1. 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

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

3. 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

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

5. 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

6. Past NRC Activities Related to GTCC Waste Disposal
January 30, Texas request for clarification on Agreement State authority to regulate GTCC
July 17, SECY – Historical And Current Issues Related To Disposal Of Greater-Than-Class C Low-Level Radioactive Waste
December 22, SRM-SECY 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, SRM-SECY – GTCC regulatory basis due 6 months after publication of Part 61 supplemental proposed rule

7. Recent NRC Activities Related to GTCC Waste Disposal
February 14, 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

8. Future NRC Activities Related to GTCC Waste Disposal
~ 6 Mo
~ 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

9. 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. 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 Alternative Disposal Request Guidance entitled, “Guidance for the Reviews of Proposed Disposal Procedures and Transfers of Radioactive Material Under 10 CFR and 10 CFR 40.13(a)”
Final guidance issuance expected early 2019. 10

11. 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.

12. Questions?