Low-Level Radioactive Waste Management in North Carolina SUBMITTED TO THE

North Carolina General Assembly BY THE

North Carolina Radiation Protection Commission April 2007 Table of Contents Executive Summary

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Current Status of LLRW Disposal Facilities

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Current Status of LLRW Management and Activities Undertaken by the Radiation Protection Section

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Lessons Learned from 1995-2000 LLRW Storage

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North Carolina and Southeast Compact Commission Issues

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Appendices A.

Annual Review of the Need for Rulemaking and/or Regulatory Guidance on LLRW Storage – published by the Nuclear Regulatory Commission

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B.

Session Law 1999-357 – An Act Withdrawing North Carolina from the Southeast Interstate LLRW Management Compact

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C.

List of Members on the North Carolina Radiation Protection Commission & the Low-Level Radioactive Waste Management Committee

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Executive Summary A major issue identified in the 2006 Low-Level Radioactive Waste Management report that was submitted to the General Assembly was the scheduled closure of the Barnwell, South Carolina disposal facility in July 2008 to all low-level radioactive waste (LLRW) generators except those in South Carolina, Connecticut and New Jersey. The scheduled closure of Barnwell is still the primary issue of concern to North Carolina generators of LLRW. When the closure of Barnwell occurs, certain waste types might not have a disposal avenue available for North Carolina LLRW generators. Based on the scheduled closure of Barnwell to out of compact generators including North Carolina in 2008, it may be necessary for North Carolina LLRW generators to develop long term on-site storage contingency plans for dealing with some portion of their LLRW after June 30, 2008. For this reason, the future of LLRW disposal remains unpredictable and will need to be monitored closely over the next few years. In the 2006 report, the North Carolina Radiation Protection Commission (RPC) recommended the following: 1. Annual reporting by the RPC to the North Carolina General Assembly during 2007 and 2008 since the dynamics and landscape of LLRW management will change dramatically. 2. The Radiation Protection Section (RPS) should focus their continued assistance to North Carolina LLRW generators in support of reducing waste inventories before the closure of Barnwell. 3. The addition of North Carolina regulatory and statutory requirements for LLRW generators to submit an annual report of LLRW information requested by the RPC, LLRW Committee. These recommendations remain valid.

This report provides current information on the status of LLRW

management in NC and the related activities of the RPC and the Radiation Protection Section (RPS).

Current Status of LLRW Disposal Facilities North Carolina LLRW generators currently have several options for the management of their LLRW. Processing facilities throughout the United States are currently accepting LLRW and using a variety of management techniques for processing. The two disposal facilities, Barnwell and Clive, are operated by EnergySolutions, LLC. North Carolina LLRW generators currently have access to these facilities for disposal of their LLRW.

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Barnwell, South Carolina The Barnwell Facility in South Carolina is currently available for disposal of commercially generated LLRW. At this time, the Barnwell site accepts Class A, B and C wastes and sealed sources for disposal. After June 30, 2008, the site will only accept waste from Atlantic Compact generators located in South Carolina, Connecticut and New Jersey. Under South Carolina law, the Barnwell facility has limited the total annual volume received at the site. The maximum LLRW disposal volumes that Barnwell will be allowed to receive for the remaining years are: 40,000 cubic feet in fiscal year 2007 35,000 cubic feet in fiscal year 2008 0 cubic feet from out-of-compact generators, including those in North Carolina – July 1, 2008 Of those amounts, approximately two-thirds are currently committed under contract. In addition, set aside volume for LLRW from Atlantic Compact generators has been allocated. Based on these commitments, projections are being made concerning how much waste to expect from the remaining customers who do not have specific importation agreements. It is noted that obtaining a permit and entering into a contract with the disposal site operator does not guarantee access to the disposal site. *Note - At the time of publication, legislation in South Carolina had been introduced that would keep Barnwell open to out-of-compact waste beyond the June 30, 2008 deadline.

Clive, Utah The facility in Clive, Utah (formerly known as Envirocare) is operated by EnergySolutions and is licensed to accept Class A waste and uranium mill tailings for disposal. This Clive site can also accept some mixed waste within limits determined by specific activity and isotope. The Clive site does not accept Class B or Class C wastes, nor do they currently accept sealed sources for disposal. However, this site has requested state approval to accept sealed sources for disposal that meet Class A criterion.

Current Status of LLRW Management and Activities Undertaken by the RPS Currently, the RPS has 1,960 radioactive material licensees, which encompass a wide variety of different types of licenses. Although the total number of active North Carolina licensees generating LLRW is 70, each radioactive 3

material licensee may at sometime have the need to dispose of their radioactive material as LLRW or transfer the material to a new licensed owner. Currently, there are 10 North Carolina facilities that are licensed by the Nuclear Regulatory Commission (NRC), a federal agency.

A listing of North Carolina LLRW disposal information from Barnwell and Clive are as follows: 2003

2004

2005

2006

Volume(ft3)

Activity (Ci)

Volume(ft3)

Activity (Ci)

Volume(ft3)

Activity (Ci)

Volume (ft3)

Activity (Ci)

Barnwell

423

484

450

34,482

685

35,551

740

96,556

Clive

366,615

168

163,086

470

254,647

60

191,749

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Based on the scheduled closure of Barnwell to out of compact generators including North Carolina in 2008, it may be necessary for North Carolina LLRW generators to develop long term on-site storage contingency plans for dealing with some portion of their LLRW after June 30, 2008. This also applies to licensees needing to dispose of sealed sources.

In preparation for the closure of the Barnwell facility, the Radioactive Materials Branch of RPS has recently sent notification letters to all North Carolina radioactive material licensees. These letters have been divided into three categories, 1) General Notification, 2) LLRW Generator Notification and 3) NRC Licensee Notification.

The General Notification letter was sent to about 1,900 North Carolina radioactive material licensees alerting them of the scheduled closure of the Barnwell disposal facility. The LLRW Generator Notification letter was sent to about 70 North Carolina radioactive material licensees alerting them of the scheduled closure of the Barnwell disposal facility as well as informing them of an administrative license amendment that would be enacted requiring them to submit an annual LLRW management report in March of each calendar year. The NRC Licensee Notification letter was sent to the 10 NRC licensees alerting them of the scheduled closure of the Barnwell disposal facility and requesting that they submit an annual LLRW management report in March of each calendar year.

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These annual reports will be combined into a final report for LLRW Management in North Carolina each calendar year to monitor any changes that have occurred and to assess the overall climate of generation, storage, management and disposal of LLRW.

Lessons Learned from 1995-2000 LLRW Storage During 1996 and 1997, LLRW generators were contacted to inquire about their current and future waste management practices, including questions on: •

Types of wastes currently generated

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Use of brokers and/or processors for waste treatment and disposal

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Adequacy of current management options for entire waste stream

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Future projections for management and storage of their LLRW

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Strategies used after North Carolina was banned from disposal at Barnwell

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Preference among the three options for LLRW management listed in the September 1999 GAO report entitled, Low-Level Radioactive Wastes – States are not Developing Disposal Facilities

We learned that many different types of LLRW were being generated throughout North Carolina. Most generators were using brokers to package their waste for shipment to out-of-state processing and/or disposal.

LLRW

generators stated that their existing management/processing/disposal options were sufficient for all of their LLRW with the exception of two types of waste, Class B and C waste. These generators were storing their Class B and C waste on-site awaiting disposal. The only disposal facility available to North Carolina generators for Class A waste at the time was Envirocare of Utah.

When questioned about current and projected availability and adequacy, generators stated that the current available management options were adequate and sufficient for their waste. The main concern was for the future. Generators stated as long as they had access to the current out-of-state disposal and treatment facilities they would be able to manage their waste.

If access to out-of-state processing and disposal facilities were restricted, most generators would not be able to store their waste for very long before having to add more storage capacity. Some generators stated they could only store waste for several months before having to add more storage; however, others stated they could store indefinitely. Generators were questioned about their actions after South Carolina denied North Carolina generators access to the Barnwell, SC disposal facility, effective July 1995. Their actions included one or more of the following: changing 5

radioactive material processes, minimizing waste, increasing storage capacity for LLRW, looking for other disposal options, employing volume reduction processes, buying waste compactors for on-site use and storing waste until another disposal option became available.

In summary, we learned: ¾ Between 1995 and 2000 the projected availability of facilities for the management of Class A waste was adequate as long as the generators continued to have access to the existing out-of-state processing and disposal facilities. ¾ A small number of LLRW generators were able to safely store their Class B and C waste, as long as they continued to have access to the existing out-of-state processing facilities.

However, these

generators eventually would need a disposal option for their Class B and C waste. ¾ A small number of radioactive material licensees who wanted to terminate their radioactive materials license were required to maintain their license for storage of their radioactive material or radioactive waste while waiting for a disposal option to become available. ¾ A majority of the generators stated that the compact system should be abandoned and the disposal market opened to the private industry.

North Carolina and Southeast Compact Commission Issues The Southeast Compact Commission (SECC) filed suit against North Carolina for $90 million. The U.S. Supreme Court dismissed the suit because the SECC was not a state. In 2002 - Alabama, Virginia, Tennessee, Florida & the SECC filed suit against NC for $90 million. The suit requested that the $90 million be paid back to the SECC. The U.S. Supreme Court decided it will hear the case and appointed a Special Master. The State of North Carolina filed a motion to dismiss the SECC from the case. The Special Master issued a preliminary report which indicated that although he would not recommend dismissing SECC, he also would not recommend enforcement of the SECC's 1999 sanctions against North Carolina. Instead, the matter will proceed to trial on other issues related to whether NC breached the Compact or otherwise is obligated to return $90 million to the plaintiffs. The trial is not anticipated to begin before 2008.

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Appendix A Policy Issue Information published by the Nuclear Regulatory Commission (SECY-06-0193) September 6, 2006 Annual Review of the Need for Rulemaking and/or Regulatory Guidance on LLRW Storage PURPOSE: This paper responds to the Commission's staff requirements memorandum (SRM) dated January 29, 2004, addressing SECY-03-0223, "Rulemaking Plan: Assured Isolation Facilities," dated December 24, 2003. In the SRM, the Commission directs the staff to "defer rulemaking on assured isolation facilities at this time and to annually review the need for further action in this area. The annual review should include not only the need for potential rulemaking associated with assured isolation facilities but also the potential need for rulemaking and/or regulatory guidance for long term storage of low-level radioactive waste in general." This paper informs the Commission of the results of the staff's annual review and of the staff's intent to initiate activities to update existing long-term LLRW storage guidance. SUMMARY: This paper provides the staff's basis for departing from the results of previous assessments that revision of guidance related to the long-term storage of LLRW was unnecessary. SECY-05-0024, "Annual Review of Need for Rulemaking on Low-Level Waste Storage," dated January31, 2005, foresaw no need for a rulemaking on assured isolation facilities and no immediate need for supplemental rulemaking/guidance associated with long-term LLRW storage. The staff still considers rulemaking to address long-term storage unnecessary. The current regulatory framework continues to provide an adequate basis for regulation of stored radioactive material including LLRW. However, for reasons outlined herein, the staff now considers reviewing and updating guidance for the long-term storage of LLRW to be a valuable endeavor particularly in light of the legislatively mandated (see below) closure of the Barnwell LLRW disposal facility in 2008. The staff has identified no policy issues raised by this paper or the initiative described herein. If policy issues are identified in the implementation process, the staff will request guidance from the Commission. BACKGROUND: Current Status of Commercial LLRW Disposal: The U.S. Nuclear Regulatory Commission (NRC) has stated, on numerous occasions, that permanent disposal is the preferred management option for LLRW. Over the past two decades, however, permanent disposal of LLRW at commercial facilities has become costly and sometimes problematic. In addition, access to the facilities could become more limited in the future. As reported in SECY-05-0024, the future availability of disposal capacity is somewhat uncertain, particularly for Class B and C waste. SECY-05-0024 cites a June 2004 Government Accountability Office (GAO) report to the Senate Committee on Energy and Natural Resources (GAO-04-604, "Low-Level Radioactive Waste-Disposal Availability Adequate in the Short-Term, but Oversight Needed to Identify Any Future Shortfalls"). In that document, GAO reported that commercial disposal capacity is adequate for the short term, but that options for users of radioactive materials who generate Class B and C LLRW are likely to be limited after 2008. On July 1, 2008, South Carolina, pursuant to a requirement in the Atlantic Interstate Low-Level Radioactive Waste Compact Implementation Act (Title 48 SCC, Chapter 46), is expected to close the Barnwell facility to all but member States of the Atlantic Compact (South Carolina, Connecticut, and New Jersey). This circumstance will foreclose disposal 7

of Class B and C LLRW to generators in 36 States, the District of Columbia and the Commonwealth of Puerto Rico. The commercial LLRW facility near Richland, Washington, is expected to continue to serve as the regional full service compact facility for the Northwest and Rocky Mountain Compacts. If Barnwell is unavailable to all but Atlantic Compact states, only the Clive, Utah, LLRW disposal facility will be open to the entire Nation. The Clive site is licensed to accept only Class A LLRW. The Texas Commission on Environmental Quality is currently reviewing a license application for a commercial LLRW disposal site near Andrews, Texas. If licensed, the facility is earmarked to serve the commercial LLRW disposal needs of generators in the Texas Compact (i.e., Texas and Vermont). The cost to dispose of LLRW has increased dramatically since the early 1980's, providing one incentive to store, rather than dispose of, LLRW. At the Barnwell LLRW facility, the price for disposal of some out-of-compact Class B and C waste exceeds $2,600 per cubic foot, including taxes and surcharges. The Health Physics Society (HPS) has cited the high cost of LLRW disposal as an impediment to the beneficial use of some radioactive material. In background information for the HPS September 2005, position statement, "Low-Level Radioactive Waste Management Needs a Complete and Coordinated Overhaul," HPS reports that disposal of some bulk Class A LLRW under government contract at the Utah facility is as low as $5 per cubic foot. Disposal of Class A waste at Barnwell or Richland can exceed $200 per cubic foot. While all types of licensees are concerned with cost escalation, such increases particularly impact some materials users in the medical and research communities. According to the HPS, some medical research has been curtailed because of the high cost of waste disposal. At a recent Advisory Committee on Nuclear Waste working group meeting on LLRW, Dr. Joseph Ring, of Harvard University, confirmed that the cost of LLRW disposal has negatively impacted some research programs. Recently, the cost to dispose of one drum of LLRW generated at a Harvard research facility was $27,000. In some cases, facility specific waste acceptance criteria also constrain LLRW disposal. For example, disposal of LLRW generated during one particular cleanup is complicated by the presence of both "traditional" byproduct material and radium in the waste stream. Such waste is excluded from Barnwell because of the radium and cannot be accepted at Richland due to Compact restrictions on byproduct material. Overview of Currently Existing LLRW Storage Guidance: NRC developed its existing guidance for the long-term storage of LLRW in the 1980's and early 1990's. The agency issued Generic Letter 81-38 "Storage of Low-Level Radioactive Wastes at Power Reactor Sites," which provides much of the substantive guidance related to the long-term storage of LLRW generated at nuclear power plants, on November 10, 1981. Similarly, on February 5, 1990, NRC issued Information Notice 90-09, "Extended Interim Storage of Low-Level Radioactive Waste by Fuel Cycle and Materials Licensees." While the governing concepts offered in the guidance are still valid, some of the implementing detail may not be. For instance, current guidance may contain information or suggestions that are inconsistent with or, at least, not reflective of current technology, since technology employed in the packaging, handling, and monitoring of stored LLRW has evolved over the past two decades. Current NRC guidance exists in many forms (generic letters, information notices, NUREGs, inspection procedures, branch technical positions, the staff health physics position papers and others), some of which are redundant. Furthermore, some references, particularly to 10 CFR Part 20, "Standards for Protection Against Radiation," are out of date. Some Agreement States have also developed and implemented guidance and, in some cases, regulations related to the long-term storage of LLRW. Furthermore, some Agreement and Non-Agreement States may have developed storage guidance related to naturally occurring and accelerator produced radioactive material, including waste, that is now subject to NRC regulatory oversight as a result of the Energy Policy Act of 2005 (EPAct 2005). The last major staff initiative to update LLRW long-term storage guidance occurred in 1994. At that time, the staff compiled all major guidance for both nuclear power plant and radioactive material facilities (SECY-94-198, 8

"Review of Existing Guidance Concerning the Extended Storage of Low-Level radioactive Waste," issued August 1, 1994). Much of the impetus for that effort came from the pending closure of the Barnwell LLRW disposal facility to the majority of the Nation's LLRW generators. When Barnwell reopened after a brief closure, the urgency for updated and consolidated LLRW storage guidance diminished and the staff efforts were redirected. Since then, the staff has reported to the Commission that significant efforts directed toward either rulemaking or updated guidance for the extended storage of LLRW were unnecessary. DISCUSSION: In late 2005, the staff of the Division of Waste Management and Environmental Protection conducted limited discussions with other NRC headquarters offices, NRC Regional staff, State radiation control personnel and cognizant industry personnel on the subject of LLRW storage guidance. The discussion in this paper reflects insights received from these limited consultations. Status of LLRW Storage in the United States: Licensees cite various reasons for storing LLRW, including to allow for decay of short-lived radioactive materials to innocuous levels to avoid the need for disposal in a LLRW facility, as well as economical benefits of storing radioactive waste before disposal, broker/processor backlog, the high cost of disposal, and concerns about the potential liability involved with sending waste to a disposal site. Since the mid-1990's, NRC and the Agreement States have allowed on-site storage of LLRW without a specified time limit as long as it is demonstrably safe. NRC and Agreement State inspection programs confirm safe storage. Since September 2001, security, as well as safety, of stored LLRW has assumed increased importance and regulatory scrutiny. In GAO-04-0604, GAO has acknowledged that storage is presently safe, but has reiterated the NRC's concern about the future safety and security of the increasing volumes of LLRW stored by thousands of licensees who may not have disposal options for Class B and C wastes in the future. Changes since the Development of LLRW Storage Guidance: Since NRC promulgated its LLRW long-term storage guidance, NRC regulations have changed significantly. For example, in the 1990s, the agency substantially revised 10 CFR Part 20. Many of the new and updated portions directly impact LLRW storage. These include, but are not limited to, changes in technology, personnel dosimetry, monitoring, container labeling, posting, and security of stored radioactive material. EPAct 2005 gives NRC increased regulatory responsibility for some naturally occurring radioactive material, such as discrete-source radium, as well as some accelerator produced radioactive material. Long-term storage of this material may introduce considerations for which additional guidance is appropriate. Since September 11, 2001, the security aspects of stored LLRW have received increased regulatory attention. Waste stored at licensed facilities is secure at present. However, some licensees may not be fully prepared for storing and securing increased volumes of LLRW for the long-term. NRC has promulgated increased controls and implementing guidance for licensees that possess radioactive material in quantities of concern. It may be appropriate for the agency to incorporate this guidance by reference, or by reporting relevant portions, in updated guidance for LLRW storage. It is also likely that changes in technology have occurred over the past several decades that may, at least, impact guidance implementation. These may include changes in waste characteristics, waste form and packaging, and aspects of storage venues, as well as methods and mechanisms for monitoring and moving stored waste. Staff Plans to Address Gaps/Shortcomings: NRC staff believes that a review of current long-term LLRW storage guidance with respect to statutory, regulatory, technology and policy changes, discussed briefly above, is likely to identify some gaps and shortcomings. Therefore, staff intends to begin work in Fall 2006 reviewing and annotating primary (e.g. NUREG 1556, Inspection Procedure 84900) and source documents (e.g. Information Notice 90-09, Policy and Guidance Directive 9

94-05) providing guidance related to long-term storage of LLRW. This review will focus on changes in NRC policy and practice related to radioactive waste safety and security since LLRW storage guidance was originally promulgated. Analyses will include consolidation with NRC regional personnel with licensing and inspection expertise related to long-term storage of LLRW. Staff also intends to consult with radiation control professionals in Agreement States both individually and, as appropriate, collectively through the Organization of Agreement States and the Conference of Radiation Control Program Directors. To the extent that one or more states may have already developed and deployed guidance that is responsive to needs identified in this effort, LLRW staff will, to the extent practicable, adopt and incorporate such guidance. Staff further intends to inform its analysis with the results of a gap analysis specific to the dispositioning of radioactive material of greatest security concern with respect to radiological dispersal devices prepared by the DOE/NRC Interagency Working Group on Radiological Dispersal Devices (May 2003). Staff believes that some of the gaps identified in this effort, particularly those related to storage of Class B and C waste at nuclear materials facilities, may represent a more immediate need for mitigation given the likely closure of the Barnwell LLRW disposal facility in 2008. Industry and State representatives have noted that nuclear utilities and fuel cycle facilities are better prepared to deal with the safety and security aspects of long-term LLRW storage than many materials licensees. They have both the infrastructure and experience to ensure adequate long-term storage based on current guidance. Further, the Electric Power Research Institute is in the process of developing detailed implementation guidance for storage of LLRW at nuclear power plants. For this reason, the staff will focus on the needs of materials licensees in the development of updated or supplemental guidance. Consultation and coordination with other NRC headquarters offices, NRC regional offices, State radiation control personnel and industry representatives will continue as noted above. No additional resources other than those already allocated (see below) are currently foreseen. Staff will align any follow-on effort to update and consolidate all LLRW longterm storage guidance, if deemed appropriate, in accordance with priorities established via its LLRW Strategic Assessment. COMMITMENTS: The staff has committed to the following actions in this paper: •

Beginning in the fall of 2006, perform a gap analysis of existing LLRW long-term storage guidance necessary to develop updated or supplemental guidance for materials licensees to address the loss of disposal capacity for many Class B and C waste generators as a result of the likely closure of the Barnwell LLRW disposal facility scheduled for July 2008.

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Appendix B 1999 Session S.L. 1999-357 GENERAL ASSEMBLY OF NORTH CAROLINA SESSION 1999 SESSION LAW 1999-357 SENATE BILL 247 AN ACT TO WITHDRAW NORTH CAROLINA FROM THE SOUTHEAST INTERSTATE LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT COMPACT, TO LIMIT THE AUTHORITY OF THE LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT AUTHORITY AND TO DIRECT THE RADIATION PROTECTION COMMISSION TO STUDY AND FORMULATE A PLAN FOR LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT. The General Assembly of North Carolina enacts: Section 1. In accordance with the provisions of G.S. 104F-1, Article VII, Section (g) of the General Statutes, North Carolina hereby withdraws from membership as a party state in the Southeast Interstate Low-Level Radioactive Waste Management Compact. Section 2. Chapter 104F of the General Statutes is repealed. Section 3. Notwithstanding any provision of Chapter 104G of the General Statutes to the contrary, the sole function of the North Carolina Low-Level Radioactive Waste Management Authority shall be to take all necessary actions to complete the process of closure and restoration of the proposed Wake County low-level radioactive waste site, and to finalize all other responsibilities and business of the Authority relating to closure and restoration on or before June 30, 2000. Section 4. Chapter 104G of the General Statutes is repealed effective July 1, 2000. Section 5. The North Carolina Radiation Protection Commission is directed to review and study the current and projected availability and adequacy of facilities for the management of low-level radioactive waste produced by North Carolina generators, and to formulate a recommended plan for complying with North Carolina’s responsibi1ities under the Low-Level Radioactive Waste Policy Act of 1980, Pub. L. No. 96-573, 94 Stat. 3347, and the Low-Level Radioactive Waste Policy Amendments Act of l985, Pub. L. 99-240, 99 Stat. 1842, 42 U.S.C. 202 lb, et seq. The Commission shall report its findings and recommendations to the General Assembly on or before May 15, 2000. No license application for a low-level radioactive waste facility shall be issued or considered by the Department of Environment and Natural Resources prior to action by the General Assembly establishing a plan for future management of low-level radioactive waste. Section 6. Sections 1, 2, 3, 5, and 6 of this act are effective when they become law. Section 4 of this act becomes effective July 1, 2000. In the General Assembly read three times and ratified this the 20th day of July, l999. s/ Marc Basnight President Pro Tempore of the Senate s/ James B. Black Speaker of the House of Representatives s/ James B. Hunt, Jr. Governor Approved 10:15 a.m. this 26th day of July, 1999

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Appendix C North Carolina Radiation Protection Commission Commission Members Wayne R. Thomann, Dr.P.H., Chairman Robert K. Andrews, Jr. Bernadine S. Ballance Charles Barry Burns, MSPH Rhonda S. Cohen, D.P.M. Holly J. Burge, M.D. Marion E. Deerhake Eugene A. Lewis, D.C., M.P.H. David J. DeMaster, Ph.D. Roy Ericson Anthony B. Bonapart Robert J. Fitzgerald Beverly O. Hall Larry E. Haynes, CHP Doug Hoell Chris G. Hoke John B. Ludlow, D.D.S. Allen M. Mabry, CHP Carmine M. Plott, Ph.D., CHP Daniel D. Sprau, Dr.P.H. Suzanne Taylor Commission Counsel James P. Longest, Jr.

Commission Position Hospital Administrator Board of Transportation Industrial Commission Radiologic Technologist Podiatrist Physician, North Carolina Medical Society Environmental Management Commission North Carolina Chiropractic Association Faculty, Institution of Higher Learning Utilities Commission Department of Labor Medical Care Commission Radiation Protection Section Nuclear Electric Utility Division of Emergency Management Commission for Health Services Dentist, North Carolina Dental Society Atomic Energy, Other Than Power Generation Expert from the State-At-Large Environmental Protection Department of Insurance Special Deputy Attorney General

Low-Level Radioactive Waste Management Committee Allen M. Mabry, CHP, Chairman

Representing Atomic Energy, Other than Power Generation

Marion E. Deerhake

Representing the Environmental Management Commission

David J. DeMaster, Ph.D.

Representing Faculty of Institution of Higher Learning

Beverly O. Hall

Section Chief of Radiation Protection Section

Larry E. Haynes, CHP

Representing Nuclear Electric Utility

Suzanne Taylor

Representing the Department of Insurance

Alan Call, Committee Resource

United States Environmental Protection Agency

Ken Ritchie, Committee Resource

Research Triangle Institute

James P. Longest, Jr.

Counsel to Committee

Wendy B. Tingle

Staff to Committee, Radioactive Waste Coordinator

12 February 2007 100 copies of this public document were printed at a cost of $0.3453 per copy.