Approaches to Risk Management in Remediation of Radioactively Contaminated Sites
D.J. Strom1; L.R. Anspaugh2; J. Flynn3; F.O. Hoffman4; D.C. Kocher4; P.A. Locke5; P.J. Merges6; B.A. Napier1; and E.I. White7 (1Pacific Northwest National Laboratory; 2University of Utah; 3Decision Research; 4SENES Oak Ridge, Inc.; 5Johns Hopkins Bloomberg School of Public Health; 6Environment and Radiation Specialists, Inc.; 7National Council on Radiation Protection and Measurements)
Dual or multiple regulation by the Nuclear Regulatory Commission (NRC), by the Environmental Protection Agency (EPA), and by state agencies of NRC-licensed facilities undergoing decommissioning has been a subject of considerable debate and controversy. Among other laws and regulations, NRC operates under the Atomic Energy Act and the License Termination Rule (10 CFR Part 20 Subpart E), and EPA operates under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and Superfund regulations. The National Council on Radiation Protection and Measurements (NCRP) Report No. 146 reviews and analyzes the laws, regulations, guidance, models, and practices of NRC and EPA in this arena as a step toward developing consistent approaches to decision-making by NRC and EPA on the cleanup of radiologically contaminated sites. Report 146 summarizes the legal and regulatory drivers and practices for their historical basis, their commonalities and significant differences, and their current and future implications as they relate to public perception, uncertainty, measurability, and radiation dose and risk estimates. The NCRP has analyzed case studies of decision-making and extracted recurrent themes. The report reaches seven conclusions: 1) Criteria differ for acceptable levels of residual soil contamination; 2) Concurrent regulation is the rule, not the exception; 3) Meaningful stakeholder involvement is required; 4) Either EPA's or NRC's approach can protect public health with site-specific cleanup levels; 5) There are many drivers for practical decision-making; 6) State involvement is vital; and 7) EPA involvement should not impede NRC license termination. *Pacific Northwest National Laboratory is operated for the U.S. Department of Energy by Battelle under Contract DE-AC06-76RLO 1830. PNNL-SA-44060.