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2 Challenges to Regulatory Flexibility and Risk-Informed Decision Making
Pages 23-30

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From page 23...
... EM has eight overarching priorities: activities to maintain a safe and secure posture in the EM complex; radioactive tank waste stabilization, treatment, and disposal; spent nuclear fuel storage, receipt, and disposition; special nuclear material consolidation, processing, and disposition; high-risk soil and groundwater remediation; transuranic and mixed/low-level waste disposition; soil and groundwater remediation; and excess facilities deactivation and decommissioning. Although much cleanup has been accomplished, there are still more than 90 million gallons of highly radioactive waste stored in more than 200 aging underground storage tanks.
From page 24...
... Ms. Williams stated that, to meet EO13514 requirements, EM has accelerated facility decontamination and decommissioning of high-energyconsuming excess facilities, ensured sites have robust energy management programs, promoted in situ decommissioning and green remediation, where appropriate, and successfully implemented energy reduction efforts at several sites.
From page 25...
... He shared his views from a personal perspective as a practitioner rather than from an official perspective as a Challenges to Regulatory Flexibility • Overlap of regulations –  Competing standards: Nuclear Regulatory Commission, EPA, state regulators – Differing implementation processes • Political and stakeholder influence • Lack of understanding of risk • Risk assessment vs. risk management • Implementation of restricted release option • Exposure scenario options Larry Camper, Nuclear Regulatory Commission, October 30, 2013
From page 26...
... There is also a challenge in communicating risk, because the general public lacks an in-depth understanding of risk, particularly of the difference between risk assessment and risk management. The extent of remediation at a site and the pathway toward risk management depend on the exposure scenarios chosen for the end state; there is a large difference between evaluating a site for residential versus industrial use.
From page 27...
... In contrast, DOE's effort to clean up waste incidental to reprocessing is an example of regulatory flexibility. Section 3116 of the National Defense Authorization Act of 2005 gives the Nuclear Regulatory Commission responsibility for consulting with DOE for assessing compliance with high level waste and waste incidental to reprocessing determinations at DOE sites in Idaho and South Carolina.
From page 28...
... Sustainable remediation should not be an excuse to weaken standards necessary to protect human health and the environment. There are several drivers to sustainable remediation, including sound public policy, short- and long-term protection of human health and the environment, source removal where possible to enable longer-term environmental restoration, and economic development, the last of which is key to keeping communities viable.
From page 29...
... • Risk management and decision making based on risk assessment results must be improved. Many aspects to risk management make it variable, including professional judgment, values, tolerance for risk, and consideration of the future value of resources.
From page 30...
... Indiana is struggling with training staff in risk assessment and risk management procedures, and in particular in interpreting a risk assessment for a given site and deciding on necessary actions. When optimizing a remediation system, it is necessary to consider all of the different factors that comprise the system (Figure 2-1)


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