The Disposition Dilemma Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities (2002) / Chapter Skim
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8 Stakeholder Reactions and Involvement
8 Stakeholder Reactions and Involvement
Pages 136-150
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From page 136... ...
The chapter then presents basic principles that the USNRC can follow to avoid past mistakes and involve its stakeholders more effectively. The Below Regulatory Concern Effort The BRC policy was intended to cover four basic clearance standards: (1)
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From page 137... ...
A letter from the Natural Resources Defense Council declining to participate was particularly persuasive in terminating the BRC process (NRDC, 1991~. The License Termination Rule Following the withdrawal of the BRC policy, the USNRC decided to focus on issuing in conjunction with an enhanced public participation process a rule governing the clearance of facilities containing residual radioactivity (USNRC, 1992~.
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From page 138... ...
an extension of the schedule for the final rule until early 1996 "to allow the NRC to more fully consider public comments received on the technical basis." That announcement of schedule extension noted the USNRC's intention to hold a public meeting in September 1995 to address specific issues and included the separate views of one commissioner questioning the adequacy of the technical basis for selecting a dose criterion of 15 mrem in contrast to 25 or 30 mrem. A letter dated September 25, 1995, from 10 environmental and consumer organizations objected to the "Commission's current move to hold a single workshop in Washington, D.C., to discuss a [new]
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From page 139... ...
This skepticism led some national environmental and consumer advocacy groups to boycott the public meetings intended to consider the issue of clearance of SRSM from USNRC-licensed facilities. Nevertheless, the USNRC received more than 900 comment letters.
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There is little support from stakeholder groups for a clearance standard for SRSM. Although agreement states and the nuclear industry favor some form of clearance standard, many consumer and environmental groups and certain affected industry organizations do not.
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clearance and conditional clearance, or between exclusions and exemptions. Summary of Stakeholder Views In summary, the committee's review of the record on the BRC policy, the License Termination Rule, and the 1999 issues paper found that many stakeholders distrust the USNRC and remain confused about important technical questions.
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. bMore specifically, representing the Conference of Radiation Control Program Directors and the Organization of Agreement States.
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Cannot Engage in Dialogue Because Dialogue Process Is Tainted Recommend Delaying Decision on a Rule Until Stakeholder Views Are Integrated with USNRC Decision Framework X X X X X X X X X X X X X
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The USNRC has successfully engaged in risk communication in limited contexts, such as the initial public participation process during development of the License Termination Rule. The USNRC's inability to follow through on the 1994 consensus is an equally compelling example of poor risk management and communication.
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From page 145... ...
For a variety of reasons discussed above, many stakeholder groups do not view it this way. Many of the stakeholder groups that boycotted the initial workshops on the most recent reconsideration of the SRSM issue expressed skepticism that the USNRC was substantively considering and responding to their views and expressed concern that USNRC had not solicited their input prior to publishing the 1999 issues paper.
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From page 146... ...
SAIC was the contractor initially selected to undertake this work (Inside NRC, 2001~. DOE canceled the SAIC contract on July 25, 2001, after environmental groups and an influential member of Congress raised concerns about possible bias stemming from SAIC's earlier involvement as a subcontractor to B NFL in the nickel recycling project (Zuckerbrod, 2001~.
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From page 147... ...
STAKEHOLDER INVOLVEMENT: METHODS AND SUCCESSES The USNRC has had limited success in obtaining meaningful stakeholder involvement. Even so, determining the proper strategy or process to increase effective public participation and rebuild the trust of stakeholder groups will be difficult.
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have extensive alternative dispute resolution programs that have received widespread attention (Creighton and Priscoli, 1996~. The EPA has published for review a draft plan for public involvement (EPA, 2000~.
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From page 149... ...
These perceptions often underlie and reinforce beliefs that USNRC contractors are not adequately trained, have not exercised credible efforts to meet safety and quality standards, and often represent too closely the interests and perspectives of the regulated industry. As noted, other agencies have adopted innovative and far-reaching approaches to public involvement, alternative dispute resolution, and consensus building.
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From page 150... ...
Most of the issues of concern to those stakeholder groups that oppose the USNRC's recent efforts to establish a rule for the release of SRSM are the same issues expressed by these groups 10 years ago during the effort to establish the BRC policy. The committee's review of the record on the BRC policy, the License Termination Rule, and the 1999 issues paper found that stakeholders distrust the USNRC and remain confused about important technical questions.
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