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We kid you not! US NRC Workshop “Low Level” Radioactive Waste Disposal for “Stakeholders” – “Panel” included “Energy Solutions” Rad Waste Co. One of the major NRC concerns is: “THE DESIRE OF THE INDUSTRY FOR GREATER FLEXIBILITY AND RELIABILITY IN LLRW DISPOSAL OPTIONS“. Yep, couldn’t make this up if we tried. The nuclear waste dump industry “DESIRES” “GREATER FLEXIBILITY” and the US NRC jumps to it! How about what the people desire?
Nuclear Waste Dump Industry "Desires"
(In case there are restrictions on the logo, we erased it. Original here: http://pbadupws.nrc.gov/docs/ML1407/ML14070A058.pdf)

“Energy Solutions” Low Level Waste Facility in Clive, Utah
zoom out with tailings pond

Comment period re US Low Level Waste ends on Monday September 15, 2014, probably at 11.59 Washington DC time, though it’s not clear: http://www.regulations.gov/#!documentDetail;D=NRC-2014-0080-0002
The law (2011) is available 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 Part updated in 2012: http://www.law.cornell.edu/cfr/text/10/61.25

Based on information provided in the NRC workshop, the topics will come back around, so unfortunately will continue to remain useful.

It’s important to recall that the term “low level” radioactive waste, in the US (and the UK), is a patent lie. There is nothing “low level”, for instance, about plutonium 241 ranging from 1,295,000 becquerels (radioactive disintegrations per second) per kilogram (2.2 pounds) for the lowest level “Class A” and 129,500,000 becquerels of plutonium 241 per kg (2.2 pounds) of “Class C”. Plutonium 241 becomes much longer lived Americium 241. These are transuranic elements of the sort which were at WIPP. (The “low level” rule for Pu 241 is a max of 3500 nanocuries/g = 129,500 bq/g = 129,500,000 bq/kg. Class A is x 0.1).

Only in NRC-pro-nuclear fantasy land can over a million radioactive emissions per second of plutonium in 2.2 pounds (1 kg) be “low level”.

Worse, while pretending that they will now make a better facility, the NRC apparently wants it to leak more. They are now saying 0.25 mSv (25 mrem) radiation exposure for the “general public” and 5 mSv (500 mrem) for the “accidental intruder” (The accidental intruder is the person who in future years doesn’t know it’s a nuclear site; it doesn’t include burrowing animals.) AND for both the “general public” and the “accidental intruder” of future generations it is 5 mSv (500 mrem)!

They will also allow the much higher, current EPA, limit for the thyroid of 0.75 mSV (75 mrem) for routine exposure. One seriously problematic component of nuclear waste is iodine 129, with a half-life of 15.7 million years. Radioactive iodine is well-recognized, even by the nuclear lobby, as causing thyroid disorders and even cancer. The nuclear lobby argues that thyroid problems are no big deal, however, since people can take thyroid replacement hormone for life. Where they don’t deny a problem, they declare it no big deal, it seems. Nobody needs their thyroids or kidneys, they appear to think. Has everyone in the NRC and nuclear lobby donated both of their kidneys to those who have damaged kidneys from uranium? If not, they need to get moving! Surely for them going to dialysis for life is not a big deal either, if it’s no big deal for other people!

The NRC also wants the option of following the ICRP exposure rate for nuclear waste disposal, which is 0.3 mSv (30 mrem). These are annual exposures and often bioaccumulative within the body and the environment. If the NRC and the nuclear industry are not brought to heel, all life is doomed. Wild animals can’t take thyroid hormone or do dialysis and these aren’t the only problems brought on by radionuclides.

It is strange that while the ICRP has decided that active nuclear facilities, like nuclear reactors, should leak at 0.1 mSv per facility per year max, where long-lived radionuclides are involved, they think that nuclear waste should be allowed to leak at 0.3 mSv. The ICRP thinks that everyone’s exposure to radiation should be 1 mSv or less from nuclear sources. These sound like small numbers, but closer examination shows that they are not, and that they are building up in the environment. The build-up is more evident in semi-closed waterways such as the Baltic, Irish Sea and surely in Scottish Lochs, if these last were tested. There must certainly be a build-up in the Great Lakes, as well.

So, while, on the one hand, the NRC has recently announced it has decided that a nuclear waste facility should be evaluated in terms of 1,000s of years, rather than a 100 years, or less, they want the facilities to LEAK MORE, and they seem to want more waste to not go to a special facility, but rather into general landfills.

WIPP for transuranic waste, such as plutonium and americium, was supposed to last 10,000 yrs, as was Asse II in Germany. WIPP lasted around 20 years; Asse II lasted less. http://en.wikipedia.org/wiki/Waste_Isolation_Pilot_Plant

FURTHERMORE, IT SEEMS THAT THE NRC’S POLICY IS THAT FOR EVERY RULE THERE IS A LOOPHOLE OR AN EXCEPTION. They appear to be seeking to formalize these into a routine, too, whereby nuclear waste goes more easily to regular landfill.

One big question is if the shift to 1,000s of years means that they will consider accessible bunker-tunnel-like facilities for “low level” waste, similar to WIPP, but in hard-rock? Or, are they still deluding themselves that they can bury it in a mound or underground? Or in salt so that it can look like Asse II or the Texas Brine-Bayou Corne-Louisiana Sinkhole?

Everyone can look at Monks Mound, or other mounds, to see that the current policy won’t work. Monks Mound, which was made of soil and clay, started slumping and filling with water almost immediately. The problems were major within a 150 or so years. It required repairs. http://en.wikipedia.org/wiki/Monks_Mound Although there may be some concrete containment-liners in the nuclear waste mounds, concrete degrades over time and more rapidly in the ground (as does everything). The clay “engineering” “barriers” will under go swelling and shrinking and cracking. It’s simply a ridiculous model. All underground structures leak and require pumping to keep dry, according to top experts in tunnel construction. How much they leak depends on location. There will be erosion, subsidence, and collapse of the facility over time. Pumping of ground water, in an effort to keep the site dry, should accelerate erosion and possibly cause sinkholes.

This was apparently the Low Level Waste comment prep session for those “in the know”, which would be people like Ralph Andersen of the “Nuclear Energy Institute”, William Dornsife of “Waste Control Specialists”, and Dan Shrum of “Energy Solutions” (He’s the one who turned in his EPA comments LATE and they were posted ahead of those who were on time), who along with some government officials were “panelists” at this “workshop” last spring. There aren’t even any academics on the panels! As panelists, the Radioactive Waste company reps must have been invited. Were you?

That is, a pro-nuclear lobby group; those who are making money disposing of radioactive waste, and those who are supposed to monitor them were “panelists”. It appears a small, backslapping, little world.
From their powerpoint slides (Emphasis added, including occasionally bold; comments added; some texts referred to added).
“NRC WORKSHOP ON THE STATUS OF LOW LEVEL RADIOACTIVE WASTE DISPOSAL RULEMAKING AND STRATEGIC ASSESSMENT OF LOW-LEVEL RADIOACTIVE WASTE REGULATORY PROGRAM http://pbadupws.nrc.gov/docs/ML1407/ML14070A058.pdf
Chip Cameron Facilitator
March 7, 2014 NRC Public Meeting Phoenix, AZ
Agenda
7:30 – 8:00 am Registration 8:00 – 8:15 Facilitator Opening Comments C. Cameron, Facilitator 8:15 – 8:30 NRC Welcome L. Camper, NRC/FSME1 8:15 8:30 NRC Welcome L. Camper, NRC/FSME
8:30 – 9:302 Status of Low-Level Radioactive Waste D. Esh, NRC/FSME Disposal Rulemaking and Discussions 9:30 – 9:45 Break 9:45 – 10:00 Strategic Assessment of M. Wong, NRC/FSME Low-Level Radioactive Waste Regulatory Program Regulatory Program 10:00 – 11:30 Panel Discussions 11:30 – 12:45 pm Facilitated Public Discussions 12:45 – 1:00 Closing Remarks A. Mohseni, NRC/FSME 12:45 1:00 Closing Remarks A. Mohseni, NRC/FSME
1 Office of Federal and State Materials and Environmental Management Programs (FSME)
2The timing is subject to change based on the status of the proposed rulemaking on 10 CFR Part 61.

NRC WORKSHOP ON THE STATUS OF LOW LEVEL RADIOACTIVE WASTE DISPOSAL LOW-LEVEL RADIOACTIVE WASTE DISPOSAL RULEMAKING AND STRATEGIC ASSESSMENT OF LOW-LEVEL RADIOACTIVE WASTE REGULATORY PROGRAM
Larry W. Camper, CEP, CIPM, Director
Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs
March 7, 2014 NRC Public Meeting Phoenix, AZ

Objective

To discuss the status of the proposed revisions to the Commission’s LLRW disposal regulations and gather information on an update to the NRC 2007 Strategic Assessment of the LLRW regulatory program from stakeholders and other interested members of the public“. (p. 4)

“STATUS OF LOW LEVEL RADIOACTIVE WASTE LOW-LEVEL RADIOACTIVE WASTE DISPOSAL RULEMAKING AND DISCUSSIONS DISCUSSIONS
David Esh
March 7, 2014 NRC Public Meeting Phoenix, AZ
Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs“(p. 6)

“2009 Commission Direction
SRM-SECY-0147-08
– Two tasks:
• Specify a requirement for a site-specific analysis, technical parameters (i.e., new definitions and performance period) to support such analysis, and develop a guidance document.
• “… in a future budget request, the staff should propose the necessary resources for a comprehensive revision to risk-inform the Part 61 waste classification framework, with conforming changes to the regulations as needed, using updated assumptions and referencing the latest ICRP methodology …”
“… This effort should explicitly address the waste classification of depleted uranium …” (p. 7)

“2012 Commission Direction
SRM-COMWDM-11-0002/COMGEA-11-0002

– Flexibility to use current International Commission on Radiological Protection (ICRP) dose methodologies

– Two-tiered period of performance:
– Two-tiered period of performance:
• Tier 1: Compliance period covering reasonably foreseeable future
• Tier 2: Longer period based on site characteristics and peak dose to a designated receptor, that is not a priori

– FLEXIBILITY to establish site-specific waste acceptance criteria based on the results of the site’s performance assessment and intruder assessment

– Balance Federal-State alignment and FLEXIBILITY (p.8)

[Notice that this means that they can say that it is unlikely that anyone will be in a certain spot in 100 or 1,000 years so that they can have lower standards. The world population is growing. People will be everywhere, if humanity survives this nuclear folly. Refer to the Monk Mound link to see how people can come from afar in a short time; for older mounds, even the American Indians don’t necessarily know who built them.]

“2014 Commission Direction SRM SECY-13-0075

– Three-tiered period of analysis:
• Tier 1: Compliance period of 1,000 years, 25 mrem dose limit for 61.41 and 500 mrem dose limit for 61.42
• Tier 2: Protective Assurance Period from 1,000 to 10,000 years, 500 mrem analytical threshold (goal) for 61.41 and 61.42
• Tier 3: Performance period > 10,000 years, qualitative analysis

– Constancy of features, events, and processes of the natural environment for Tier 2 unless compelling scientific evidence

– Realistic intruder scenarios based on expected activities on and around the disposal site at the time of closure.(p. 9)

[Oh, oh – See that? Assumes environment unchanging, unless “compelling” evidence otherwise. AND, intruder assumed based on time of closure!]

“2014 Commission Direction SRM SECY-13-0075

– The proposed rule should be published with a compatibility category “B” applied to the most significant provisions of the revised rule, including the Period of Compliance, the Protective Assurance Analysis Period and its analytical threshold, and the Waste Acceptance Criteria Acceptance Criteria.

– The Protective Assurance Analysis Period (Tier 2) requires the applicant to propose remedial changes to the disposal site design, or impose inventory limits, or propose alternative methods of disposal as it is approached.

Stress defense-in-depth and safety case.

– Thorough review of guidance by LLW community“. (p.10)

[Who’s the “community”? The people near the facility or the “community” of nuclear waste companies?]

“Path Forward

• Staff will revise the rule, statement of considerations, and guidance document over the next year.
• Proposed rule issued for public comment in 2015.
• Extensive stakeholders outreach – 120 days comment period – 1 or more public meeting to engage stakeholders“(p. 11)

[Who are the stakeholders? Where is the “public meeting” going to be held?
HOW IS ONE PUBLIC MEETING SUFFICIENT FOR A COUNTRY AS HUGE AS THE USA? EVEN FOR A STATE OR A TINY COUNTRY IT WOULDN’T BE MUCH! CALL IT DEMOCRACY? Yeah, yeah, a “Republic” but I was referring to the Bruce Cockburn song, really. OH THIS WAS ALLEGEDLY A PUBLIC MEETING, TOO! WERE YOU INVITED? THE PANEL GUESTS ALMOST CERTAINLY WERE! WHERE IS THEIR PRESENTATION?]

“STRATEGIC ASSESSMENT OF LOW LEVEL STRATEGIC ASSESSMENT OF LOW-LEVEL RADIOACTIVE WASTE REGULATORY PROGRAM PROGRAM
Melanie Wong
March 7, 2014 NRC Public Meeting Phoenix, AZ

Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental M t P Management Programs” (p. 12)

“Topics

• Background
• Status of the 2007 Strategic Assessment
• Proposed updates to the Strategic Assessment
• Next steps” ( p. 13)

“Background

Challenges and issues included:
• THE DESIRE OF THE INDUSTRY FOR GREATER FLEXIBILITY AND RELIABILITY IN LLRW DISPOSAL OPTIONS;
• increased storage of Class B and Class C LLRW;
• the potential need to dispose of large quantities of power plant decommissioning waste and depleted uranium;
• increased safety concerns;
• the LLRW program required greater resources than were available;
• increased security concerns; and
• new waste streams that may be generated“.
(p. 14)

“Background (continued)
2007 Strategic Assessment of the NRC’s regulatory program for LLRW

Goal:
• identify and prioritize staff activities

Objectives:
• ensure safe and secure LLRW disposal;
• improve the effectiveness, EFFICIENCY, and ADAPTABILITY of the NRC’s LLRW regulatory program; and
• ensure regulatory stability and predictability“. (p.15)

“Background (continued)
• Variety of activities proposed
• List of 20 activities developed
• Priorities of high (7 tasks), medium (6 tasks), or low (7 tasks) assigned tasks) assigned”
(p.16)

“Background (continued)
High Priority Activities

Task # Task Description

1 Review and update guidance on extended storage of LLRW.

2 Develop guidance on 10 CFR 20.2002 Alternate Disposal Requests.

3 Determine if disposal of large quantities of depleted uranium would change the waste classification tables.

4 Update Branch Technical Position on Concentration Averaging and Encapsulation Encapsulation.

5 Develop procedures for IMPORT/EXPORT Review.

6 Develop guidance on alternate waste classification (10 CFR 61.58).

7 Perform scoping study of the need to revise/expand byproduct material financial assurance to account for life-cycle cost.“(p. 17)

HUGE LOOPHOLE:
“§ 20.2002 Method for obtaining approval of proposed disposal procedures. A licensee or applicant for a license may apply to the Commission for approval of proposed procedures, not otherwise authorized in the regulations in this chapter, to dispose of licensed material generated in the licensee’s activities. Each application shall include:
(a) A description of the waste containing licensed material to be disposed of, including the physical and chemical properties important to risk evaluation, and the proposed manner and conditions of waste disposal; and
(b) An analysis and evaluation of pertinent information on the nature of the environment; and
(c) The nature and location of other potentially affected licensed and unlicensed facilities; and
(d) Analyses and procedures to ensure that doses are maintained ALARA and within the dose limits in this part. Page Last Reviewed/Updated Thursday, July 10, 2014” http://www.nrc.gov/reading-rm/doc-collections/cfr/part020/part020-2002.html

Power point continues:
“Background (continued)

Medium Priority Activities
Task # Task Description

1 Develop licensing criteria for greater than Class C (GTCC) disposal facility.

2 Consolidate LLRW guidance.

3 Develop guidance that summarizes disposition OPTIONS for low-end materials and waste.

4 Coordinate with other agencies on consistency in regulating low activity waste disposal.

5 Identify new waste streams.

6 Develop information notice on waste minimization Develop information notice on waste minimization“.(p. 18)

“Background (continued)

Low Priority Activities
Task # Task Description

1 Evaluate potential changes to LLRW regulatory program as a result of severe curtailment of disposal capacity.

2 Promulgate rule for disposal of low-activity waste.

3 Identify and evaluate potential legislative changes.

4 Implement major revisions to 10 CFR Part 61.

5 Develop waste acceptance criteria for LLRW disposal in uranium mill tailings impoundments.

6 Examine need for guidance on DEFINING WHEN RADIOACTIVE MATERIAL BECOMES LLRW.

7 Develop and implement national waste tracking system“. (p. 19)

US NRC POWER PT LLRW 2014

From: “10 CFR Ch. I (1–1–11 Edition)” [Not in powerpoint slides]
Ҥ 61.58 Alternative requirements for waste classification and characteristics.

The Commission may, upon request or on its own initiative, authorize other provisions for the classification and characteristics of waste on a spe-cific basis, if, after evaluation, of the specific characteristics of the waste, disposal site, and method of disposal, it finds reasonable assurance of compli-ance with the performance objectives in subpart C of this part. (p. 223)

“Subpart C—Performance Objectives

§ 61.40 General requirement.

Land disposal facilities must be sited, designed, operated, closed, and”
(p. 217)

“10 CFR Ch. I (1–1–11 Edition) § 61.41

controlled after closure so that reasonable assurance exists that exposures to humans are within the limits estab-lished in the performance objectives in §§61.41 through 61.44.

§ 61.41 Protection of the general population from releases of radioactivity.

Concentrations of radioactive material which may be released to the general environment in ground water, surface water, air, soil, plants, or animals must not result in an annual dose exceeding an equivalent of 25 millirems to the whole body, 75 millirems to the thyroid, and 25 millirems to any other organ of any member of the public. Reasonable effort should be made to maintain releases of radioactivity in effluents to the general environment as low as is reasonably achievable.

§ 61.42 Protection of individuals from inadvertent intrusion.

Design, operation, and closure of the land disposal facility must ensure protection of any individual inadvertently intruding into the disposal site and occupying the site or contacting the waste AT ANY TIME AFTER ACTIVE INSTITUTIONAL CONTROLS over the disposal site are removed.

§ 61.43 Protection of individuals during operations.

Operations at the land disposal facility must be conducted in compliance with the standards for radiation protection set out in part 20 of this chapter, EXCEPT for releases of radioactivity in effluents from the land disposal facility, which shall be governed by §61.41 of this part. Every REASONABLE effort shall be made to maintain radiation exposures as low as is reasonably achievable.

§ 61.44 Stability of the disposal site after closure.

The disposal facility must be sited, designed, used, operated, and closed to achieve long-term stability of the disposal site and to eliminate to the ex-tent practicable the need for ongoing active maintenance of the disposal site following closure so that only surveillance, monitoring, or minor custodial care are required“. (p.218) [RECALL THAT ALARA, ALARP HAVE NOTHING TO DO WITH WHAT MOST PEOPLE THINK IS “REASONABLE”. IT DOES NOT MEAN FEASIBLE. IT HAS TO DO WITH THE PROFIT OF THE WASTE FACILITY VS. PUBLIC HEALTH RISK, AS THE GOVT. DEFINES RISK! ALARA-ALARP HAVE ROOTS IN A COAL MINING ACCIDENT IN THE UK, WHERE THE WIDOW LOST.]

[Return to powerpoint presentation]
“Proposed Updates to the Strategic Assessment

• Review 2007 Strategic Assessment and could reprioritize some of remaining activities
• Develop licensing criteria for greater than Class C disposal facility.
• Perform scoping study of the need to revise/expand byproduct material financial assurance to account for life cycle cost life-cycle cost.
• Develop procedures for Import/Export Review“. (p 21)

“Initial Scoping of the Update to the Strategic Assessment

• Activities to consider include
• Licensing Criteria for GTCC
• Low Activity Waste Rulemaking
• Revision of the Waste Manifest
• Waste Attribution” (p. 22)

“Next Steps
• Information gathering
• Federal Register Notice soliciting comments on proposed activities
• Request comment on draft updated Strategic Assessment”
(p.23)

“NRC WORKSHOP ON THE STATUS OF LOW-LEVEL RADIOACTIVE WASTE DISPOSAL RULEMAKING AND STRATEGIC ASSESSMENT OF LOW-LEVEL RADIOACTIVE WASTE REGULATORY PROGRAM Chip Cameron, Facilitator
March 7, 2014 NRC Public Meeting, Phoenix, AZ
Introduction of Panelists

Brad Broussard Texas Commission on Environmental Quality

Earl Fordham Washington Department of Health

Rusty Lundberg Utah Department of Environmental Quality

Ralph Andersen Nuclear Energy Institute

William Dornsife Waste Control Specialists

Dan Shrum Energy Solutions

Christine Gelles U.S. Department of Energy-Environmental Management

Michael Garner Northwest Interstate Compact on Low-Level Radioactive Waste Management/State of Washington

Gregory Suber U.S. Nuclear Regulatory Commission” (p. 26)

“Topics

• What changes are anticipated to the national landscape in the LLRW area in the context of safety security and in the LLRW area in the context of safety, security, and the protection of the environment in the next 5-7 years?

• As a result of the new national landscape, what activities from the 2007 Strategic Assessment should remain on the list and are they appropriately prioritized 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?
• As a result of the new national landscape, what additional changes are needed to the NRC regulatory framework?“( p. 27)

“Recap and Closing Recap and Closing
Aby Mohseni, Deputy Director
Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs
March 7, 2014 NRC Public Meeting Phoenix, AZ

Insights From Insights From Today’s Workshop Today’s Workshop

Next Steps

• Evaluate today’s comments
• Additional Outreach efforts
• Expect proposed 10 CFR Part 61 rule issued for public comment in 2015
• Draft Strategic Assessment issued for public comment in early 2015” (p.30) “QUESTIONS” (p. 31) http://pbadupws.nrc.gov/docs/ML1407/ML14070A058.pdf

“Aby Mohseni
Mr. Mohseni joined the NRC in 1990 in the Office of Nuclear Reactor Regulations.
He is currently the Deputy Director for Environmental Protection and Performance Assessment Directorate.
His prior appointment was Deputy Director of Spent Fuel Alternative Strategies Division in the Office of Nuclear Materials Safety and Safeguards.
Prior to that, for 5 years, he served as Deputy Director for Licensing and Inspection Directorate, Division of High-Level Waste Repository Safety.
In 2000, he served as Science Advisor to the Chairman of the US Senate Committee on Environment and Public Works.
Prior to joining the NRC, Mr. Mohseni was the Head for Nuclear Safety, Washington State Office of Radiation Protection.
He also served as Senior Project Manager for I&C and for Nuclear Steam Supply System at Satsop Nuclear Plant (WNP-3) in Washington State.
Mr. Mohseni earned a Bachelor’s degree in Physics and a Master’s degree in Nuclear Engineering from the University of Washington, Seattle, WA.
Page Last Reviewed/Updated Wednesday, July 17, 2013”
http://www.nrc.gov/public-involve/conference-symposia/ric/past/2013/docs/bios/bio1-730.html