Industry Input on NRC’s Low-Level Waste Program Strategic Assessment Janet Schlueter Senior Director, Fuel and Materials Safety Low-Level Waste Forum Meeting October 2014 • Denver

Industry is Involved In the Past: Most Recently: 2007 – Industry support for and input to original LLWP strategic assessment by NRC Since 2007 – Industry engagement and input to NRC on specific issues, e.g., DU Most Recently: March 2014 – Industry participation in NRC workshop in Phoenix annual meeting September 2014 – NEI letter to NRC builds on workshop and is subject of this presentation

Industry Supports NRC’s Objective “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 LLRW management system.” Industry fully supports NRC’s objective and offers the following suggestions regarding previously and newly identified priority activities.

Complete Existing Activities The following activities arose from the 2007 strategic assessment, are in progress and should retain the priority and associated resources needed for timely completion; notwithstanding new priority activities. These activities include: Revision to the Branch Technical Position on Concentration Averaging and Encapsulation Limited Part 61 Rulemaking (Site-Specific Analysis) Regulatory Issue Summary on Reporting on the Uniform Waste Manifest (H-3; C-14; Tc-99; I-129)

Suggested High Priority Activities Industry suggests that 4 activities be identified in the current assessment update as High Priority: 1. Disposition of Very Low-Level Waste Rulemaking consistent with international standards and reflecting domestic Federal and State experience Coordinated Federal and State actions to allow for disposal of VLLW at hazardous waste sites, etc. Guidance on acceptable alternative disposal options

Suggested High Priority Activities (continued) 2. Revisions to Regulatory Guidance on LLRW tracking and reporting (RG 1.21, NUREG BR-0204) Agency alignment to clarify LLRW attributions and conditions under which radioactive material is classified as LLRW Result: Enhanced efficiency and consistency in LLRW processing and allow use of DOE information system to comply with NRC reporting requirements

Suggested High Priority Activities (continued) 3. Rulemaking to the Part 61 Waste Classification Tables Updated to reflect more current technical basis consistent with ICRP 103 Updating the criteria to reflect contemporary radiation dosimetry would enhance risk-informed underpinnings of rule, improve transparency, and achieve greater consistency with international standards; leverage Part 20 rulemaking insights

Suggested High Priority Activities (continued) 4. Rulemaking to create regulatory framework for licensing disposal of Greater-Than-Class-C waste Presently stored safely and securely in absence of disposal option Expect DOE to issue its proposed plans in near future and one existing disposal site is assessing possible disposal Simultaneously, NRC should update its waste classification tables.

In Summary Industry appreciates the opportunity to participate in the NRC’s effort to update its LLRW Program Strategic Assessment We look forward to being informed by further discussions with stakeholders such as the LLW Forum members and others