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. 2 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 3 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. 4 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 5 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 7 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. 8 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 9 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 10 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 11 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 12 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 13 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 14 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 15 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 16 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/ 18
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