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10:30 AM - SESSION 2 (Copper Rm.)
STATUS OF THE DEVELOPMENT OF REGULATIONS FOR REUSE/RECYCLE OF RADIOACTIVE METAL FROM DECOMMISSIONING
Co-chairs: Stephan Halaszovich, FZJ-Juelich
R. Scott Moore, JUPITER Corporation
John Karhnak, the Director of the Center for Cleanup and Reuse in EPAs Office of Radiation and Indoor Air, presented the status of EPAs consideration of standards for scrap metal released from nuclear facilities for recycling. Current guidelines for recycling are incomplete in that they deal only with surface contamination and apply to individual radionuclidesand thus do not give an accurate indication of total exposure if more than one nuclide is present. Mr. Karhnak outlined the exposure pathways, the economic analysis, and the cost-benefit analysis that has been performed to examine the potential impacts of recycling. These documents have been available for public comment, and Mr. Karhnak indicated that public response has been overwhelmingly negative. In light of this, proceeding with rulemaking on this issue will likely be difficult to justify.
Dr. Robert Meck, a Sr. Project Manager within NRCs Office of Nuclear Regulatory Research with responsibilities for NRCs consideration of regulatory options for clearance of scrap metal, presented the status of NRCs efforts in setting standards for release of materials and equipment from licensed control. Dr. Meck described the draft radiological dose assessment associated with the clearance (release) of very slightly contaminated materials and equipment. The assessment included the evaluation of the direct reuse of equipment and the evaluation of the recycle and disposal of concrete and scrap steel, copper, and aluminum. Dr. Meck also indicated that the staff have requested direction from the Commission on which regulatory option to pursue. In its request, the staff presented advantages and disadvantages on options ranging from no regulatory change to conducting a fully-developed enhanced participatory rulemaking.
Edward Regnier, J.D., with the DOE Office of Environment, Safety, and Health, spoke to the implementation of DOE residual radioactive material release standards. Mr. Regnier indicated that the DOE standards in DOE Order 5400.5 are being codified at 10 CFR 834 and that DOE release standards, processes, and guidance are in place and being used to release and recycle materials. Mr. Regnier also indicated that most of the materials are released under surface limits and that the recycle of scrap metals under existing standards is protective and represents a saving of natural resources, disposal space, and taxpayer money. In addition, Mr. Marvin Bennett, of the National Program for Metals Recycle, a DOE Center of Excellence based in Oak Ridge, TN, was introduced to the audience.
Val Loiselle, the Executive Director of ARMR, provided ARMR and industry perspectives on the potential volumetric release standards for scrap metal. Mr. Loiselle described industry needs, which include a risk based standard endorsed by both EPA and NRC with specific requirements for residual activity (both surface and volumetric contamination). Mr. Loiselle indicated that while industry needs specific measurable limits, the public policy aspects of rulemaking are more likely to focus on public questions on whether any level of slight contamination is safe.
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