Low-Level Radioactive Waste Management and Disposition Proceedings of a Workshop (2017) / Chapter Skim
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2 Describing the Universe of Low-Level Waste
2 Describing the Universe of Low-Level Waste
Pages 9-46
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From page 9... ...
LLW category is broad and provides limited guidance for dispositioning unusual or unanticipated LLW waste streams. The second is that standards, orders, and regulations tied to the management and disposition of LLW are not sufficiently tied to risk.
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One solution to the problem of unanticipated waste streams is to create new waste classifications that include them. A nother option is to use case-by-case exceptions that are based on specific and known criteria and that can be applied in a consistent and predictable way.
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From page 11... ...
Second, despite its complexity, the United States has a system for regulating the disposal of LLW that works well in the great majority of cases as demonstrated by the large volumes and variety of LLW streams that have been efficiently and successfully disposed of. However, the challenging LLW streams are not trivial -- by volume and/or hazard -- and many of these waste streams attract controversy when decisions are made regarding storage, transportation, and disposal.
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. Near-surface disposal is appropriate for Class A, B, and C wastes but is not appropriate for GTCC wastes.6 There are currently four commercial sites for LLW disposal using near-surface disposal methods in the United States; they are located in Utah, Texas, South Carolina, and Washington.
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in New Mexico. Two additional DOE sites dispose of offsite LLW in addition to their own wastes: US Ecology, Inc., LLW Disposal Facility at the Hanford Site, Washington, and the Nevada National Security Site (NNSS, previously named the Nevada Test Site)
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Similarly, there are no commercial entities whose sole focus is waste disposal. Prior to 2008, the Canadian radioactive waste classification scheme was similar to that for the United States -- defining LLW by exclusion and using the following waste categories: nuclear fuel waste (used fuel)
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Boiling water reactors also produce irradiated hardware LLW streams; however, this waste stream is not included in this discussion because it represents a small fraction of waste. Figure 2-2a shows the volume of waste types (i.e., dry active and wet wastes)
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16 FIGURE 2-1 Major radioactive waste management sites in Canada. SOURCE: Canadian Nuclear Safety Commission.
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for 65 Plants by Waste Class by Waste Class Class C, 759, 1% Class B, 7,446, 13% Class A, 50,889, 86% FIGURE 2-2 Historic average annual waste volumes by (a) waste type and (b)
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From page 18... ...
The individuals responsible for the packaging and management of radioactive waste are internally motivated; other plant workers may not understand the potential impact of waste management mistakes. Those individuals who are involved in waste management consider themselves to be the environmental guardians of the plant, making sure the NPPs do not encounter problems over the waste management and disposition decisions.
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14 allows for specific waste streams to be approved for disposal 14 brief explanation of the exemption is provided on the USNRC's website: "10 CFR A 20.2002 is available for use by licensees for wastes that typically are a small fraction of the
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The green solid line excludes the very low-activity portion of the waste that could potentially be diverted to RCRA facilities instead of LLW disposal facilities. The cost of disposing of this waste in RCRA facilities is significantly lower -- EPRI estimates the total savings would be in the $6 billion range -- than disposing of the waste in a LLW facility.
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From page 21... ...
Because of its higher hazard, Class C waste must be buried at least 5 meters below the surface and have an engineered barrier.18 EnergySolutions has received a wide variety of LLW streams at its disposal facilities including paper, rags, plastic, glassware, syringes, protective clothing, cardboard, packaging material, spent pharmaceuticals, water-treatment residues, contaminated ion exchange resins, filters, tools, irradiated metals from nuclear power plants, and animal carcasses. The animal carcasses have to be incinerated because the facilities cannot directly dispose of organic materials.
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From page 22... ...
The United States now has four operating disposal facilities for commercial LLW (see Figure 2-4 and Table D-1 in Appendix D) : • EnergySolutions LLW Disposal Facility, Barnwell, South Carolina, accepts Class A, B, and C waste; 20 See Appendix D for further descriptions of Agreement States and the state compact system.
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From page 23... ...
waste; and • US Ecology, Inc., LLW Disposal Facility, Hanford Site, Washington, accepts Class A, B, and C waste. Since the LLRWPA was enacted, the EnergySolutions LLW Disposal Facility in Clive and WCS in Texas have opened.
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A comparison between U.S. RCRA disposal facilities and VLLW disposal facilities that exist in France and Spain concluded that the sites compare favorably in terms of protectiveness.
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Mr. Camper recalled that several years ago, the USNRC's Office of General Counsel asked the USNRC staff to identify a basis for using a "few millirem" for a lower threshold.
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They can then be released for conventional recycle or disposal, depending on the waste type. In a number of cases, this resulted in a reduction of more than 50 percent in the amount of waste that has to be treated as radioactive waste.
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." 25 See 10 CFR Part 61.55, Table 2 for the list of radionuclides and their concentration limits. For the text of the 1995 guidance, see "Issuance of Final Branch Technical Position on Concentration Averaging and Encapsulation, Revisions in Part to Waste Classification Technical Position," accessed April 9, 2017, https://www.nrc.gov/docs/ML0336/ML033630732.pdf.
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From page 28... ...
Many legacy waste streams are not well characterized in terms of radionuclide content, physical forms, or volumes. They have been stored or disposed of in facili 27 The following documents provide history and further background on the TRU waste problem (USNRC, 2015a and 2015c)
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Mr. Camper identified the key regulators of radioactive waste within the United States and stressed the key role that Agreement States play in regulating the four commercial LLW disposal facilities.
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National Environmental Policy Act (1969) : describes the environmental analyses that are performed for licensing ac tions, including the licensing of LLW disposal facilities.
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Requirements must be unique to DOE and must avoid duplicating information from other directives or any existing legal source." These orders and DOE policies provide for site-specific performance assessments and site-specific waste acceptance criteria to establish an envelope of acceptable LLW forms and packages between waste generators and waste disposal sites. See: "DOE: DIRECTIVES HELP," accessed March 1, 2017, https://www.
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Mr. Camper noted that the United States is fortunate to have four LLW disposal facilities; many countries have not yet determined a long-term solution to storage and disposal of LLW.
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• What are the strengths and weaknesses of the respective approaches? Andrew Orrell, section head of waste management and environmental safety, IAEA, provided an international regulatory perspective; Thomas Magette, managing director of PricewaterhouseCoopers, provided an industry perspective; and Mark Yeager, environmental health manager for South Carolina Department of Health and Environmental Control (DHEC)
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. Safety requirements are the middle level of the hierarchy (in red)
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Mr. Orrell's presentation included examples of a number of safety guides relevant to radioactive waste management, predisposal, storage, and disposal.
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Mr. Orrell noted that the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management41 is a legal instrument to the 75 contracting parties that obligates each to implement the principles contained in the IAEA safety standards.42 The Joint Convention went into force in 2001.
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He identified several reasons for his opinion. The first is that Agreement States have been given the authority to regulate LLW.
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The other complication is the period of institutional control following the closure of the LLW disposal facility. The public debate with USNRC staff focused on institutional controls and whether it was reasonable to maintain such control beyond 100 years.
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He noted that Texas, Utah, Washington, and South Carolina regulate the four commercial LLW disposal facilities in the United States. These are Agreement States, and each works within similar regulatory structures.
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The recent update of the BTP has affected the volume of LLW received at the BDF by allowing the blending down of Class B and Class C to higher concentrations of Class A It is also important to mention that each commercial LLW disposal facility has established Waste Acceptance Criteria which both allows and restricts certain waste forms.
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, to assist in the regulatory oversight of this activity and the resulting radiological wastes. Finally, it was noted that tritium, due to its elemental form, is an insidious environmental contaminant common in all LLW disposal sites and some solid waste landfills.
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For example, the four commercial LLW disposal facilities in the United States are currently regulated by Agreement States. Each respective regulatory program is subject to peri 44 Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)
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DOE, as a self-regulating agency, might benefit from an assessment of its LLW disposal regime by other regulatory entities. Consensus on a unified approach to LLW disposal across Agreement States and federal jurisdictions is also needed, noted Mr.
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From page 44... ...
Camper's characterization of the complex framework as a "regulatory mosaic" and suggested another term which he believes is more accurate: a "regulatory morass." Dr. Black highlighted several examples to support this opinion including containment requirements, the compliance period for DU, and overly complicated LLW regulations (Black et al., 2014)
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From page 45... ...
Additionally, oil and gas producers may dispose of NORM and TENORM waste outside of the radioactive waste regulatory regime.45 Long compliance periods and other requirements add to the cost of radioactive waste disposal, which in turn can impact nuclear energy generation and nuclear medicine use.
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