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Reminder that the US NRC comment period for Low Level Waste ends on Monday September 15, 2014. As we have seen, “Low Level” is a misnomer and includes very dangerous radionuclides. http://www.regulations.gov/#!documentDetail;D=NRC-2014-0080-0002
The law is here: http://www.gpo.gov/fdsys/pkg/CFR-2011-title10-vol2/pdf/CFR-2011-title10-vol2-part61.pdf and here: http://www.law.cornell.edu/cfr/text/10/part-61 This seems the only thing changed since 2011: http://www.law.cornell.edu/cfr/text/10/61.25 (You can double check at http://www.law.cornell.edu/cfr/text/10/part-61 ). The NRC site has errors.

This Radiation Free Lakeland reblog clearly lays out what putting radioactive materials in landfills means on a day to day basis and who is doing it. The Lillyhall landfill is next to a school. The residents worked hard to recycle. Their reward? Radionuclides dumped in their landfill from all over the UK: https://miningawareness.wordpress.com/2014/09/12/radioactive-waste-dump-is-born-without-fanfare-or-fuss-the-banality-of-evil/

Two of the major “concerns” of the US NRC appear to be disposing of large quantities of materials from old decommissioned reactors, and depleted uranium – more of which is constantly produced in the making of fuel for nuclear reactors (apparently there are only so many people the military can shoot the stuff at). Additionally, the largest amount, or one of the largest, of low level waste is from the filtration systems of nuclear reactors. Not only is there no place for old waste, but the nuclear industry continues to make more. Nuclear power plants make constant waste, and the only way to stop making more waste is to shut them down. Even then, there is a lot of old waste to contend with.

As we have said for some time, all pro-nuclear advocates should really keep nuclear waste, proportionate to their usage, and then some, in a lead vault in their home. Certainly if everyone had to keep their share of nuclear waste in their home, the industry would shut down really quickly. Instead, some of the waste is starting to move silentiously into home products and landfills and, of course, into food and water. Variations in background radiation means that you will probably never ever know, especially for hyper dangerous alpha emitters. Safely monitored, in bunkers, under the US Congress and pro-nuclear Houses of Parliament (e.g. UK, France, Russia, Japan) would be another excellent place to start storing the waste. You can be certain that there would be no cost-cutting and that it would be well-protected, if situated under government in DC, at the l’Elysee, at Westminster, etc. Anti-nuclear activist, Scots Nationalist, Willie MacRae colourfully observed that nuclear waste belonged with those who promoted its creation, i.e. at Westminster: ”Nuclear waste should be stored where Guy Fawkes put his gunpowder.(Mullwharcher Enquiry on nuclear dumping, 1980) http://50daysofyes.wordpress.com/2014/08/07/what-price-legitimacy-the-beautiful-shining-example/

US and Sellafield by USDOE
US-UK meeting at Sellafield in October 2013, from the US DOE newsletter below
For those who doubt that the UK has anything to do with the the US, think again. Not only are some of the contractors the same; at least one of the head people (Carol Johnson) has rotated from Hanford to Sellafield and now back to Savannah River; there are internship exchanges; and there is even a newsletter outlining how the US DOE is working with the UK NDA at Sellafield. As for-profit companies are involved, you can be certain that everything will push down to the lowest common denominator. Above is a picture from the following newsletter. Although the US DOE itself wasn’t able to go, because the US gov was shut down, plenty of contractors for US Nuclear Labs had reps there. Some newsletter excerpts:
A Quarterly Update on Joint UK NDA/US DOE Activities and Initiatives Issue 9: Winter 2014
FOREWORD: This is the first edition of “Across The Pond” for some time. However, the absence of the newsletter is not a reflection on the level of effort and success that is being generated from the UK NDA/US DOE relationship; quite the opposite. In 2013, more effort went in to developing collaborative efforts and sharing lessons learned than ever before. We believe it is important to share details about what is happening, so we have produced this 2013 Summary newsletter. We hope you enjoy reading about the many areas of collaboration currently underway. Ana Han, Lead Foreign Affairs US DOE EM John Mathieson, Head of International Relations, UK NDA

At the Waste Management Conference in Phoenix in 2013 it was agreed that NDA and USDOE at Savannah River would benefit from a closer working relationship and that specifically it would allow personnel from both entities to “benchmark” their respective approaches
The DOE carries out a much wider role on the site when compared with the NDA. For example, the DOE carries out the safety compliance role, which is undertaken by the contractor and the Regulator at Sellafield
Teams from Savannah River and Sellafield have been working together to share lessons learned and best practice for the decommissioning of alpha-contaminated facilities….
In the UK, Sellafield Ltd has just recently completed Phase 3B of the decommissioning of a fuel fabrication plant which was contaminated with Plutonium oxides including some with similar properties to those in Building 235-F. Given the similarities in the two projects, a number of conference calls were arranged to share lessons learned during the decommissioning of this facility…. Further discussions are planned in 2014 as the work on 235-F progresses and the Sellafield team can bring additional expertise and experience to bear on the project
“. http://energy.gov/sites/prod/files/2014/03/f8/UK%20ATP%20Winter%202014%20UK%20Final%5B1%5D.pdf (Emphasis added)

Having read the above, it is clear that what the UK does-has done will have repercussions on the US (and vice versa).

We have still not figured out what level of radiation is allowed to go into a landfill in the US. It appears to currently fall under the following. If this is so, the US NRC probably is looking for a clear law regarding what is landfilled waste, so that they do not have to bother with giving exemptions. (The UK offers defined exemptions). From the US Rule:
61.6 Exemptions.
The Commission may, upon application by any interested person, or upon its own initiative, grant any exemption from the requirements of the regulations in this part as it determines is authorized by law, will not endanger life or property or the common defense and security, and is otherwise in the public interest
.
” 10 CFR Ch. I (1–1–11 Edition), p. 205 Somehow these laws always have a HUGE loophole. And, this looks like a whopper!

The UK regs seem unclear:  On the one hand, they say that there should only be 400 Bq per kg for wastes that are insoluble in water (whereas the water soluble are the most dangerous for spreading out of landfill and getting into bodies of people, plants and animals), on the other hand there is the contradictory, non-specified, definition of Low volume Very Low Level Waste as less than 400,000 Becquerels per 0.1 m3 of waste (i.e. 100 liters or roughly 100 kg). That would be 4,000 Becquerels per liter or approximately 4,000 per kg. That is 4 per gram. Recall that a becquerel is one radioactive disintegration (i.e. emission) per second.  The High Volume Very Low Level Rad waste for bulk disposal allows 4 Megabecquerels per tonne, that is 4,000,000 becquerels per tonne (1,000 kg), or 4,000 Bq per kilogram (2.2 pounds).

For radioactive carbon and hydrogen (tritium), which, as students of organic chemistry know, form the very foundation of life, the becquerels are: 400,000 Becquerels per 100 liters (approx. 100 kg), i.e. 4,000 Bq per liter (kg) for Low volume VLLW, but 40,000,000 Bq/tonne, 40,000 Bq per kg (liter) for High Volume Very Low Level waste. Individual items range from 40,000 Bq up to 400,000 Bq for “Low Volume” VLLW.

From the UK’s “MANAGEMENT OF RADIOACTIVE MATERIALS AND RADIOACTIVE WASTE ON NUCLEAR LICENSED SITES , Document Type: Nuclear Safety Technical Assessment Guide:
Substances of Low Activity (SoLA) Exemption Order. This specifies a level for exemption from regulatory control of 0.4 becquerels (Bq)/g for wastes which are substantially insoluble in water.http://www.onr.org.uk/operational/tech_asst_guides/ns-tast-gd-024.pdf (This is 400 Bq per kg).

But then, it appears to contradict itself:
Very Low Level Radioactive Waste (VLLW), (a sub-category of LLW) VLLW (Low volume) A3. Low volumes (‘dustbin loads’) can be safely disposed of to an unspecified destination with municipal, commercial or industrial waste (“dustbin” disposal) if:
a. each 0.1m3 of waste contains less than 400 kilobecquerels (kBq) of total activity or single items contain less than 40 kBq of total activity.
b. For wastes containing carbon-14 or hydrogen-3 (tritium):
i. in each 0.1m3, the activity limit is 4,000 kBq for carbon-14 and hydrogen-3 (tritium) taken together; and
ii. or any single item, the activity limit is 400 kBq for carbon-14 and hydrogen-3 (tritium) taken together.

A4. Controls on disposal of this material, after removal from the premises where the wastes arose, are not necessary.

VLLW (High volume) A5. For bulk disposals – High Volume VLLW – where:
a. “Radioactive waste with maximum concentrations of four megabecquerels per tonne (MBq/te); or ST-GD-024 Revision 4 Page 13 of 13
b. for waste containing hydrogen-3 (tritium), with maximium concentrations of 40MBq/te; can be disposed of to specified landfill sites.

A6. Controls on disposal of this material, after removal from the premises where the wastes arose, will be necessary in a manner specified by the environmental regulators.
From “MANAGEMENT OF RADIOACTIVE MATERIALS AND RADIOACTIVE WASTE ON NUCLEAR LICENSED SITES, Document Type: Nuclear Safety Technical Assessment Guide, Unique Document ID and Revision No: NS-TAST-GD-024 Revision 4, Date Issued: May 2013 Review Date: May 2016Crown Copyright-Open government license (Emphasis our own) http://www.onr.org.uk/operational/tech_asst_guides/ns-tast-gd-024.pdf

Basically the same is found here: “Strategy for the management of solid low level radioactive waste from the non-nuclear industry in the United Kingdom , Part 1 – Anthropogenic radionuclides” 12 March 2012 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/48291/4616-strategy-low-level-radioactive-waste.pdf This document on non-nuclear waste specifies that there may be alpha emitters such as plutonium and americium. The nuclear one does not specify.

Depleted uranium is a misnomer. It is still radioactive. It is both a heavy metal chemical poison, like lead (which it eventually becomes), and a radiological danger. It is particularly hard on the kidneys. So hard that we believe that nuclear advocates should donate both their kidneys to someone else and go to dialysis for the rest of their lives, since they think it is fine for other people to do so. Not surprisingly it appears related to birth defects, as well:
Taylor & Francis. “Cancer and birth defects in Iraq: The nuclear legacy.” ScienceDaily. ScienceDaily, 21 May 2013 .
Riyad Abdullah Fathi, Lilyan Yaqup Matti, Hana Said Al-Salih, Douglas Godbold. “Environmental pollution by depleted uranium in Iraq with special reference to Mosul and possible effects on cancer and birth defect rates. Medicine, Conflict and Survival“, 2013; 29 (1): 7 DOI: 10.1080/13623699.2013.765173

Around 99.284% of natural uranium is uranium-238, which has a half-life of 1.41×1017 seconds (4.468×109 years, or 4.468 billion years). Depleted uranium has an even higher concentration of the 238U isotope, and even low-enriched uranium (LEU), while having a higher proportion of the uranium-235 isotope (in comparison to depleted uranium), is still mostly 238U. Reprocessed uranium is also mainly 238U, with about as much uranium-235 as natural uranium, a comparable proportion of uranium-236, and much smaller amounts of other isotopes of uranium such as uranium-234, uranium-233, and uranium-232.http://en.wikipedia.org/wiki/Uranium-238

According to a US EPA document on depleted uranium, by Brian Littleton, depleted uranium can also have other components:
US EPA Brian Littleton
Depleted Uranium, Technical Brief,EPA 402-R-06-011, December 2006
This EPA document seems to underplay risks of depleted uranium, but must still admit there is risk.

The following is from the UK Nuclear Free Authorities for a 2010 Consultation. But, the topics covered are even more pertinent today, whether in the US or the UK or other countries who have had nuclear power plants or experimental reactors:
NFLA Radioactive Waste Briefing 26
Prepared for NFLA member authorities, 20th September 2010
Environment Agency Consultation on exemptions regime for radioactive substances
“. The original pdf is found here with embedded links to documents: http://www.nuclearpolicy.info/docs/radwaste/Radioactive_Waste_Briefing_26_EA_RS_exemptions.pdf

We have highlighted and underlined parts which appear especially pertinent to the US low level waste consultation. If you are not in Scotland, or wish for Scotland to stay in the UK, a good idea is to have your local government join the Nuclear Free Local Authorities. More information is found at the http://www.nuclearpolicy.info.
NFLA Radioactive Waste Briefing 26, p. 1 a
p. 1 b
NFLA Radioactive Waste Briefing 26, p. 2
NFLA Radioactive Waste Briefing 26, p. 3
NFLA Radioactive Waste Briefing 26, p. 4
NFLA Radioactive Waste Briefing 26, p. 5
NFLA Radioactive Waste Briefing 26, p. 6
NFLA Radioactive Waste Briefing 26, p. 7 Full text original pdf is found here: http://www.nuclearpolicy.info/docs/radwaste/Radioactive_Waste_Briefing_26_EA_RS_exemptions.pdf

We apologize for any mathematics errors. Unlike the Queen, we are sorely understaffed and have no time to accept comments, including corrections. It has been checked by more than one person, more than once.