1. IAEA International Atomic Energy Agency Presenter Name School of Drafting Regulations for Borehole Disposal of DSRS 2016 Vienna, Austria Waste Acceptance Criteria

2. IAEA Outline of the Presentation Presentation resouces Overview of Waste Acceptance Regulations (WAC) So what are waste acceptance criteria? Definition and Theory; Chicken or the Egg Common WAC’s, Characterization & Testing Non-compliant (with WAC) packages; Packages with Cat I/II quantities of material; WAC’s from South Africa and Washington; Summary and conclusions. 2

3. IAEA Presentation Resources Borehole Disposal Facilities for Radioactive Waste – Specific Safety Guide; IAEA Safety Standards Series No. SSG-1, IAEA Vienna (2009). BOSS: Borehole Disposal of Disused Sealed Sources – A Technical Manual, IAEA-TECDOC-1644, Vienna (2011). International Atomic Energy Agency, Categorization of Radioactive Sources, IAEA Safety Standards Series No. RS-G-1.9, IAEA, Vienna (2005). 3

4. IAEA Regulatory Framework Basis in national statues May be based upon IAEA documents Many countries have national regulations for LLW disposal Protection of the public and the environment Examples of typical regulations governing licensing: Public dose Worker dose – conditioning/hot cell Training Isotope limits due to site safety assessment 4

5. IAEA Waste Acceptance Criteria Definition of waste acceptance criteria Technical and administrative requirements that a waste must meet in order for it to be accepted at a treatment, storage, or disposal facility. Source: USDOE’s Draft Environmental Impact Statement for the Disposal of Greater-Than-Class C (GTCC) Low-Level Radioactive Waste and GTCC- Like Waste (DOE/EIS-0375-D, Volume 1) February 2011. 5

6. IAEA Waste Acceptance Criteria General theory behind waste acceptance criteria A key component of the collection of limits, controls and conditions to be applied by the operator is the waste acceptance criteria (WAC). No waste package can be accepted for disposal unless it is compliant with the WAC, which aim to ensure that waste packages are consistent with the safety case, especially the safety assessments for transport, predisposal operations, disposal operations and post-closure. Generally developed by the operator and approved by the regulatory body. 6

7. IAEA Waste Acceptance Criteria Which comes first: the WAC or the Site Safety Case (The proverbial question: which comes first, the chicken or the egg?) Without a disposal facility safety case, how can you determine the waste acceptance criteria. Rarely a problem; many member states are conditioning waste, including SRS, without a disposal facility. Prevents an over-restrictive WAC; drives the WAC to be more inclusive of waste streams and packaging. Caution, however, is required by operator who packages waste before the adoption of WAC and associated management regime. For a small number of waste packages that cannot be accepted for disposal, repackaging may be an option. 7

8. IAEA Common WAC’s Site and borehole activity limits; Weight & physical size of waste packages; If allowed, gas release rates; Waste container specs (materials, size, testing); Only specific encapsulation materials; Solids only (physical form limitation); Radionuclide content (isotope), fissile content (gms), total activity, surface radiation level; Stable chemical and physical properties; Management systems for characterization, packaging, handling and storage. 8

9. IAEA Characterization and Testing If WAC exist, then waste needs to be characterized; Models are used to verify waste is compliant with the waste acceptance criteria (WAC). Waste packages are commonly tested for physical and chemical stability under disposal conditions in a laboratory simulation. Lab tests of packages can also simulate accident scenarios; Well known materials (e.g., 316 SS, Ordinary Portland cement) may have relevant information already available via internet search. 9

10. IAEA Packages not compliant with WAC Written procedures need to be in-place for packages that are not compliant with the WAC; Depending on the severity of the non-conformance, the actions may range from: verbal notification to the generator/waste packager and remediation at the borehole disposal facility (i.e., don’t put waste back on the road unnecessarily) to Enforced shutdown of the production process for waste packages and a suspension of shipping privileges. Notify regulatory body of significant non- conformances (e.g., other than manifest corrections). 10

11. IAEA Category I and II SRS Sealed sources containing Cat I/II quantities of radionuclides should not be disposed of in near surface boreholes unless: Additional physical or administrative controls in place to prevent or reduce the likelihood of intrusion and/or Controls can mitigate the consequences of the intrusion. Otherwise, intermediate depth disposal should be considered. Category I and II radionuclides of particular concern have longer half-lives, such as Sr-90, Cs-137, Pu-238 and Am-241 11

12. IAEA S.A. Waste Acceptance Criteria Generic Waste Acceptance Criteria Early work in South Africa, 10 years ago WAC sets the boundaries for the Generic Safety Assessment WAC may be based upon conditioning equipment Limit operator doses South African ex: 4 x 10 10 Bq Co-60 for conditioning unit 4 x10 13 Bq Co-60 for BOSS hot cell If willing to perform the work, site specific waste acceptance criteria can be generated. Hanford’s central burial ground compared to US Nuclear Regulatory Commission limits in regulation 12

13. IAEA S.A. Waste Acceptance Criteria Generic Conditions include: Maximum activity for either disposal site or conditioning unit. Source – documentation traceability Physical size (fit inside the capsules) Maximum heat generation: 50W Leaking sources are acceptable if meet all other conditions Sealed gas and liquid sources ok if they meet the WAC Conditioned in a capsule; containerized in a disposal drum 13

14. IAEA S.A. Waste Acceptance Criteria Generic Conditions include: Approved procedures followed Capsules and containers manufactured from stainless steel per QA plan. Multiple SRS can be placed in one capsule so long as sum- of-fractions <1 Site inventory limits Entire site or by groups of boreholes Source of waste (e.g., WIPP must be defense-related) 14

15. IAEA Waste Acceptance Criteria Generic Conditions from Washington (USA) Waste (SRS) shall not contain, or be capable of generating toxic gas, fumes, or vapors. Material does not contain pyrophoric, hazardous, dangerous, or chemical explosive material; nor is it violently reactive with water or moisture. Liquids prior to conditioning must be non-corrosive (pH is the band of 4 to 11). Non-radiological hazards shall be reduced to the maximum extent practicable. Special regulatory body approval needed for special waste such as RaBe, PuBe, and AmBe SRS to ensure proper conditioning and packaging. 15

16. IAEA Summary and Conclusions Waste Acceptance Criteria is a formal program to ensure waste is treated per the facility safety case. WAC’s are generally proposed by the site operator and approved by the regulatory body. There is no requirement that the safety case is completed before the WAC’s are approved. Common WAC’s are related to the physical, chemical and radiological characteristics of the SRS. 16

17. IAEA 17 Thank you!