NRC Extends Comment Period re Part 61 Draft Regulatory Analysis

On November 24, 2017, the U.S. Nuclear Regulatory Commission (NRC) published a Federal Register notice reopening and extending the public comment period on the draft regulatory analysis, “Draft Regulatory Analysis for Final Rule: Low-Level Radioactive Waste Disposal.”  Among other things, the draft regulatory analysis seeks specific cost and benefit information to better inform the updated draft regulatory analysis.  (See 82 Federal Register 48,283 dated October 17, 2017.)

The comment period originally closed on November 16, 2017.  In order to allow more time for members of the public to develop and submit their comments, however, the NRC decided to reopen and extend the public comment period until December 18, 2017.

The Part 61 Working Group (P61WG) of the Low-Level Radioactive Waste Forum (LLW Forum), the South Carolina Department of Health and Environmental Control (SC DHEC) and the Utah Department of Environmental Quality’s Division of Waste Management and Radiation Control (Utah DEQ DWMRC) previously submitted comments on the draft regulatory analysis.

The Federal Register notice requesting public comment on the draft regulatory analysis is available at https://www.federalregister.gov/documents/2017/10/17/2017-22459/low-level-radioactive-waste-disposal. 

Comment letters from the P61WG, South Carolina and Utah regarding the draft regulatory analysis are available on the Resources Page of the Part 61 Working Group (P61WG) website at http://part-61.org/resources/. 

For additional information, please contact Gregory Trussell, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, at (301) 415-6445 or at Gregory.Trussell@nrc.gov.

DSWG Releases Report re Source Disposition Options and Costs

The Disused Sources Working Group (DSWG) of the Low-Level Radioactive Waste Forum (LLW Forum) is pleased to announce the release of its report titled, “Disposition Options and Costs for Certain Radioactive Sealed Sources and Devices.”

The report is intended to serve as a companion document to educational materials released by the DSWG earlier this year including educational brochures for current and prospective licensees of radioactive sealed sources and devices.

The new report can be accessed via a link on the Resources Page of the DSWG website at http://www.disusedsources.org/resources/#disposition.

Overview  The DSWG report is intended to assist stakeholders in understanding the likely options and estimated costs related to the disposition of common radioactive sealed sources and devices.  These include industrial radiography devices, fixed industrial gauges, well logging and brachytherapy sources, portable gauges, teletherapy devices, and both self-contained and panoramic irradiators.  Common characteristics of these devices are summarized in Table 1 at the end of the document.

Readers are cautioned that the information contained in the report is intended as a guide only, providing general information about the most common types of sources and devices.  The identified costs are provided as estimates only based on current information and guidance and should not be relied upon as determinative of actual future disposal costs.

Companion Documents  The new DSWG report on disposition options and costs is intended to serve as a companion document to educational brochures for current and prospective licensees of radioactive sealed sources and devices that were developed and released earlier this year by the DSWG in conjunction with the E-34 Committee of the Conference of Radiation Control Program Directors (CRCPD).   The brochures provide information regarding the ownership and use of radioactive sealed sources and devices including:

  • understanding the life-cycle costs including initial purchase price, regulatory license fees, financial assurance, operating expenses, security and end-of-life disposition;
  • consideration of the use of alternative technologies;
  • potential liabilities of using radioactive sealed sources or devices;
  • proper management and disposition of disused sources including information about the Source Collection & Threat Reduction (SCATR) Program — including a chart documenting the diminishing cost share — and the Off-Site Source Recovery Project (OSRP); and,
  • potential liabilities of storing disused sources.

Generic versions of the educational materials—which include fillable fields to incorporate individual office logos and contact information—are now available on the DSWG website to federal, state and industry stakeholders to modify and distribute as each deems appropriate.

Background  The LLW Forum is a non-profit organization of representatives appointed by Governors and compact commissions that seeks to facilitate state and compact implementation of the Low-Level Radioactive Waste Policy Act of 1980 and its 1985 amendments, as well as to promote the objectives of regional low-level radioactive waste disposal compacts.

In September 2011, the LLW Forum formed the DSWG to develop recommendations from the states and compacts for improving the management and disposition of disused sources.

For additional information about the LLW Forum and DSWG, please contact LLW Forum Executive Director and DSWG Project Director Todd D. Lovinger, Esq at (754) 779-7551 or at LLWForumInc@aol.com.

LLW Forum to Hold Spring 2018 Meeting

April 16-17, 2018 in San Francisco, California

The spring 2018 meeting of the Low-Level Radioactive Waste Forum (LLW Forum) will be held at the Hyatt Regency San Francisco Airport in Burlingame, California on April 16-17, 2018.  Please mark your calendars accordingly and save the date!  The Southwestern Low-Level Radioactive Waste Compact Commission is co-sponsoring the meeting with the LLW Forum.

Overview  The spring 2018 LLW Forum meeting will be held on Monday, April 16 (9:00 am – 5:00 pm) and Tuesday, April 17 (9:00 am – 1:00 pm) at:  

Hyatt Regency San Francisco Airport
1333 Bayshore Highway
Burlingame, California

The Hyatt Regency is located just minutes from the San Francisco International Airport on Interstate 101.  Complimentary shuttle service is available through the hotel 24 hrs a day.  In addition, the Bay Area Rapid Transit (BART) commuter train station with direct service to downtown San Francisco will also be available by shuttle service from the Hyatt Regency. 

Background  Officials from states, compacts, federal agencies, nuclear utilities, disposal operators, brokers/processors, industry, and other interested parties are encouraged to attend the spring 2018 LLW Forum meeting.

LLW Forum meetings are an excellent opportunity to stay up-to-date on the most recent and significant developments in the area of low-level radioactive waste management and disposal.  They also offer an important opportunity to network with other government and industry officials and to participate in decision-making on future actions and endeavors affecting low-level radioactive waste management and disposal.

If you have questions or require additional information, please contact Todd D. Lovinger, Esq.—Executive Director of the LLW Forum and Project Director of the Disused Sources and Part 61 Working Groups (DSWG/P61WG)—at (754) 779-7551 or at LLWForumInc@aol.com

Texas Compact Activity, Disposal Reporting and Pending Legislation

At the spring 2017 meeting of the Low-Level Radioactive Waste Forum (LLW Forum) in Denver, Colorado on April 24-25, 2017, the Executive Director of the Texas Low-Level Radioactive Waste Disposal Compact Commission (TLLRWDCC or Commission) provided the following information and overview related to Commission activities and operations.

Background

The Texas Low-Level Radioactive Waste Disposal Compact (Texas Compact) includes the State of Vermont and is not an agency of the State of Texas.  The TLLRWDCC is a “legal entity separate and distinct from the party states…”  The Commission must comply with its federal compact law and is charged with protecting the capacity of the compact facility for Texas and Vermont generators.

Limitations to Jurisdiction and Purview

The Texas Compact does not own or operate the compact facility, which is owned by the State of Texas and operated by Waste Control Specialists (WCS).  The Texas Compact does not set surcharges or charge fees of any type, nor does it determine licensing requirements or license the facility.  The Texas Commission on Environmental Quality (TCEQ) licenses the compact facility and approves waste streams.  The following matters are outside of the TLLRWDCC’s purview:  high-level waste, transuranic waste, Greater-than-Class C waste, spent fuel storage, NORM or TENORM, site operations at the compact waste facility (TCEQ), and waste shipments (TCEQ and DSHS).

Imports and Exports

The TLLRWDCC authorizes imports and exports in alignment with Texas policy and law and ensures protection of capacity.  For imports, the Commission has developed an approach based on:  a policy to ensure maximum disposal of allowed curies; the need for flexibility based on the regulatory and industry hurdles generators/brokers encounter; and, a need for a fair and unbiased allocation of curie availability.  The TLLRWDCC supports exports for good cause.  As such, it will be conducting an analysis of exported quantities.

Irradiated Hardware

Given that irradiated hardware can have a significant impact on the amount of curies disposed at the compact facility, the TLLRWDCC will continue to approve import applications as it always has with the exception of irradiated hardware.  Under the Commission’s policies, irradiated hardware must be submitted as a separate import application.  All requests over 15,000 curies, if approved, will be issued conditionally.  Once the generator submits documentation that substantiates volume, curies and shipment date, the Commission will release conditionally authorized curies, if available on a first come, first served basis.  This approach has been adopted as policy that can be found on the Commission’s website.

Forms and Automation

The TLLRWDCC rules require the use of an Import Application Form—a.k.a. “Annex A.”  The form is currently available as a pdf on the Commission’s website.  In addition, the Export Application Form and Generator Authorization Form are also available on the website.  The Commission is beginning work to automate import and export processing.  This will require the import and export forms to be fillable.

Annual Reporting and Disposal Numbers

Annual Reports are available at http://www.tllrwdcc.org/reports-more/.  The 2016 Annual Report is more robust and includes:  listing of import agreements, volume and curies; listing of export agreements; and, fees generated.  Disposal numbers in volume and curies for imported waste and in-compact waste are available at http://www.tllrwdcc.org/reports-more/.

Legislative Activities

Because the Texas Compact receives funding through the State of Texas appropriation process, the status of the Compact as an agency presents confusion.  The Texas Compact is with working with the legislature to provide clarification to State of Texas employees that the Texas Compact is a “legal entity separate and distinct from the party states …”  During the current legislative session, two items—SB 1667 by Senator Seliger and HB 3946 by Representative Landgraf—have been filed as companion bills.  SB 1667 and HB 3946 relate to the nature, funding, and functions of the TLLRWDCC.

Management Rule

TLLRWDCC Commissioner Linda Morris chairs a committee that is charged with drafting rules for management of low-level radioactive waste in the Texas Compact.  These rules will have applicability in Vermont.  The scope of the rule will likely include only reporting requirements.  The rulemaking will include an informal comment period before instituting the formal process.

Workshops

In September 2016, the Texas Compact conducted its first workshop in Burlington, Vermont.  The workshop was geared toward Vermont generators.  The Texas Compact is considering doing a similar workshop for Texas generators, particularly small generators.  The compact will also consider workshops for larger generators, as may be needed.

For additional information, please contact Texas Compact Commission Executive Director Leigh Ing at (512) 305-8941 or at leigh.ing@tllrwdcc.org

LLW Forum Releases Report re Compact Import-Export Requirements

The Low-Level Radioactive Waste Forum (LLW Forum) is pleased to announce the release of a report on Compact Import and Export Requirements.  The report, which was prepared by the Disused Sources Working Group (DSWG), includes links to each individual low-level radioactive waste compact’s websites, as well as links to any applicable policy statements and forms.  For those compacts that have export and/or import permit requirements, a brief explanation of the program is provided.  Any specific questions about a compact’s permit program should be addressed to the respective compact.  The contact information is available on the compact’s website.

The LLW Forum is a non-profit organization of representatives appointed by Governors and compact commissions that seeks to facilitate state and compact implementation of the Low-Level Radioactive Waste Policy Act of 1980 and its 1985 amendments, as well as to promote the objectives of regional low-level radioactive waste disposal compacts.   In September 2011, the LLW Forum formed the DSWG to develop recommendations from the states and compacts for improving the management and disposition of disused sources.

For additional information about the LLW Forum and DSWG, please contact LLW Forum Executive Director and DSWG Project Director Todd D. Lovinger, Esq at (754) 779-7551 or at LLWForumInc@aol.com.

A copy of the report can be found on the LLW Forum website at http://llwforum.org/about/#compact.

LLW Forum Announces Details re Fall 2017 LLW Forum Meeting

The Low-Level Radioactive Waste Forum (LLW Forum) is pleased to announce that our fall 2017 meeting will be held on Monday, October 16 (9:00 am – 5:00 pm) and Tuesday, October 17 (9:00 am – 1:00 pm) at: 

Hilton Alexandria Old Town Hotel
1767 King Street
Alexandria, Virginia

Located in the historic, vibrant King Street neighborhood, the Hilton Alexandria Old Town hotel is one of the most convenient hotels in Alexandria, Virginia for business and leisure travelers visiting the Washington, DC metropolitan area.  The hotel is just steps away from King Street Metro station and close to Reagan National Airport.  Downtown DC attractions and government buildings are minutes away by metro.

The Southeast Compact Commission for Low-Level Radioactive Waste Management and the Central Interstate Low-Level Radioactive Waste Compact Commission are co-sponsoring the meeting.

If you have questions or require additional information, please contact Todd D. Lovinger, Esq.—Executive Director of the LLW Forum and Project Director of the Disused Sources and Part 61 Working Groups (DSWG/P61WG)—at (754) 779-7551 or at LLWForumInc@aol.com

Registration Open for Spring 2017 LLW Forum Meeting

Embassy Suites Downtown Hotel in Denver, Colorado

April 24-25, 2017

The Low-Level Radioactive Waste Forum (LLW Forum) is pleased to announce that registration is now open for our spring 2017 meeting, which will be held at the Embassy Suites Downtown Convention Center Hotel in Denver, Colorado on April 24-25, 2017.  Please mark your calendars accordingly and save the date!

Interested stakeholders are encouraged to register and make hotel reservations for the meeting at your earliest convenience, as there is limited space available in our discount room block.

The Rocky Mountain Low-Level Radioactive Waste Board and Midwest Interstate Low-Level Radioactive Waste Compact Commission are co-sponsoring the meeting.

The meeting documents—including a meeting bulletin and registration form—have been posted to the LLW Forum’s web site at www.llwforum.org.

As a new option for interested stakeholders, a registration form may be completed and submitted online by going to the bottom of the LLW Forum web site’s home page at www.llwforum.org.

Attendance

Officials from states, compacts, federal agencies, nuclear utilities, disposal operators, brokers/processors, industry, and other interested parties are encouraged to attend the spring 2017 LLW Forum meeting.

LLW Forum meetings are an excellent opportunity to stay up-to-date on the most recent and significant developments in the area of low-level radioactive waste management and disposal.  They also offer an important opportunity to network with other government and industry officials and to participate in decision-making on future actions and endeavors affecting low-level radioactive waste management and disposal.

Location and Dates

The spring 2017 LLW Forum meeting will be held on Monday, April 24 (9:00 am – 5:00 pm) and Tuesday, April 25 (9:00 am – 1:00 pm) at: 

Embassy Suites by Downtown Convention Center Hotel
1420 Stout Street
Denver, Colorado 80202

The hotel offers a gateway to Denver’s lively downtown scene.  Boasting a contemporary convention venue, the hotel is within walking distance of the best attractions in the downtown area.

Registration

All persons must pre-register for the meeting and pay any associated registration fees in order to be allowed entry.  Registration forms are needed in order to ensure that you receive a meeting packet and name badge.  Accordingly, interested attendees are asked to please take a moment to complete the registration form at your earliest convenience and return it to the Administrator of the Rocky Mountain Board at the mailing address, e-mail or fax number listed at the bottom of the form.

The meeting is free for up to two individuals representing members of the LLW Forum.  Additional and non-member registration is $500, payable by check only to the “LLW Forum, Inc.”  (Credit card payments are not accepted.)

Reservations

Persons who plan to attend the meeting are strongly encouraged to make their hotel reservations and send in their registration forms as soon as possible, as we have exceeded our block at the last few meetings.

A limited block of hotel rooms has been reserved for Sunday, April 23rd and Monday, April 24th at the rate of $178.00 plus tax per night (for single/double occupancy).

To make a reservation, please call (800) 445-8667.  Please ask for the LLW Forum block in order to get the discounted meeting rate.

The deadline for reserving a room at the discounted rate is Wednesday, April 5, 2017.

Transportation and Directions

From Denver International Airport (DIA), one way taxi fare is available for approximately $70.00.  Another option is the train from DIA to Union Station downtown.  From Union Station, you can walk or take the 16th street mall shuttle the additional 1.2 miles to the hotel off of Stout Street.

If you have questions or require additional information, please contact Todd D. Lovinger, Esq.—Executive Director of the LLW Forum and Project Director of the Disused Sources and Part 61 Working Groups (DSWG/P61WG)—at (754) 779-7551 or at LLWForumInc@aol.com

Registration Open for the Fall 2016 LLW Forum Meeting

Registration is now open for the fall 2016 Low-Level Radioactive Waste Forum (LLW Forum) meeting, which will be held at the Embassy Suites by Hilton Saratoga Springs Hotel on November 7-8, 2016.  Interested stakeholders are encouraged to register and make hotel reservations for the meeting at your earliest convenience, as there is limited space available in our discount room block.  The New York State Energy and Research Development Authority (NYSERDA) is sponsoring the meeting.

The meeting documents—including bulletin and registration form—have been posted to the LLW Forum’s web site at www.llwforum.org.

Attendance

Officials from states, compacts, federal agencies, nuclear utilities, disposal operators, brokers/processors, industry, and other interested parties are invited and encouraged to attend.

The meeting is an excellent opportunity to stay up-to-date on the most recent and significant developments in the area of low-level radioactive waste management and disposal.  It also offers an important opportunity to network with other government and industry officials and to participate in decision-making on future actions and endeavors affecting low-level radioactive waste management and disposal.

Location and Dates

The fall 2016 LLW Forum meeting will be held on Monday, November 7 (9:00 am – 5:00 pm) and Tuesday, November 8 (9:00 am – 1:00 pm) at:

Embassy Suites by Hilton Saratoga Springs
86 Congress Street
Saratoga Springs, New York 12866

Located in the heart of downtown Saratoga Springs, the Embassy Suites is walking distance to the Saratoga Heritage Area Visitor’s Center, Congress Park, the Canfield Casino, and Broadway for its restaurants and shopping.

Registration

All persons must pre-register for the meeting and pay any associated registration fees in order to be allowed entry.  Registration forms are needed in order to ensure that you receive a meeting packet and name badge.  Accordingly, interested attendees are asked to please take a moment to complete the registration form at your earliest convenience and return it Cecilia Snyder of the LLW Forum at the address, e-mail or fax number listed at the bottom of the form.

The meeting is free for up to two individuals representing members of the LLW Forum.  Additional and non-member registration is $500, payable by check only to the “LLW Forum, Inc.”  (Credit card payments are not accepted.)

Reservations

Persons who plan to attend the meeting are strongly encouraged to make their hotel reservations and send in their registration forms as soon as possible, as we have exceeded our block at the last few meetings.

A limited block of hotel rooms has been reserved for meeting attendees for Sunday (November 6) and Monday (November 7) at the prevailing federal per diem rate (which is currently $120/night) plus tax/single or double.  A limited number of rooms are available at this rate for one day prior to and one day following the meeting, subject to availability.

To make a reservation, please call 1-800-HILTONS and ask for a room in the “LLW Forum block” at the Embassy Suites Saratoga Springs or use the following dedicated link:  http://embassysuites.hilton.com/en/es/groups/personalized/A/ALBESES-LLW-20161105/index.jhtml?WT.mc_id=POG

In order to receive the discounted rate, please make your reservation by October 6, 2016.

Transportation and Directions

Saratoga Springs is a 30-minute drive from the Albany International Airport.  A taxi from the airport to the hotel is a minimum estimated charge of $50/each way.   Driving directions from both airports can be found at http://embassysuites3.hilton.com/en/hotels/new-york/embassy-suites-by-hilton-saratoga-springs-ALBESES/maps-directions/index.html.  Parking at the hotel is free.

For additional information, please contact Todd D. Lovinger, the LLW Forum’s Executive Director, at (754) 779-7551 or go to www.llwforum.org.