Overview of NRC Low-Level Waste Activities and Initiatives John Tappert, Director Division of Decommissioning, Uranium Recovery and Waste Programs (DUWP) Office of Nuclear Material Safety and Safeguards (NMSS) U.S. Nuclear Regulatory Commission LLW Spring Forum Meeting April 16, 2018 San Francisco, California

Objective To provide an overview of the NRC’s Low-Level Radioactive Waste (LLW) Program and status of its activities

Outline Management Changes Status of 10 CFR Part 61 Rulemaking Greater-Than Class C (GTCC) Regulatory Basis 10 CFR 20.2002 Alternative Disposal Request Guidance Uniform Waste Manifest

Management Changes Marc Dapas, Director, NMSS (June 2016) John Tappert, Director, DUWP (January 2016) Michele Sampson, Deputy Director, DUWP (February 2018) Maria Arribas-Colon, Acting Chief, LLW Branch (January 2018)

Status of 10 CFR Part 61 Rulemaking Commission Approved Proposed Rule Proposed Rule and Associated Draft Guidance Issued Draft Final Rule to Commission SECY-16-0106: ML16188A290 Commission Issues Staff Requirements Memorandum SRM-SECY-16-0106: ML17251B147 2/12/14 3/26/15 9/15/16 9/8/17

SRM-SECY-16-0106 Staff Requirements Memorandum (SRM) SECY-16-0106 – Final Rule: Low-Level Radioactive Waste Disposal The Commission directed the staff to make substantive revisions and republish as a supplemental proposed rule

SRM-SECY-16-0106 Allow case-by-case application of new requirements Major Changes Allow case-by-case application of new requirements Reinstate 1,000 year compliance period Clarify safety case definition Narrow defense-in-depth considerations Be informed by costs and benefits 7

Greater-Than Class C (GTCC) Regulatory Basis In 2014, Waste Control Specialist LLC (WCS) filed a Petition for Rulemaking with the State of Texas to allow WCS to dispose of GTCC and GTCC-like waste (including transuranic waste). In 2015, the Texas Commission on Environmental Quality asked the NRC questions on the State's authority to license a disposal cell for GTCC, GTCC-like, and transuranic waste. Sealed Sources Reactor Vessels

Staff Analysis In SECY-15-0094, the staff conducted an analysis of the questions Texas posed and developed three options for Commission consideration.

Commission Direction SRM-SECY-15-0094 provided direction to the staff. Specific elements include: Develop regulatory basis for disposal of GTCC and transuranic waste Determine hazards Hold public workshops Note case-by-case review available Address transuranic waste definition in 10 CFR 61.2 lease

Commission Direction (Cont.) SRM-SECY-16-0106 changed due date to 6 months after publication of the Part 61 supplemental proposed rule. 11

Public Outreach Efforts February 22, 2018 Public Meeting in Rockville, Maryland and Webinar Federal Register Notice to Conduct GTCC and Transuranic Waste Scoping Meeting and Request for Comment (83 FR 6475): Feb. 14, 2018 March 23, 2018 Public Meeting in Phoenix, Arizona and Webinar

Draft Technical Analysis ADAMS Accession No. ML17362A012 Assist in the identification of potential hazards, for example, Inventories Security Assist public to respond to NRC staff questions

Three Questions What are the important radionuclides that need to be considered for the disposal of the GTCC and transuranic wastes? How might GTCC and transuranic wastes affect the safety and security of a disposal facility during operations (i.e., pre-closure period)? How might GTCC and transuranic wastes affect disposal facility design for post- closure safety including protection of an inadvertent intruder?

How to Provide Comments Federal Register notice provides various methods of submitting comments: Federal Rulemaking Website: Go to http://www.regulations.gov and search for Docket ID NRC-2017-0081 Email comments: Rulemaking.Comments@nrc.gov Fax comments: 301-415-1101 Mail comments to: Secretary, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, ATTN: Rulemakings and Adjudications Staff Hand deliver comments: 11555 Rockville Pike, Rockville, Maryland 20852, between 7:30 a.m. and 4:15 p.m. (EST) Federal workdays; telephone: 301-415-1677. Comment period ends Today

For Additional Information Federal Rulemaking Website: Go to http://www.regulations and search for Docket ID (NRC-2017-0081) NRC’s GTCC Public Web Site: https://www.nrc.gov/waste/llw-disposal/llw-pa/gtcc-transuranic-waste-disposal.html NRC Contact: Cardelia Maupin – Sr. Project Manager 301-415-4127; Cardelia.Maupin@nrc.gov

10 CFR 20.2002 Alternative Disposal Request Guidance Purpose of revising draft guidance Provides more clarity, consistency, and transparency Clarifies the NRC’s position regarding disposal, including reuse and recycling NRC issued for public comment a revision of its 20.2002 Alternative Disposal Request Guidance entitled, “Guidance for the Reviews of Proposed Disposal Procedures and Transfers of Radioactive Material Under 10 CFR 20.2002 and 10 CFR 40.13(a)” Final guidance issuance expected 2018 17

Uniform Waste Manifest 10 CFR Part 20 Appendix G requires that an NRC Uniform Waste Manifest (UWM) be prepared for waste intended for ultimate disposal at a licensed LLW land disposal facility. Staff identified necessary changes to UWM and NUREG/BR-0204. Work is ongoing and a draft for comment is planned for Summer 2018.

Questions?