The National Academies Low – Level Radioactive Waste Management

The National Academies Low-Level
Radioactive Waste Management
and Disposition Workshop
Jenny Heimberg
Study Director and Rapporteur
April 24, 2017
Low-Level Radioactive Waste Forum, Inc.
Spring Meeting
Motivation for the Workshop
Department of Energy—Office of Environmental Management’s
(DOE) mission:
The safe cleanup of sites associated with the government-led
development of nuclear weapons and nuclear energy.
A Memorandum of Understanding between Nevada and DOE:
• Acknowledges shared interests regarding Nevada National
Security Site (NNSS) activities and safe disposal of waste.
• Agree that a broad spectrum of wastes exist within the LLW
classification and the current classification system would benefit
from an independent scientific review.
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Workshop Proceedings
• Useful in highlighting a topic for discussion by a diverse
set of participants.
• Contain factual descriptions of the presentations and
discussions held at the workshops.
• Discussions are moderated.
– Even if the participants routinely meet in other forums,
Academies-managed workshops tend to initiate new thoughts
and information.
• Workshop proceedings are not consensus reports.
– No findings, conclusions, or recommendations
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Statement of Task
The workshop presentations and discussions will address the
following topics:
• Identification of key physical, chemical, and radiological
characteristics of low-level radioactive waste that govern its safe
and secure management (i.e., packaging, transport, storage) and
disposition, in aggregate and for individual waste-streams.
• How key characteristics of low-level waste are incorporated
into standards, orders, and regulations that govern the
management and disposition of low-level radioactive waste in the
United States and in other major waste-producing countries.
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Workshop Committee, Reviewers, and Staff
Planning Committee
JOHN S. APPLEGATE
LARRY W. CAMPER
REBECCA A. ROBBINS
NINA D. ROSENBERG
Chair, Indiana University
Advoco Professional Services, LLC and USNRC (retired)
International Atomic Energy Agency
Los Alamos National Laboratory
Reviewers
JOHN S. APPLEGATE*
MIKLOS GARAMSZEGHY*
CHRISTINE GELLES
ROGER SEITZ
MARK YEAGER*
Indiana University
Canadian Nuclear Waste Management Organization
Longenecker and Associates
Savannah River National Laboratory
Department of Health and Environmental Control, SC
Staff (Nuclear and Radiation Studies Board)
JENNIFER HEIMBERG
Study Director
TONI GREENLEAF
Administrative/Financial Associate
DARLENE GROS
Senior Program Assistant
*workshop participant
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Participants
A variety of domestic and international technical,
regulatory, and policy experts from:
DOE-EM, NNSA
USNRC
EPA
GAO
USGS
States: NV, TX, SC, TN, PA
Universities
Military
Public interest groups: NIRS
Industry
IAEA
International: Canada, France,
Great Britain
Format of the Workshop
Outline the scope and challenge of LLW classification, definition
of LLW and regulations:
• Identify “challenging” wastes streams
Session 1
Highlight examples of successful case studies:
• Identify similarities in key characteristics of the wastes and
their incorporation into standards and regulations
• Suggest ideas, tools, or frameworks to assist disposition
decisions about other LLW
Session 2
Describe LLW that pose challenges in disposal:
• Apply suggested tools in break-out sessions
Session 3
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Highlights from the Workshop
Several recurrent themes emerged from the discussions over
the course of the workshop:
– Complexity of regulation,
– Communication among stakeholders,
– Diversity of low-level waste type, source, and hazard,
and
– Integrating knowledge gained from operations.
A “common themes approach” was suggested and discussed
as a tool for discussing potential disposal options for future
unanticipated LLW.
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Complexity of LLW Regulation
• Current regulatory system in United States is the result of numerous
“tweaks” and “adjustments” to regulations that were developed years
ago.
– Result is complex system or a “regulatory mosaic”
– Some suggested: “starting from scratch” or adopting a “revolutionary as
opposed to an evolutionary” approach
• Some noted that the states’ role in managing and disposing of LLW
adds to the current complexity.
• US regulatory system is flexible and can adjust to the wide variety of
LLW types.
• Unintended impacts of the current complex system:
– Potential loss of public trust
– Mounting costs for disposal
– Regulations that are disproportionate to hazards posed by the waste
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Examples from the Workshop
The regulatory process has a proven
track record and has been shown to
adequately protect health and safety.
However, the process is complicated
(a “regulatory mosaic”), may be
difficult to understand or explain, and
lacks exact alignment with other
international regulatory frameworks.
There is room for improvement.
Larry Camper
Advoco Professional Services, LLC and
USNRC (retired)
If one were to redesign a system
to regulate LLW with our current
understanding of the variety and
volumes of LLW streams, it is hard
to imagine a system that would
allow individual states to regulate
LLW because there is no
distinction in health and safety
benefit as one crosses state lines.
Thomas Magette
PricewaterhouseCoopers
If the regulations become too unwieldy for waste generators [hospitals, for
example], the likelihood of the sealed sources remaining on-site in storage
increases, which also increases the potential risk that the sources could be
stolen or weaponized in place.
Sealed Sources subgroup
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Communication among Stakeholders
• Complexity of regulations leads to communication
problems with stakeholders:
– Stakeholders assume hazard must be high to have regulations
that are strict and complex
– Apparent inconsistencies in decisions on LLW
• Importance of language and a change in mindset:
– Definition of “stakeholder” (“interested parties”)
– Discriminatory or condescending
• Talking “to” the public, or “educating the public”
• Encourage a continuing conversation
• Importance of broader issues related to waste:
– responsibility to future generations
– the benefits of nuclear products
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Examples from the Workshop
Case-by-case decisions can seem
ad hoc, subjective, and reactive
without a reference system to
compare the decisions to—
especially when viewed from the
outside.
Greg Lovato
Nevada Division of Environmental Protection
…The current generation benefits
from the electricity generated by
nuclear power plants, so it should be
responsible for solving the waste
management problem for following
generations.
Gérald Ouzounian
ANDRA
…communication and transparency with the public are
important throughout the entire lifecycle of LLW.
Lisa Edwards
Electric Power Research Institute
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Diversity of LLW Type, Source, and Hazard
• Definition by exclusion in the United States:
– Not based on inherent hazard of the waste
– Includes higher activities and longer lived wastes than in other
countries
– Includes very low-activity wastes which are addressed differently
in other countries
– No low-end threshold so no “cleared” category
• States have authority to regulate some radioactive
wastes:
– Required coordination between states and federal regulators
– Potential inconsistencies between states for similar wastes
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Examples from the Workshop
A strong argument can be
made that US regulatory
requirements for wastes
classified as “very low-level” (or
very low-activity) in other
countries are overly
burdensome and costly…
Lisa Edwards
EPRI
Classification of radioactive waste
streams in France.
SOURCE: G. Ouzounian, ANDRA
Consensus on a unified approach to LLW disposal across Agreement States
and federal jurisdictions is needed… Such a consensus could encourage
buy-in from stakeholders and the public and possibly reduce disposal costs.
Mark Yeager
Department of Health and Environmental Control, SC
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Integrating Knowledge Gained from Operations
• Nuclear waste disposal has existed for ~6 decades
• Early disposal practices and facility designs have
evolved substantially
• Modern facility design benefits from applying knowledge
gained from construction and operations
• Characteristics of the site are important aspect of design
• Rules and regulations in the United States have not
integrated this new knowledge into regulations that
manage and dispose of LLW
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Examples from the Workshop
10 CFR Part 61 is based on an EIS that was prepared at the time the
regulation was created, but the EIS has never been updated. Facility
design and operations assumptions that were used in the original EIS may
be different than modern facility designs and operations.
Larry Camper
Advoco Professional Services, LLC and USNRC (retired)
…nuclear waste disposal
industry has matured over the
past 40 years. Modern state-ofthe-art disposal facilities…are
remarkably different in siting and
design than older disposal
facilities…
Scott Kirk
BWXT
…[The French have] noted the
importance of adapting to knowledge
gained from waste disposal experience
in general. The process of developing an
approach for the management and
disposition of nuclear waste began in
1969, and much has been learned
progressively.
Gerald Ouzounian
ANDRA
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Common Themes Approach:
Hazard versus Protections
The Four A’s:
 Anchors: The current regulatory
framework
 Anticipation: Reduce “surprises” by
identifying future waste streams
 Analogies: Learn from successful
disposition of similar wastes.
 Adjustments: Use flexibility within
current regulatory frameworks
Plus: Review of further dimensions
including communications and
stakeholder concerns
Scalable, consideration of waste characteristics and options for disposal,
compared against each other in a transparent way
Workshop-related links
• Workshop webcast and presentations:
– http://dels.nas.edu/Past-Events/Level-Radioactive-WasteManagement/AUTO-6-58-82-D?bname=nrsb
– [hint: search “NRSB DELS” and select “Events”]
• Workshop Proceedings:
– https://www.nap.edu/catalog/24715/
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