TableCalculator: a Transparent Public Tool to Replicate US NRC LLW Classification Table Calculations - 19395
Classification of Low-Level Waste (LLW) as Class A, B, C, or Greater than Class C (GTCC) is based on tables provided in Section 61.55 of Title 10 of the Code of Federal Regulations (CFR). Those tables were developed from model projections of dose to an inadvertent intruder in agricultural and construction scenarios at different times after closure of a LLW land disposal site. The calculations were performed with two FORTRAN codes, which are documented in US NRC guidance documents published in the early 1980's. Although the equations and parameter values used in the codes are publicly available, no modern, user-friendly implementation of the codes is known to US NRC staff. Because Very Low-Level Waste (VLLW) and GTCC waste disposal are related to the low end and high end of the existing LLW waste classifications, respectively, recent interest in options for disposal of VLLW and GTCC waste have generated public interest in the original assumptions made during the development of the LLW classification tables. Certain stakeholder analyses have recommended alternatives to the existing LLW concentration limits by calculating a projected intruder dose under different conditions than were evaluated in the original development of 10 CFR Part 61 (e.g., using more modern dosimetry or assuming deeper disposal) and comparing the radionuclide concentrations that result in a projected annual dose of 5 milliSieverts (mSv) (500 millirem (mrem)) total effective dose equivalent (TEDE) to the concentrations in the waste classification tables. However, beginning with the 10 CFR Part 61 LLW classification limits and modifying only one or two assumptions to generate a proposed concentration limit could lead to misleading results without a thorough analysis of whether other assumptions made in the original development of the waste classification tables remain valid. In particular, the US NRC made adjustments to the 10 CFR 61.55 table values during the rulemaking process based on qualitative considerations. Those adjustments mean that many of the values in the final tables cannot simply be assumed to quantitatively represent a 5 mSv (500 mrem) projected inadvertent intruder dose without an assessment of whether the technical bases used to develop the adjustments are applicable to the new analysis. Furthermore, the waste classification limits were based on the limiting critical organ dose rather than a TEDE. Therefore, any calculation based on the assumption that the waste classification limits correspond to 5 mSv (500 mrem) TEDE could benefit from consideration of how differences in exposure pathways could affect the limiting critical organ dose differently from the TEDE. To facilitate a more comprehensive understanding of the calculations used to develop the waste classification tables, the US NRC staff has developed a user-friendly tool to replicate the original calculations. Results were verified against output from the FORTRAN codes and the classification table values. The tool, TableCalculator, is expected to be made publicly available and will allow the user to trace the original calculations and to observe the effects of changes in disposal assumptions and other parameter values. (authors)