Overview of NRC Low-Level Radioactive Waste Activities and Initiatives Andrea Kock, Deputy Director Division of Decommissioning, Uranium Recovery and Waste Programs (DUWP) Office of Nuclear Material Safety and Safeguards (NMSS) U.S. Nuclear Regulatory Commission LLW Fall Forum Meeting October 3, 2018 Richland, Washington

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

Division Re-Organization Division of Decommissioning, Uranium Recovery, and Waste Programs (DUWP) John Tappert Andrea Kock Reactor Decommissioning Branch (RDB) Bruce Watson Risk and Technical Analysis Branch (RTAB) Chris McKenney Uranium Recovery and Materials Decommissioning Branch (URMDB) Bill Von Till Low-Level Waste and Projects Branch (LLWPB) Stephen Koenick

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

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 5

Past NRC Activities Related to GTCC Waste Disposal January 30, 2015 - Texas request for clarification on Agreement State authority to regulate GTCC July 17, 2015 - SECY-15-0094 – Historical And Current Issues Related To Disposal Of Greater-Than-Class C Low-Level Radioactive Waste December 22, 2015 - SRM-SECY-15-0094 - prepare a regulatory basis for the disposal of GTCC waste through means other than deep geologic disposal March 9, 2016 – NRC sent response to the Texas inquiry. Response describes the development of the regulatory basis September 8, 2017 - SRM-SECY-16-0106 – GTCC regulatory basis due 6 months after publication of Part 61 supplemental proposed rule

Recent NRC Activities Related to GTCC Waste Disposal February 14, 2018 - Issued Federal Register Notice requesting stakeholder participation and involvement in identifying the various technical issues that should be considered in the development of the regulatory basis Review Public Comments in response to February 14, 2018 FRN (83 FR 6475) including draft “NRC Staff Analyses Identifying Potential Issues Associated with the Disposal of Greater-Than-Class C Low-Level Radioactive Waste,” Comment period ended on April 16, 2018 Two Public Meetings with webinars (February and March of 2018) Revising Draft Technical Analysis (ADAMS Accession No. ML17362A012) 7

Future NRC Activities Related to GTCC Waste Disposal ~ 6 Mo ~ 1 -2 Mo Final GTCC Regulatory Basis ~ 1 Mo Public Workshops on GTCC and Part 61 Publish Draft GTCC Regulatory Basis ~ 5 Mo Publish Part 61 Supplemental Proposal Rule Resolve how the “grandfather provision” should be applied 8

Possibility of needing to substantially revise final regulatory basis Relationship Between Part 61 Rulemaking and GTCC Regulatory Basis Regulatory basis analyzes GTCC disposal within the framework of Part 61 requirements to identify any potential safety and security gaps Clarity on the regulatory framework under which the GTCC regulatory basis is developed will ensure appropriate assumptions and analyses Multiple issues in drafting two separate rules in one 10 CFR Part at same time Possibility of needing to substantially revise final regulatory basis Ensuring consistency of rule language changes OMB scheduling impacts 9

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 the final draft 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 early 2019. 10

Uniform Waste Manifest 10 CFR Part 20 Appendix G requires that an NRC 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. Draft for comment planned for Fall 2018.

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