Jeremy L. Dillon
RW Monitor
5/16/2014
The Nuclear Regulatory Commission’s Low-Level Radioactive Waste Program is soliciting public comment on a new update to its 2007 Strategic Assessment to address developments in the national program for LLRW disposal as well as changes in the regulatory environment since it originally formed its assessment, according to a notice this week. The original 2007 Strategic Assessment included 20 activities with various priority levels that would respond to changes in the regulatory environment, including updating guidance for LLRW storage, and evaluating the disposal of depleted uranium and the measures needed to ensure its safe disposal. According to the notice, though, the program continues to evolve so the NRC is seeking comment to update the assessment. “In order to set the direction for the NRC’s LLRW regulatory program in the next several years, the NRC staff will begin developing an updated Strategic Assessment of the NRC’s LLRW program,” the Federal Register notice said. “As part of that effort, the staff is proposing to revise the alternative future disposal scenarios specified in the 2007 Strategic Assessment. The new assessment will provide opportunities for stakeholder engagement. The objectives of this updated Strategic Assessment remain the same as the 2007 Strategic Assessment; i.e., to identify and prioritize activities that the staff can undertake to ensure a stable, reliable and adaptable regulatory framework for effective LLRW management, while also considering future needs and changes that may occur in the nation’s commercial LLRW management system.” Public comments are due by July 14.
Among the topics that the NRC is seeking public comment on is to help determine if the disposal scenario assumptions on the future of waste disposal should be changed or updated. The NRC lists three scenarios for the future of disposal: optimistic, realistic, and pessimistic. The optimistic scenario says that all aspects of the management of waste from the back end of the fuel cycle are continuously available with some limited competition in disposal costs that are reasonable. In the realistic scenario, NRC indicates that Class A, B, and C LLRW have clear paths forward for disposal, while disposal options for low-activity waste are few, and approvals continue to be on a case-by-case basis that takes significant time to obtain approval. Greater-than-class C waste, mainly sealed sources, begin moving from the commercial sector to the Department of Energy, but a GGTC disposal facility is still years away. The pessimistic scenario says that disposal capacity for all types of LLRW is severely constrained and costs of disposal are prohibitively high for many generators leading to large increases long-term storage. GGTC disposal facility has no prospects, and public and industry confidence in regulations erode.
The NRC has already begun to seek stakeholder comments on the Strategic Assessment update via a workshop held in Phoenix in March. The main topic of discussion during that workshop was the growing issue of Greater-than-class C disposal. Members of a panel made of up of government and industry officials recommended a gap analysis of the current regulatory framework for low-level radioactive waste, especially when considering the 10.CFR.61 rule update underway at the NRC and its ramifications on site-specific waste acceptance criteria for waste like GGTC. Some argued during this workshop that the classification table for LLRW was antiquated in the face of site-specific waste acceptance criteria.
