ML20217J565

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Summary of 990915-16 Meeting on Control of Solid Matls in San Francisco,California.Further Details Will Be Provided in Summary Being Prepared by Merdian Institute.Copy of Slides, Attendee List,Ltr to Citizens Groups & Hps Statement Encl
ML20217J565
Person / Time
Issue date: 10/25/1999
From: Cool D
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
NRC
Shared Package
ML20217J569 List:
References
NUDOCS 9910250112
Download: ML20217J565 (22)


Text

1 Note to: Glenn Tracy

~ From: Donald A. Cool, Director Division cf 'ndustrial and Medica: Nuclear Safety, NMSS

SUBJECT:

SUMMARY

OF SAN FRANCISCO MEETING ON CONTROL OF SOLID MATERIALS Attached is a brief summary of the San Francisco meeting. These are the h ~,hlights that were raised in the discussions during each session. We have only provided the f.sy points but further details will be provided in a summary being prepared by Meridian Institute. A draf t of the summary wll be submitted to NRC in two weeks. In addition, the staff is preparing a Commission item of interest regarding the meeting, as well as a summary for Congressional affairs.

l I am also providing you with hard cop. s of the slides used and the material that was submitted j in writing at the meeting. This incluos.1) the attendee list; 2) a letter to me from 12 citizen f

groups; 3) written statement from the Health Physics Society; and 4) a summary of EPA's mixed waste regulations.

' The invitation letters for the Atlanta meeting were sent out by FAX on Friday, September 17, 1999. A draft agenda is expected to be sent out this Wednesday.

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i Summary of Major Points raised at NRC Workshop on Control of Solid Materials September 15-16,1999 l San Francisco, California i 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.

i i

Session 1: Why are we here today j i

This session focused on three principal topics: 1) why NRC is examining its approach for I controlling solid materials; 2) what is NRC's purpose in publishing the issues paper and I holding public meetings; and 3) what process for decision-making is being considered. l Most of the discussion centered around the 3'8 item.

Some of the principal comments received from attendees included:

I a) Other ways to get public input:

hold workshops in communities, either by request or as part of other meetings give special attention to tribal interests rely on State assistance for outreach

=

. learn from the experience of DOE public interest / advisory group meetings .

I use tools like te!evision to involve the public more broadly and effectively continue use of NRC website b) Discussions on decision-making process should: l be understandable  !

state NRC's role and its decision-making process 1' note that we are discussing small doses of radiation clarify that materials are being cleared every day {

emphasize benefits of nuclear technology (e.g. health, energy, etc.).  ;

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 j about; 2) what is the potential radiation dose being considered and how does it compare l to the dose received from other sources; and 3) what are other Federal agencies, States, j 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:

different materials have different dose levels and it should be clear that this effort focuses on those with low levels; a " low" level of contamination should be defined '

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mixed waste needs to be addressed in this effort 1 should address NORM and NARM l a national standard ultimately needs to cover all materials a pilot program could be used to address different materials incrementally b) Issues regarding other Federal agencies, States, countries ,and organizations:

must consider State, local and tribal authority and constraints States vary significantly in their regulatory options; a regulation could help manage these inconsistencies .

reactors would benefit from having common criteria used by NRC and States need to be consistent with international efforts an ANSI standard has been approved which contains a dose-based criterion of 1 mrem per year which should be considered by NRC l a regulation could be used under CERCLA to aid the Army Corps of Engineers in i decommissioning l

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.

. The comments from this session principally noted that: (a) Reg. Guide 1.86 doesn't provide a dose number which is needed; (b) a national standard would be helpful for l compliance monitoring; and (c) better consistency is needed for surveying materials with l surface and volumetric contamination. There was general agreement that a dose based

. standard is needed to replace Reg Guide 1.86.

Session 4: What are some other alternatives for control of solid material?

I

! This session focused on listing potential alternatives and soliciting suggestions for other l alternatives.

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

a) Unrestricted use steel industry representatives were opposed to unrestricted use because they were concerned about the impact of a " perception" of contamination in its products a standard could be set at a level at which the material is no longer considered to be radioactive, i.e., is considered to be " clean" should ALARA be considered in defining dose criteria b) Restricted use restricted use could be defined as: 1) restrict first use; further uses would then be unrestricted; or 2) permanent restrictions

an option is to release materials only to a dedicated, licenced facility for processing prior to release c) Prohibition of releases of solid materials question were raised regarding its impact and practicality

-. practicality for, and impacts on, nuclear medicine licensees should be specifically taken into account d) Suggestions for new alternatives adopt the ANSI standard.

combine restricted / unrestricted options to give licensees flexibility set controls specific to materials use generallicensing

. use an interim storage facility have a buy-back program of contaminated materials during first use processing guarantee that a dedicated steel mill is not responsible for financiallosses if contamination occurs at the mill resulting from the material received

. Session 5: 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 otherimpacts that should also be considered.

Attendees suggested that the following should be considered the risk to the public of not having a standard I whether collective dose should be included in evaluations I cultural impacts on Tribal lands and resources issues of environmental justice to avoid disproportionate impacts  ;

impacts from variability in radionuclide levels in recycled steel '

pre-existing radioactivity levels in steel I Session 6: What are th e potential economic and cost-benefit considerations associated with various alternatives?

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

also.

Comments from attendees were received on the following economic considerations:

a) Costs of doing a regulation:

I' -

additional costs associated with conducting a rulemaking should be considered adoption of ANSI standard would reduce cost to government for developing a regulation

b) Costs of restricted use:

the regulatory costs to Federal and State agencies associated with developing and enforcing the restrictions could be high.

c) Costs of prohibition of release of solid materials LLW disposal costs could be extremely high prohibition could be impractical because it might include more mobile materials as well as fixed items this alternative needs to be modified so that it does not include everything in facilities this alternative includes all biomedical research and could result in research being curtailed or stopped if all contents have to go to LLW.

d) Scrap industry and steel melting / manufacturing industry adverse economic impacts on steelindustry could be significant there could be loss of income to companies and employees if a steel mill is contaminated.

there could be increased cost for monitoring and worker protection monitors at scrap yard and steel mill gates will alarm at levels near background, e) Additional considerations 1 costs for disposal at LLW have increased dramatically l international standards or other countries' specific standards need to be considered

]

1 evaluate opportunity cost of not reusing material Session 7: How should control of solid material be assured under various alternatives?

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

i Suggestions made by attendees for methods for contro!Iing releases included: l a) With regard to surveys:

criteria set below 1 mrem /yr could cause detection problems l

NRC must address survey procedures and surface / volumetric measurements NRC should consider process knowledge in survey method

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there was concem that NUREG-1640 values are so low that licensees cannot detect material with turrent equipment new guidance should not be based on instrument measurement capability DOE is uncertain if 1mremlyr is detectable; NRC should seek additional information on detectability there was general consensus that measurement and implementation methods are essential but will be very difficult to develop for a regulation

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P b) Other considerations as to what should be done:

use a second feture ANSI standard that will deal with implementation issues.

include materials other than metals when developing implementation guidance develop dose-ba' sed regulation and associated concentration values that States and licensees can use.

be aware that if concentrations are in the rule and information changes, the rule must be changed.

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Why is NRC examining its approach for l controlli solid materials with small amounts of radioactivi ?

- Session 1

= There are sold matenals at Icensed facihtes that will need disposition y are we here today7 . s- of tne sso maenai nas smen enounm of reacact.

=Overall queston, 'Wiat should be done with these-rnaterials?"

. Should all matenals be buned fi loonsed kw lewl waste (llW) disposal sites, or a is there a safe way lo reuse or recyde scrre of these materals if radoacturty lewis are icwenotgh7

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Why is NRC examining,its approach for Has NRC made any decisions to date?

. controllmg solid matenals with small amounts of radioactiv#ty (cont'd)?

.NRC indcated in a June 1999 FRN that several aThere are no NRC regulations for control of most of these attematNe courses of action are open for discussion still seek b release sold materals when obsolete or a NRC published issues Paper in the Federal Reaister in atdeamnissonry June 1999 to seek pubic cornment

  • Deosons are berg made case by<ase
  • M of citena catees insisistunt release lews and nanunki M of p a NRC is holding public meetings to solcit input from a variety of interested partes i . cNRC wants to consider all issues in an open public forum:

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  • All heat and envuortraital rnrects twoNed wm the situatori

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  • Related ecorrmc aspects

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What process for decisionmaking is being What is NRC's purpose in publishing the issues considered?

Paper and holding public meetings?

Steps in a typcal rulemakiry process

= Present ssues and attematrves related to control of sold

. Earty and :obstantNe input by Agreement Statir Dewlop proposed rule (indudn] as teses NEPA ard E O.

12291)and publish for pubic cmYnent

= Listen to and consider a broad spectrtm of viewpoints on . Cmsider pubic cmmnts and prepare rnal rule the issues and attematrves What additional steps for early and continuing input are abased on the vets gM being used in an enhanced process?

  • Idmtfy concxsnswith issues Paper
  • lssues Paper n FRN and on e e ldermfy other isajes and afbrnatNes rot addressed n the issues
  • Faoldatedpublerneetings Paper

. Folitwo1ckximentsonwebsite

  • Pubic amnent capiibdtty by e< nail, web postng, list serwr, etc

= Conduct enhan d participation including opportunites for Upd was and bnerngs of conmesm opm e the arc both earty and continuing dialogue and input What process for decisionmaking is. being about both the issues Why Paperare and weNEPA talking scoping today?

considered (cont'd)?

aWhat other approaches to enhance input could also be a lt is effective and efficient to seek ccmnent and hold used? dscussions on both at the same tme to best utilize and coordinate available expertise and input.

. Issues Paper dentfes potental health and enwormental rnpacts of alernatNe acproaches

. A"scrpng pm ss' also dentfies the range of enwormental isaes e ocmply with EPA Pmcpal issues discussed n both are essentally the sarne

What is NRC's role and authority in setting standards?

Session 2 .NaC autnanty and respons,bintes estaensnee in Atomc Energy Act of 1954 (amended 1975)

. Issues repubtms br protectcn of pubic haam and safety fnyn How does what we are use of raccac!M)materal by it

.Reguietes and nspects u e ofeact,e nsees s11 metenel by ,1s discussing today fit into the '-

overall nicture? r" "

=NRC/ EPA roles

. EPA ses gmerally appicabb enwonmalul standards that NRC riipkments

. EPA es not currently consderrig rubnakng n this area

. b Ihe absen of EPA standards. FRC has authonty b set radaton proledon standards for its kmsees n this area What types of solid materials and what NRC What is the potential radiation dose being licensees arewe talking about? considered and how does it compare to tne dose received from other radiation sources?

Metals, concrew, soils

.Empnent, ppng, turniture, etc. =N of the alternatives ri the Issues Paper discusses potential dose entena of 0,0.1,1, or 10 mrem /yr

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=Cornparison with other exposures

= Licensee types . Aerage U S natural background - 300 mrunNr (vares fran

. Most kcensees are users of sealed sources atxut 1001000 mrsnyr)

-Typedy how no contumnation .PRC's pubicdose Imrt rs 100 mrtmNr

. Other hcensees (e g., reactors, recearch bboratones, hospitals): Dagnoste x-ray -40 mrem

. One round-trp coast-b< cast Mght 10 mran

[ anm nuy new rnaenah we snan arnomts of

  • Dose inm use of coalam -10mrunNr

=NCRP c>nsiders 1 mrem /yr a neg!gble ridtvidual dose k

What are other countries, agencies, and/or States What are other countries, agencies, and/or

, doing wrth regard to control of solid rnaterials? States doing with regard to control of solid materials (continued)? .

=U S EPA EPA s not crosdenry ruitmakng n hs area at es trre aInternatonal

. Currently uxkry wth VEA. Departnent of State and omer Federal agences on controllog rnport/ export contunnated . IAEAEC/rdvdual natrns seting standaros maternis orprocbcts a States

. Staes haw authonty e approve release of NORM.NATW sold maternis not *egubloc by NRC Releases maerial inder DOE Order consistent wth existing rna NRC gudants as w- :n What is the current NRC case-by-case approach?

Session 3 . current NRC regulations do not contain dose entere for control of sold matenals generally applicable to matenals and equipment HOw dOes NRC currently .ucensees stm se to rew soie matenai dunng operations or at decommisskriing handle COntFOI Of SOI*d i . umnsees are required e surwy maenas e ete ineir rEdobgic,Ihazard ma OficTS.Q . tansees use ine cntena of Re<viaery cuee s es or rm.

detctabikty br release of sold rnalenals

. MlC also evaluales spec S requests for release on a careby-case tasrs

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(cont hat,d)?is the current NRC case-by-case approach Howmuch solid material has been released so far under current practices? i l

Regulatory Gude 186 ~ .Lcensees are currenty required to

. Perform a radation surwy axi record and ma:ntan results

. Apploable b surfam contmnaton only . Surwy records are not regi; ired b be sutmited to NRC

  • Ba liy cn rnaasurement capability of surwy

.NRC does not track the amount of sold materal released

. NRC nspects fansee's radaton protecton programs and a Requests for approval of altemate deposal procedures surWy recDrds

. Releases made in cxmplance uth licensee programs are consistent uth existng NRC regulatons .

  • Albus Icensees b seek MK: au1hortzaton for dmposal of .Egosures are estmated b be bu l

rnaerets with bu lewis of witmetnc contamreton

. Onsite bunal, disposal at landfills . knount of rnetal and concrete released b date is small cxmpared b the anotnt available n future deocnmissonngs 1

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l What are some other attematives for addressing controlof solid materials?

eList of pretminary alternatives M,lOfl 4 Continue current practa

. Set xrmhNa dose lewis n a lationwhch must be rnet bebremaerals could be re brunrestncied use

. Establish restnctons imitng rebase of sold maenals b certan What are SOme Other eut-ed uses

. Establish a regulaton that cbes not permit release of maerals allematiVOS fOr Control Of SOlld tet had e n an a= *= radactne rrenal was e w sbred mater.ialS? ote'5 a5 de*bped n meetngs a sccmmmt e Each altemative has certain health, environmental, and econome mpacts assocated with it

. Evaltete tradeoffs betmen alternatne amroades (i e ,

compare benefits and mpacts)

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What are the potential health and environmental impacts that should be considered?

Session 5 . Basis for Nac s conseeraton is protecton of puerc health and safety and the environment What are potential health and aeotentei radoicgcai n, pacts environmentalimpacts of .goetem b an ne-various altematives? - - .-.a -

- Smnanos and patways of emosure. rnaerw fkw mrxks

  • Potental colledte radaton doses b different popubton groups

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What are the potential health and environmental and environmental hipacts that shouM be considered (cont'd)? What mpactsare that the should potential be cons health,dered (cont'd)?

Impacts on biota and land use =S Tie f these mpacts may be competog

^ . Pubic use areat wetlands, presemd hhtats, etc

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= Environmental justice cirnpacts of minng and rocessing of new metals to replace metals sent to blW.

.non,,go w .mp3 cts.

  • Polluton
  • occupatonal npy,

. transportaton, -

. Inaeased occgutonal opnes rotse,

+ road constructon

  • Others

= Others

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Why consider economics and cost 4mnefit?

Session 6

= Federal agences must consder cost 4xcefit in their ,

evaluatonsof altematrves j What are the potential . secu1,0,ee, ,m, l econornic and cost-benefit . o sa sa . .n o negume,y % s ou m meso, m considerations associated with " '

various altematives?

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l What are the economic impacts of various thts? What are the economic impacts of various attematives (cont'd)?

e Radological surveys to venfy permissble levels have beenrnet =Disposalcosts

. Pubic landfill

. LLWdisposal faalrty c Econome mpact on scrap metal and other industries

  • Manubctunngpro sses = Costs for other industries
  • Suneysof ncxmng maerals . Fitn
  • Poenbal for rw J. g b " false
  • contamnation alarms or br . Eleduc rejedon of matenals at melW, scrap yard etc.

. Om eReplacanentmetalproducton

= Potental for buildup of rad'eactrvity in cornnerce over tme

  • knpacts ofmong and pro ssog of newmetals b replace metals re!nt b LLW.

eSocoeconomic'mpacts

=What other costs should be considered? _ _ _

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I What is involved in a cost benefit analysis?

e For each altemative, we evaluate potential health, safety.

and envirorrnental mpacts against the costs required to Session 7 c::hieve or preserve them

. nut benents ame tron eacn aiernatw? How should control of solid )

.wetoeinmmes netongcosts-resuittrane mateTial be assured

  • W'd albrnatw best serws te country as a whole? under various alternatives? '

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= How should control of solid materials be assured How could you assure that solid materials are forvarious attematives? contmiled for the various attematives (coat'd)?

cSurveys are required to control solid matenals

  • Prowciares br control a Survey method will depend on the attemative
  • Radeton iru uiuii g before any sold malenal could be released

. Range of alernatws requires evaluaton of a vanety of surwy appraeces elssues with current survey programs

  • Dose cntena tut are wry tw or zero, above background may

. Vanatons n m sensitnnbes and equpnmt require wry sesitw aarwy rneM and equpnent

  • Exising guidance geared tward releasog sold materal with surface wi na n muu,, .For restncted use, what other controls are needed?

. Lrnitatons for measumg wkmetnc contanruton .Li nsngof Arstuserand/orpro say

  • Publictwcwpro ss

. Length of tme for restnctKn

. What oter optons shtx;d be consderecf)

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