ML23130A189

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Slides to Support Integrated Low-Level Radioactive Waste Disposal Rulemaking Public Meeting
ML23130A189
Person / Time
Issue date: 05/17/2023
From: George Tartal
NRC/NMSS/DREFS/MRPB
To:
References
RIN 3150-AI92
Download: ML23130A189 (38)
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Text

Public Meeting:

Regulatory Concepts for Integrated Low Level Radioactive Waste Disposal Rulemaking May 17, 2023 ADAMS Accession No. ML23130A189

Purpose

  • Describe the staffs preliminary direction on regulatory concepts associated with the Integrated Low Level Radioactive Waste Disposal rulemaking
  • Obtain feedback from members of the public
  • No formal comments collected during this meeting - rather we will describe future opportunities to submit comments 2

Agenda Welcome and logistics Opening remarks Rulemaking background Safety case and technical assessments Timeframes (compliance period)

Waste acceptance

[BREAK]

Agreement State matters Operational safety and criticality for GTCC waste Exception criteria and significant quantities Implementation guidance Next steps Closing remarks 3

Logistics

  • This meeting is being recorded
  • When prompted for questions and discussion, please indicate your desire to speak by using the Raise Hand button in Teams (or press *5 if participating by phone)
  • Once your name has been called by the facilitator, you will need to unmute yourself (press *6 if participating by phone)
  • Chat feature is also enabled
  • Presentation slides shown on the Microsoft Teams screen and in ADAMS at ML23130A189
  • Phone attendees should e-mail george.tartal@nrc.gov for attendance record 4

Opening Remarks Jeremy Groom Deputy Director Division of Decommissioning, Uranium Recovery, and Waste Programs (DUWP)

Office of Nuclear Material Safety and Safeguards (NMSS) 5

Low-Level Waste and Transuranic Waste 6

Class B

Class A

Class C

GTCC Trans-uranic Waste LLW

Challenges to the Current Regulatory Framework in 10 CFR Part 61 7

1982 Assumption Current Practice Waste hazard to inadvertent intruder duration Class A and B: 100 years Class C: 500 years Some defaulted Class A wastes are being disposed of in greater quantities than assumed and could cause hazards past these periods (e.g., Depleted Uranium (DU))

Only DOE enriches uranium DU only commercially available in small quantities Private sector enrichment facilities Average disposed waste concentration expected to be well below Class limit Blended wastes create wastes much closer to Class limit and may be disposed in large amounts together Greater-than-Class-C (GTCC) waste disposal in geologic repository or by Commission approval Considering near-surface disposal (in top 30 m) for certain GTCC waste streams

Prior Rulemaking Efforts

  • LLW Disposal rulemaking to address waste streams that differ significantly in quantity and concentration from what Part 61 originally assumed
  • Regulatory basis for the disposal of Greater-than-Class-C (GTCC) waste through means other than deep geological disposal.
  • In 2019 the NRC issued the draft regulatory basis for public comment.
  • The regulatory basis concluded that most of the GTCC waste streams are potentially suitable for near-surface disposal.

8

9

  • Combine the Part 61 and GTCC efforts to address overlapping technical requirements, streamline stakeholder outreach, and gain efficiency in proceeding as one rulemaking activity (SECY-20-0098)
  • Commission issued Staff Requirements Memorandum (SRM-SECY-20-0098) on April 5, 2022 Commission Directions

Integrating the LLW Rulemakings 10 Integrated Low-Level Radioactive Waste Disposal Rulemaking Site-Specific Analyses NRC is preparing an integrated rulemaking to:

Consolidate and integrate criteria for GTCC and 10 CFR Part 61 rulemaking Conduct site-specific analyses for all waste streams including DU and GTCC waste Include graded approach for compliance period Include TRU waste in the definition of LLW Address physical protection and criticality concerns in GTCC waste streams Provide for Agreement State licensing of certain GTCC waste streams

Safety Case and Technical Assessments

  • Safety Case

Widely recognized internationally

Original Part 61 has many elements

Useful to stakeholders to better understand basis for decisions

  • Technical Analyses (61.13)

Performance assessment (not new - renamed)

Intruder assessment (new)

Site stability assessment (new for significant quantities of long-lived)

Operational safety assessment (for some types of GTCC waste)

Performance period analyses (for significant quantities of long-lived) 11

Safety Case

  • A high-level summary of the information and analyses that support the demonstration that the land disposal facility will be constructed and operated safely - think executive summary.
  • Provides reasonable assurance that the disposal site will be capable of isolating waste and limiting releases to the environment.
  • Describes the strength and reliability of the technical analyses.

12

13 Performance Assessment

  • The technical analyses completed for existing sites for the potential impacts to an offsite member of the public are considered synonymous with a modern performance assessment
  • Understanding, tools, and capabilities have improved significantly since the early 1980s
  • Significant guidance developed to support the proposed requirements for performance assessment (e.g., FEPs, uncertainty, model support)

14 Performance Assessment - Guidance Example

15 Intruder Assessment

  • The basis for 61.55 in the current regulation is an NRC intruder assessment
  • Revised requirements would allow for a site-specific intruder assessment This is a flexible and risk-informed approach

16 Site Stability Assessment

  • Most problems with early disposal sites arose from short-term stability issues
  • Those problems were addressed through design and site characteristic requirements
  • Disposal of significant quantities of long-lived radionuclides may require long-term stability assessment

- Addressed in the context of 61.41 and 61.42

17 Operational Safety Assessment

  • Operational safety (61.43) is typically achieved through a combination of systems, procedures, controls, and training
  • Accidents scenarios were evaluated by NRC when 10 CFR 61 was developed
  • Some GTCC waste may contain sufficient radioactivity that an operational safety assessment may be necessary

18 Performance Period Analyses

  • Performance period only applies if significant quantities of long-lived radionuclides will be disposed
  • Expected proposed standard is to reduce exposures to the extent reasonably achievable
  • Provide transparency to stakeholders on the expected long-term performance of the disposal system
  • Long-term results not a measure of projected human health impacts

19 Safety and Compliance

  • Safety can be achieved through different means:

- Disposal concept

- Prescriptive design

- Technical analyses

  • Proposed approach leans more heavily on technical analyses to afford greater flexibility

20

  • Commission direction has two options
  • Peak dose or
  • Use different compliance periods depending on the long-lived component of the waste
  • Staff is considering the latter option - flexible and site-specific
  • Compliance period of 1,000 years without significant quantities of long-lived radionuclides otherwise 10,000 years and performance period Timeframes (Compliance Period)

21 Timeframes (Compliance Period)

  • Carefully examined comments on this issue
  • Primary consideration is current practices by Agreement States (AS)

Compatibility class will likely allow the AS to be more restrictive

  • Considered what has been done in the US and internationally

22 Timeframes (Compliance Period)

Uncertainties in societal and environmental conditions will increase over time Regulatory approval to allow disposal needs to evaluate impacts, recognizing the uncertainty - not stop the analysis Other approaches could be used to mitigate uncertainties:

Require deep geologic disposal (i.e., Germany)

Place restrictions on long-lived radionuclides appropriate for near-surface disposal

Use design requirements (e.g., 10+ m disposal depth for large quantities of depleted uranium)

23 Timeframes (Compliance Period)

DRAFT

24 Timeframes (Compliance Period)

Class A DRAFT

Waste Acceptance

  • Site-Specific Waste Acceptance Criteria (WAC) (§ 61.58)
  • Use §61.55 limits or results of

§61.13 technical analyses

  • Licensees review their waste acceptance program annually
  • If approved, incorporated into license 25

Preliminary Regulatory Concepts and Requirements

  • Quantities greater than critical mass
  • Long-lived transuranic (>10,000 pCi/g)
  • GTCC-like waste (government owned or generated)

- DOE has authority for disposal in federal or commercial facility

- Agreement State licensed facility subject to some regulations appropriate to other waste 26

Criticality Protection

  • Critical mass quantity (prior to disposal)

- Waste in concentrations of fissile material that cannot go critical

- Exemption from fissile material classification specified at 10 CFR 71.15(c)

  • Significant amount of fissile material in a disposal unit (after disposal)

- Identify design features for limiting potential for reconcentration of fissile material, as appropriate 27

Physical Protection

- Account for very dilute waste not mechanically separable (i.e.,

limited attractiveness)

- Exemption for waste at a low-level waste disposal facility specified at 10 CFR 73.67(b)

- Consistent with IAEA and DOE approaches

- Part 20 Subpart I Storage and Control of Licensed Material

- Part 37 Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material (16 specific radionuclides) 28

Exception Criteria

  • § 61.1 (b) (Purpose and scope)

- Exception criteria

  • the land disposal facility license was originally issued before the effective date of this rule
  • the licensee does not accept a significant quantity of long-lived radionuclides after the effective date of this rule
  • Licensees who meet these exceptions do not need to comply with revised Technical Analyses (§ 61.13), revised Performance Objectives (§ 61.41 and § 61.42), and WAC

(§61.58) 29

What are Significant Quantities?

  • Definition in § 61.2

- Significant quantities of long-lived radionuclides means an amount (volume or mass) and concentration accepted for disposal after the

[effective date of this rule] that could, if released, result in the performance objectives of subpart C of this part not being met.

  • Amount for selection of compliance period (1,000 or 10,000 years)
  • Amount for demonstrating meeting exception criteria
  • For the purposes of this paragraph, less than 10 metric tons of depleted uranium is not considered a significant quantity of long-lived radionuclides.

30

Significant Quantities

  • Site-specific calculations to determine what amounts are significant

- Though a simple approach is preferred, to properly account for the multiple key factors a more complex approach could be needed

- Determined by licensee and approved by regulators

- Table of concentrations of long-lived radionuclides for potential use as generic screening values 31

Implementation Guidance

- Flowcharts, NRC staff recommendations, and examples for how licensees can develop high-quality technical analyses

- Guidelines for what licensees or applicants should include and what regulators should review for each type of analysis

- Suggested references, screening tools, and case studies 32

Implementation Guidance

  • Draft in 2015 for public comment
  • Draft final version of guidance published in 2016 on NRC Part 61 website
  • Updates for Revision 1

- Appendix for GTCC waste disposal considerations

- Appendix for approach to calculate significant quantities of long-lived radionuclides

- Revisions based on proposed rule language 33

Next Steps

  • Deliver proposed rule to the Commission

- Public comment period after Commission approval

  • Other conferences/symposia/etc.
  • Deliver final rule to the Commission 34

Where to Find Information 35 Go to https://www.regulations.gov and search for docket ID NRC-2011-0012

George Tartal george.tartal@nrc.gov 301-415-0016 Priya Yadav priya.yadav@nrc.gov 301-415-6667 Cardelia Maupin cardelia.maupin@nrc.gov 301-415-4127 36 Contacts

Abbreviations, Acronyms and Initialisms ADAMS Agencywide Documents Access and Management System AS Agreement States CFR Code of Federal Regulations DOE Department of Energy DU Depleted Uranium FEP Features, Events and Processes FRN Federal Register Notice GTCC Greater Than Class C IAEA International Atomic Energy Agency ILW Intermediate Level Waste LLW Low Level Waste MD Management Directive NEI Nuclear Energy Institute NRC Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation PRM Petition for Rulemaking SECY Document from the NRC staff to inform or seek decision from the Commission SRM Staff Requirements Memorandum TRU Transuranic Waste WAC Waste Acceptance Criteria 37

How did we do?

  • The public meeting feedback form can be accessed on the meeting details page:

https://www.nrc.gov/pmns/mtg?do=details&Code=20230463 38

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