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Streamlining Proposed Part 61 Rule for Radioactive Waste Management

This document outlines a set of comments on NRC’s proposed Part 61 rule, suggesting updates for clarity and efficiency. Recommendations include developing a single rule, amending LLW definitions, and streamlining analysis structures.

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Streamlining Proposed Part 61 Rule for Radioactive Waste Management

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  1. NRC’s New Proposed Part 61 Rule John Greeves and Paul Lohaus Talisman International, LLC 1000 Potomac Street, NW Suite 300 Washington, DC 20007 202/471-4244 www.talisman-intl.com Turner, Harper & Associates, Inc. 1828 L Street, NW, Suite 710 Washington, DC 20036 (202) 496-1801

  2. COMMON SET OF COMMENTS • Agree update needed (e.g. modern dose method, 500 mrem intruder limit, 1000 year compliance period, analysis to peak dose) • BUT, proposed Part 61 unnecessarily burdensome, lacks clarity, & disruptive to future regulatory actions • Proposal is an overreach • 61.7 Concepts • 61.13 Technical Analysis • 61.44 10,000 year stability • 61.xx Defense-In-Depth analysis

  3. SUGGESTED APPROACH FINAL PART 61 RULE • Develop a SINGLE Part 61 rule (DU, GTCC, outstanding Classification question) • Amend LLW definition to include “Transuranic Radionuclides” • Retain existing Section 61.58. • Repackage a stand alone Long-Lived Radionuclides Section (61.60 or Subpart H) for sites proposing to accept large quantities of long-lived radionuclides • Clarify Per Section 61.1(a), existing sites not subject to all new requirements • Replace proposed three-tiered approach with two-tiered analysis

  4. RATIONALE FOR SUGGESTED APPROACH • GTCC waste contains long-lived radionuclides like the “newer” waste streams • Single rule would provide consistent, equivalent level of health, safety and environmental protection • Significant time and resource savings • Delaying a final determination on DU or GTCC classification will result in significant regulatory uncertainty • Eliminates the need for a separate new rulemaking to address waste classification

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