Rationale for Independent Site Clean-Up and Radiological Clearance Standards

Over the past few years, the U.S. nuclear power industry has gained substantial experience and appreciation of the technical complexity and rigor required to meet a performance-based site clean-up standard. Five large power reactors and several smaller ones are now well along the path to license termination. They have not been on this journey alone. There has been a steep learning curve for all stakeholders involved in the process including state and federal radiation regulators, legislators, and the public. We have all learned that the translation of results from a post remediation survey interpreted through pathway modeling for comparison with a dose-based clean-up standard is for many a leap of faith. Our regulator has an understandable desire to address this uncertainty by demanding conservative analysis at each turn. As a result, it is extremely demanding to demonstrate that a clean-up standard in the 0.15–0.25 mSv/a range has been met. It is not likely that a standard in the 10 μSv/a level, typically associated with radiological clearance standards, can be practically demonstrated while still meeting the current expectations of U.S. Nuclear Regulatory Commission for technical rigor.