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WIPP 22 May 2014
WIPP waste dump, 22 May 2014

As you will see, an error in the US NRC “library” about the “Licensing Requirement for Land Disposal of Radioactive Waste“, is a simple typographical error with potentially dangerous consequences. Actually, it appears not even a typo but an unchecked cut and paste. Perhaps by the time you read this it will be already rectified, but the screen shot is below. (Update: As of Monday, May 25, 2015, it still has not been corrected! During the day of Oct. 8th and 9th this blog was visited by the NRC. This error has gone from looking like an accident to looking really bad to looking intentional. This is beyond criminal negligence. The NRC page says that it was Last Reviewed/Updated April 14, 2015.)

However, this sort of simple oversight could have led to the disaster at WIPP.

This simple error, in fact, could allow waste considered too radioactive for WIPP to go into low level radioactive waste dumps!

The NRC missed the basic tenet of first grade (probably now kindergarten): always check your work. For something as critical as nuclear, there needs to be two or more checking the work. Furthermore, the original text, which is accurate, is not findable at the NRC web site.

If the NRC would have simply provided the original text, then there would not have been the opportunity for such a serious error. We had looked for the original, because we prefer an original pdf file. Seeing that something was amiss, we found the correct version first at the Cornell law school web site, and then found an official text at the US GPO web site. It is worth noting that Cornell law school was attentive enough to check their work – not make this mistake, whereas the NRC was not.

People should be worried. The standards are weak and un-protective, as is. If the nuclear industry is not stopped, the waste problem will only grow. Even if it is stopped, it will not go away. This is serious.

According to the NRC library site for “Alpha emitting transuranic nuclides with half-life greater than 5 years“, there is allowed up to 1100 curies per cubic meter. It is supposed to be 100 nanocuries per gram. There are 37 billion becquerels (radioactive disintegrations-emissions per second) in one curie. Whereas the maximum allowed for low level waste sites is supposed to be then 3,700,000 Bq/kg, the error allows roughly 40,700,000,000 Bq/kg [(m3=1000 liter is approximately 1000 kg (based on water at 4 C)]. Recall that a kilogram is 2.2 pounds. For this, although significantly over what should be allowed, at 1.1 curie per liter, we are still under the 23 curies per liter allowed for remotely handled, too dangerous to touch, waste at WIPP.

For Plutonium 241 (Pu-241), the NRC reading room tells us that 13,500 curies per cubic meter are allowed, whereas it is 3,500 nanocuries per gram. Bad enough that there are up to 129,500,000 Bq/kg (i.e. radioactive emissions per second) Plutonium 241 allowed as low level radioactive waste, the NRC reading room tells those wanting to know the licensing requirements for land disposal of radioactive waste, that it is approximately 499,500,000,000 Bq per kg. That is 129,500,000 radioactive disintegrations per second vs. 499,500,000,000 radioactive disintegrations per second. Thus, the NRC reading room says that 3,857 times more radiation is allowed than is legally allowed! Plutonium 241 has a half-life of 14 years meaning that it will still be in the environment for over 200 years. Worse, it turns into Americium 241 with a half life of 432.7 years! It then becomes neptunium-237, which is also radioactive.

But, it gets worse still! Whereas, up to 20,000 nanocuries per gram of Curium 242 are legally allowed for low level waste, the NRC reading room error puts it at 120,000 curies per meter cubed. That is, up to 740,000,000 radioactive disintegrations per second (becquerels) per kilogram are legally allowed as low level waste. But, the NRC reading room puts it at 4,440,000,000,000 Bq per liter (kg). WIPP allows 851,000,000,000 Bq per liter.

Thus, the NRC reading room error allows for 120 curies per liter, compared to the 23 curies per liter maximum allowed at WIPP.

Therefore, waste 5 times more radioactive than that allowed in WIPP could be, or have been, placed in low level radioactive waste dumps, if a company-employee uses the NRC reading room, rather than using the Cornell law web site or the original GPO text!

Whereas Curium 242 has a half life of only 160 days, it becomes Plutonium 238 (Pu 238) with a half life of 87.7 years. This means that it will be around for over 1,400 years. It becomes Uranium 234 with a half life of 246,000 years. U 234 makes up only 0.0055% of natural uranium, and is still not stable.

NRC reading room low level waste rules typo
http://www.nrc.gov/reading-rm/doc-collections/cfr/part061/full-text.html

“PART 61—LICENSING REQUIREMENTS FOR LAND DISPOSAL OF RADIOACTIVE WASTE”

low level waste law NRC
http://www.gpo.gov/fdsys/pkg/CFR-2011-title10-vol2/pdf/CFR-2011-title10-vol2-part61.pdf (Emphasis added)

COMMENT PERIOD RE LOW LEVEL WASTE ENDS ON SEPTEMBER 15, 2014: http://www.regulations.gov/#!documentDetail;D=NRC-2014-0080-0002
While we intend to come back to the topic, if possible, the law is available to start studying here: http://www.gpo.gov/fdsys/pkg/CFR-2011-title10-vol2/pdf/CFR-2011-title10-vol2-part61.pdf
(There may be a 2012 or more recent version but this is all that we could find. The Cornell law school web site seems to tell when and if there were modifications, as do the sections on the NRC web site).

Regarding maximum radiation at WIPP:
“To confirm the total activity for compliance with LWA limits concerning the total waste inventory (i.e., no more than 5.1 million curies of RH TRU waste disposed; 23 curies per liter limit per canister) and to track radionuclides that are important to the calculation of releases (Regulatory basis: LWA, EPA Certification of the WIPP).
Type of data to collect:
Data on the activity of the waste in each container, including the activities and masses of 241Am, 238Pu, 239Pu, 240Pu, 242Pu, 233U, 234U, 238U, 90Sr, and 137Cs.”
“REMOTE-HANDLED TRU WASTE CHARACTERIZATION PROGRAM IMPLEMENTATION PLAN
DOE/WIPP-02-3214, Revision 3, September 19, 2012 , U.S. Department of Energy Carlsbad Field Office” http://www.wipp.energy.gov/rcradox/DOE-WIPP_02-3214_Rev_3.pdf

While most will recall how dangerous and bio accumulative (over a life time) plutonium is, many may not recall how dangerous Americium is.
“Americium-241 poses a significant risk if ingested (swallowed) or inhaled. It can stay in the body for decades and continue to expose the surrounding tissues to both alpha and gamma radiation, increasing the risk of developing cancer. Americium-241 also poses a cancer risk to all organs of the body from direct external exposure to its gamma radiation. One source of direct exposure would be contaminated soil.
…
People may be directly exposed to gamma radiation from americium-241 by walking on contaminated land. They may also be exposed to both alpha and gamma radiation by breathing in americium contaminated dust, or drinking contaminated water. Because americium-241 was widely dispersed globally during the testing of nuclear weapons, … found in the soil, plants, and water.
…
Americium-241 is an unstable (radioactive) isotope with a half-life of 432.7 years. As it decays, it releases alpha and gamma radiation and changes into neptunium-237, which is also radioactive.” (Emphasis added) http://www.epa.gov/radiation/radionuclides/americium.html#inbody

WIPP is supposed to be Transuranic, TRU, waste:
“Transuranic waste (TRU) is, as stated by U.S. regulations and independent of state or origin, waste which has been contaminated with alpha emitting transuranic radionuclides possessing half-lives greater than 20 years and in concentrations greater than 100 nCi/g (3.7 MBq/kg).[1]
Elements having atomic numbers greater than that of uranium are called transuranic. Elements within TRU are typically man-made and are known to contain americium-241 and several isotopes of plutonium.[2] Because of the elements’ longer half-lives, TRU is disposed of more cautiously than low level waste and intermediate level waste. In the U.S. it is a byproduct of weapons production, nuclear research and power production, and consists of protective gear, tools, residue, debris and other items contaminated with small amounts of radioactive elements (mainly plutonium). Under U.S. law, TRU is further categorized into “contact-handled” (CH) and “remote-handled” (RH) on the basis of the radiation field measured on the waste container’s surface. CH TRU has a surface dose rate not greater than 2 mSv per hour (200 mrem/h), whereas RH TRU has rates of 2 mSv/h or higher. CH TRU has neither the high radioactivity of high level waste, nor its high heat generation. In contrast, RH TRU can be highly radioactive, with surface dose rates up to 10 Sv/h (1000 rem/h)” http://en.wikipedia.org/wiki/Transuranic_waste The amounts of radiation allowed, according to the NRC reading room, were higher than RH TRU waste!

Assumptions on which we based our calculations:
1 nanocurie is 37 Bq
1 curie is 37 billion Bq (37,000,000,000)
1,000 grams is 1 kg
1 cubic meter (m3) is 1,000 liters
1 liter is approximately 1 kg (based on pure water at 4 degrees centigrade (39.2 degrees F); obviously this then will vary but it gives a sense).

We hope that all of you learned, if you hadn’t known it before, that you can’t trust the US NRC.

America the Radioactive:
Oh Terrifying for Radioactive Skies, for Radioactive Waves of Grain, for Radioactive Mountain Majesties, Beyond the Radioactive Plain,
America, America, God Have Mercy on Thee… From Sea to Radioactive Sea”
Cascade Canyon Main Canyon, NPS, Grand Teton
“Cascade Canyon Main Canyon, Photo by US NPS, View of Cascade Canyon and trail with Cathedral Group in background, Grand Teton National Park.