

summary to follow. l l

Session 1: Why are we here today This session focused on three principal topics: 1) why NRC is examining its approach for controlling solid materials; 2) what is NRC's purpose in publishing the issues paper and j holding public meetings; and 3) what process for decision-making is being considered.

Most of the discussion centered around the 1" and 3" items.

Some of the principal comments received from attendees related to NRC's examination of its approaches for controlling solid materials included:

consistency of standards would be useful, e.g., some comments noted that because standards are different around the country, a national standard is i needed materials need to be released from facilities each day and decisions are needed about what should be done with these materials criteria are needed because without them it is difficult for licensees to clean up their facilities Some of the principal comments received from attendees related to the process for decision-making included:

this area impacts many industries and it is good to have early input there was disappointment that public groups were not attending the meeting; a process is needed that has support of the public interest community steelindustry representatives noted that public perception of safety of products are key issues; without public acceptance, there can be an effect on manufacturers of these products and on potential for development of a standard it was noted that the public is involved and informed and has written letters to the Vice President in opposition to this process there is public concern related to potential for releases because of recent events like Paducah it was noted that much information on effects of radioactivity is obtained from various media, e.g., television, magazines, etc NRC should clarify whether what it is proposing would result in releasing more material and what would be different in society it may be appropriate to develop a result similar to when FAA determines that certain standards and activities are safe

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e in 1 7, EPA published a technical report and received 200 letters opposed to recycling as part of this process, it should be clear that the U.S. imports material derived from recycled radioactive material Session 2 - How does what we are discussina today fit into the overall picture?

This session focused on three topics: 1) what type of solid materials are we talking about; 2) what is the potential radiation dose being considered and how does it compare to the dose received from other sources; and 3) what are other Federal agencies, States, countries, and organizations doing with regard to control of solid materials Comments received from attendees on the following topics included:

a) Types of solid materials:

the impact on metals should be the main issue because of concerns about recycled material in steel products and the history of problems for the steel and recycling industry from lost sources all material should be covered in a dose-based standard; this may be difficult to do, but it would establish a basis for control of radioactive materials questions were raised as to whether other types of material will also be covered; analyses are being done of soil and concrete as well as metals; other materials could be studied b) Issues regarding other Federal agencies, States, countries ,and organizations:

EPA NRC is working with EPA on this effort; the agencies have previously worked together to develop technical bases EPA noted it is not developing a standard in this area because of higher priorities; NRC is within theirjurisdiction to develop standards in this area for its licensees lAEA Technical Document (TecDoc) 855 is being developed internationally (with EPA and NRC coordination) as a consensus document; because releases of materials can go worldwide, TecDoc 855 could impact many decisions and areas need to consider how NRC efforts correspond to IAEA and other European and international work; there is concern that an NRC standard, if different from and more restrictive than international standards, would not be accepted worldwide and trade problems could occur States these are policy issues needing Agreement State input; NRC should offer flexibility in compatibility levels for Agreement States for any standard issued

Session 3: How does NRC currently handle control of solid materials?

This session focused on two topics: 1) what is the current NRC case-by case approach; and 2) how much solid material has been released so far under current practices.

Most of the comments centered on the current case-by-case approach. Suggestions and comments from attendees included the following areas:

a) Use of Reg Guide 1.86:

some comments noted problems with Reg Guide 1.86, e.g., it does not have dose assessment guidance, volumetric contamination is not considered, it does not address tritium or carbon-14 some comments noted that continuing the current use of Reg Guide 1.86 should be considere; reasons for continuing its use included: 1) it has been a useful tool for 20 years; 2) it is health protective and 3) there is common understanding as l to how to use it 1 should consider the effect on the current case-by-case approach of more material j being available for release in the future because of decommissionings that will occur any changes from current practice will impact not only large licensees, but also j

' thousands of smaller licensees l

should consider if a regulation is adopted whether this would eliminate the  !

capability to request " case-by-case" reviews there should be consideration of implications for NRC inspectors if the current ,

approach is changed i a graded approach for use with 1.86 or retaining of elements of Reg Guide 1.86 should be considered b) Use of "not detectable" evaluations:

discussions clarified NRC's "not detectable" policy used for reactor licensees in

- the following areas: 1) reactors are held to a no detectable standard before any material cannot be released; 2) NRC guidance determines the level of how hard to look with no-detectable standard; and 3) there can be inconsistencies in cases where "non-detectable" could be detectable because it depends on technology used c) Use of case-by-case evaluations l

' getting approvais using the current case-by-case can be a long and difficult process in some cases Session 4: What are some other alternatives for control of solid material? l This session focused on listing the potential alternatives described in the issues Paper and solic.iting comment on these alternatives and suggestions for other alternatives. The session also noted that each alternative would be evaluated on its health and environmental impact, its economic tradeoffs, and its ability to control releases.

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• I . l Suggestions from attendees regarding the list of potential alternatives in the issues Paper (Federal Register Notice, June 30,1999) and for new alternatives included:

i a) Unrestricted use steel industry representatives indicated that they were opposed to recycling of materials from licensed facilities because of public concerns over contamination in metal products l b) Restricted use need to keep in mind that restricted use can be viewed as a delayed release of solid materials for unrestricted use; therefore need to consider in advance what would happen to the radioactive material when the authorized use product reached the end of its useful life; this would include consideration of radioactive decay that would occur during the lifetime of the authorized use; need to define the unrestricted use release that would be acceptable after the end of the lifetime of the authorized use use of restrictions to certain uses, as opposed to permitting unrestricted use in which the material can wind up in consumer uses, may be the only alternative acceptable to the public need to define points in the process where authorized use would begin and licensed control would end '

questions were raised as to what would be the additional burden on local regulatory authorities and the waste disposal community authorized first use is being considered by the international community one possibility is a dedicated melter as a licensed NRC facility; metals would be refined and melted and also cleaned up by a regulated facility; in this type of scenario, the dedicated melter products could tse regulated need to consider the impact of a U.S. restricted use regulation on international trade there is too much material potentially available for release for it all to be used as shield blocks at DOE facilities considerations in setting restrictions need to include type of material, and the type and nature of authorized uses c) Prohibition of releases of solid materials any prohibition must consider excluding items that have no history of exposure to licensed radiological operations because these should be of no concern to NRC, e.g., fences around sites need to consider what is the boundary between things that could be released and those that would gc to LLW; e.g., would the entire restricted area to be included, administrative offices, etc.?

a problem with this alternative is that it precludes incentives to develop technology to clean up materials and reuse them for useful purposes l

if European countries develop a standard of, for exenple 1mremlyr, need to l consider what would happen to material imported to the U.S. under an NRC standard which prohibited release f

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d) Suggestions for new alternatives or for items to consider in evaluating attematives:

should consider _ adopting ANSI standard, ANSI N13.12, which is intended to look at volumetric contamination and other materials in a facility could combine unrestricted and restricted use, i.e., if the unrestricted dose level is exceeded, the material could go to restricted uses could develop a pilot project or standard that would not include all licensees or

-uses e) Suggestions for items to consider in evaluating alternatives:

the concept of ALARA should be incorporated in any future standard DOT harmonization limits need consideration by NRC NRC should set health-based standards and allow the market to work within the bounds of the standard there needs to be a connection between any standard developed here and the criteria of the license termination rule Session 5: How should control of solid material be assureel under various alternatives?

This session focused on implementation aspects that should be considered by NRC in its decision making.

Suggestions made by attendees for methods for controlling releases included:

the ability to survey depends on which radionuclides are being measured; need to consider measurements of natural uranium there was some discussion of what is the capability to instruments to measure at the levels being considered; it was noted that it can be difficult to measure at the low doses being considered; it was also noted that a standard of 1 mrem /yr implies an evolution in des lgns which should be achievable whereas a 0.1 mrem /yr standard implies a revolution in measuring background that would make measuring it difficult; others expressed concern over ability to measure at a 1 mrem /yr standard

- L there is a need for practical criteria can be used in the field, e.g., need to consider if there are hand held instruments that can measure at these levels

- any standard must consider safety and also the ability to implement the standard;

- need to be able to make it clear to the public that whatever standards are developed can be measured so that materials can be controlled to the standard

. there should be penalties to those releasing materialin violation of any standard need to consider cost-effectiveness of replacing instruments.

should allow process knowledge (i.e., knowledge of use and location of the material during licensed operations) in evaluating materials in a survey some specific questions were asked including: 1) whether representative samples for the survey should be allowed; 2) over what volume or surface area should the survey take place; use of a 100 percent sample or statistical samples I

Session 6 - Discussion of NUREG-1640. "Radiolonical Assessments for Clearance ,

of Eauipment and Materials from Nuclear Facilities" '

This session focused on discussing and clarifying the content of NUREG-1640. It was noted that NUREG-1640 does not set criteria for a rule but rather that it provides a tool for evaluating alternatives by relating the radioactivity on, or in, a given amount of material to the radiological dose. This analysis is done by considering material flow patterns and potential pathways of exposure to different population groups. It was noted that NUREG- 1640 is a draft document for public comment.

Comments and suggestions from attendees on NUREG-1640 included:

the approach is generally sound it was noted that most of the exposure is generally to workers involved in the material flow, e.g., drivers involved in transporting scrap, scrap yard workers, slag workers, etc, and that dose factor is lower for members of the public using consumer products general questions asked on the NUREG included what kinds of furnaces used in processing are included in the analysis and where do radionuclides concentrate when the metals are melted analysis of other materials, e.g., roofing, sludges, calcium fluoride, should be considered Session 7: What are potential health and environmental impacts of various alternatives?

This session focused on potential health and environmental impacts that should be considered by NRC in its decision-making and requested comments on other impacts that should also be considered.

Attendees suggested that the following should be considered there was concem about use of collective dose in analyses should examine cumulative impact of potential build-up of material over many years when determining public health impacts recycle does not exactly replace the mined material that would be used should evaluate the ecological / economic impact as a result of materials that nuclear weapon testing has introduced into the steel industry and should account for that impact in assessing further impacts

-- should evaluate Environmental Justice impacts of material going to a landfill instead of recycle should evaluate exposure to multiple sources and effect of multiple products made from released material; in regard to this it was noted that metal recyclers generally receive materials from multiple locations raised a question as to whether, and if so how, perception of risk should be factored into environmental analysis because public perception on people's health and the environment is important it was noted that 46% of power plant material is recyclable and that this number

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should be used to analyze cumulative impacts over many years and in various streams environmental analyses should investigate whether levels are safe, if the l materials will accumulate in the environment, what are the chronic and acute

! risks, potential for multiple exposures, all approoriate pathways, etc.

l need to examine specific impacts for sensitive populations Session 8: What are the potential economic and cost-benefit considerations associated with various alternatives?

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This session focused on economic impacts that should be considered by NRC in its decision making and requested comments on other impacts that should be considered also.

Comments from attendees were received on the following economic considerations:

the amount of recycled steel from NRC-licensed facilities materialis so small that economic impact of this material going into recycle is small; there exists an oversupply of most of these metals; ferrous metal are not likely to be affected by recycling especially over 30 years; nickel and copper producers could be impacted there can be a large economic impact on an industry if there is public concern or perception of concern with that industry's products; metals industries face a particular economic situation in that there is competition between industries and alternative materials available which can have large economic and job impacte for the industry if there is concern with products if an owner of a piece of equipment has to go through a series of dose calculations for equipment before release is allowed, the owner may prefer to send the material to the waste stream need to consider build-up of materials in commerce need to consider economic impact on the consumer of increasing LLW disposal; costs of sending material to LLW or to controlled release will depend on the level that is set in any standard should account for regulatory impacts, e.g., compliance, analyses, etc, in the cost / benefit analysis need to consider costs and impacts if a mistake is made a cost-benefit analysis is helpful in this process need to consider costs for changing survey equipment and protocols to meet any new standard; should consider issues of grand-fathering of case-by-case decisions need to consider economics of disposal, e.g., disposal costs of $40.00 - $60.00 per cubic foot as compared to a disposal cost for Subtitle C wastes of $20.00 per ton l

A0 66-99 01:17 njgs iD=202 462 218a P02/09 9

LETTER TO THE UNITED STATES NUCLEAR REGULATORY COMMISSION AGAINST RADIOACTIVE RECYCLING AND RELEASE RE: Nuclear Regul9 tory Conunission 10 CFR 20 Release of Solid ! .terials at Licensed Facilities: Scoping Process for Environmental Issues and Notice of Public Meetings October 6,1999

- To the United States Nuclear Regulatory Commission:

The environmental and public it. est commtr 'ities are declining to participate in the Nuclear Regulatory Commission (F RC)'s Atlanta rulemaking workshop for two reasons.

First, the concept of release of radioactively contaminated materials into the nlarketplace is unconscionable, morally abhorrent and contrary to the NRC's mission to protect public health and safety.

Second, we told you exactly that in 1990 with the BRC (Below Regulatory Concern) hearings and again in 1993 when we participated in the NRC rulemaing procedure which established the decommissioning criteria l I

for n iclear power plants. The final decommissioning standard flies in the face ofinput the 14RC was given by public interest groups and the American

. people to allow zero (0) release (above preexisting 3 natural background). In fact, by the NRC's own estimates, thousands of people could die if NRC's

_ standard is used.  !

Our position remains: the NRC's enforced standard must be to contain radioactive wastes--isolate them from the environment.

INRC enimates the Hyposetical Lifettme Risk from Continuing Annual Dose of 100 millirems TEDE/; caris 3.5 fatal cancers per 1000 exposed. This is I fatal cancer m 286 individuals exposed at tha dose rate. Source: Table 1, page 8, NRC BRC Policy statement July 3.1990, based on " Sources. Effects and Risks oflor.izing Radiation," United Nations scientific Committee on the Effects of Atomic Radiation (UsNCEAR),198R Repon and "Heakh Effects of Exposures to Low Levels oflonizing Radiation, BEIR V," 1990, Natiors! Research Council, and NUREC/CR-4214 Rev.1 The NRC decommissioning. rule, t

CFR 20 subpan E, allows 25 to 100 to 00 millirems annual dose from a decommissioned site

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Two other controversial and environmentally unacceptable practices are showcased in the current NRC process: dumping of so-called " low-level" radioactive waste and dismantling and landfilling of used nuclear power plants, the source of massive amounts of contaminated' metal and soil.

We share a common concern for the high volume of contaminated metals, matedals and earth that have been spoiled for other w by the nuclear industry. It is high time our species faces the grim reality of nuclear waste and comes to terms with it.

There is no known safe level of exposure to radiation. Let us not be l j seduced by short-term economic concerns to make decisions that can wreak irrevocable damage in the gene pools of every species of animal and {

plant on our Eanh.

The honorable nuclear work is now towards developing and implementing effective technol.ogies for nuclear waste containment.

We call on the NRC to proldbit the release of radioactive materials  !

and wastes to the marketplace and the environment.

Please enter these comments into the National Environmental Policy Act record.

l l Signed, l

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REGIONAL, STATE and LOCAL l'

l. Glenn Canoll Mary Byrd Davis L Georgians Against Nuclear Energy Uranium Enrichment Project Earth Island Institute Ed Arnold Georgetown, Kentucky-

, Physicians for Social Responsibility / ,

l Atlanta Vina Colley.

L PRESS-Portsmouth/Piketon Residents Representative June Hegstrom, for Environmental Safety and Security l

l District 66 - Ohio j Scottdale, Georgia- j

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. Joan O. King .- Carolina Peace Resource Center l .

20/20. VISION Georgia John Runkle l Sally Wylde, MarciMcLendoon Conservuion Council of North Carolina Atlanta Wornen's Action for New Directions-WAND Jim Wanen

,. North Carolina WARN l Bob Darby, Tom Ferguson

. Food Not Bcmbs David Dmding l Atlanta Peoples' Action for a Safe Environment .

l (PASE):

Leigh Lytle Fayetteville, Arkansas l Earth Challenge i Decatur, Georgia B.J. Medley -

! ECO Harry L. Williams Oklahoma Coalition for a Healthy Envimnment '

Tennessee Scott Portzline Three Mile Island Alert Jackie Kittrell, Cliff Honicker _

Harrisburg PA

- American Eny'tal Health Studies Pro.iect

~ Knoxville,TN - Jonathan Parfrey Physicians for Social Responsibility /

Tom Phillips Los Angeles Nashville Peace Action -

Tennessee Judith Johnsrud, Ph.D.

Environmental Coalition on Nuclear Ara Hams .

Power We the People,Inc. of Tennessee Pennsylvania Alliance for Public Heahh & Safety 3-

cLr* m-7 w s a a w n w u su m ~ur - ca ruon Dave Kraft Deb Katz Nuclear Energy Information Service Citizens Awareness Network Illinois New England Jennifer Olaranna Viereck Judy Treichel Healing Global Wounds Nevada Nuclear Waste Task Force Califomia Don Finch Leon Glicenstein. Ph.D. F.A.C.T.S. (For A Clean Tonawanda Central Pennsylvania Citizens for Site), Inc.

Survival Kerrucre, New York Peg Ryglisyn, Michael Albrizio Lea Foushee Connecticut Opposed to Waste North American Water Office Minnesota Madelyn Hoffman Grass Roots Environmental Laurence LaFond Organi7ation North American Water Office New Jersey Oregon Michael Gregory Mark D. Stansbery Arizona Toxics Information Community Organizing Center Columbus, Ohio Corinne Carey, Alice Hirt Dont Waste Michigan Michael Welch Redwood Alliance Karl J. Novak Arcata,Califomia Pennsylvania Enviromnental Network Joe Mirabile Liz Apfelberg EcoBridge San Luis Obispo Mothers for Peace San Francisco, California ,

l Califomia Paige Knight Karen Hadden Hanford Watch j

. Peace Action-Texas Oregon Chris Williams, Grant Smith Jaime Chavez WaterInformation Network Citizens Action Coalition of Indiana Albuquerque,NM Robin Richman Bruce A Drew Steppin'Out PmirieIsland Coalition Chicago, IL Minnesota Joseph W. Wilson Earthwise Co.

Lewisville, Texas 4

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[ 1G-G6-99 G1:19 HIRS IDa202 462 2163 P06/09 Kate R. Iezier, CPA Henry Peters KRLCP,Inc. / TuffBaggs Radiological Evaluation and Action East Greenbush,NY Project-Great Lakes l

Diane Klostenneier Susan Griffm Safeguard Our State Committee Chenango North Energy Awareness Arizona Group South Plymoutil, N.Y.

Chuck Johnson Center for Energy Research Stephen M. Brittle Salem, Oregon Don't Waste Arizona, loc.

David Ellison Frank C. Subjeck Green Party of Ohio Air, Water, Earth, Org.  !

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Arizona Bob Brister Madera County Greens Betty Schroeder i

Califomia Arizona Safe Energy Coalition Lisa Guido Linda Lynch The Catholic Worker Organization of Hudspeth Directive tbr Conservation Ithaca Texas New York ,

Shean Bjoralt Sara Shannon Eanh Cycles, LTD MothersAlert Minneapolis, MN  ;

New York,New York Chris Drew Molly Johnson Uptown Multi-Cultural An Center Save Ward Valley Chicago, Illinois Califomia Chris Trepal Bill Snurnow Earth Day Coalition Nuclear FreeNew York Ohio Carole Starkes Terry Lodge C ESUMaple School Toledo Coalition for Safe Energy San Francisco, Califomia Kathryn Cumbow t

I SusanClark Citizens for Alternatives to Chemical Americans for a Safe Future Contamination Califomia Citizens for a Healthy Planet j Michigan Tim Judson CentralNew York--Citizens Awareness  ;

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' Huntington, NY FrankMchughlin l

Environmental Response Network . Janet Marsh Zeller Ocean View,NJ

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Blue Ridge Environmental Defense League-

~ Amy Manel North Carolina

' Stockton Peace Action Pomona, NJ . Maite Diez The Inner Ear Lloyd Marbet Hull, MA l . Don't Waste Oregon

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Diane AJ Burton IIcartland Operation to Protect the ~

l Norm Cohen .

Unplug Salem Campaign Envinanment Linwood,NJ Nebraska H.G. (Skip) Brack l-

. Jane Williams Califomia Communities Against Toxics Center for Biological Monitoring L . Hulls Cove, ME '

Jenny Carter Vermont Public Interest Research Group Ray Shadis Friends of the Coast - Opposing Nuclear Jessica Hopper Pollution .

~ Edgecomb, Maine Hyper PR Chicago, Illinois Citizens Action for Safe Energy

-LaNell Anderson Grandparents of East Hanis County Oklahoma Texas Richard Boren Harvey Wassenaan Southwest Toxic Watch Citizens Protecting Ohio (C-PRO) Tucson, AZ Loren Olson Robert Lepley Tippecance Environmental Council LongIsland Alliance for Peaceful LWest Lafayette, Indiana.-

Altematives Greg Wingard Waste Action Project Seattle, Washington 6 'l

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NATIONAL INTERNATIONAL Susan Shaer, Pat Ortmeyer Dr. Helen Caldicott Women's Action for New Directions- FoundingPresident Physicians for Social Responsibihty l WAND _ _

Arlington, Massachusetts Damon Moglen Diane D'Arrigo Greenpeace NuclearInformation and Resource E

Service: Alexander B. Kuzma Children of Chomobyl Relief Ftmd Washington, DC-Wenonah Hauter Pamela Ransom Women's Environment and Public Citizen Washington, DC

..velopment Organization Barbara W;edner Anna Adlio US Public Interet Research Group Grandmothers For Peace Intemational Washington, DC Francis U.Macy Center For Safe Energy Scott Denman Safe Energy Communication Council Earth Island Institute Washington, DC Paxus Calta Friends of the Earth International

~ Alice Slater l Gksbal Resource Action Center for the Mary Beth Brangan, Jim Heddle Environment (GRACE) The Nuclear Democracy Network New York,New York Califomia I

Jay M. Gould, Ph.D. l Radiation and Public Health Project Laurie Grossman i Y2K World Atomic Safety Holiday-New York,New York l WASH Campaign Bonnie Urfer, John LaForge l Wendy Oser Nukewatch Nuclear Guardianship Project Wisconsin  !

Berkeley, California

- Patricia Birnie l Peer de Rijk GE Stockholders' Alliance World Infonnation Servi:e on Energy.

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WISE International Amsterdam, The Netherlands Fascal Braud 1 Reseau Sortir du Nucleaire Lyon, France 7

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' Howard Siegel Karen Bloustine

. Bronx, NY El Paso, TX PeggyPryor Scott Shively

- Andrews, Texas Seattle, WA Amy Cockerill Karen Channan Dayton, Ohio New York,New York i l

Eric Stahan Richard Dawson Fullerton, Califomia Torrance,CA David W.Chappell Barbara S. Richardson '

Cherokee, NC Penryn,Califomia I

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