STRATEGIC ASSESSMENT OF LOWLEVEL RADIOACTIVE WASTE 

REGULATORY PROGRAM

Gregory Suber, Chief

Low-Level Waste Branch

Division of Waste Management and Environmental Protection

Office of Federal and State Materials and Environmental 

Management Programs

July 8, 2014

NRC Public Webinar

Rockville, MD
Objective

To gather information on an update to the NRC’s 2007 

Strategic Assessment of the LLRW regulatory program 

from stakeholders and other interested members of the 

public.

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Agenda 

Tuesday, July 8, 2013

1:00 – 1:15 pm Introduction G. Suber (NRC)

1:15 – 1:30 pm Background on M. George (NRC)

 2007 Strategic Assessment

1:30 – 1:45 pm Specific Requests for Comments M. George (NRC)

1:45 – 3:45 pm Questions and Comments Public

3:45 – 4:00 pm Conclusion G. Suber (NRC)

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QUESTIONS?
BACKGROUND ON 2007 STRATEGIC 

ASSESSMENT OF LOW-LEVEL RADIOACTIVE 

WASTE REGULATORY PROGRAM

Matthews George

Low-Level Waste Branch

Division of Waste Management and Environmental Protection

Office of Federal and State Materials and Environmental Management 

Programs

July 8, 2014

NRC Public Webinar

Rockville, MD
Topics

• Background

• Status of the 2007 Strategic Assessment

• Proposed updates to the Strategic Assessment

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Background

Challenges and issues included:

• Desire of industry for greater flexibility and reliability in 

LLRW disposal options; 

• Increased storage of Class B and Class C LLRW; 

• Potential need to dispose of large quantities of power plant 

decommissioning waste and depleted uranium;

• LLRW program required greater resources than were 

available; 

• Increased security concerns; and 

• New waste streams that may be generated. 

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Background (cont...)

2007 Strategic Assessment of the NRC’s LLRW

regulatory program 

Goal:

• Identify 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. 

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Background (cont...)

• Variety of activities proposed

• List of 20 activities developed

• Priorities of high (7 tasks), medium (6 tasks), or low 

 (7 tasks) assigned

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Background (cont...)

High Priority Activities

Task 

#

Task Description

1 Review and update guidance on extended storage of LLRW.

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.

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Background (cont...)

Medium Priority Activities

Task 

#

Task Description

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

facility.

2 Consolidate LLRW guidance.

3 Develop guidance that summarizes disposition options for low-end 

materials and waste.

4 Coordinate with other agencies on consistency in regulating low activity 

waste disposal.

5 Identify new waste streams.

6 Develop information notice on waste minimization.

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Background (cont...)

Low Priority Activities

Task 

#

Task Description

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

severe curtailment of disposal capacity.

2 Promulgate rule for disposal of low-activity waste.

3 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.

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

√ * Determine if disposal of large quantities of Depleted Uranium would 

change waste classification tables

* Develop guidance on 10 CFR 20.2002 Alternate Disposal Requests

⃰ Update Branch Technical Position on Concentration Averaging and 

Encapsulation

⃰ Develop guidance on alternate waste classification (10 CFR 61.58)

- Develop procedures for Import/Export Reviews

- Perform scoping study of the need to revise/expand byproduct

 material financial assurance 

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 = completed projects and * = current projects 13
Proposed Updates to the 

Strategic Assessment

• Review 2007 Strategic Assessment and could 

reprioritize some of remaining activities, such as:

• Develop licensing criteria for greater than Class C 

disposal facility;

• Perform scoping study of the need to revise/expand 

byproduct material financial assurance to account for 

life-cycle cost; or 

• Develop procedures for Import/Export Review.

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March 7, 2014 Phoenix Workshop on 

Update to the Strategic Assessment

• Issues to consider include:

• Low-activity waste;

• Waste classification;

• Proposed 10 CFR Part 61 rulemaking;

• Clearance;

• Disposal capacity;

• Gap analysis;

• Greater than Class C waste;

• Waste manifest;

• New waste streams;

• Sealed sources; and 

• Waste attribution.

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SPECIFIC REQUESTS FOR COMMENTS

Matthews George

Low-Level Waste Branch

Division of Waste Management and Environmental Protection

Office of Federal and State Materials and Environmental Management 

Programs

July 8, 2014

NRC Public Webinar

Rockville, MD
Topics

• Current national LLRW disposal program 

• Current LLRW disposal regulatory system

• Update to the 2007 Strategic Assessment 

• Communication & cooperation 

• Factors to evaluate the proposed activities

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Specific Requests for Comments

• Current National LLRW Disposal Program:

– What changes anticipated in LLRW area may 

impact safety, security & protection of the 

environment?

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Specific Requests for Comments 

(cont...)

• Current LLRW Disposal Regulatory System:

1. What are the key safety concerns relative to LLRW disposal?

2. What improvements in the current regulatory approach toward LLRW disposal in 

the US would enhance the NRC’s ability to ensure safe & secure LLRW disposal? 

3. What actions could be taken by the NRC & other Federal and State authorities, as 

well as private industry to optimize the management of LLRW?

4. Are there additional actions that can/should be taken regarding specific issues? 

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Specific Requests for Comments 

(cont...)

• Update to the 2007 Strategic Assessment:

– What activities should remain, removed or added to the 

list of proposed activities developed in 2007 Strategic 

Assessment?

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Specific Requests for Comments 

(cont...)

• Communication & Cooperation 

1. What works well and not-so-well, domestically and/or 

internationally with regard to communicating with 

affected and interested stakeholders on the 

management of radioactive waste?

2. What specific actions can NRC take to improve 

coordination with other Federal agencies for a more 

consistent treatment of radioactive waste that possess 

similar or equivalent levels of biological hazards?

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Factors to Evaluate the Proposed 

Activities 

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• Impact to Strategic Goals (e.g., safety, security)

• Need (near, medium, or long terms)

• Resulting benefits

• Level of efforts (cost, resources)

• Potential disposal scenarios 
Factors to Evaluate the Proposed 

Activities (cont...)

• Potential Disposal Scenarios 

– When evaluating the proposed activities, the responsiveness to 

potential disposal scenarios will be considered. 

– The following three (3) revised disposal scenarios are proposed for 

incorporation in the updated Strategic Assessment

•“optimistic future” scenario: a continuous expansion of safe, 

secure disposal capacity for the entire spectrum of LLRW. 

•“realistic future” scenario: a clear path to disposal exist for Class 

A, B and C wastes.

• “pessimistic future” scenario: disposal capacity is constrained for 

LLRW in the not too distant future.

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QUESTIONS AND COMMENTS

July 8, 2014

NRC Public Webinar

Rockville, MD
CONCLUSION

Gregory Suber, Chief

Low-Level Waste Branch

Division of Waste Management and Environmental Protection

Office of Federal and State Materials and Environmental 

Management Programs

July 8, 2014

NRC Public Webinar

Rockville, MD
Next Steps

• Information gathering

• Federal Register Notice soliciting comments on 

proposed activities, 

– Comment period closes on September 15, 2014

• Request comment on draft updated Strategic 

Assessment in 2015

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Contact Information

• Information available at NRC website:

– http://www.nrc.gov/waste/llw-disposal/llw-pa/llw-strategicassessment.html

• Written comments to www.regulations.gov under Docket ID NRC2014-0080

• Points of Contact:

– Melanie Wong

(301) 415-2432, Melanie.Wong@nrc.gov

– Mathews George

(301) 415-7065, Mathews.George@nrc.gov

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