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Setting Radiation Protection Standards
Before EPA sets radiation protection standards or issues guidance, we follow a process that responds to a host of questions in several areas.
On this page:
- Deciding whether to set a standard
- Selecting the appropriate form for the standard
- Developing the standard
- Obtaining review and comment
- Issuing the final standards and responding to public comment
Deciding Whether to Set a Standard
Does the problem call for action?
Is there a widespread situation potentially affecting large numbers of people, or is the problem localized or relatively remote from the public? Will the problem solve itself if more people know about it?Do we have the statutory (legal) authority?
Our broadest authority to regulate radiation is the Atomic Energy Act, but there are limits to our AEA authority, most commonly when either the Nuclear Regulatory Commission or the Department of Energy is also using its specific AEA authority. We also use non-radiation-specific statutes, such as the Clean Air Act, Safe Drinking Water Act, and Comprehensive Emergency Response, Compensation and Liability Act, to regulate certain situations involving radiation exposures to the public. Sometimes we are directed by Congress to take specific action, as in the case of the Waste Isolation Pilot Plant and Yucca Mountain repository. For example, Congress assigns EPA specific authority in the WIPP Land Withdrawal Act or the Energy Policy Act.
Do we have the resources?
We frequently have to evaluate our proposed action against other competing priorities to ensure that the program as a whole can continue meeting its objectives. Setting standards takes time and a great deal of effort, and sometimes our most effective action is to issue guidance or work directly with the affected public. In cases where we are fulfilling Congressional direction, resources for the directed activity are generally made available.
Selecting the Appropriate Form for the Standard
The standards we set are all aimed at limiting exposures to radiation, but this purpose can be expressed in different ways. The form of the standard generally reflects the critical factors for a particular situation (for example, a spent fuel repository, site cleanup, and operating facility have different characteristics).
Dose
The most straightforward, and probably most familiar standard, is a dose limit, such as in our Yucca Mountain standards.
Radionuclide Concentration
Another way to limit exposures is to limit concentrations of radionuclides in waste or environmental media. We have used this approach in some site cleanup situations, and for treating drinking water and protecting ground water.
Environmental Release
Yet a third way to limit exposures is to limit releases of radionuclides to the environment. We have applied this approach to radon emanation rates from uranium mill tailings and in the Containment Requirements found in our generic regulations for disposal of spent nuclear fuel, high-level radioactive waste, and transuranic radioactive waste.
Once the appropriate form is selected, we move on to developing the standard.Developing the Standard
First we gather necessary information.
- What we know about radionuclides
- What we know about the health effects of the radionuclides
- What we know about their behavior in the environmentWe also have to consider where they will be in the environment. For example, will they be in an engineered disposal facility, or present in soil?
- How people could be exposedThe basic exposure pathways (ingestion, inhalation, direct exposure) do not vary, but their relative importance does. For example, direct exposure and radon emanation from Yucca Mountain will be minuscule, but may be the driving factor in cleaning up a contaminated site.
Next we use mathematical models to evaluate potential solutions.
The long lifetimes of many radionuclides,and the complex decay chains, means that in some cases, we have to project potential exposures for hundreds to thousands of years into the future. To make the extremely complex calculations that tell us what is likely to happen to radionuclides in the environment (potentially far into the future), we develop computerized, mathematical models. They take into account many factors:
- decay rates of the radionuclides initially present
- the behavior of these radionuclides in the environment
- decay chain products, their decay rates, and their behavior in the environment
- the type of environment (air, water, rock formations).
Then we assess the feasibility of potential solutions.
- Which solutions can be implemented with existing technology?
- What are the economic impacts of the proposed solutions?
- Which solutions are consistent with existing policies?
Obtaining Review and Comment
Once we have identified a feasible solution, we ask groups of experts from outside EPA and the general public to review and comment on it.
Scientific groups: EPA's Science Advisory Board, National Academy of Sciences
These groups also give us important feedback or advice while we are developing the proposal. The Science Advisory Board ensures that Agency projects receive independent scientific and engineering advice. The National Academy of Sciences may be commissioned by Congress to prepare studies to be used as input to Agency rulemakings. For example, we gave the NAS' Yucca Mountain Report great weight when developing our standards. You can learn more at the Science Advisory Board Web site.
Regulatory Groups: CRCPD, Other Federal Agencies
States and other federal agencies are important partners in developing appropriate standards (or guidance). We frequently encounter overlapping regulatory spheres. For example, in the case of Yucca Mountain, the Department of Energy is the regulated party, the Nuclear Regulatory Commission is the regulator, and we issued standards for NRC to implement.The Public: General Public and Regulated Communities
Before any standard is issued, we must publish a public notice in the Federal Register and provide an opportunity for the public to comment on the standard. During the comment period, the general public and various industries or other groups affected by the standard may review the standards and send comments to the agency.
Issuing the Final Standard and Responding to Public Comments
Before we issue the final standard, we must consider and respond to comments we receive from the public. We are required to respond in writing to each comment on the proposed standard in a document known as the "Response to Public Comment." This document, along with technical support documents and economic analyses, becomes part of the administrative record (or docket) for the standard .
The last step is to publish both the final standard and the Response to Public Comment document in the Federal Register.
