Appendix D

Low-Level Radioactive Waste Management and Disposition: Background Information

The Department of Energy’s Office of Environmental Management (DOE) is responsible for the cleanup of sites used by the federal government for nuclear weapons development and nuclear energy research. DOE “cleanup” involves the retrieval, treatment, storage, transportation, and disposal of a wide variety of radiological and hazardous wastes and materials. Low-level radioactive waste (LLW) is the most volumetrically significant radiological waste stream in the DOE cleanup program, consisting of millions of cubic meters per year.

LLW is defined by exclusion in the United States—that is, it is a residual category for radioactive waste material that is not otherwise categorized—and has no lower or upper activity limits (see Box D-1). As a result, its physical, chemical, and radiological characteristics are extremely diverse. Examples range from lightly contaminated soils and building materials to highly activated nuclear reactor components and sealed sources.

This workshop is charged to explore:

• the key physical, chemical, and radiological characteristics of LLW that govern its safe and secure management (i.e., packaging, transport, storage) and disposal, in aggregate and for individual waste-streams, and

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NOTE: An earlier draft of this paper was provided as background material to the workshop participants. The draft was updated and edited after the workshop to produce the document shown in this appendix.

• how key characteristics of LLW are incorporated into standards, orders, and regulations that govern the management and disposal of LLW in the United States and in other major waste-producing countries.

To accomplish this task, case studies will be presented to show how LLW previously without clear or non-optimal disposition pathways have been successfully managed in the United States and internationally. Lessons to be learned from these successes will be highlighted and discussed, particularly with respect to how they can be applied to LLW waste streams that currently lack clear or have potentially non-optimal disposition pathways—referred to as challenging wastes¹ in these proceedings.

The LLW “universe” contains numerous examples of challenging waste streams whose management and disposal pathways do not align directly with the existing U.S. regulatory regime. This workshop will consider waste characteristics, classification, and criteria that have promise for matching

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¹ This proceedings refers to LLW without a clear or potentially non-optimal disposition pathway due to their origin, content, or incompatibly with existing regulations and rules as “challenging LLW.”

challenging waste streams with appropriate disposition options and could be applied more broadly to other LLW streams in the United States. International classification schemes and case studies will also be presented.

This white paper is intended to inform the workshop discussions and provides background information on the following:

• Entities responsible for the management and disposal of LLW,
• Classification of wastes,
• Current disposal options for LLW,
• Current regulatory landscape for LLW,
• Previous relevant Academies studies, and
• An overview of case studies and challenging LLW.

D.1 ENTITIES RESPONSIBLE FOR THE MANAGEMENT AND DISPOSAL OF LOW-LEVEL WASTE

The main agencies that regulate and oversee LLW disposal in the United States are DOE, the U.S. Nuclear Regulatory Commission (USNRC), and the Environmental Protection Agency (EPA). The states also serve an important role, including regulatory oversight of the four commercially operating LLW disposal facilities in the United States.

The mission of DOE is to safely address the environmental legacy brought about from five decades of nuclear weapons development and government-sponsored nuclear energy research.² During the Manhattan Project and the Cold War, LLW was generated through the production and utilization of special nuclear materials, including uranium enrichment, reactor fuel and target fabrication, reactor operations, and plutonium production and recovery. In addition, DOE continues to generate LLW through cleanup activities such as facility decommissioning, tank waste retrieval and immobilization, and soil and groundwater cleanup. This waste is referred to as “government-owned LLW” (previously referred to as “defense LLW”).

DOE manages the largest, most diverse, and technically complex environmental cleanup program in the world. While it has completed the cleanup of more than 90 of the original 108 sites in its cleanup program,³ the remaining sites present some of the most difficult technical and regulatory challenges—including those posed by the diversity and volumes of LLW. For example, in fiscal year 2015 the DOE complex-wide disposal rate

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² “Mission and Functions Statement for the Office of Environmental Management,” accessed February 24, 2017, http://energy.gov/em/downloads/mission-functions-statement-office-environmental-management.

³ A site may still contain radioactive and chemical contamination after cleanup is completed. These sites will continue to be managed by DOE into perpetuity.

for LLW and mixed LLW (MLLW⁴) was 16.67 million cubic feet per year (Marcinowski, 2016).

The USNRC regulates the civilian use of radioactive materials within the United States under the Atomic Energy Act⁵ and also has the responsibility to ensure safe and protective disposal of commercial radioactive waste. Commercial LLW is generated through the maintenance and decommissioning of nuclear power facilities, and through industrial, medical, and research activities. The USNRC may relinquish a portion of its regulatory and licensing authority to Agreement States.⁶

The EPA has the authority to set limits on radiation exposure and issue guidelines for radiation protection to federal agencies, including the USNRC and DOE. The EPA also has authority to regulate hazardous chemicals through the Resource Conservation and Recovery Act (RCRA) and the Toxic Substances Control Act (TSCA). MLLW contains hazardous chemicals and is subject to regulation by the EPA and states that host DOE facilities.

LLW is generated in nearly every U.S. state. The Low-Level Radioactive Waste Policy Act of 1980 and its amendment in 1985 (see Box D-2) assigned to each state the responsibility of disposing of its own LLW. Disposal may also be facilitated through state compacts (congressionally ratified agreements among groups of states).

D.2 CLASSIFICATION OF LOW-LEVEL WASTE

LLW is defined by U.S. law, but there is no standard classification system for LLW across federal agencies. For example, DOE identifies requirements for LLW to be disposed of in near-surface disposal facilities using waste acceptance criteria. The USNRC utilizes a classification system based on the content and concentration of specific radionuclides: Class A, B, and C wastes and Greater-than-Class C (GTCC) wastes. Moreover, international regulatory schemes, discussed in a later section, follow a different system.

Most LLW generated in the United States readily aligns with current LLW classification system and regulatory structure. However, some types of LLW were not anticipated or in existence when the classifications,

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⁴ MLLW is LLW that contains hazardous chemicals.

⁵ In addition, the Energy Policy Act 2002 gave the USNRC the authority for regulating discrete sources of radium and accelerator-generated material.

⁶ Section 274b of the Atomic Energy Act allows the USNRC to relinquish portions of its Act-derived regulatory authority to states for source materials, byproduct materials, and small quantities of special nuclear materials. An Agreement State has agreed to take responsibility of licensing commercial storage facilities under authority of the USNRC through a written agreement between the state’s governor and the USNRC.

regulations, and laws were developed and do not readily conform to existing classification systems. Some examples include GTCC and transuranic (TRU) wastes, sealed sources, and incident wastes. Thus, the appropriate disposition pathway and destination for permanent disposal are difficult to plan and the final decisions can be contentious. These and other examples are discussed in a later section.

D.3 CURRENT LOW-LEVEL WASTE DISPOSAL OPTIONS

It is DOE policy to reduce, manage, and dispose of government-owned LLW at its site of generation (i.e., onsite generated LLW) to the extent allowable by site conditions. Government-owned LLW that cannot be disposed of onsite will be disposed of at offsite DOE-managed facilities—except that DOE may also dispose of government-owned LLW in commercial facilities when appropriate for cost reduction or as needed to supplement DOE’s capabilities. There are currently six DOE facilities available for the disposal of government-owned LLW: four allow for the storage and disposal of onsite generated LLW, and two allow for disposal of LLW and MLLW generated offsite.

The four DOE sites that allow for disposal of onsite generated LLW are the Idaho National Laboratory; Los Alamos National Laboratory, New Mexico; Oak Ridge Reservation, Tennessee; and Savannah River Site, South Carolina. The other two sites—the Hanford Site near Richland, Washington, and the Nevada National Security Site (NNSS)—allow for disposal of both onsite and offsite generated LLW and MLLW, as long as the waste

meets each sites’ waste acceptance criteria.⁷ In addition, there are two commercial sites that can accept government-owned LLW: EnergySolutions LLW Disposal Facility in Clive, Utah; and Waste Control Specialists (WCS) in Andrews, Texas.

There is currently no disposal capability in the United States for GTCC LLW. However, DOE published the final environmental impact statement for the “Disposal of Greater-Than-Class C (GTCC) Low-Level Radioactive Waste and GTCC-Like Waste” in January 2016 (DOE, 2016);⁸ it identifies land disposal at generic facilities and/or the Waste Isolation Pilot Plant (WIPP) as preferred options for the disposal of GTCC LLW and GTCC-like waste.⁹

There are four commercial LLW disposal sites in the United States. They are located in Barnwell, South Carolina, and operated by EnergySolutions; in Clive, Utah, also operated by EnergySolutions; the Hanford site in Washington, operated by U.S. Ecology; and Andrews, Texas, operated by WCS LLC (see Table D-1). Each of these sites is located in an Agreement State and are licensed by their host states under authority provided by the USNRC. Three of the sites (Barnwell, Hanford, and WCS) serve state compacts, and the fourth site (Clive) accepts Class A waste from all U.S. states. The Agreement States determine the types of LLW allowed for disposal in the facilities. Refer to Table D-1 for additional information.

D.4 CURRENT REGULATORY LANDSCAPE FOR LOW-LEVEL WASTE

Several U.S. federal laws govern the regulation and management of LLW; see Box D-2.¹⁰ DOE is self-regulating and implements its responsibilities and authorities for waste management and disposal through directives and orders. These are incorporated into government contracts and enforced through contract and federal oversight (e.g., the Low-level Waste Disposal

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⁷ “Disposal Information,” accessed February 24, 2017, http://www.hanford.gov/page.cfm/ DisposalInformation and “Nevada National Security Site Waste Acceptance Criteria,” accessed February 24, 2017, http://www.osti.gov/scitech/servlets/purl/1080356/.

⁸ “Greater-Than-Class C Low-Level Radioactive Waste Environmental Impact Statement (GTCC EIS) Documents,” accessed February 24, 2017, http://www.gtcceis.anl.gov/documents/index.cfm#final.

⁹ “GTCC-like waste” is waste generated or owned by DOE that contains concentrations of radionuclides that are similar to commercially generated GTCC LLW.

¹⁰ See also Improving the Regulation and Management of Low-Activity Radioactive Wastes (National Research Council, 2006), for descriptions of other U.S. laws that are not listed in Box D-1 (see Sidebars 2.1 and 2.2, Appendix A, available as https://www.nap.edu/catalog/11595/improving-the-regulation-and-management-of-low-activity-radioactive-wastes [accessed April 9, 2017]).

TABLE D-1 Facilities Available for Commercial LLW Disposal

SOURCE: Data from “USNRC Information Digest, 2016-17,” NUREG-1350, Volume 28, Section 5: Radioactive Waste, accessed February 24, 2017, http://www.nrc.gov/docs/ML1624/ML16245A052.pdf).

Facility Federal Review Group [LFRG]). The directives and orders may be revised over time.

There are two DOE orders that govern radioactive waste management and disposal:

• DOE Order 458.1, Radiation Protection of the Public and the Environment, requires DOE to establish requirements to protect the public and the environment against undue risk from radiation associated with radiological activities conducted under the control of DOE.¹¹
• DOE Order 435.1, Radioactive Waste Management, provides requirements for the management and disposal of HLW, TRU, government-owned LLW, DOE-accelerator produced waste,¹² and the radioactive component of mixed waste.¹³

Under DOE Order 435.1, for instance, a Disposal Authorization Statement (DAS) is required for design and operation of a LLW disposal facility. The DAS consists of a variety of technical documents, including a performance assessment and composite analysis.¹⁴ Waste acceptance criteria are required on a case-by-case basis for each site to meet the order’s performance objectives.

The Atomic Energy Act (AEA) (see Box D-2) assigns the USNRC the responsibility for regulating and licensing commercial disposal facilities. The USNRC regulations in 10 CFR Part 61: Licensing Requirements for Land Disposal of Radioactive Waste apply to all commercial LLW containing source, special nuclear, or byproduct material (see Box D-1 for definitions) suitable for near-surface land disposal. A subsection within this regulation, Part 61.55,¹⁵ defines three LLW classes from lowest radioactivity levels to highest: Class A, B, and C (see Tables D-2 and D-3). LLW with concen-

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¹¹ “DOE O 458.1, Radiation Protection of the Public and the Environment,” accessed February 24, 2017, https://www.directives.doe.gov/directives-documents/400-series/0458.1-BOrder.

¹² “DOE-accelerator produced waste” is radioactive waste produced as a result of operations of DOE accelerators. Accelerator-produced waste is not included in the AEA or NWPA.

¹³ “DOE O 435.1 Chg 1, Radioactive Waste Management,” accessed February 24, 2017, https://www.directives.doe.gov/directives-documents/400-series/0435.1-BOrder-chg1.

¹⁴ From the “LFRG DOE Order 435.1,” accessed February 24, 2017, https://energy.gov/em/lfrg-doe-order-4351, p. IV-12:

“(3) Composite Analysis: For disposal facilities which received waste after September 26, 1988, a site-specific radiological composite analysis shall be prepared and maintained that accounts for all sources of radioactive material that may be left at the DOE site and may interact with the low-level waste disposal facility, contributing to the dose projected to a hypothetical member of the public from the existing or future disposal facilities.”

¹⁵ “USNRC: Part 61.55 Waste Classification,” accessed February 24, 2017, https://www.gpo.gov/fdsys/pkg/CFR-2011-title10-vol2/pdf/CFR-2011-title10-vol2-sec61-55.pdf.

TABLE D-2 Near-Surface Disposal for Allowable Concentrations of Long-Lived Radionuclides

^a Units are nanocuries per gram.

TABLE D-3 Allowable Concentrations of Short-Lived Radionuclides for Near-Surface Disposal

^a There are no limits established for these radionuclides in Class B or C wastes. Practical considerations such as the effects of external radiation and internal heat generation on transportation, handling, and disposal will limit the concentrations for these wastes. These wastes shall be Class B unless the concentrations of other nuclides in Table D-2 determine the waste to be Class C independent of these nuclides.

SOURCE: for Tables D-2 and D-3, “USNRC Part 61.55: Waste Classification,” Tables 1 and 2, accessed February 24, 2017, https://www.nrc.gov/reading-rm/doc-collections/cfr/part061/part061-0055.html.

trations of radionuclides that exceed the Class C limits are referred to as GTCC wastes.

Federal laws have assigned three responsibilities to the states related to LLW management and disposal:

• Each state must dispose of LLW generated within its borders, either within the state or through state compacts.
• States may assume portions of the USNRC’s regulatory authority for LLW by becoming an Agreement State.
• States regulate non-AEA wastes under authority provided by the state legislature (non-AEA wastes are not covered by federal laws).

The International Atomic Energy Agency (IAEA) issues safety standards to protect health and minimize danger to life and property. The IAEA uses these standards in its own operations, and its member states incorporate these standards in whole or part into their own regulations. The IAEA Classification of Radioactive Waste—General Safety Guide, No. GSG-1 (IAEA, 2009) presents a scheme for classification and management of radioactive waste based on specific radionuclides, their half-lives, and activity levels in the waste. The standards define six categories of waste (listed here from lowest to highest level of radioactivity):

• exempt waste (EW),
• very short-lived waste (VSLW),
• very low-level waste (VLLW),
• low-level waste (LLW),
• intermediate-level waste (ILW), and
• high-level waste (HLW).¹⁶

The objective of the IAEA’s classification system is to ensure the long-term safety of the public and the environment through the proper management and disposal of the waste. Therefore, the waste is classified according to the degree of containment and isolation required based on the activity content and half-lives of the contained radionuclides.

DOE has previously requested the advice of the National Academies on its waste management programs. Improving the Regulation and Management of Low-activity Radioactive Wastes (National Research Council, 2006), funded in part by DOE, is particularly relevant to the current workshop. The report recommended a tiered approach to clarify and simplify

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¹⁶ See Figure 1: Conceptual illustration of the waste classification scheme (IAEA, 2009), “Classification of Radioactive Waste,” accessed April 9, 2017, http://www-pub.iaea.org/MTCD/Publications/PDF/Pub1419_web.pdf.

the current system for managing low-activity waste¹⁷ by converting it to a risk-informed system. The tiered approach, which identified a set of options in order of increasing complexity, resources, and time, acknowledged that changes to regulations would likely take many years and would require coordination among many federal and state agencies.

The report also found that current laws and regulations for low-activity wastes provide adequate authority for protection of workers and the public (FINDING 1) (see National Research Council, 2006, Appendix A). However, the current system of managing and regulating low-activity waste—as described partially above—is complex (FINDING 2). The report’s summary notes that classification systems are becoming more complex as unanticipated waste streams are identified. Indeed, this is one of the motivating factors for the current workshop.

The report further found that certain categories of low-activity wastes have not received consistent regulatory oversight and management (FINDING 3) and that current regulations for low-activity wastes are not based on systematic consideration of risk (FINDING 4). These last two findings pertain primarily to uranium and thorium mill tailings, naturally occurring radioactive material (NORM), and technologically enhanced radioactive material (TENORM). TENORM can contain significant concentrations of radioactive materials. NORM and TENORM wastes are not generally regulated by federal agencies; moreover, their regulation by the states is inconsistent.

The National Academies also published a workshop summary that is relevant to LLW management and disposal: Best Practices for Risk-Informed Decision Making Regarding Contaminated Sites—Workshop (National Research Council, 2014), funded by DOE. This workshop explored long-term remediation decisions for contaminated sites based on sustainability principles (balancing between the environmental, societal, and economic goals) rather than purely risk-based or regulation-based approaches.

The National Academies report Waste Forms Technology and Performance (National Research Council, 2011) provided guidance on improving current methods for processing radioactive wastes and producing waste forms for disposal. The report found that laws and regulations governing DOE wastes do not establish specific requirements for waste form performance in disposal systems, therefore allowing DOE flexibility in the selection of waste forms.

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¹⁷ The 2006 committee intended the term “low-activity waste” (LAW) to be more inclusive than LLW, which has a specific definition through the NWPA. DOE often uses the term LAW to describe lower-activity fractions of tank waste; National Research Council (2006) did not use the term in that sense.

D.5 CASE STUDIES AND EXAMPLES OF CHALLENGING LOW-LEVEL WASTES

The following five case studies will be discussed during the workshop. They represent instances in which an appropriate and acceptable disposal pathway was found for the LLW involved. The presentations on the first day of the workshop will consider these case studies in greater detail, with an eye to drawing lessons for other challenging waste streams for which clear disposal pathways do not currently exist or which are potentially not optimal.

Case Study 1: Separations Process Research Unit Tank Waste Sludge

In the early 1950s, research on plutonium and uranium separation techniques such as PUREX and REDOX¹⁸ was performed at the Knolls Atomic Power Laboratory’s¹⁹ (KAPL’s) Separation Process Research Unit (SPRU). Radioactive liquid and sludge wastes resulting from the research were stored in seven tanks located onsite. The separations research ended in 1953, and the liquids were retrieved from the tanks in the 1960s, but the sludge wastes remained in the tanks. DOE completed solidification of the sludge and removal of the tanks from KAPL in 2014.²⁰ The cleanup required coordination among several organizations: DOE, its contractor (URS Corporation), the Office of Naval Reactors (the site’s landlord), and WCS. WCS accepted the tank sludge waste and the remediated tanks at its LLW disposal facility in Andrews, Texas.

Case Study 2: Disposal of Low-Level Radioactive Waste at the NNSS

The secure shallow-land burial (to 24 feet [7.3 meters] below ground surface) in the Area 5 Radioactive Waste Management Site at the NNSS accepts LLW, MLLW, and classified waste²¹ from more than 25 different sites within the DOE Complex. Per agreement with DOE, Nevada’s Division of Environmental Protection (NDEP) participates in the review of waste

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¹⁸ REDOX (reduction oxidation) and PUREX (Plutonium and Uranium Recovery by Extraction) are processes for separating plutonium and uranium from irradiated fuel and targets.

¹⁹ The Knolls Atomic Power Laboratory is located in upstate New York. It is a research and development laboratory for the U.S. Navy Nuclear Propulsion Program.

²⁰ “EM’s SPRU Celebrates Waste Removal Success, Safety Milestone,” accessed February24, 2017, http://energy.gov/em/articles/em-s-spru-celebrates-waste-removal-success-safety-milestone.

²¹ DOE Order 435.1-1 defines classified waste as “Radioactive waste to which access has been limited for national security reasons and cannot be declassified shall be managed in accordance with the requirements of DOE 5632.1C, Protection and Control of Safeguards and Security Interests, and DOE 5633.3B, Control and Accountability of Nuclear Materials.”

profiles proposed for disposal at the NNSS and in the review of the NNSS Waste Acceptance Criteria.

NDEP’s perspectives on the variation in certain key criteria with the broad spectrum of LLW reviewed for disposal at the NNSS will be presented at the workshop, including:

• isotope half-life duration;
• radionuclide activity concentrations as compared to concentrations shown by the existing site performance assessment to meet site performance objectives; and
• plutonium equivalent gram activity.

NDEP will also review general measures that have been taken by DOE, the state of Nevada, and others to address stakeholder concerns associated with transportation and disposal of this LLW.

Case Study 3: Canada: Port Hope Area Initiative

The Port Hope Area Initiative (PHAI)²² is focused on the cleanup of approximately 1.2 million cubic meters of historic low-level radioactive waste currently stored across sites within the municipality of Port Hope. These wastes, primarily contaminated soil, resulted from radium and uranium refining activities in the 1930s through the 1950s. Construction of a long-term waste management facility (an engineered above-ground mound) is under way. Its location will be within an existing LLW management facility. Waste at the existing site and specified wastes from other sites in Port Hope will be placed in the above-ground mound.²³

Case Study 4: Canada: Deep Geologic Repository for Low- and Intermediate-Level Waste

Canada does not have an operating disposal facility for low- or intermediate-level wastes (L&ILW).²⁴ Each waste generator is responsible for

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²² The PHAI Management Office is a tripartite organization involving Atomic Energy of Canada Limited, Natural Resources Canada, and Public Works and Government Services Canada (PWGSC). This office is responsible for carrying out the LLW disposal and cleanup projects in the Port Hope area.

²³ “Port Hope Area Initiative,” accessed February 24, 2017, http://www.phai.ca/en/home/default.aspx.

²⁴ Canadian definitions of low- and intermediate-level wastes are different from U.S. definitions. Current Canadian definitions were adopted in 2008 and are consistent with the IAEA GSG-1 classification system (IAEA, 2009). Canada previously recognized three classes of waste: nuclear fuel waste, uranium mining and milling waste, and low-level waste—the latter defined similarly to the U.S. definition as wastes not included in the first two categories.

the long-term management of their wastes. A new L&ILW disposal facility, a deep geologic repository, in Kincardine (Ontario) is currently undergoing licensing. Ontario Power Generation (OPG), a major Canadian utility and nuclear waste generator, owns and operates the site on which this repository will be built. The repository will be located on an existing nuclear site—the Bruce Nuclear Power Generating Station, adjacent to OPG’s Nuclear Waste Management Organization facility. The repository will have a reference depth of 680 meters and has a potential waste capacity totaling approximately 200,000 cubic meters. The municipality of Kincardine is a willing volunteer host for the facility. The hosting agreement specifically excludes the possibility of disposing of used reactor fuel in the facility.

Case Study 5: France: Very LLW and Intermediate LLW Facilities

The management and disposal of LLW in France differs in important ways from approaches used in the United States, even though the waste characteristics are similar in both countries. The French approach considers the physical characteristics of the waste and its hazard, based on half-lives and activities of radionuclides, in determining treatment and disposal options. The French classification makes a distinction between:

• very short-lived, short-lived, and long-lived waste, and
• very low-, low-, intermediate-, or high-level waste (VLL, LL, IL or HL waste).

Approximately 96 percent by volume of nuclear waste in France is VLL and LL short- and long-lived waste and IL short-lived waste. This waste contains less than 0.1 percent of the overall waste activity. Conversely, approximately 4 percent of France’s waste by volume is IL long-lived waste and HL short- and long-lived waste containing more than 99.9 percent of the activity.²⁵

France has two disposal facilities of relevance to the current workshop. For waste that has a very low-activity level (between 0 and 100 becquerels per gram [Bq/g] or 0 to 2.7 nanocuries per gram [nCi/g]), the waste is managed at the ANDRA CSTFA (Centre de stockage des déchets à très faible activité) disposal facility located in the Aube district, southeast of Paris.²⁶ This facility has been operational since 2003 and is the first disposal facility in the world for this type of waste. Low- and intermediate-level short-lived

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²⁵ “ANDRA: Waste Classification,” accessed February 24, 2017, https://www.andra.fr/international/pages/en/menu21/waste-management/waste-classification-1605.html.

²⁶ “ANDRA: Very-low-level waste,” accessed February 24, 2017, https://www.andra.fr/international/pages/en/menu21/waste-management/waste-classification/very-low-levelwaste-1607.html.

waste, such as waste related to maintenance (i.e., clothes, tools, gloves, filters) and the operation of nuclear facilities (i.e., residues from the treatment of gaseous and liquid effluents) has been disposed of at the ANDRA CSFMA (Centre de stockage des déchets à faible et moyenne activité et à vie courte) waste disposal facility since 1992.²⁷ France currently does not have a facility to dispose of low-level long-lived waste but plans to commission a repository by 2019.²⁸ Cigéo, a geological disposal facility for intermediate- and high-level and long-lived waste, is expected to be commissioned in 2025.

D.6 CHALLENGING LOW-LEVEL WASTE STREAMS

As noted previously, challenging LLW streams lack clear or have potentially non-optimal disposition pathways. They will be discussed during the breakout sessions on the second day of the workshop.

GTCC and Commercial TRU Waste Exceeding 100 nCi/g

There are three types of GTCC waste considered in DOE’s final environmental impact statement analysis (DOE, 2016): Activated metals (generated from the decommissioning of nuclear reactors including core shrouds and core support plate), sealed sources, and other waste (contaminated equipment, debris, scrap metal, filters, resins, soil, and solidified sludge). The combined GTCC LLW and GTCC-like waste inventory is projected to be about 12,000 cubic meters (~420,000 cubic feet) and will contain a total activity of about 160 million curies (MCi); about 75 percent of this waste is commercial GTCC LLW and 25 percent is DOE-owned GTCC-like LLW.²⁹

DOE evaluated five alternatives in the final environmental impact statement for the disposal of the GTCC LLW and DOE-owned GTCC-like waste (DOE, 2016). As noted previously, the preferred alternative for the disposal of GTCC LLW and GTCC-like waste is land disposal at generic commercial facilities and/or disposal at the Waste Isolation Pilot Plant (WIPP) near Carlsbad, New Mexico.

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²⁷ “ANDRA: Low and intermediate level short-lived waste,” February 24, 2017, https://www.andra.fr/international/pages/en/menu21/waste-management/waste-classification/short-lived-low--and-intermediate-level-waste-1609.html.

²⁸ “ANDRA: Low-level long-lived waste,” February 24, 2017, https://www.andra.fr/international/pages/en/menu21/waste-management/waste-classification/low-level-long-livedwaste-1616.html.

²⁹ “Supplement to Greater-Than-Class C (GTCC) Low-level Radioactive Waste and GTCC-like Waste Inventory Reports,” accessed February 24, 2017, http://www.gtcceis.anl.gov/documents/docs/Supplemental-Inventory-Report.pdf.

Sealed Sources

Sealed sources are used in industry, medicine, research, and oil exploration. Some examples include cobalt-60 for medical therapy; cobalt-60 and cesium-137 for bulk irradiation (e.g., medical equipment and food); americium-241/Be for well logging (e.g., for petroleum exploration); and iridium-192 and cobalt-60 for industrial radiography. Disused or unwanted sealed radiation sources range in activity from micro- to kilo-curies; these sources meet USNRC’s definition for Class C or GTCC LLW. They can cause acute radiation effects in humans and serious contamination incidents if not managed properly (Cuthbertson et al., 2014).

Clearance or Exempt Waste and Low-Activity Waste

Waste that has very low activity levels is referred to as “clearance” or “exempt” waste by the IAEA (IAEA, 1996). The United States does not have a clearance or exempt classification category. The activity level of this type of waste falls into the lower end of the USNRC Class A designation. This type of LLW may occur in very large volumes. Examples include lightly contaminated wastes generated from decommissioning of nuclear facilities at DOE and civilian sites and from site cleanup activities, including debris, rubble, construction materials, and soils.

Incident Waste

These are wastes resulting from a nuclear incident,³⁰ for example a severe nuclear accident or nuclear or radiological terrorist attack. Examples of incident wastes include agricultural materials and soils, concrete, asphalt (roads), rubble, debris, metal, activated components, emergency responders’ equipment, and cleaning materials. There is potential for very large amounts of waste with low- to high-levels of radioactivity, depending on the type of incident.

Depleted Uranium (DU)

DU waste is a created through the enrichment of uranium, for both commercial and defense applications. DU is unique in its disposal requirements because the activity (and exposure risk) of DU increases with time

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³⁰ Section 11q of the AEA defines a nuclear incident as “any occurrence, including an extraordinary nuclear occurrence, within the United States causing, within or outside the United States, bodily injury, sickness, disease, or death, or loss of or damage to property, or loss of use of property, arising out of or resulting from the radioactive, toxic, explosive, or other hazardous properties of source, special nuclear, or byproduct material.”

due to the ingrowth of decay products. Most DU exists as a hexafluoride (DUF₆) and must be converted to DU oxide (e.g., DU₃O₈) for disposal.

Small quantities of DU are currently being disposed of as a Class A waste. However, more than 1 million metric tons (MT) of DU (up to 800 kMT DU at Paducah and Portsmouth and ~300 kMT commercial DU) will require disposal.

There are currently two LLW disposal facilities that are authorized to dispose of uranium oxide: WCS in Texas and the NNSS. A third site, EnergySolutions in Utah, is seeking a permit to authorize disposal of DU in its Class A LLW disposal facility. DOE is currently preparing a supplemental environmental impact statement to analyze the environmental impacts of DU oxide disposition.³¹ A USNRC staff review (USNRC, 2008) concluded that existing regulations need to be amended to ensure that commercial DU is disposed of safely.

REFERENCES

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³¹ To download the Notice of Intent, see “DOE: EIS-0359-S1 AND EIS-0360-S1: Notice of Intent,” accessed February 24, 2017, http://energy.gov/nepa/downloads/eis-0359-s1-and-eis0360-s1-notice-intent.

USNRC (United States Nuclear Regulatory Commission). 2008. Letter to the Commissioners, “Response to Commission Order CLI-05-20 Regarding Depleted Uranium.” Accessed February 24, 2017, https://www.nrc.gov/reading-rm/doc-collections/commission/secys/2008/secy2008-0147/2008-0147scy.pdf.

USNRC. 2015. SECY-15-0094, Policy Issue: Historical and Current Issues Related to Disposal of Greater-than-Class C Low-Level Radioactive Waste. Available at https://www.nrc.gov/docs/ML1516/ML15162A807.pdf. Accessed February 26, 2017.

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