A proposed solution to the challenges of disposal of greater than class C low-level radioactive waste - 15172
In 1982, the US Nuclear Regulatory Commission (NRC) adopted rules for the disposal of low-level radioactive waste. These rules established new standards for the siting, construction, operation and closure of low-level radioactive waste disposal facilities. The new rules also set out a classification system for low-level radioactive waste based on half-life and concentration of the radionuclides in the waste stream. The defined classes - Class A, Class B and Class C - were based on increasing toxicity with Class A being the least hazardous and Class C being relatively more hazardous. Radioactive waste that could not fit the classification scheme due to its long half-life or its high concentration of radioactive material was deemed to be greater than Class C low-level radioactive waste, with the ascribed acronym 'GTCC' low-level radioactive waste. Such waste was deemed not suitable for shallow land disposal based on the design standards for low-level radioactive waste landfills in place at that time. This resulted in a radioactive waste stream that had no disposal option. To remedy this problem, the US Congress in 1985 stipulated that the US Department of Energy would be responsible for the disposal of GTCC waste. Subsequently, the NRC amended its regulations to require GTCC low-level waste to be disposed in a geologic repository unless the Commission approved proposals for disposal in a low-level radioactive waste disposal facility. The Commission did not concurrently establish any specific technical requirements for GTCC disposal in a low-level radioactive waste disposal facility, but did infer that a site-specific performance analysis could be conducted in support of any proposal for land disposal of such waste. In light of this, Waste Control Specialists LLC (WCS) has conducted such a site-specific performance analysis that has indicated the disposal facility at Andrews Texas will perform satisfactorily as a disposal facility for certain types and quantities of GTCC waste. Concurrently with this analysis, WCS has submitted to the Texas Commission on Environmental Quality a petition for rulemaking that will permit disposal of GTCC waste in their disposal facility. This paper summarizes the technical and legal analyses that were conducted in support of the proposed rulemaking. (authors)