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NUCLEAR GUARDIANSHIP FORUM, On The Responsible Care of Radioactive Materials,
Issue # 2, Spring 1993, p. 11.


HOW SAFE IS SAFE:   the Public Speaks to the NRC

The Nuclear Regulatory Commission (NRC) is holding workshops in 1993 to hear recommendations on criteria for certifying that a decommissioned nuclear facility is safe for any public or private use in the future. Only with such certification can a corporation or inshtution licensed to possess and use radioactive materials be liberated from its legal responsibility for protecting people and the environment from radiation. At the workshop held in San Francisco on February 23-24, 1993, representatives of the Nuclear Guardianship Project emphasized that many sites will long remain unsafe for unrestricted human use and that citizens have moral responsibilities to participate in maintaining safety at each nuclear facility for generations.

The NRC is responsible (under the Atomic Energy Act) for protecting public health and safety in the use of nuclear materials. It licenses companies, hospitals, universities, and other civilian entities to possess and utilize radioactive substances. Once the approved activities have ceased, as when a nuclear power plant closes, the NRC requires the decommissioning of the facilities so that not only the property but also any remaining buildings, equipment, and waste sites are safe for "unrestricted use" by the public. Material that exceeds safe radiation levels must be decontaminated or removed from the site.

There are no established standards
of acceptable or safe levels
of radioactivity applying to all cases.

In the U.S., as in Europe, determination that a decommissioned site is safe and healthy is made on a case by case basis. There are no established standards of acceptable or safe levels of radioactivity applying to all cases. NRC, currently lacking radiological criteria for declaring former nuclear facilities safe for unrestricted use, feels under pressure to develop and promulgate such rules. It has been criticized by government, industry, and citizens for lack of clarity and consistency, and for inefficiency and delay that sometimes prolong decommissioning procedures over many years.

In 1993 there are about 7,500 NRC licensees in the United States. About half of those, with medical or industrial applications, use either sealed radioactive sources or small amounts of short-lived radioactive materials that leave little or no residual contamination. Of the other half, many produce "substantial radioactive contamination." These include nuclear power plants with their spent fuel storage pools (112 at 75 sites), research and test reactors (74), fuel fabrication plants (14), uranium mill facilities (49), and others. (Ouotes and data are from the NRC document distributed at the workshop, entitled: Proposed "Rule Making to Establish Radiological Criteria for Decommissioning: Issues for Discussion at Workshops".)

The proposed NRC radiological criteria will apply to many of these facilities, but not to uranium mines and mill tailing sites, high-level waste repositories, nor low-level waste.disposal facilities, which are subject to regulation of the Environmental Protection Agency. The nuclear weapons complex of the Department of Energy is not subject to NRC standards but might be affected by them.

At the San Francisco workshop, representatives of nuclear utilities and fuel cycle firms expressed concern that the NRC standards for decommissioning facilities include predictability, measurability, practicality, alacrity, and economy in the decommissioning process. Citing the problems of costs and delays in decommissioning, they urged that their limited resources for clean-up be focused on the problems of greatest risk to employees and the public and not on cleaning up "the last spoonful of contamination:" i.e., technology of cleanup should be driven by cost.

Many citizen groups at the San Francisco workshop had much different concerns. Representatives of the Nuclear Guardianship Project (NGP), Redwood Alliance, Northwest Environmental Advocates, Alliance for Survival Western States Legal Foundation, and the Nuclear Democracy Network pointed out the facts that transport of nuclear materials is extremely hazardous and that completely safe conditions at many nuclear facilities will probably be unattainable for the foreseeable future. Radioactive waste would therefore best be secured on the sites that are already contaminated rather than creating new sites for waste in uncontaminated areas. The goal of creating conditions for "unrestricted use" should be reexamined in the light of the facts -- and of our moral responsibility to future generations.

"To pretend that contamination is
`cleaned-up' by moving it
somewhere else is irresponsible.
Let's get real."

Joanna Macy of NGP, noted that honesty is essential to ensure responsible care of radioactive sites. "The word 'clean-up' is a dangerous euphemism. To talk about returning radioactively contaminated areas to 'unrestricted use' is wishful thinking at best. To pretend that contamination is `cleaned-up' by moving it somewhere else is irresponsible. Let's get real. Let's talk instead about how we can contain the mess in the best ways we can figure out, and how we can pass on to future generations the knowledge they will need to protect themselves. Talking about cost of clean-up, we need to recognize that most of the people affected by this contamination -- and those who will pay the highest cost -- are not born yet."

"the people affected by this contamination
-- and those who will pay the highest cost
-- are not born yet."

Francis Macy of NGP stressed that the off-site depository promised to utilities by the Federal government, for irradiated fuel assemblies and contaminated reactor structures, would likely not exist for at least a generation (if ever). He proposed a new category, inoperative nuclear power stations that are licensed, secured, inspected, and regulated by NRC for safety and considered to be in a "delayed decommission status." These sites would still be the possession of the utilities that built them, and also their continuing financial and legal responsibility.

Entombment... is far less costly
than trying to remove
all radioactivity from a site
-- and also safer...
projected savings ... $100-150 billion
per site.

Richard Fasnacht of the Midwest Energy Services Center of the NUS Corporation, a nuclear clean-up contractor in Illinois, stated that entombment technology is far less costly and safer than trying to remove all radioactivity from a site. He projected a savings to the utilities and their rate payers of $100-150 billion per site. In the case of entombment, buildings, soil, and equipment that have become radioachve at power plants are encased in cement and chemical grout and monitored.

Irradiated fuel assemblies can be stored in dry casks on site or removed, according to Fasnacht, with everything monitored for radiation releases and necessary repair. From his experience as field superintendent at two Corp of Engineers nuclear plant decommissionings, Fasnacht stated that entombment sites can be returned to background levels of radiation and remain so by monitoring and maintenance.

NRC admitted, in its document "Issues for Proposed Rule Making," that "there may be a small number of sites where clean-up criteria for unrestricted release developed in this rule making may not be practical.", The Commission asks workshop participants and the public: "What should be done in those cases where sites cannot reasonably be decontaminated to the point where they are appropriate for unrestricted use?"

Representatives of citizens' organizations were concerned that those living near a nuclear facility have an adequate role in the decommissioning process and on-going monitoring. Joanna Macy for NGP stated that "it is good that representadves of citizens' organizations are meeting here with representatives of industry and government. For it is neither fair nor wise to leave such far-reaching decisions to persons whose jobs put them under pressures of bureaucratic, political, or economic expediency. All elements of the public should be involved, especially local citizens whose families now live, and whose descendants will live, with the radioactive contamination our generation has produced. Wider participation in the deliberative process and a site-by-site approach will allow them to exercise the moral responsibility they feel."

"The only effective solutions will combine
technical measures with spiritual and
political considerations."

Mary Beth Brangan of the Nuclear Democracy Network explained to NRC that citizens regard this as a moral issue, "not only technical but trans-technical and trans-generational. . . The only effective solutions will combine technical measures with spiritual and political considerations."

On the subject of health protection, many participants, such as Greg Debruller of Columbia River United, criticized the government's record of suppressing findings on the health consequences of radiation exposure. He called for consideration of scientific data on the long-term impact of low-level radiation from such specialists as Drs. John Gofman, Ernest Sternglass, and Rosalie Bertell. NRC should listen to these researchers' challenge to the NRC contention that a level of radiation -- above natural background -- is safe for human life: the so-called "acceptable risk." Debruller and other citizen representadves called for a return to background levels as the criterion to be used in decommissioning, when sites are considered for unrestricted use.

By holding seven workshops, the NRC intends "to foster a clearer understanding of the positions and concerns of affected interests as well as to identify areas of agreement and disagreement." Invited to sit around the table for two days to discuss a narrow range of rule-making issues are fifteen to twenty people representing interested and informed organizations including state governments, local governments, tribal governments, Federal agencies, citizen groups, nuclear utilities, fuel cycle facilities, non-fuel cycle facilities, companies in decommissioning work, and professional societies. The workshops, facilitated by the Keystone Center, permit more in-depth and informal interchange than official government hearings.

Anyone can submit written observations until May 28,1993 to Secretary, U.S. Nuclear Regulatory Commission, Washington, D.C., 20555, ATTN.: Docketing and Service Branch.

Videotapes of the San Francisco workshhp are available from the Nuclear Democracy Network, P.O. Box 1947, Bolinas CA 94924. Tel: 415/868-1900, Fax: 415/868-1901.

For dates and locations offuture Nuclear Regulatory Commission Workshops, tel: 301/504-1642.

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