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4 The Common Themes Approach
Pages 77-102

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From page 77...
... waste • Incident waste • Sealed sources • Very Low-level and Very Low-Activity Waste • Depleted uranium (DU) 1  "Challenging LLW streams," as used in these proceedings, are LLW streams that have potentially non-optimal or unclear disposition pathways due to their origin or content and incompatibility with existing standards, orders, or regulations.
From page 78...
... Examples of past decisions for successful disposition of challenging LLW streams offer additional guidance for future waste disposal decisions. • Adjustments: Use flexibility within current regulatory frameworks for making decisions about disposing of challenging LLW streams.
From page 79...
... The common themes approach for disposing of challenging LLW streams acknowledges the roughly proportional relationship between the inherent hazard of a waste stream and the level of protection required from the facility that will be used for its disposal. This proportionality is represented by the solid black line on the figure.
From page 80...
... Challenging LLW streams can also be plotted on the conceptual line based on their hazards and needed levels of disposal facility protectiveness. This type of graphical representation could help guide disposition decisions for wastes without clear or potentially non-optimal disposition pathways and could also help explain disposal decisions to non-experts.
From page 81...
... . DOE has also augmented the technical information provided in the waste profiles for potentially challenging LLW streams such as sealed sources; for example, describing how the wastes that need to be disposed of have benefitted s ­ociety.
From page 82...
... The common themes approach and the figure are helpful for explaining management and disposal decisions on challenging LLW streams. Commercial Disposal Costs Participants with commercial disposal experience noted that the costs for disposal will affect disposal decisions, particularly when there is more than one disposal option.
From page 83...
... These waste streams were described by experts from each of the subgroups in plenary session. Lawrence "Rick" Jacobi, Jr., president of Jacobi Consulting, introduced GTCC and TRU wastes.
From page 84...
... The remaining GTCC (and possibly TRU waste) could be disposed of in a facility comparable to the 6  "USNRC: Branch Technical Position on Concentration Averaging and Encapsulation," accessed February 26, 2017, https://www.nrc.gov/waste/llw-disposal/llw-pa/llw-btp.html.
From page 85...
... Finally, he recommended that performance assessments used to develop the USNRC waste classification system should be conducted with modern computer codes, newer standards, and data from modern LLW disposal facilities. Sealed Sources A sealed source is "[a]
From page 86...
... VLLW is a large-volume, low-activity waste stream with a low intrinsic hazard compared to other LLW streams, even most Class A waste streams. It falls on the lower part of the notional line on Figure 4-1 represented by the lower orange circle.
From page 87...
... Mr. Nichols recently participated in an r IAEA consultancy that developed a technical guidance document on the management of large volumes of radioactive waste that would result from a nuclear/radiological emergency.8 He provided highlights from the draft IAEA guidance document to scope the workshop's breakout discussions on incident waste.
From page 88...
... In 1982, the USNRC promulgated 10 CFR 61, which defined uraniumcontaining waste as Class A waste. The analysis supporting the rulemaking considered typical or expected waste streams that were in existence at that time, such as small quantities of DU from commercial generators.
From page 89...
... . NOTE: Activity ratio is the activity of the DU at some future time divided by its initial activity.
From page 90...
... in recognition that surprises can be avoided through anticipation of future waste streams. The dotted lines in FIGURE 4-3  Updated sliding scale of hazards versus protections of the common themes approach.
From page 91...
... Experts from each subgroup summarized the subgroup's discussions on applying the common themes approach to the previously identified challenging LLW streams. Subgroup members offered additional comments and identified actions that could lead to finding management and disposal decisions for challenging LLW streams.
From page 92...
... Specifically, the Land Withdrawal Act for the Waste Isolation Pilot Plant defined TRU waste as waste containing transuranic elements that exceeded 100 nCi/g with a half-life longer than 20 years. But the Act provided three exceptions [WIPP, 1996, pp.
From page 93...
... The upcoming USNRC Branch Technical Position on Concentration Averaging and Encapsulation (BTP) for Class A, B, and C waste may affect how these types of sealed sources are managed and disposed of.
From page 94...
... Mr. Martin noted that challenging sealed source waste streams are limited in number and identifiable (the "anticipation" step outlined in the updated common themes approach)
From page 95...
... The subgroup thought it would be easier to describe VLLW disposal decisions to stakeholders and the public through a new classification than through the current exemption process, which is complicated, granted on a case-by-case basis, and lacks transparency. The terminology is also confusing: VLLW is reviewed through an exemption process for disposal at a RCRA facility, but the waste is not "exempt" waste.
From page 96...
... In fact, some in the subgroup thought that "incident waste" ought to be established as a separate waste classification and that performance assessment be used to guide its management.
From page 97...
... DU may also be appropriate for disposal at more modern LLW disposal facilities, for example the WCS facility in Andrews, Texas -- subject to the completion of the final 10 CFR Part 61 rulemaking. 14  At atmospheric temperature and pressure, UF6 is a solid.
From page 98...
... Facility design and operation assumptions that were used in the original EIS may be different from modern facility designs and operations. For example, the EIS did not envision disposal facilities like WCS in Texas or EnergySolutions in Clive, or even the changes to facility designs and operations that have occurred at the EnergySolutions LLW disposal facility in Barnwell, South Carolina.
From page 99...
... 4.5  FINAL THOUGHTS: REVIEW OF THE COMMON THEMES APPROACH Mr. Applegate asked the participants for final thoughts on using the decision framework (or, as he referred to it, the Common Themes approach)
From page 100...
... For example, there may be more public support for disposal of radioactive waste from medical treatments than from weapons development or for the disposal of sealed sources to reduce terrorist threats. Even if the waste characteristics and hazards are similar, the fact that it was generated from different processes influences public perceptions.
From page 101...
... THE COMMON THEMES APPROACH 101 explain how waste from other processes could be managed. It would also be an opportunity to discuss disposal options that are commensurate with the level of hazard posed by the wastes.


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