Low-Level Waste Regulation: Putting Principles Into Practice - 13297 The Richard S. Hodes, M.D., Honor Lecture Award

In carrying out its mission to ensure the safe use of radioactive materials for beneficial civilian purposes while protecting people and the environment, the U.S. Nuclear Regulatory Commission (NRC) adheres to its Principles of Good Regulation. The Principles—Independence, Openness, Efficiency, Clarity, and Reliability—apply to the agency as a whole in its decisionmaking and to the individual conduct of NRC employees. This paper describes the application of the Principles in a real-life staff activity, a guidance document used in the NRC’s low-level radioactive waste (LLW) program, the Concentration Averaging and Encapsulation Branch Technical Position (CA BTP). The staff’s process to revise the document, as well as the final content of the document, were influenced by following the Principles. For example, consistent with the Openness Principle, the staff conducted a number of outreach activities and received many comments on three drafts of the document. Stakeholder comments affected the final staff positions in some cases. The revised CA BTP, once implemented, is expected to improve management and disposal of LLW in the United States. Its positions have an improved nexus to health and safety; are more performance-based than previously, thus providing licensees with options for how they achieve the required outcome of protecting an inadvertent human intruder into a disposal facility; and provide for disposal of more sealed radioactive sources, which are a potential threat to national security.