NRC WORKSHOP ON THE STATUS OF

LOW LEVEL RADIOACTIVE WASTE DISPOSAL

-LEVEL RADIOACTIVE WASTE DISPOSAL

RULEMAKING AND STRATEGIC ASSESSMENT OF LOW-LEVEL RADIOACTIVE WASTE REGULATORY 

PROGRAM

Chip Cameron Facilitator Chip Cameron, Facilitator

March 7, 2014

NRC Public Meetin

g

Phoenix, AZ
Agenda 

7:30 - 8:00 am Registration8:00 - 8:15 Facilitator Opening Comments C. Cameron, Facilitator 8:15 - 8:30 NRC Welcome L. Camper, NRC/FSME1 8:15 8:30 NRC Welcome L. Camper, NRC/FSME8:30 - 9:302 Status of Low-Level Radioactive Waste D. Esh, NRC/FSME

Disposal Rulemaking and Discussions

9:30 - 9:45 Break9:45 - 10:00 Strategic Assessment of M. Wong, NRC/FSME

Low-Level Radioactive Waste 

Regulatory Program

10:00 - 11:30 Panel Discussions11:30 - 12:45 pm Facilitated Public Discussions12:45 - 1:00 Closing Remarks A. Mohseni, NRC/FSME 12:45 1:00 Closing Remarks A. Mohseni, NRC/FSME1Office of Federal and State Materials and Environmental Management Programs (FSME)2The timing is subject to change based on the status of the proposed rulemaking on 10 CFR Part 61. 

2
NRC WORKSHOP ON THE STATUS OF

LOW LEVEL RADIOACTIVE WASTE DISPOSAL

-LEVEL RADIOACTIVE WASTE DISPOSAL

RULEMAKING AND STRATEGIC ASSESSMENT OF LOW-LEVEL RADIOACTIVE WASTE REGULATORY 

PROGRAM

Larry W. Camper, CEP, CIPM, Director

Division of Waste Mana

gement and Environmental Protection

Office of Federal and State Materials and Environmental 

Management Programs

March 7, 2014

NRC Public Meetin

g

Phoenix, AZ
Objective

To discuss the status of the proposed revisions to the Commission’s LLRW revisions to the Commission s LLRW

disposal regulations and gather information 

on an update to the NRC 2007 Strategic on an update to the NRC 2007 Strategic

Assessment of the LLRW regulatory 

program from stakeholders and other program from stakeholders and other

interested members of the public.

4
QUESTIONS?
STATUS OF

LOW LEVEL RADIOACTIVE WASTE -LEVEL RADIOACTIVE WASTE

DISPOSAL RULEMAKING AND 

DISCUSSIONS

David Esh

March 7, 2014

NRC Public Meeting

Phoenix, AZ

Division of Waste Management and Environmental Protection

Office of Federal and State Materials and Environmental 

M tP anagement Programs
2009 Commission Direction

SRM

-SECY

-08

-0147 SRM

-SECY

-08

-0147

– Two tasks:

• Specify a requirement for a site-specific analysis, technical 

parameters (i.e., new definitions and performance period) to 

support such analysis, and develop a guidance document.

• “... in a future budget request, the staff should propose the 

necessary resources for a comprehensive revision to riskinform the Part 61 waste classification framework, with conforming changes to the regulations as needed, using 

d t d ti d f i th l t t ICRP upd

a

t

e

d assumptions an

d re

ferencing the la

tes

t ICRP

methodology ...” “... This effort should explicitly address the waste classification of depleted uranium ...”

7
2012 Commission Direction

SRM-COMWDM-11-0002/COMGEA-11-0002

– Flexibility to use current International Commission on 

Radiological Protection (ICRP) dose methodologies

– Two

-tiered period of performance: tiered period of performance:

• Tier 1: Compliance period covering reasonably foreseeable 

future

Tier 2: Longer period based on site characteristics and peak

• Tier

2: Longer period based on site characteristics and peak

dose to a designated receptor, that is not a priori

– Flexibilit

y to establish site-s

pecific waste acce

ptance criteria 

y p p

based on the results of the site’s performance assessment and intruder assessmentBalance Federal State alignment and

– Balance Federal

-State alignment and

flexibility

8
2014 Commission Direction

SRM SECY

-13

-0075 SRM SECY

-13

-0075

– Three-tiered 

period of anal

ysis:

• Tier 1: Compliance period of 1,000 years, 25 mrem dose limit for 

61.41 and 500 mrem dose limit for 61.42

• Tier 2: Protective Assurance Period from 1 000 to 10 000 years Tier

2 Protective Assurance Period from

1,000 to 10,000 years, 

500 mrem analytical threshold (goal) for 61.41 and 61.42

• Tier 3: Performance period > 10,000 years, qualitative analysis

– Constancy of features, events, and processes of the natural 

environment for Tier 2 unless compelling scientific evidence

Realistic intruder scenarios based on expected activities on and

– Realistic intruder scenarios based on expected activities on and

around the disposal site at the time of closure.

9
2014 Commission Direction

SRM SECY

-13

-0075 SRM SECY

-13

-0075

– The proposed rule should be published with a compatibility category 

“B” li d t th t i ifi t i i f th i d l “B” appli

e

d

to the mos

t significan

t provisions o

f the revise

d rule, 

including the Period of Compliance, the Protective Assurance Analysis Period and its analytical threshold, and the Waste 

Acceptance Criteria Acceptance Criteria. 

– The Protective Assurance Analysis Period (Tier 2) requires the 

applicant to propose remedial changes to the disposal site design, or 

impose inventory limits, or propose alternative methods of disposalas it is approached.Stress defense

-in

-depth and safety case

– Stress defense

-in

-depth and safety case.

– Thorough review of guidance by LLW community.

1010
Path Forward

• Staff will revise the rule, statement of considerations, 

and guidance document over the next year. g y

• Proposed rule issued for public comment in 2015.• Extensive stakeholders outreach

– 120 days comment period– 1 or more public meeting to engage stakeholders

11
STRATEGIC ASSESSMENT OF LOW LEVEL ASSESSMENT OF LOW-LEVEL

RADIOACTIVE WASTE REGULATORY 

PROGRAM

Melanie Wong

March 7, 2014

NRC Public Meeting

Phoenix, AZ

Division of Waste Management and Environmental Protection

Office of Federal and State Materials and Environmental 

M tP anagement Programs
Topics

• Background• Status of the 2007 Strategic Assessment Status of the 2007 Strategic Assessment• Proposed updates to the Strategic Assessment• Next steps

13
Background

Ch ll d i i ldd Challenges and issues included:

• the desire of industry for greater flexibility and reliability in 

LLRW disposal options; LLRW disposal options;

• increased storage of Class B and Class C LLRW; • the potential need to dispose of large quantities of power 

plant decommissioning waste and depleted uranium;

• increased safety concerns; 

th LLRW i d t th • e LLRW program required greater resources than were 

available; 

• increased security concerns; and concerns; and

• new waste streams that may be generated. 

14
Background (continued) continued)

2007 Strategic Assessment of the NRC’s regulatory program for LLRWGoal:• identify and prioritize staff activities and prioritize staff activities.

Objectives:

• ensure safe and secure LLRW disposal; • improve the effectiveness, efficiency, and adaptability of 

the NRC’s LLRW regulatory program; and 

• ensure regulatory stability and predictability. 

15
Background (continued)

• Variety of activities proposed• List of 20 activities developed• Priorities of high (7 tasks), medium (6 tasks), or low (7 

tasks) assigned tasks) assigned

16
Background (continued (continued)

High Priority Activities

Task 

#

Task Description

1 Review and update guidance on extended storage of LLRW. pg g

2 Develop guidance on 10 CFR 20.2002 Alternate Disposal Requests.3 Determine if disposal of large quantities of depleted uranium would 

change the waste classification tables.

4 Update Branch Technical Position on Concentration Averaging and 

Encapsulation.

5 Develop procedures for Import/Export Review.6 Develop guidance on alternate waste classification (10 CFR 61.58).7 Perform scoping study of the need to revise/expand byproduct material 

financial assurance to account for life-cycle cost.

17
Background (continued)

Medium Priority Activities Priority Activities

Task 

#

Task Description

1 Develop licensing criteria for greater than Class C (GTCC) disposal 

facility.

2 Consolidate LLRW guidance.3 D l id th t i di iti ti f l d Develop guidance that summarizes disposition options for low-end

materials and waste.

4 Coordinate with other agencies on consistency in regulating low activity 

t di l waste disposal.

5 Identify new waste streams.6 Develop information notice on waste minimization Develop information notice on waste minimization.

18
Background (continued)

Low Priority Activities Priority Activities

Task 

#

Task Description

1 Evaluate potential changes to LLRW regulatory program as a result of p g g yp g

severe curtailment of disposal capacity.

2 Promulgate rule for disposal of low-activity waste.3 Id tif d l t t ti l l i l ti h Identify and evaluate potential legislative changes.4 Implement major revisions to 10 CFR Part 61.5 Develop waste acceptance criteria for LLRW disposal in uranium mill 

tailings impoundments.

6 Examine need for guidance on defining when radioactive material 

becomes LLRW becomes LLRW.

7 Develop and implement national waste tracking system.

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Status of the Strategic 

Assessment• Strategic Assessment 7 high prioritized activities

√ Review and update guidance on Extended Storage√ Develop guidance on 10 CFR 20.2002 Alternate 

Disposal Requests

√

* Determine if disposal of large quantities of Depleted Determine if disposal of large quantities of Depleted

Uranium would change waste classification tables

 Update Branch Technical Position on Concentration 

Averaging and Encapsulation

 Develop guidance on alternate waste classification (10 

CFR 61 58

) CFR 61.58)

– Develop procedures for Import/Export Reviews– Perform sco

pin

g stud

y of the need to revise/ex

pand pg y p

byproduct material financial assurance 20

 = completed projects and 

* = current projects.
Proposed Updates to the 

Strategic Assessment Strategic Assessment

• Review 2007 Strategic Assessment and could 

reprioritize some of remaining activities

• Develop licensing criteria for greater than Class C 

disposal facility. disposal facility

• Perform scoping study of the need to revise/expand 

byproduct material financial assurance to account for life cycle cost

-cycle cost.

• Develop procedures for Import/Export Review.

21
Initial Scoping of the 

Update to the Strategic Update to the Strategic Update to the Strategic

Assessment

• Activities to consider include

• Licensing Criteria for GTCC• Low Activity Waste Rulemaking• Revision of the Waste Manifest • Waste Attribution Waste Attribution

22
Next Steps

• Information gathering• Federal Register Notice soliciting comments on 

proposed activities

• Request comment on draft updated Strategic 

Assessment

23
QUESTIONS?
NRC WORKSHOP ON THE STATUS OF NRC WORKSHOP ON THE STATUS OF

LOW-LEVEL RADIOACTIVE WASTE DISPOSAL 

RULEMAKING AND STRATEGIC ASSESSMENT OF 

LOW-LEVEL RADIOACTIVE WASTE REGULATORY 

PROGRAM

Chip Cameron Facilitator Chip Cameron, Facilitator

March 7, 2014

NRC Public Meeting

Phoenix, AZ
Introduction of Panelists

Brad Broussard Texas Commission on Environmental QualityEarl Fordham Washington Department of Health Earl Fordham Washington Department of HealthRusty Lundberg Utah Department of Environmental QualityRalph Andersen Nuclear Energy Institute Ralph Andersen Nuclear Energy InstituteWilliam Dornsife Waste Control SpecialistsDan Shrum EnergySolutions Dan ShrumChristine Gelles

U.S. Department of Energy-Environmental Management

Michael Garner Northwest Interstate Compact on Low-Level Radioactive Waste Management/State of Washington Gregory Sube

r U.S. Nuclear Regulatory Commission

26
Topics

• What changes are anticipated to the national landscape 

in the LLRW area in the context of safety security and in the LLRW area in the context of safety, security, and

the protection of the environment in the next 5-7 years?

• As a result of the new national landscape, what activities 

from the 2007 Strategic Assessment should remain on the list and are they appropriately prioritized in order to strengthen the NRC’s ability to ensure safe and secure g yLLRW disposal, improve the effectiveness of its regulations, and assure regulatory stability and predictability while allowing flexibility in disposal options? predictability while allowing flexibility in disposal options?

• As a result of the new national landscape, what 

additional changes are needed to the NRC regulatory framework? 27
Recap and Closing p 

Aby Mohseni, Deputy Director

Division of Waste Management and Environmental Protection

Office of Federal and State Materials and Environmental 

Management Programs

March 7, 2014

NRC Public Meeting

Phoenix, AZ
Insights From Insights From

Today

’s Workshop Today s Workshop
Next Steps

• Evaluate today’s comments• Additional Outreach efforts

• Expect proposed 10 CFR Part 61 rule p pp

issued for public comment in 2015

• Draft Strategic Assessment issued for Draft Strategic Assessment issued for

public comment in early 2015

30
QUESTIONS?