RadWaste Vol. 8 No. 38
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RadWaste Monitor
Article 5 of 7
October 09, 2015

Q&A: Former NRC Official Talks LLW Issues

By Jeremy Dillon

Jeremy L. Dillon
RW Monitor
10/9/2015

After over 25 years of government service,  Larry Camper, director of the Nuclear Regulatory Commission’s Division of Decommissioning, Uranium Recovery, and Waste Programs, retired last week. Under Camper’s direction the NRC office has undertaken many low-level radioactive waste rulemakings, including an update to the 10.CFR.61 rulemaking, the issuance of the branch technical position, and now the issue of Greater Than Class C licensing. Andrew Persinko, the division’s deputy director, will serve as acting director.

Camper sat down with RW Monitor this week at the Nuclear Decommissioning and Used Fuel Strategy Summit in Charlotte to discuss some of the larger LLW issues facing the commission, as well as some of the changes at the NRC over his time there.

What would say are the biggest issues facing the low-level waste community?

I think the biggest issues are clearly Greater Than Class C waste—what will the commission decide to do in regards to the jurisdictional question that was raised by [Waste Control Specialists] and then Texas to the NRC? I think that the completion of the Part 61 rulemaking that will address disposal of large quantities of depleted uranium and other long-lived radionuclides that were not included at the time of the Part 61 rulemaking is also very important.

Now that you have left NRC, where do you think those issues are heading, or what would you advise the commission to direct those issues?

Let’s take GTCC first, the staff recommended in our recent commission paper and in a briefing that option No. 2 that the state of Texas could be allowed to license the disposal of GTCC. We made that recommendation after careful consideration and discussion with the Office of General Counsel, and we believed that it is the most efficient and effective way to handle that issue. I certainly hope that the commission will agree with the Staff recommendation.

Also, equally as important, we recommended that there needs to be a rulemaking to address TRU waste greater than 100 nanocuries per gram. At the moment, there is no regulatory pathway for the disposal of commercial TRU waste in excess of those nanoncuries. That’s a problem, and we need to fix that. So, I hope the Commission will take the Staff’s recommendation for a rulemaking to fix that issue.

Should that be put into the current Part 61 rule update that is ongoing?

That’s a challenging question, and there’s two ways to look at that. On one hand, the commission has shown a great deal of interest in seeing this rulemaking brought to closure as expeditiously as possible because it does address the disposal, potentially, of large quantities of depleted uranium. On the other hand, another way to look at it is, you have a rulemaking vehicle at your disposal, which could be reopened to address the TRU waste issues, and perhaps to that matter, to address any need that is perceived by the commission with regard to a standard GTCC waste disposal.

Do you have preference for which direction to take, or are you going to leave it as a policy decision for the commission to decide?

Well, it’s clearly a policy decision. There is no question about that. I could probably make an argument for either way. On one hand, having worked with the staff for a number of years to get the proposed rule out there, I would certainly like to see it brought to closure. Sometimes the best way to eat an elephant is one bite at a time. It would be nice to get something completed and done.

On the other hand, resources are precious. Rulemaking resources are valuable, and I can see the merit of opening this rulemaking again and addressing these issues at this time. One could argue from an efficiency standpoint that makes more sense. And there’s a lot of people who want to see certainty and see all this Part 61 rulemaking come to a closure addressing all these issues. I can make an argument either way.

What are some of the biggest changes you have seen over your time at NRC?

I would say the biggest changes that I have seen is much more, active participation by the commission in its direction to the staff. Staff Requirement Memoranda are longer and more detailed than they used to be many, many years ago. And commission vote sheets are considerably more detailed than they used to be. That translates into a much more active commission, and a commission that is willing to express these in-depth views to the staff. That’s the biggest change.

The second change that I have seen is the nature and the extent of stakeholder involvement. Both from the stakeholders themselves, their desire to be involved, their desire to influence the process, and from the agency standpoint, in terms of the steps and efforts it makes to reach out to stakeholders. Huge change compared to all those years ago.

Both good things?

I think they are good things. Yes I do. I mean, the commission’s active involvement shows that the commission is doing what they were appointed by the president to do. They are actively engaged in policy creation. That is a positive.

Stakeholder interaction is a good thing because being in many, many public meetings and hearing a lot of stakeholder input, frankly, there are times when you get valuable input that can and should influence a policy outcome. That’s part of the process. That’s the way it is supposed to work. So, yes, it’s a good thing.

What’s one thing you want the commission to tackle that hasn’t been addressed yet?

We in the United States need to have a de minimis quantity standard. Exempt waste, if you will.  The [International Atomic Energy Agency] approach includes at the low end exempt waste. I think we would be well served by having an exempt waste standard. Whether that’s at the lowest end of the Class A waste for example, or whatever that number is, we need to recognize that the risk that is not there should also drive to some degree the regulatory program that is brought to bear.

The commission has tried a couple of times. One time we looked at what’s was called below regulatory concern, but that did not work out. Back in 2005-2006, the staff was working on another clearance rule. It was delayed and tabled by the commission at the time due to higher priority issues such as security in a post-9/11 environment. But at some point, I think we should get back to it and figure out what to do on this point.

Anything else you would like to say about your time at NRC?

I can’t say enough about the value and the enjoyment I had from working for the Nuclear Regulatory Commission. The staff is superb. It’s a great place to work. I enjoyed working with the commission. And I’m extremely fond of being an NRC alumnus. 

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