CRCPD position on control of solid materials
D. McBaugh (State of Washington, Dept. of Health)
The Conference of Radiation Control Program Directors (CRCPD) recognizes inconsistencies exist in current approaches to decisions made on clearing solid materials from regulatory control. At the present time, no nationally accepted regulatory standard or regulation exist for consistently clearing solid materials from nuclear facilities. The CRCPD advocates for sensible rulemaking in this area and for development of risk informed and technically defensible standards to improve public confidence while maintaining human health and protection of the environment. Such standards should include a prohibition against the importation of solid materials exceeding the U.S. standard, and technical bases for rulemaking developed by the US Nuclear Regulatory Commission should include considerations of naturally occurring, accelerator produced, and technologically enhanced radioactive materials (NORM/NARM/TENORM). Additionally, the states have historically indicated strong preference for unrestricted release pathways over restricted releases.