Radioactive Mine and Low-Level Radioactive Waste Regulation In The 21st Century

1
Radioactive Mine and Low-Level Radioactive Waste
Regulation In The 21st Century

• Anthony J. Thompson
• ShawPittman, Washington, D.C.

2
I. INTRODUCTION - Are Existing And Past Uranium
Recovery (UR) And LLRW Regulations Prologue For
Future Radioactive Mine Waste Regulation?

• Some Mine Wastes Are Similar To Waste Produced
  From UR Milling Operations
• While Mine Wastes Are Currently Regulated By The
  States, Some Have Suggested Regulating
  Radioactive Mine Waste In A Similar Fashion To
  Uranium Mill Tailings
• UR, LLRW And NORM Regulatory Proceedings And
  Requirements Provide A Working, Changing,
  Real-life Laboratory To Evaluate Potential Future
  Regulatory Developments.

3
Introduction Contd

• Four Entities That Impact UR Recovery, LLRW, and
  NORM Regulation Include
• NRC
• EPA
• DOE
• Interstate Compacts
• We Address Each Below.

4
II. NUCLEAR REGULATORY COMMISSION (NRC)

• Uranium Recovery (UR) Operations Regulatory
  Program
• Low Level Radioactive Waste (LLRW) Regulatory
  Program.

5
Nuclear Regulatory Commission (NRC) Contd

• A. The UR Operations Regulatory Program
• 1. NMA Issued White Paper On UR Regulation In
  19981-- Examined Key Elements of NRCs
  Regulatory Program For UR, And Proposed
  Reforms.
• Goal Of White Paper Establish A Rational,
  Coordinated Framework For Regulation Of UR
  Activities.

6
Nuclear Regulatory Commission (NRC) Contd

• NMAs White Paper Addressed The Following Issues
• Concurrent State/NRC Jurisdiction Over
  Non-Radiological Components of Byproduct
  Material
• NRC Regulation of ISL Activities (not discussed)
• Direct Disposal of Non-11e.(2) Byproduct Material
  in UR Tailings Disposal Facilities
• Use of Alternate Feeds at Licensed UR Mills.

7
Nuclear Regulatory Commission (NRC) Contd

• Concurrent Jurisdiction Issue Do Non-Agreement
  States Exercise Concurrent Jurisdiction Over
  Non-Radiological Aspects of 11e.(2) Byproduct
  Material?
• 1980 NRC Staff Position2 Yes
• Position Developed Just After Passage of UMTRCA,
  When Expansive New Statutory Authority Not Well
  Understood and Regulatory Program in Infancy.

8
Nuclear Regulatory Commission (NRC) Contd

• Practical Implications of Concurrent
  Jurisdiction
• Dual Federal/State Regulation -- Resulting in
  Sub-Optimized Disposal Requirements
• Delays in Site Closure As Licensees Attempt to
  Satisfy Different, Sometimes Inconsistent Sets of
  Requirements
• Reluctance of DOE to Assume Custody Following
  Site Closure. 3

9
Nuclear Regulatory Commission (NRC) Contd

• White Paper Arguments
• UMTRCA Establishes a Pervasive Federal Scheme of
  Regulation Over Both Radiological and for the
  First Time Non-Radiological Aspects of 11e.(2)
  Byproduct Material
• Concurrent Jurisdiction Conflicts With The
  Statute And Frustrates Congress Purpose Of
  Ensuring Timely Disposition of Tailings Under
  Uniform National Standards.

10
Nuclear Regulatory Commission (NRC) Contd

• In August 2000, NRC Adopted the Position
  Advocated in NMAs White Paper, Voting to Assert
  Exclusive Jurisdiction Over Both Radiological and
  Non-Radiological Aspects of 11e.(2) Byproduct
  Material.4

11
Nuclear Regulatory Commission (NRC) Contd

• Direct Disposal of Non-11e.(2) Byproduct Material
  In Uranium Mill Tailings Impoundments
• Sound Policy Due To Limited Capacity for High
  Volume, Low Activity Wastes
• Current NRC Policy Creates Numerous Hurdles
  Licensees Must Overcome, Making it Nearly
  Impossible to Dispose of Non-11e.(2) Material in
  Tailings Impoundments. 5

12
Nuclear Regulatory Commission (NRC) Contd

• NMA White Paper Proposed Several Modifications
  to NRCs Non-11e.(2) Disposal Policy, To
  Facilitate Use of Tailings Impoundments For
  Disposal of High Volume, Low Activity Wastes
  Similar to Uranium Mill Tailings.
• Commission Directs Staff to Look at Liberalizing
  Policy.6

13
Nuclear Regulatory Commission (NRC) Contd

• Processing Alternate Feeds At Uranium Mills. The
  Concept Wastes Containing Uranium Can Be
  Processed Through a Mill To Recover Their Uranium
  Content, And the Resulting Tailings and Wastes
  Can Be Disposed Of As 11e.(2) Byproduct Material.7

14
Nuclear Regulatory Commission (NRC) Contd

• Disposal As 11e.(2) Byproduct Material
  Effectively Eliminates Long Term Contingent
  Liability For the Generator of the Alternate Feed
  (e.g., Liability Under Superfund). Title to the
  Waste Passes to Long Term Government Custodian,
  which is Subject to Perpetual NRC License.

15
Nuclear Regulatory Commission (NRC) Contd

• Under UMTRCA, Material Must be Processed
  Primarily for its Source Material Content to
  Generate 11e.(2) Byproduct Material.
• Commission Has Ruled That Motive of Licensee
  for Processing to Obtain Disposal or Recycling
  Fee Does not Disqualify a Material from Being
  Used as an Alternate Feed.8

16
Nuclear Regulatory Commission (NRC) Contd

• As Long as Uranium Will Be Recovered From
  Alternate Feed Material, Sham Processing is Not
  an Issue.
• Disposal/Recycling Fees Make It Economically
  Feasible For Mills to Process Alternate Feeds --
  Now Impossible For Conventional Ores.

17
Nuclear Regulatory Commission (NRC) Contd

• NRC Authority to Regulate Tailings And Wastes
  Generated Prior to 1978 -- i.e., Pre-1978
  Byproduct Material 9
• NRC Has Flip-Flopped Position On Jurisdiction
  Over Pre-1978 Byproduct Material
• NRC Previously Asserted Such Material Was Subject
  to Regulation As 11e.(2) Byproduct Material, and
  NRC Authorized Disposal in 11e.(2) Facilities.
• More Recently, NRC Has Allowed Pre-1978 Byproduct
  Material To Be Disposed of in RCRA Facilities,
  Asserting That the Material Is Not Subject to AEA
  Regulation as 11e.(2) Byproduct Material.

18
Nuclear Regulatory Commission (NRC) Contd

• As a Result of its Flip-Flops, NRC Has Created a
  Commingled Waste Problem 11e.(2) Byproduct
  Material Has Been Commingled With Non-11e.(2)
  Wastes
• Problems With Dual Jurisdiction
• Questions Regarding DOEs Willingness to Take
  Custody Following Site Closure
• Contrary to NRCs Non-11e.(2) Disposal Policy.10

19
Nuclear Regulatory Commission (NRC) Contd

• This Issue Has Raised the Profile of
  Risk-Informed Regulation in Congress (i.e.,
  Wastes Posing Similar Risks Should Be Treated in
  a Similar Fashion). 11
• To Do So Would Require Major Changes in the
  Current Rules Because AEA and RCRA are
  Definitionally Based (e.g. NORM mine waste can be
  virtually identical to 11e.(2) waste, yet is
  definitionally different Same for Listed Versus
  Characteristic Hazardous Waste.)

20
Nuclear Regulatory Commission (NRC) Contd

• 2. Alternate Concentration Limits (ACLs)
• Under NRCs Regulations Hazardous Constituents in
  Groundwater From Tailings Disposal Sites Must
  Fall Within Specified Limits at a Designated
  Point of Compliance (POC).12
• The Standard Limits That Must be Achieved are
  Maximum Contaminant Levels ("MCLs"), Background,
  Whichever Is Higher

21
Nuclear Regulatory Commission (NRC) Contd

• Or, the Regulations Allow the Licensee to Propose
  ACLs for One or More Relevant Constituents
• ACLs Must Adequately Protect Human Health and
  Environment at the Point of Exposure (POE),
  Defined as the Location(s) at Which
  Humans/Wildlife Reasonably Likely To Be Exposed.

22
Nuclear Regulatory Commission (NRC) Contd

• 3. Alternatives
• Alternatives to NRC Requirements for Disposal of
  11e.(2) Byproduct Materials.
• A licensee may propose alternatives to specific
  requirements whichmay take into account local
  or regional conditions. 13
• These alternatives will be satisfactory if such
  alternatives
• will achieve a level of stabilization and
  containment of the sites concerned and
• a level of protection for public health, safety,
  and the environment from the site
• which is equivalent to, to the extent
  practicable, or more stringent that the level
  which would be achieved by standards and
  requirements adopted and enforced by the
  Commission or EPA for the same purpose.

23
Nuclear Regulatory Commission (NRC) Contd

• 4. Supplemental Standards
• EPAs Regulations at 40 C.F.R. Part 19214
  Establish Groundwater Concentration Limits for
  Various Contaminants at Inactive (Title I)
  Uranium Mill Sites
• These Standards Allow for Natural Flushing and
  Institutional Controls If Active Remediation Is
  Not Appropriate.

24
Nuclear Regulatory Commission (NRC) Contd

• When Restoration Of Groundwater To The Limits
  Established In The Regulations Is Technically
  Impracticable, or When the Groundwater Cannot Be
  Used For Drinking Because Of Background
  Conditions, Supplemental Standards May Be
  Applied or

25
Nuclear Regulatory Commission (NRC) Contd

• If Achieving The Standards Set Out In The
  Regulations Would Result in More Harm Than Good.
• Supplemental Standards Must
• Assure Protection of Human Health And the
  Environment
• Preserve Current And Projected Groundwater Uses.
• Supplemental Standards as an Alternative at a
  Title II Site.15

26
Nuclear Regulatory Commission (NRC) Contd

• B. Low Level Radioactive Waste
• 1. NRC Decommissioning Decontamination Rules.
• 1988 NRC Regulations Defined Decommissioning to
  Mean to remove nuclear facilities safely from
  service and to reduce residual radioactivity to a
  level that permits unrestricted use and
  termination of the license. 16

27
Nuclear Regulatory Commission (NRC) Contd

• 1993-1994 Concerns About the Pace and Quality of
  facility decommissioning and decontamination
  (DD) efforts involving NRC, EPA, DOE, DOD and
  states led to generic regulatory inquiries to
  determine
• Who must pursue DD
• To what level and by what means
• When DD should or must take place
• How much waste will be generated by DD and,
• What are the conditions for control or disposal
  of such waste.

28
Nuclear Regulatory Commission (NRC) Contd

• 1994 - NRCs Timeliness in Decommissioning rule
  issued requiring licensed facilities (or portions
  thereof) that have not been used for licensed
  activities for 24 months must begin the DD
  process or seek a waiver. 17

29
Nuclear Regulatory Commission (NRC) Contd

• 1994 - NRC proposes Radiological Criteria For
  License Termination 18
• Risk limit (15 mrem/y) Plus ALARA (whichs 3
  mrem/y)
• Risk goal (e.g. Like an MCLG)
• Best efforts (e.g. BACT)
• Return to background
• Possible separate groundwater standard.

30
Nuclear Regulatory Commission (NRC) Contd

• 1997 NRC issues final DD regulations19
• 25 mrem/y for all pathways risk limit for 1,000
  years plus ALARA for unrestricted use
• A tiered system allowing sites to be released for
  restricted use under certain conditions (e.g..
  durable institutional controls (ICs) that can
  reasonably be expected to be effective into the
  foreseeable future financial assurance a
  100mrem/y fail safe cap if ICs fail

31
Nuclear Regulatory Commission (NRC) Contd

• Costs (including environmental impacts) of
  unrestricted use of would be unreasonable and,
• Must Consult with potentially affected and/or
  interested members of the community.

32
Nuclear Regulatory Commission (NRC) Contd

• Alternative criteria for license termination
  other than in compliance with the 25 mrem/y limit
  (i.e. reasonable assurance that dose to members
  of the critical group will not exceed 100 mrem/y
  based on comprehensive risk analysis ICs to
  restrict site use, ALARA, detailed public
  involvement).
• An exception for up to 500 mrem/y in unusual
  site specific circumstances if approved by the
  Commission and verification of ICs every five
  years.20

33
Nuclear Regulatory Commission (NRC) Contd

• Restricted Use and ICs
• NRC DD regulations21 - Stringent ICs, such as
  legally enforceable deed restrictions and/or
  engineering controls backed by government
  ownership should be established with the
  objective of lasting 1,000 years.
• ICs and controls or barriers that restrict access
  to the site to limit potential exposure (e.g.
  industrial versus residential use or industrial
  versus domestic groundwater use).

34
Nuclear Regulatory Commission (NRC) Contd

• NUREG 1727 (September, 2000) Chapter 16.0 NMSS
  Decommissioning Standard Review Plan sets forth
  restricted use criteria and durable ICs (e.g.,
  legal opinion regarding enforceability of IC
  under particular state law). 22

35
Nuclear Regulatory Commission (NRC) Contd

• Institutional Controls A Site Managers Guide
  to Identifying, Evaluating and Selecting
  Institutional Controls at Superfund and RCRA
  Corrective Action Changes (September 29, 2000)
  23
• Non-engineered instruments such as administrative
  and/or legal controls that minimize the potential
  for human exposure from contamination by limiting
  land or resource use

36
Nuclear Regulatory Commission (NRC) Contd

• Even in the unusual case where a CERCLA Record of
  Decision (ROD) only requires implementation of
  ICs, it is considered to be a limited action,
  not a no action ROD
• Informational devices (Deed Notations) are most
  likely to be used as a secondary layer to help
  insure the overall reliability of other ICs.

37
Nuclear Regulatory Commission (NRC) Contd

• Protecting Health and Safety with Institutional
  Controls, Larry Snapf, NRE (Spring 2000). 24
• Thus, it is important that the instrument
  creating the institutional control identify the
  party who will have the right to enforce the
  restrictions and be responsible for maintaining
  and repairing the controls.

38
Nuclear Regulatory Commission (NRC) Contd

• Responsibilities of the enforcer may include
• Making periodic site inspections to ensure that
  prohibited activities are not taking place
• Checking the integrity of caps, fencing and other
  barriers
• Ensuring that site use has not extended into
  prohibited areas and
• Inspecting drinking water wells to make sure that
  they are not being used.

39
Nuclear Regulatory Commission (NRC) Contd

• 2. Guidance
• Site Characterization and Cleanup Verification
• Multi Agency Radiation Survey Site
  Investigation Manual (MARSSIM)25
• Excellent discussion of issues, goals, policies
  and techniques
• Problematic for demonstrating compliance with 25
  mrem/y with naturally occurring radionuclides.

40
Nuclear Regulatory Commission (NRC) Contd

• DD Code
• Alternative to RESRAD but is very conservative
  and impractical - i.e., One Nuclide and Only
  homogenous, surface contamination and no
  groundwater application.

41
Nuclear Regulatory Commission (NRC) Contd

• C. Source Material (S/M) Reconsideration
• 2000 - NRC considers amending 10 CFR 40 requiring
  NRC approval for transfers of unimportant
  quantities (e.g. lt 0.05) of S/M from licenses to
  exempt persons.26
• Section 40.13(a) exempts from licensing s/m
  w/less than 0.05 of U or Th or a combination
  thereof.
• Raised question of reducing the licensable level
  to less than 0.05.

42
Nuclear Regulatory Commission (NRC) Contd

• Would bring significant parts of the mining
  industry under NRC regulation
• Could be considered to violate AEA without
  Congressional approval
• Could provide EPA with AEA authority (i.e.
  opportunity) to regulate U and Th below 0.05.

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III. ENVIRONMENTAL PROTECTION AGENCY (EPA)

• A. Low Level Radioactive Waste
• 1. LLRW 1993 - EPA publishes an ANPR outlining
  potential DD issues including LLRW, Mixed
  Waste, NORM/NARM, regulatory approaches, waste
  management and waste recycling and reuse issues
  under AEA and CERCLA27
• Cleanup to detection limits
• Cleanup to background levels
• Cleanup to a risk level or range of risk levels
• Cleanup to BACT.
• Never Promulgated!

44
ENVIRONMENTAL PROTECTION AGENCY (EPA) Contd

• 2. EPA/NRC Dispute
• 1997 - EPA challenges NRC intent to and actual
  decision to abandon 15 mrem/y limit for 25
  mrem/y and decision not to require a 4 mrem/y
  separate groundwater limit.28
• EPA threatens to consider NRCs rule not
  protective under CERCA and national groundwater
  policy and to reconsider exempting NRC sites from
  the NPL.

45
ENVIRONMENTAL PROTECTION AGENCY (EPA) Contd

• This dispute continues
• NRC has requested that Congress resolve the
  dispute
• EPA has issued Superfund Radiation Guidance
  questioning protectiveness of NRC regulations for
  CERCLA purposes29
• 15 mrem/y is not to be considered a cleanup limit
  but rather a preliminary remediation goal
• (15 mrem/y 3x10-4).

46
ENVIRONMENTAL PROTECTION AGENCY (EPA) Contd

• EPA states
• 40 CFR Part 190 25 mrem/y limit actually s 15
  mrem/y
• 40 CFR Part 192 5/15 pCi/g standard for radium in
  Soil (EPA Estimated dose of up to 80 mrem/y when
  promulgated) also s 15 mrem/y.
• If 25 15 and 80 15 why quarrel with NRCs 25?

47
ENVIRONMENTAL PROTECTION AGENCY (EPA) Contd

• B. EPA Council of State Radiation Control
  Program Directors (CRCPD) Dispute
• (1) 1997 - EPA challenges draft CRCPD NORM
  regulations as inconsistent with Superfund
  protectiveness goals30
• Draft rule only requires SDWA MCLs be met at the
  tap and no separate groundwater standard
• Draft rule allows for 100 mrem/y exposure

48
ENVIRONMENTAL PROTECTION AGENCY (EPA) Contd

• Draft expresses no preference for permanent
  remedies
• Result -- may lead to creation of more Superfund
  sites.

49
ENVIRONMENTAL PROTECTION AGENCY (EPA) Contd

• 2. Council of State Radiation Control Program
  Directors (CRCPD) TENORM Model Standards
• Long term effort cumulated w/proposal from NORM
  Commission which utilized NORM Advisory
  Committee
• Moved to dose based approach in Final Subpart N
  Model Regulations.31

50
ENVIRONMENTAL PROTECTION AGENCY (EPA) Contd

• No Licensee shall cause a member of the public to
  receive TEDE from all licensed sources including
  TENORM in excess of 100 mrem/y
• Does not apply to indoor radon or source Material
  under AEA (i.e., U Th) or TENORM regulated
  under CERCLA or RCRA
• Release for unrestricted use must assume that
  reasonable maximally exposed individual will
  receive an annual TEDE in excess of some
  fraction of 100 mrem/y above background.
• left states with freedom to choose fraction
• NJ has chosen 15 mrem/y
• Incorporates 5/15 pCi/g RA-226 rule for soil
  contaminated w/Radium.
• Disposal of TENORM in UR tailings impoundment or
  other AEA licensed disposal facility or in
  accordance w/authorized Agency alternatives.

51
ENVIRONMENTAL PROTECTION AGENCY (EPA) Contd

• 3. EPA TENORM Project
• EPA published several draft Diffuse NORM Reports
  such as Diffuse NORM Wastes Waste
  Characterization and Preliminary Risk Assessment
  (1993) that were filled with so many
  inaccuracies and irrelevancies as to be
  useless32
• EPA moving to a series of individual reports on
  TENORM wastes and products for different
  industries33
• UR is first on the list
• Designed to be information gathering and not for
  regulation.

52
ENVIRONMENTAL PROTECTION AGENCY (EPA) Contd

• C. Mixed Waste
• Dual Regulatory Scheme imposed by NRC under the
  AEA and EPA under RCRA34
• RCRA 1006 mandates that RCRA yield to the AEA to
  prevent inconsistencies, however the section has
  never been used successfully to exempt materials
  from regulation under RCRA
• Has been interpreted to prohibit RCRA regulation
  only in cases where it is physically impossible
  to comply with both statutes.
• LLRW standards would provide adequate protection
  - maybe some EPA movement in that direction.

53
ENVIRONMENTAL PROTECTION AGENCY (EPA) Contd

• D. Radioactive Mine Waste on Federal Lands
• Executive Order 12580 amended by President
  Clinton to authorize Federal Natural Resource
  Trustees and Land Management Agencies to issue
  unilateral administrative orders under 106 of
  CERCLA35
• April 1998 - Meeting in Grand Junction, Colorado
  to initiate discussions about cleanup of inactive
  and abandoned uranium mines on government lands
  pursuant to the above amendment
• EPA urged federal agencies to pursue clean up
  under 106 to the 15 mrem/y level
• Concerns about elevated radionuclide emissions
  and mobilization of uranium by acid mine drainage.

54
ENVIRONMENTAL PROTECTION AGENCY (EPA) Contd

• E. EPA Maximum Containment Levels (MCLS) for
  Radionuclides under the Safe Drinking Water Act
  (SDWA)
• Tap water standards that will be applied to
  groundwater corrective action under CERCLA
• NRC opposes EPA MCL Package for radionuclides as
  inconsistent and outmoded but failure to satisfy
  MCLs could leave a terminated NRC license
  vulnerable to EPA reopeners.

55
ENVIRONMENTAL PROTECTION AGENCY (EPA) Contd

• Radionuclide MCLs36
• Radium - 5 pCi/l is retained in spite of evidence
  of a radium threshold in humans.
• Uranium - 30 U/g/l (27 pCi/l) will pose a
  potentially significant cleanup problem for
  mining waste operations.

56
IV. Department of Energy (DOE)

• Section 151(b) of the Nuclear Waste Policy Act
  (NWPA) provides DOE with the authority to take
  wastes under certain circumstances.37
• DOE Established a Long-term Stewardship Program
  under Environmental Restoration Division to
  address waste sites that it already must take
  (eg.Title I) and those that it may need to take
  under 151(b).

57
Department of Energy (DOE) Contd

• Critical issues for DOE include
• Concerns that state may attempt to regulate sites
  under FFCA for hazardous materials
• Concerns that Long-Term Financial Assurance will
  not be in place
• Potential Use of trust mechanisms to insure
  financing.

58
V. COMPACT SYSTEMS

• A. Compacts Have Become Irrelevant
• GAO (September 1999) reports that States have
  spent almost 600 million attempting to find and
  develop about 10 sites for disposing commercially
  created LLRW none of the states or compacts
  have successfully developed a new disposal
  facility. The efforts by states to develop
  new disposal facilities have essentially
  stopped.38

59
V. COMPACT SYSTEMS Contd

• Barnwell, S.C. facilitys remaining disposal
  capacity could be used up in 10 years.
• Northwest/Rocky Mountain Compacts - 11 states
  here use the Richland, WA facility.
• B. Envirocare is seeking authority to dispose of
  Class B and C wastes.

60
VI. Lessons Learned That May or Will Affect
Waste Regulation in This Century

• Goal of White Paper To Proactively Stimulate
  Conservation of a Rational, Coordinated Framework
  for Regulation of UR Activities.

61
Summary Contd

• Risk-informed performance based regulation works
  and has established a foothold
• Pre-1978 11e.(2) issue has elevated the risk
  based regulatory approach to public debate.
• Performance based licensing is established at NRC
  even with reactors (eg. 10CFR 50.59).

62
Summary Contd

• The Active controls (i.e., treatment) first in
  all cases approach is giving way to less active
  controls (i.e., ACLs and ICs) to remediate
  sites in the face of reality.
• Eg Pump and treat is too expensive and often
  ineffective so
• ACLs
• Supplemental standards.

63
Summary Contd

• Long term stewardship and restricted use make
  sense
• ICs

64
Summary Contd

• Duplicative Regulation Will Continue to Be a
  Problem
• DD Rule Conflict
• Mixed Waste

65
Summary Contd

• Anything That Resonates Thru CERCLA and RCRA
  Program That Threatens Change May Hit a Road
  Block With EPA.
• Absolute Power Corrupts Absolutely and So It Is
  With EPA and CERCLA Which Has Taken On A Deified
  Life of Its Own.

66
Summary Contd

• Huge Volumes of Waste-high Cost of Removal And/or
  Treatment (Particularly With NORM) Are Leading to
  Creative Thinking That Is Forcing Rigidity of the
  Past Aside -- So
• Regulators and Regulated Need to Be Creative and
  Think Outside the Box
• Public Opinion Must Be Addressed but More and
  More Frequently Will Accept in Situ Closure
  Rather Than Costs and Risks of Removal

67
Summary Contd

• Flexibility To Address Site-Specific Conditions
  At Complex Sites (Such As ACLs, Alternatives,
  Supplemental Standards, Restricted Use through
  ICs And Informational Devices.) Is An Absolute
  Necessity If Successful Site Closures Are To Be
  Achieved.