americium, burying radioactive waste, Clive Utah, dangerous radionuclides, Energy Solutions, low level waste, Low Level Waste Facility Clive Utah, nuclear energy, nuclear power, nuclear waste, plutonium, radiation, radioactive emissions, US Low Level Waste Comment, USA, Utah
“Energy Solutions” Low Level Rad Waste Facility in Clive Utah
At least it IS in an arid climate. Clueless as to why there are what appears to be tailings ponds. Large metal components include nuclear steam generator components. Energy Solutions appears mostly owned-run by former Goldman Sachs investment bankers.
This is an annotated version of the US Low Level Waste Rules. Unless you have read the rule at least 3 to 5 times, chances are that it’s worth looking at again. Comment period re US Low Level Waste ends on Monday September 15, 2014: http://www.regulations.gov/#!documentDetail;D=NRC-2014-0080-0002
The law (2011) is available to start studying 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 One part updated in 2012: http://www.law.cornell.edu/cfr/text/10/61.25
Everyone, from all over the world, should write at least one sentence to let the US NRC know they are being watched, and that it can’t be business as usual.
Some of the questions, which they ask, are at the bottom of this post.
It is important to know that there are some rules and regulations for dealing with radioactive waste. And, while there are too many exceptions and loopholes, it is still better to have lined trenches, for instance, than unlined trenches. It is better to have monitored waste leaking some, than to just throw it into a regular landfill, unmonitored. https://miningawareness.wordpress.com/2014/09/13/low-level-nuclear-waste-exemptions-uk-us-perspective/
It is better to monitor for 100 years at taxpayer expense, than not at all. It is also important to examine the rules in case they are violating them. They give lip service, for instance, to the importance of a dry climate, but the Barnwell, South Carolina site still operates. The NRC also made this dangerous error, which remained uncorrected for at least a week and may still remain uncorrected: https://miningawareness.wordpress.com/2014/09/04/the-dangerous-us-nrc-typo-making-low-level-radioactive-waste-more-radioactive-than-allowed-at-wipp/
Before looking at the official rule-law, we found this nuclear lobby comment regarding metal recycling. It looks ominous. However, in the document he claims that upon melting plutonium comes to the surface and that the recycled materials are used in the nuclear industry. But, who knows? Hyper Dangerous alpha emitters can certainly be hidden under this rule, if it is a rule.
1 m2= 100 cm x 100 cm = 10,000 cm2. Therefore, the “minimum sensitivity” is 8,300 Bq/m2. And, that excludes alpha! Truck monitoring is gamma only.
“METAL RECYCLE IN THE UNITED STATES
There are no clearance levels for metal waste from power plants in the United States. Waste to be unconditionally released from radiological control (for general use or to a recycler) must be shown to contain “no detectable radioactivity” in conformance with US NRC guidance. The unconditional release survey of metals must be conducted as follows:
Using a survey instrument with a minimum sensitivity of 0.83 Bq/cm 2 (Beta/Gamma Activity)
Perform a final aggregate survey of the waste (Typically performed as the truck exits the site using a gamma sensitive Truck Monitor)” “Note that U.S. regulations allow the component activity to be averaged over the entire weight of the large component. This has allowed some S/G Lower Assemblies to qualify as Class A waste for disposal at Clive, Utah.” “A new EPRI report to be published in 2014, ‘Waste Management for Decommissioning’, will discuss all aspects of Decommissioning Waste Management.” From: “Symposium on Recycling of Metals Arising from Operation and Decommissioning of Nuclear Facilities“, Studsvik Facility Nyköping, Sweden April 8-10, 2014, “WASTE MANAGEMENT FOR DECOMMISSIONING OF NUCLEAR POWER PLANTS: AN EPRI DECOMMISSIONING PROGRAM REPORT“, By Richard McGrath (Presenter), Richard Reid, Electric Power Research Institute, Palo Alto, California USA, http://www. oecd-nea.org/rwm/wpdd/studsvik2014/documents/E-1__waste_management__R-McGrath.pdf
“The Electric Power Research Institute (EPRI) …is a nonprofit organization funded by the electric utility industry, founded and headquartered in Palo Alto, California. EPRI is primarily a US-based organization, but receives international participation.” http://en.wikipedia.org/wiki/Electric_Power_Research_Institute
Bold, caps, comments by us:
“Nuclear Regulatory Commission § 61.2
L. 102–486, sec. 2902, 106 Stat. 3123 (42 U.S.C. 5851).
SOURCE: 47 FR 57463, Dec. 27, 1982, unless otherwise noted.
Subpart A—General Provisions
§ 61.1 Purpose and scope.
(a) The regulations in this part establish, for land disposal of radioactive waste, the procedures, criteria, and terms and conditions upon which the Commission issues licenses for the disposal of radioactive wastes containing byproduct, source and special nuclear material received from other persons. Disposal of waste by an individual licensee is set forth in part 20 of this chapter. Applicability of the requirements in this part to Commission licenses for waste disposal facilities in effect on the effective date of this rule will be determined on a case-by-case basis and implemented through terms and conditions of the license or by orders issued by the Commission.” [grandfather clause?] “(b) Except as provided in part 150 of this chapter, which addresses assumption of certain regulatory authority by Agreement States, and §61.6 “Exemptions,” the regulations in this part apply to all persons in the United States. The regulations in this part do NOT apply to— (1) Disposal of high-level waste as provided for in part 60 or 63 of this chapter; (2) Disposal of uranium or thorium tailings or wastes (byproduct material as defined in §40.4 (a-1) as provided for in part 40 of this chapter in quantities greater than 10,000 kilograms and containing more than 5 millicuries of radium-226; or (3) Disposal of licensed material as provided for in part 20 of this chapter. (c) This part also gives notice to all persons who knowingly provide to any licensee, applicant, contractor, or sub-contractor, components, equipment, materials, or other goods or services, that relate to a licensee’s or applicant’s activities subject to this part, that they may be individually subject to NRC enforcement action for violation of §61.9b.
[47 FR 57463, Dec. 27, 1982, as amended at 56 FR 40690, Aug. 15, 1991; 63 FR 1898, Jan. 13, 1998; 66 FR 55791, Nov. 2, 2001]”
DEFINITIONS – VERY IMPORTANT
“§ 61.2 Definitions.
As used in this part: ACTIVE MAINTENANCE means any significant remedial activity needed during the period of institutional control to maintain a REASONABLE assurance that the performance objectives in §§61.41 and 61.42 are met“. NB: Their idea of “reasonable” generally turns around the cost to the nuclear industry. Read about ALARA and ALARP. It goes back to an old UK coal mine ruling, which should have nothing to do with the nuclear industry.
“Such active maintenance includes ongoing activities such as the pumping and treatment of water from a disposal unit OR one-time meas-ures such as replacement of a disposal unit cover. Active maintenance does NOT include custodial activities such as repair of fencing, repair or replacement of monitoring equipment, revegetation, minor additions to soil cover, minor re-pair of disposal unit covers, and general disposal site upkeep such as mowing grass.
BUFFER ZONE is a portion of the disposal site that is controlled by the licensee and that lies under the disposal units and between the disposal units and the boundary of the site.
CHELATING AGENT means amine polycarboxylic acids (e.g., EDTA, DTPA), hydroxy-carboxylic acids, and polycarboxylic acids (e.g., citric acid, carbolic acid, and glucinic acid).
COMMENCEMENT OF CONSTRUCTION means any clearing of land, excavation, or other substantial action that would adversely affect the environment of a land disposal facility. The term does NOT mean disposal site exploration, necessary roads for disposal site exploration, borings to determine foundation conditions, or other preconstruction monitoring or testing to establish background information related to the suitability of the disposal site or the protection of environmental values.
COMMISSION means the Nuclear Regulatory Commission OR its duly authorized representatives.
CUSTODIAL AGENCY means an agency of the GOVERNMENT designated to act on behalf of the government owner of the disposal site.
DIRECTOR means the Director, Office of Federal and State Materials and Envi-ronmental Management Programs, U.S. Nuclear Regulatory Commission.
DISPOSAL means the isolation of radio-active wastes from the biosphere in-habited by man and containing his food”
Mar2010 08:18 Mar 01, 2011 with CFR
10 CFR Ch. I (1–1–11 Edition) § 61.2
“chains by emplacement in a land disposal facility.”
WHAT A JOKE! IF YOU BELIEVE THIS WE’VE LAND TO SELL YOU AT BAYOU CORNE, LA. (aka Louisiana Sinkhole) THIS IS WHAT DISPOSAL SHOULD MEAN, BUT FOR THEM IT APPARENTLY DOES NOT OR THERE WOULDN’T BE MONITORED LEAKAGE!
“DISPOSAL SITE means that portion of a land disposal facility which is used for disposal of waste. It consists of disposal units and a buffer zone.
DISPOSAL UNIT means a discrete portion of the disposal site into which waste is placed for disposal. For near-surface disposal the unit is usually a trench.”
“ENGINEERED BARRIER means a man-made structure or device that is intended to improve the land disposal facility’s ability to meet the performance objectives in subpart C“. AS YOU WILL SEE, THEY AREN’T TALKING NASA HIGH TECH HERE BUT ANIMAL-LIKE ENGINEERING SUCH AS CLAY AND PLASTIC LINERS. BUT AS WE’VE SEEN BEAVERS VIGILANTLY MONITOR THEIR ENGINEERED SITES. Pretty certain that’s not the case of the humans involved here.
“EXPLOSIVE MATERIAL means any chemical compound, mixture, or device, which produces a SUBSTANTIAL instantaneous release of gas and heat spontaneously or by contact with sparks or flame“.
SO A SMALL RELEASE IS OK?
“GOVERNMENT AGENCY means any executive department, commission, independent establishment, or corporation, wholly OR PARTLY owned by the United States of America which is an instrumentality of the United States; OR any board, bureau, division, service, office, officer, authority, administration, or other establishment in the executive branch of the government.
HAZARDOUS WASTE means those wastes designated as hazardous by Environmental Protection Agency regulations in 40 CFR part 261.
HYDROGEOLOGIC UNIT means any soil or rock unit or zone which by virtue of its porosity or permeability, or lack there-of, has a distinct influence on the storage or movement of groundwater.
INADVERTENT INTRUDER means a person who might occupy the disposal site after closure and engage in normal activities, such as agriculture, dwelling construction, or other pursuits in which the person might be unknowingly exposed to radiation from the waste“.
THEY DIDN’T BOTHER TO MENTION THAT ANIMALS-ESPECIALLY BURROWING ONES – AND EVEN PLANTS CAN BE INADVERTENT INTRUDERS. (They do mention animals much later in the text, but do not classify them as inadvertent intruders).
“INDIAN TRIBE means an Indian tribe as defined in the Indian Self-Determination and Education Assistance Act (25 U.S.C. 450).
INTRUDER BARRIER means a sufficient depth of cover over the waste that inhibits contact with waste and helps to ensure that radiation exposures to an inadvertent intruder will meet the performance objectives set forth in this part, or engineered structures that provide equivalent protection to the inadvertent intruder“.
“LAND DISPOSAL FACILITY means the land, building, and structures, and equipment which are intended to be used for the disposal of radioactive wastes. For purposes of this chapter, a “geologic repository” as defined in part 60 or 63 is NOT considered a land disposal facility.
LICENSE means a license issued under the regulations in part 61 of this chap-ter.
LICENSEE means the holder of such a license.
MONITORING means observing and making measurements to provide data to evaluate the performance and characteristics of the disposal site.
NEAR-SURFACE DISPOSAL FACILITY means a land disposal facility in which radio-active waste is disposed of IN OR WITHIN the upper 30 meters of the earth’s surface.
PERSON MEANS (1) any individual, CORPORATION, partnership, firm, association, trust, estate, public or private in-stitution, group, GOVERNMENT AGENCY other than the Commission or the Department of Energy (except that the Department of Energy is considered a person within the meaning of the regulations in this part to the extent that its facilities and activities are subject to the licensing and related regulatory authority of the Commission pursuant to law), any State or any POLITICAL SUB-DIVISION of or any political entity within a State, any ANY FOREIGN GOVERNMENT or nation or any political subdivision of any such government or nation, or other entity; and (2) ANY LEGAL SUCCESSOR, representative, agent, or agency of the foregoing.
PYROPHORIC LIQUID means any liquid that ignites spontaneously in dry or moist air at or below 130 °F (54.5 °C).
A PYROPHORIC SOLID is any solid material, other than one classed as an explosive, which under normal conditions is liable to cause fires through friction, retained heat from manufacturing or processing, or which can be ignited readily and when ignited burns so vigorously and persistently as to create a serious transportation, handling, or disposal hazard. Included are spontaneously combustible and water-reactive materials“. p. 204 SO IF IT BURNS SOME BUT NOT VIGOROUSLY AND PERSISTENTLY IT IS OK?
Mar2010 08:18 Mar 01, 2011
Nuclear Regulatory Commission § 61.6
“SITE CLOSURE AND STABILIZATION means those actions that are taken upon completion of operations that prepare the disposal site for custodial care and that assure that the disposal site will remain stable and will not need ongoing active maintenance“. WHAT A RIDICULOUS STATEMENT! OF COURSE IT WILL NOT REMAIN STABLE; OF COURSE IT WILL NEED MAINTENANCE. SOIL WILL WASH AWAY, SUBSIDENCE WILL OCCUR. THE SPEED WILL BE FASTER IN WET CLIMATES.
“STATE means any State, Territory, or possession of the United States, Puerto Rico, and the District of Columbia.
STABILITY means structural stabillity.
SURVEILLANCE means observation of the disposal site for purposes of visual detection of need for maintenance, custodial care, evidence of intrusion, and compliance with other license and regulatory requirements.” VISUAL DETECTION? DOES THIS MEAN THAT THEY AREN’T GOING TO TEST FOR RADIATION?
“TRIBAL GOVERNING BODY Tribal Governing Body means a Tribal organization as defined in the Indian Self-Determination and Education As-sistance Act (25 U.S.C. 450).
WASTE means those low-level radioactive wastes containing source, special nuclear, or byproduct material that are acceptable for disposal in a land disposal facility. For the purposes of this definition, low-level radioactive waste means radioactive waste not classified as high-level radioactive waste, transuranic waste, spent nuclear fuel, or byproduct material as de-fined in paragraphs (2), (3), and (4) of the definition of Byproduct material set forth in §20.1003 of this chapter“.[47 FR 57463, Dec. 27, 1982, as amended at 54 FR 22583, May 25, 1989; 58 FR 33891, June 22, 1993; 66 FR 55792, Nov. 2, 2001; 72 FR 55933, Oct. 1, 2007; 73 FR 5725, Jan. 31, 2008]
AND YET LOW LEVEL INCLUDES TRANSURANIC WASTE SUCH AS PLUTONIUM AND AMERICIUM IN THIS RULE!
“§ 61.3 License required.
(a) No person may receive, possess, and dispose of radioactive waste con-taining source, special nuclear, or by-product material at a land disposal fa-cility unless authorized by a license issued by the Commission pursuant to this part, OR UNLESS EXEMPTION HAS BEEN GRANTED by the Commission under §61.6 of this part.” THAT’S ONE HELL OF A LOOPHOLE!
“(b) Each person shall file an application with the Commission and obtain a license as provided in this part before commencing construction of a land dis-posal facility. Failure to comply with this requirement MAY be grounds for denial of a license“. MAY BE GROUNDS? HOW ABOUT “IS GROUNDS”?
“§ 61.4 Communications.
Except where otherwise specified, all communications and reports concerning the regulations in this part and applications filed under them should be sent by mail addressed: ATTN: Docu-ment Control Desk; Director, Office of Federal and State Materials and Envi-ronmental Management Programs, U.S. Nuclear Regulatory Commission, Washington, DC 20555–0001; by hand de-livery to the NRC’s Offices at 11555 Rockville Pike, Rockville, Maryland; or, where practicable, by electronic submission, for example, via Electronic Information Exchange, or CD–ROM. Electronic submissions must be made in a manner that enables the NRC to receive, read, authenticate, distribute, and archive the submission, and proc-ess and retrieve it a single page at a time. Detailed guidance on making electronic submissions can be obtained by visiting the NRC’s Web site at http:// http://www.nrc.gov/site-help/e-submittals.html; by e-mail to MSHD.Resource@nrc.gov; or by writing the Office of Information Services, U.S. Nuclear Regulatory Commission, Washington, DC 20555– 0001. The guidance discusses, among other topics, the formats the NRC can accept, the use of electronic signa-tures, and the treatment of nonpublic information.
[73 FR 5725, Jan. 31, 2008, as amended at 74 FR 62683, Dec. 1, 2009]
§ 61.5 Interpretations.
EXCEPT as specifically authorized by the Commission in writing, no interpretation of the meaning of the regulations in this part by any officer or em-ployee of the Commission other than a written interpretation by the General Counsel will be considered binding upon the Commission.
§ 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 regula-tions 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“. THAT GIVES A LOT OF ROOM TO DO WHATEVER DOESN’T IT?
VerDate Mar2010 08:18 Mar 01, 2011
“10 CFR Ch. I (1–1–11 Edition) § 61.7”
DESPITE A RATHER DREARY NAME “CONCEPTS” IS ONE OF THE MOST IMPORTANT PARTS. IT DESCRIBES WHAT THE WASTE DUMP IS SUPPOSED TO LOOK LIKE.
“§ 61.7 Concepts.
(a) THE DISPOSAL FACILITY.
(1) Part 61 is intended to apply to land disposal of radioactive waste and not to other methods such as sea or extraterrestrial disposal. Part 61 contains procedural requirements and performance objectives applicable to any method of land disposal. It contains specific technical requirements for near-surface disposal of radioactive waste, a subset of land disposal, which involves disposal in the uppermost portion of the earth, approximately 30 meters. Near-surface disposal includes disposal in engineered facilities which may be built totally or partially above-grade provided that such facilities have protective earthen covers.”
THIS IS A BURIAL MOUND – ABOVE OR BELOW GROUND! IT’S A MISUSE OF THE TERM ENGINEERED FACILITIES. Even human dead bodies are often buried in as, or more, strict conditions. No one speaks of “engineered facilities” when people are buried in caskets and burial vaults! Some human (dead body) burial vaults may involve lead and concrete.
“Near-surface disposal does not include disposal facilities which are partially or fully above-grade with no protective earthen cover, which are referred to as “above-ground disposal.” Burial deeper than 30 meters may also be satisfactory. Technical requirements for alternative methods may be added in the future.
(2) Near-surface disposal of radio-active waste takes place at a near-surface disposal facility, which includes all of the land and buildings necessary to carry out the disposal. The disposal site is that portion of the facility which is used for disposal of waste and consists of disposal units and a buffer zone. A disposal unit is a discrete portion of the disposal site into which waste is placed for disposal. For near-surface disposal, the disposal unit is usually a TRENCH. A BUFFER ZONE is a portion of the disposal site that is controlled by the licensee and that lies under the site and between the boundary of the disposal site and any disposal unit. It provides controlled space to establish monitoring locations which are intended to provide an early warning of radionuclide movement, and to take MITIGATIVE MEASURES if needed. In choosing a disposal site, site characteristics should be considered in terms of the indefinite future and evaluated for at least a 500–year timeframe.
(b) Waste classification and near-surface disposal. (1) Disposal of radioactive waste in near-surface disposal facilities has the following safety objectives: protection of the general population from releases of radioactivity, protection of individuals from inadvertent intrusion, and protection of individuals during operations. A fourth objective is to ensure stability of the site after closure“. WHAT JOKERS THEY ARE! THEY ALLOW A CERTAIN AMOUNT OF LEAKAGE! THE SITE CANNOT REMAIN STABLE ON ITS OWN OVER TIME.
“(2) A cornerstone of the system is stability—stability of the waste and the disposal site so that once emplaced and covered, the ACCESS OF WATER TO THE WASTE can be MINIMIZED“. THEY AREN’T AIMING TO KEEP WATER OUT – BECAUSE THEY CAN’T IN SUCH AN UNDERGROUND MOUND THAT IS SEALED OFF. THEY AIM TO “MINIMIZE”!
THEY AIM TO MINIMIZE MIGRATION OF RADIONUCLIDES IN THIS WAY:
“Migration of radionuclides is thus minimized, long-term active maintenance can be avoided, and potential exposures to intruders reduced“. OH, THESE PEOPLE! THE SITE WILL HAVE TO BE MAINTAINED. NO MIGRATION OF RADIONUCLIDES IS ACCEPTABLE!
THE NRC CONTINUES WITH THEIR BS:
“While stability is a desirable characteristic for all waste much radioactive waste does not contain sufficient amounts of radionuclides to be of great concern from these stand-points; this waste, however, tends to be unstable, such as ordinary trash type wastes“. AS SEEN FURTHER DOWN THE WASTE CAN INCLUDE HYPER DANGEROUS RADIONUCLIDES AND ALL RADIONUCLIDES ARE DANGEROUS ANYWAY. IF IT WERE SAFE IT WOULDN’T NEED TO BE MONITORED OR BURIED!
“If mixed with the higher activity waste, their deterioration could lead to failure of the system and permit water to penetrate the disposal unit and cause problems with the higher activity waste“. DUH!
RELATIVELY INNOCUOUS WASTE! RELATIVELY INNOCUOUS! DOES NRC MEAN NUTTY COMMISSION? HIGH LEVELS OF RADIONUCLIDES ARE ALLOWED!
Pu 241 is allowed at up to 3500 nanocuries/g = 129,500 becquerels per gram or 129,500,000 bq/kg. Class A is x 0.1 or less, so between 1,295,000 bq (Class A) and 129,500,000 becquerels per kg (Class C) of Plutonium 241 are classified as Low Level Waste, for instance. Plutonium 241 becomes much longer lived alpha emitter Americium 241. A Becquerel is a radioactive disintegration per second!
MANY OF THE RADIONUCLIDES STAY IN THE BODY FOR EXTENDED PERIODS TOO AND SOMETIMES A LIFETIME (AMERICIUM AND PLUTONIUM)!
“Therefore, in order to avoid placing requirements for a stable waste form on relatively innocuous waste, these wastes have been classed as Class A waste. The Class A waste will be disposed of in separate disposal units at the disposal site. However, Class A waste that is stable may be mixed with other classes of waste. Those higher activity wastes that should be stable for proper disposal are classed as Class B and C waste.”
HERE THEY GO AGAIN WITH THEIR LOOPHOLES! PRACTICABLE TO THEM DOES NOT MEAN FEASIBLE!
“TO THE EXTENT THAT IT IS PRACTICABLE, Class B and C waste forms or containers should be designed to be stable“, THEY SHOULD BE DESIGNED TO BE STABLE TO THE EXTENT PRACTICABLE, MAKING THE LOOPHOLE EVEN LARGER! NOT THAT CONTAINERS SHOULD BE STABLE BUT SHOULD BE DESIGNED TO BE SO! They continue
“i.e., maintain gross physical properties and identity, over 300 years“. Yeah, right. This will only happen if it is maintained, in which case it must be an internal structure, like an underground bunker-vault. Or, they can put it in a stone pyramid in a desert and they aren’t doing that! They continue: “For certain radio-nuclides prone to migration, a maximum disposal site inventory based on the characteristics of the disposal site MAY be established to LIMIT potential exposure.” SO, IF RADIONUCLIDES WILL MIGRATE DUE TO PLACING IT IN A RAINY CLIMATE NEAR A SWAMP, LIKE AT BARNWELL, THEN IF THEY FEEL LIKE IT THEY MAY LIMIT EXPOSURE – NOT THAT THEY WILL BUT THAT THEY MAY LIMIT THE AMOUNT OF RADIONUCLIDES AT THE SITE TO LIMIT EXPOSURE. WHO DETERMINES? NRC? THE SWEET AND GENTLE GOLDMAN SACHS INVESTMENT BANKERS RUNNING MANY OF THE DUMP SITES NOW VIA ENERGY SOLUTIONS? STATES?
“(3) It is POSSIBLE but UNLIKELY that persons might occupy the site in the future and engage in normal pursuits without knowing that they were receiving radiation exposure. These persons are referred to as inadvertent intruders. Protection of such intruders can involve two principal controls: institutional control over the site after operations by the site owner to ensure that no such occupation or improper use of the site occurs; or, designating” NOW THEY ARE CLAIRVOYANT? SINCE THEY ARE SO CLAIRVOYANT, DON’T THEY OR ANYONE ELSE KNOW THAT THE WORLD POPULATION IS GROWING AND THE AMOUNT OF LAND IS NOT? OF COURSE IT WILL BE INADVERTENTLY USED! THERE ARE PLENTY OF OLD MOUNDS AND THINGS IN THE US AND ELSEWHERE AND PEOPLE ARE MOSTLY CLUELESS ABOUT THEM! How many can trace even their ancestors back 300 or 400 years? Or know where they are buried? Or, maybe they know that there won’t be any humans left by the time the nuclear industry is done with us! For that reason alone it is silly to try to mark the waste spots for future generations – there won’t be any.
Mar2010 08:18 Mar 01, 2011, p. 206
“Nuclear Regulatory Commission § 61.7
which waste could present an unacceptable risk to an intruder, and disposing of this waste in a manner that provides some form of intruder barrier that is intended to prevent contact with the waste. This regulation incorporates both types of protective controls.
(4) Institutional control of access to the site is required for UP TO 100 years. This permits the disposal of Class A and Class B waste without special provisions for intrusion protection, since these classes of waste contain types and quantities of radioisotopes that will decay during the 100-year period and will present an acceptable hazard to an intruder“. THIS IS A PATENT LIE. UNLESS IT IS RADIONUCLIDES WITH A HALF LIFE OF 7 YEARS OR SO IT WILL NOT DECAY TO AN ACCEPTABLE LEVEL. NOTICE “UP TO” SO IT MAY BE LESS.
“The government land-owner administering the active institu-tional control program has flexibility in controlling site access which may include allowing productive uses of the land provided the integrity and long- term performance of the site are not affected“. THIS MEANS THAT IT WILL BE MADE A WALKING TRAIL OR NATURE PARK AND THAT THIS WILL WEAR DOWN THE SITE AND PEOPLE MAY UNKNOWINGLY BE EXPOSED TO RADIATION.
“(5) Waste that will not decay to lev-els which present an acceptable hazard to an intruder within 100 years is des-ignated as Class C waste. This waste is disposed of at a greater depth than the other classes of waste so that subsequent surface activities by an intruder will not disturb the waste.”
HERE COME THE HUGE LOOPHOLES AGAIN! BURIAL MAY BE MORE SHALLOW. CONCRETE COVERS MIGHT BE USED BUT MIGHT NOT. EVEN HIGHER THAN C MAY BE BURIED ON A CASE BY CASE BASIS.
“Where site conditions prevent deeper disposal, in-truder barriers such as concrete covers may be used. The effective life of these intruder barriers should be 500 years. A maximum concentration of radio-nuclides is specified for all wastes so that at the end of the 500 year period, remaining radioactivity will be at a level that does not pose an unacceptable hazard to an intruder or public health and safety. Waste with concentrations above these limits is GENERALLY unacceptable for near-surface disposal. There may be some instances where waste with concentrations greater than permitted for Class C would be acceptable for near-surface disposal with special processing or design. These will be evaluated on a case-by-case basis. Class C waste must also be stable“.
“(c) The licensing process.
(1) During the preoperational phase, the potential applicant goes through a process of disposal site selection by selecting a region of interest, examining a number of possible disposal sites within the area of interest and narrowing the choice to the proposed site. Through a detailed investigation of the disposal site characteristics the potential applicant obtains data on which to base an analysis of the disposal site’s suitability. Along with these data and analyses, the ap-plicant submits other more general in-formation to the Commission in the form of an application for a license for land disposal. The Commission’s review of the application is in accordance with administrative procedures established by rule and may involve participation by affected State governments or In-dian tribes. While the proposed disposal site must be owned by a State or the Federal government before the Commission will issue a license, it may be privately owned during the preoperational phase if suitable ar-rangements have been made with a State or the Federal government to TAKE OWNERSHIP in fee of the land before the license is issued“. DOES THIS MEAN EMINENT DOMAIN MAY BE DECLARED IN THE PUBLIC INTEREST?
“(2) During the operational phase, the licensee carries out disposal activities in accordance with the requirements of this regulation and any conditions on the license. Periodically, the authority to conduct the above ground operations and dispose of waste will be subject to a license renewal, at which time the operating history will be reviewed and a decision made to permit or deny con-tinued operation. When disposal oper-ations are to cease, the licensee applies for an amendment to his license to per-mit site closure. After final review of the licensee’s site closure and sta-bilization plan, the Commission may approve the final activities necessary to prepare the disposal site so that on-going active maintenance of the site is not required during the period of institutional control“.
IT WILL HAVE TO BE MAINTAINED AND COST FALLS ON THE BACKS OF THE TAXPAYER AS SEEN BELOW!
“(3) During the period when the final site closure and stabilization activities are being carried out, the licensee is in a disposal site closure phase. Following that, for a period of 5 years, the li-censee must remain at the disposal site for a period of post-closure observation and maintenance to assure that the disposal site is stable and ready for in-stitutional control. The Commission MAY APPROVE SHORTER or require longer periods if conditions warrant. At the end of this period, the licensee applies“p. 207 YES, IT MIGHT STAY STABLE FOR 5 YEARS BUT AFTER THAT? 10 YEARS? 50? 100? 500? 5,000? LONGER?
for a license transfer to the disposal site owner.
(4) After a finding of satisfactory dis-posal site closure, the Commission will transfer the license to the State or Federal government that owns the dis-posal site. If the Department of Energy is the Federal agency administering the land on bahalf of the Federal gov-ernment the license will be terminated because the Commission lacks regu-latory authority over the Department for this activity.
Under the conditions of the transferred license, the owner will carry out a program of monitoring to assure continued satisfactory dis-posal site performance, physical sur-veillance to restrict access to the site and carry out minor custodial activi-ties. During this period, productive uses of the land might be permitted if those uses do not affect the stability of the site and its ability to meet the per-formance objectives. At the end of the prescribed period of institutional con-trol, the license will be terminated by the Commission.” [47 FR 57463, Dec. 27, 1982, as amended at 58 FR 33891, June 22, 1993] REMEMBER THE OWNER IS THE GOVERNMENT, SO THE TAX PAYER PAYS AND AFTERWARDS IT IS LEFT TO SOME INNOCENT PARTY IF ANY ARE STILL ALIVE IN 100 YEARS!
“Nuclear Regulatory Commission § 61.12
§ 61.12 Specific technical information.
The specific technical information must include the following information needed for demonstration that the per-formance objectives of subpart C of this part and the applicable technical requirements of subpart D of this part will be met: (a) A description of the natural and demographic disposal site characteris-tics as determined by disposal site se-lection and characterization activities. The description must include geologic, geotechnical, hydrologic, meteorologic, climatologic, and biotic features of the disposal site and vicinity. (b) A description of the design fea-tures of the land disposal facility and the disposal units. For near-surface disposal, the description must include those design features related to infil-tration of water; integrity of covers for disposal units; structural stability of backfill, wastes, and covers; contact of wastes with standing water; disposal site drainage; disposal site closure and stabilization; elimination to the extent practicable of long-term disposal site maintenance; inadvertent intrusion; occupational exposures; disposal site monitoring; and adequacy of the size of the buffer zone for monitoring and po-tential mitigative measures.
(c) A description of the principal de-sign criteria and their relationship to the performance objectives.
(d) A description of the design basis natural events or phenomena and their relationship to the principal design cri-teria.
(e) A description of codes and stand-ards which the applicant has applied to the design and which will apply to con-struction of the land disposal facilities.
(f) A description of the construction and operation of the land disposal fa-cility. The description must include as a minimum the methods of construction of disposal units; waste emplacement; the procedures for and areas of waste segregation; types of intruder barriers; onsite traffic and drainage systems; survey control program; methods and areas of waste storage; and methods to control surface water and groundwater access to the wastes. The description must also include a description of the methods to be employed in the handling and disposal of wastes containing chelating agents or other non-radiological substances that might affect meeting the performance objectives in subpart C of this part.
(g) A description of the disposal site closure plan, including those design features which are intended to facilitate disposal site closure and to elimi-nate the need for ongoing active maintenance. [BS, of course, it WILL need maintenance].
“(h) An identification of the known natural resources at the disposal site, the exploitation of which could result in inadvertent intrusion into the low- level wastes after removal of active in-stitutional control.
(i) A description of the kind, amount, classification and specifications of the radioactive material proposed to be re-ceived, possessed, and disposed of at the land disposal facility.
(j) A description of the quality assurance program, tailored to LLW dis-posal, developed and applied by the applicant for the determination of nat-ural disposal site characteristics and”
“10 CFR Ch. I (1–1–11 Edition) § 61.13
for quality assurance during the de-sign, construction, operation, and clo-sure of the land disposal facility and the receipt, handling, and emplace-ment of waste.
(k) A description of the radiation safety program for control and monitoring of radioactive effluents to ensure compliance with the performance objective in §61.41 of this part and occupational radiation exposure to ensure compliance with the requirements of part 20 of this chapter and to control contamination of personnel, vehicles, equipment, buildings, and the disposal site. Both routine operations and accidents must be addressed.” RECALL THAT THE EXPOSURE TO RADIATION, INCLUDING PLUTONIUM, IS AS THE NUCLEAR INDUSTRY AND GOVT. LACKEYS DEEM ACCEPTABLE!
“The program description must include procedures, instrumentation, facilities, and equip-ment. (l) A description of the environ-mental monitoring program to provide data to evaluate potential health and environmental impacts and the plan for taking corrective measures if migration of radionuclides is indicated. (m) A description of the administra-tive procedures that the applicant will apply to CONTROL activities at the land disposal facility. (n) A description of the facility elec-tronic recordkeeping system as required in §61.80.
[47 FR 57463, Dec. 27, 1982, as amended at 58 FR 33891, June 22, 1993; 60 FR 15666, Mar. 27, 1995]”
“§ 61.13 Technical analyses.
The specific technical information must also include the following anal-yses needed to demonstrate that the performance objectives of subpart C of this part will be met: (a) Pathways analyzed in demonstrating protection of the general population from releases of radioactivity must include air, soil, ground-water, surface water, plant uptake, and exhumation by burrowing animals. The analyses must clearly identify and differentiate between the roles performed by the natural disposal site characteristics and design features in isolating and segregating the wastes. The analyses must clearly demonstrate that there is REASONABLE assurance that the EXPOSURE to humans from the release of radioactivity WILL NOT EXCEED the LIMITS SET FORTH in §61.41“. THEY ONLY ASK FOR “REASONABLE ASSURANCE” (IN WHICH THERE IS ALWAYS AN ECONOMIC COMPONENT IF YOU READ ALARA AND ALARP) AND THAT THE LIMITS OF EXPOSURE WHICH THEY LAY OUT WILL NOT BE EXCEEDED. SO, THE ONLY GUARANTEE IS THAT THERE WILL BE EXPOSURE!
“(b) Analyses of the protection of indi-viduals from inadvertent intrusion must include demonstration that there is reasonable assurance the waste clas-sification and segregation require-ments will be met and that adequate barriers to inadvertent intrusion will be provided. (c) Analyses of the protection of indi-viduals during operations must include assessments of expected exposures due to routine operations and likely accidents during handling, storage, and disposal of waste. The analyses must provide reasonable assurance” [ONCE AGAIN READ ABOUT ALARA AND ALARP] “that exposures will be CONTROLLED to meet the requirements of part 20 of this chapter.” EXPOSURE WILL BE CONTROLLED BUT NOT PREVENTED! THAT, OF COURSE, IS OBVIOUS SIMPLY DUE TO IT BEING BURIED! EVEN WHERE THEY USE CONCRETE AND PLASTIC LINERS, CONCRETE CRACKS AND DEGRADES AND PLASTIC LINERS TEAR AND ANIMALS EAT HOLES IN THEM!
“(d) Analyses of the long-term stability of the disposal site and the need for ongoing active maintenance after closure must be based upon analyses of active natural processes such as erosion, mass wasting, slope failure, set-tlement of wastes and backfill, infiltration through covers over disposal areas and adjacent soils, and surface drainage of the disposal site. The analyses must provide REASONABLE assurance that there will not be a need for ongoing active maintenance of the disposal site following closure.”
THIS IS THE TYPICAL CONTRADICTORY MUMBO JUMBO WE HAVE COME TO EXPECT FROM THE US NRC – THEY TALK ABOUT THE ANIMALS, EROSION, ETC. AND THEN PRETEND IT DOESN’T MATTER! ALARA AND ALARP SOUND GREAT UNTIL YOU UNDERSTAND WHAT THEY CONSIDER REASONABLE AND THE BASIS! IT’S YOUR EXPOSURE VS. THE COMPANY’S PROFIT! WHO WINS?
“§ 61.14 Institutional information.
The institutional information must include:
(a) A certification by the Federal or State government which owns the disposal site that the Federal or State government is prepared to accept transfer of the license when the provisions of §61.30 are met, and will assume responsibility for custodial care after site closure and postclosure observa-tion and maintenance“. THERE YOU GO, CORPORATE PROFITS ON THE BACKS OF THE CITIZEN’S POCKETBOOK AND HEALTH FOR PERPETUITY. NOW THIS HAS BECOME ANOTHER BANKER’S FLEECE, IT SEEMS. LOW LEVEL WASTE – INVESTMENT BANKER’S DELIGHT. AN ETERNITY OF LIABILITIES FALL ON EVERYONE ELSE.
“(b) Where the proposed disposal site is on land not owned by the Federal or a State government, the applicant must submit evidence that arrangements have been made for assumption of ownership in fee by the Federal or a State government before the Commission issues a license.
§ 61.15 Financial information.
The financial information must be sufficient to demonstrate that the fi-nancial qualifications of the applicant are adequate to carry out the activities for which the license is sought and
Mar2010 08:18 Mar 01, 2011”
“Nuclear Regulatory Commission § 61.23
meet other financial assurance requirements as specified in subpart E of this part.
§ 61.16 Other information.
Depending upon the nature of the wastes to be disposed of, and the design and proposed operation of the land disposal facility, additional information may be requested by the Commission including the following:
(a) Physical security measures, if appropriate. Any application to receive and possess special nuclear material in quantities subject to the requirements of part 73 of this chapter shall demonstrate how the physical security re-quirements of part 73 will be met. In determining whether receipt and pos-session will be subject to the require-ments of part 73, the applicant shall not consider the quantity of special nu-clear material that has been disposed of.
(b) Safety information concerning criticality, if appropriate. (1) Any application to receive and possess special nuclear material in quantities that would be subject to the requirements of §70.24, “Criticality accident requirements” of part 70 of this chapter shall demonstrate how the requirements of that section will be met, unless the applicant requests an exemption pursuant to §70.24(d). In determining whether receipt and possession would be subject to the requirements of §70.24, the applicant shall NOT consider the quantity of special nuclear material that has been disposed of.” HUH? CRITICALITY IS RELATED TO QUANTITY OF MATERIALS! HOW IS QUANTITY NOT CONSIDERED?
“(2) Any application to receive and possess special nuclear material shall describe proposed procedures for AVOIDING accidental criticality, which address both storage of special nuclear material prior to disposal and waste emplacement for disposal.” HOW ABOUT PREVENTING? AVOIDING IS NOT GOOD ENOUGH!
“§ 61.20 Filing and distribution of application.
(a) An application for a license under this part, and any amendments there-to, must be filed with the Director, must be signed by the applicant or the applicant’s authorized representative under oath or affirmation, and, if the document is in paper form, must be the signed original.
(b) The applicant shall maintain the capability to generate additional copies of the application for distribution in accordance with written instruc-tions from the Director or the Direc-tor’s designee. (c) Fees. Application, amendment, and inspection fees applicable to a li-cense covering the receipt and disposal of radioactive wastes in a land disposal facility are required by part 170 of this chapter“.
[47 FR 57463, Dec. 27, 1982, as amended at 49 FR 9405, Mar. 12, 1984; 68 FR 58814, Oct. 10, 2003] (p. 213)
“§ 61.21 Elimination of repetition.
In its application, the applicant may incorporate by reference information contained in previous applications, statements, or reports filed with the Commission if these references are clear and specific.
[49 FR 9405, Mar. 12, 1984]
§ 61.22 Updating of application.
(a) The application must be as com-plete as possible in the light of infor-mation that is available at the time of submittal. (b) The applicant shall supplement its application in a timely manner, as necessary, to permit the Commission to review, prior to issuance of a li-cense, any changes in the activities proposed to be carried out or new infor-mation regarding the proposed activi-ties.
[49 FR 9405, Mar. 12, 1984]
§ 61.23 Standards for issuance of a li-cense.
A license for the receipt, possession, and disposal of waste containing or contaminated with source, special nu-clear, or byproduct material will be issued by the Commission upon finding that the issuance of the license will not be inimical to the common defense and security and will not constitute an UNREASONABLE RISK to the health and safety of the public, and: (a) The applicant is qualified by reason of training and experience to carry out the disposal operations requested in a manner that protects health and MINIMIZES DANGER to life or property“. p. 213 HOW ARE INVESTMENT BANKERS QUALIFIED TO PROTECT HEALTH AND MINIMIZE DANGER TO LIFE AND PROPERTY?
“10 CFR Ch. I (1–1–11 Edition) § 61.24
(b) The applicant’s proposed disposal site, disposal design, land disposal fa-cility operations (including equipment, facilities, and procedures), disposal site closure, and postclosure institutional control are adequate to protect the public health and safety in that they provide REASONABLE assurance that the general population will be protected from releases of radioactivity as specified in the performance objective in §61.41, Protection of the general popu-lation from releases of radioactivity“.
ONCE AGAIN REASONABLE AS IN WIPP ALARA (UK ALARP) NO GUARANTEES PLUS THEIR IDEA OF ACCEPTABLE EXPOSURE. THERE IS NO SAFE DOSE OF IONIZING RADIATION AND PLUTONIUM AND AMERICIUM STAY IN ONE’S BONES FOR A LIFETIME.
“(c) The applicant’s proposed disposal site, disposal site design, land disposal facility operations (including equip-ment, facilities, and procedures), dis-posal site closure, and postclosure in-stitutional control are adequate to pro-tect the public health and safety in that they will provide reasonable as-surance that individual inadvertent in-truders are protected in accordance with the performance objective in §61.42, Protection of individuals from inadvertent intrusion. (d) The applicant’s proposed land dis-posal facility operations, including equipment, facilities, and procedures, are adequate to protect the public health and safety in that they will pro-vide reasonable assurance that the standards for radiation protection set out in part 20 of this chapter will be met. (e) The applicant’s proposed disposal site, disposal site design, land disposal facility operations, disposal site clo-sure, and postclosure institutional con-trol are adequate to protect the public health and safety in that they will pro-vide reasonable assurance that long- term stability of the disposed waste and the disposal site will be achieved and will eliminate TO THE EXTENT PRACTICABLE the need for ongoing active maintenance of the disposal site fol-lowing closure. (f) The applicant’s demonstration provides reasonable assurance that the applicable technical requirements of subpart D of this part will be met. (g) The applicant’s proposal for insti-tutional control provides reasonable assurance that institutional control will be provided for the length of time found necessary to ensure the findings in paragraphs (b) through (e) of this section and that the institutional control meets the requirements of §61.59, Institutional requirements“. ONCE AGAIN “REASONABLE ASSURANCE” AND WHEN THEY GET TIRED OF THAT THEY CHANGE TO “TO THE EXTENT PRACTICABLE” WHICH IS ALARA AND WHICH HAS AN ECONOMIC CONSIDERATION. IT DOES NOT MEAN FEASIBLE SAFETY. EVERYONE WHO LISTENED TO THE WIPP PUBLIC HEARINGS HEARD THESE MISLEADING TERMS AGAIN AND AGAIN. IT ALL GOES BACK TO A LAW SUIT IN THE UK AGAINST THE GOVERNMENT OWNED COAL COMPANY, MINE UPKEEP, AND THE DEATH OF ONE COAL MINER. THE JUDGE RULED AGAINST THE WIDOW AND THAT IS THE EXCUSE TO POISON EVERYONE WITH RADIONUCLIDES FOR PERPETUITY. SUCH A DISTORTION OF COMMON LAW! THIS WAS WELL AFTER THE US GOT ITS INDEPENDENCE TOO!
“(h) The information on financial as-surances meets the requirements of subpart E of this part. (i) The applicant’s physical security information provides reasonable assur-ance that the requirements of part 73 of this chapter will be met, insofar as they are applicable to special nuclear material to be possessed before dis-posal under the license. (j) The applicant’s criticality safety procedures are adequate to protect the public health and safety and provide reasonable assurance that the require-ments of §70.24, Criticality accident re-quirements, of part 70 of this chapter will be met, insofar as they are applica-ble to special nuclear material to be possessed before disposal under the li-cense. (k) Any additional information sub-mitted as requested by the Commission pursuant to §61.16, Other information, is adequate. (l) The requirements of subpart A of part 51 of this chapter have been met. [47 FR 57463, Dec. 27, 1982, as amended at 49 FR 9405, Mar. 12, 1984]
§ 61.24 Conditions of licenses.
(a) A license issued under this part, or any right thereunder, may be trans-ferred, assigned, or in any manner dis-posed of, either voluntarily or involun-tarily, directly or indirectly, through transfer of control of the license to any person, only if the Commission finds, after securing full information, that the transfer is in accordance with the provisions of the Atomic Energy Act and gives its consent in writing in the form of a license amendment. (b) The licensee shall submit written statements under oath upon request of the Commission, at any time before termination of the license, to enable the Commission to determine whether or not the license should be modified, suspended, or revoked. (c) The license will be transferred to the site owner only on the full imple-mentation of the final closure plan as approved by the Commission, including post-closure observation and mainte-nance. (d) The licensee shall be subject to the provisions of the Atomic Energy” p. 214
[Most of p. 115 skipped for now due to time constraints]
BECAUSE “CHANGES” WAS CHANGED WE PUT THE ORIGINAL AND THE NEW ONE, THOUGH WE’VE NO TIME TO COMPARE THEM FOR NOW.
“§ 61.25 Changes.
(a) Except as provided for in specific license conditions, the licensee shall not make changes in the land disposal facility or procedures described in the license application. The license will in-clude conditions restricting subsequent changes to the facility and the proce-dures authorized which are important to public health and safety. These li-cense restrictions will fall into three categories of descending importance to public health and safety as follows: (1) those features and procedures which may not be changed without (i) 60 days prior notice to the Commission, (ii) 30 days notice of opportunity for a prior hearing, and (iii) prior Commission ap-proval; (2) those features and proce-dures which may not be changed with-out (i) 60 days prior notice to the Commisson, and (ii) prior Commission approval; and (3) those features and procedures which may not be changed
VerDate Mar2010 08:18 Mar 01, 2011 Jkt 223031 PO 00000 Frm 00225 Fmt 8010 Sfmt 8010 Y:\SGML\223031.XXX 223031” (p. 215)
2012 update of “Changes”, as found on the Cornell web site:
“§ 61.25 Changes.
(a) Except as provided for in specific license conditions, the licensee shall not make changes in the land disposal facility or procedures described in the license application. The license will include conditions restricting subsequent changes to the facility and the procedures authorized which are important to public health and safety. These license restrictions will fall into three categories of descending importance to public health and safety as follows: (1) those features and procedures which may not be changed without (i) 60 days prior notice to the Commission, (ii) 30 days notice of opportunity for a prior hearing, and (iii) prior Commission approval; (2) those features and procedures which may not be changed without (i) 60 days prior notice to the Commisson, and (ii) prior Commission approval; and (3) those features and procedures which may not be changed without 60 days prior notice to the Commission. Features and procedures falling in paragraph (a)(3) of this section may not be changed without prior Commission approval if the Commission, after having received the required notice, so orders.
(b) Amendments authorizing site closure, license transfer, or license termination shall be included in paragraph (a)(1) of this section.
(c) The Commission shall provide a copy of the notices of opportunity for hearing provided in paragraph (a)(1) of this section to State and local officials or tribal governing bodies specified in § 2.104(c) of this chapter.
[47 FR 57463, Dec. 27, 1982, as amended at 77 FR 46600, Aug. 3, 2012]”
[pages skipped due to lack of time; may or may not add them on later; if we add onto this post we will put a notification at Ongoing Saga and at the top of the post.]
One curie is one billion radioactive disintegrations (emissions) per second. We broke the following chart down here: https://miningawareness.wordpress.com/2014/09/04/the-dangerous-us-nrc-typo-making-low-level-radioactive-waste-more-radioactive-than-allowed-at-wipp/
The chart below is accurate. The error was at the NRC web site. However, if you find becquerels easier to understand it is converted at the above post.
WE HAVE HAD TO SKIP MANY PAGES BECAUSE WE’VE RUN OUT OF TIME. MUCH, BUT NOT ALL, IS REPETITIVE. IT IS VERY IMPORTANT TO UNDERSTAND THAT, DESPITE OUR CRITICISM, HAVING SOME RULES FOR BURIAL OF THE WASTE IS BETTER THAN NONE AT ALL. THEY DO NOT APPEAR TO BE ADEQUATELY PROTECTIVE, BUT THEY ARE BETTER THAN THE NOTHING, WHICH THE US NRC PROBABLY WANTS TO HAVE. THE EXCEPTIONS AND LOOPHOLES ARE UNEXCEPTABLE AND PROTECTIONS SHOULD BE INCREASED.
These are some of the questions, which the NRC asked for the comments. The questions are mostly repetitive, though there is a question re a 2007 document. Notice and beware the focus on optimization and flexibility, which appears code for deregulation and/or a blanket rad waste exception, as in the UK. Be certain to read this to help read between the lines, if you have not: https://miningawareness.wordpress.com/2014/09/13/low-level-nuclear-waste-exemptions-uk-us-perspective/
“Regarding the Current LLRW Disposal Regulatory System
1. As a result of the new national landscape, what are your key safety concerns relative to LLRW disposal?
2. What vulnerabilities or impediments, if any, are in the current regulatory approach toward LLRW disposal in the U.S. that need to be addressed in order to strengthen the NRC’s ability to ensure safe and secure LLRW disposal, improve the effectiveness of its regulations, and assure regulatory stability and predictability while allowing flexibility in disposal options?
3. What actions could be taken by the NRC and other Federal and State authorities, as well as by private industry and national scientific and technical organizations, to optimize management of LLRW? Which of the following actions are most likely to yield benefits?
a. Changes in regulations;
b. Changes in regulatory guidance;
c. Changes in industry practices; and
d. Other (name).
4. Are there additional actions (regulatory and/or industry initiated) that can/should be taken regarding specific issues such as:
a. Storage, disposal, tracking and security of Greater-than-class-C (GTCC) waste (particularly sealed sources);
b. Extended storage of LLRW;
c. Disposal options for low-activity waste/very low level waste;
d. On-site disposal of LLRW; and
e. Other (name).
5. What unintended consequences might result from the potential changes identified in response to questions 3 and 4?” https://www.federalregister.gov/articles/2014/05/15/2014-11285/low-level-radioactive-waste-regulatory-program