Andrews, Andrews Texas, BEIR, burial of highly radioactive waste, burial of plutonium, cancer, cancer deaths, Class A B C Greater than C radioactive waste, declaring radioactive waste non-radioactive, depleted uranium, DU, environment, future generations, Health impacts nuclear, High Level Nuclear Waste, import of foreign radioactive waste, iodine 129, long-lived nuclear waste, long-lived radionuclides, Low Level Nuclear Waste, NIRS, nuclear energy, nuclear power, nuclear regulatory commission, nuclear safety, nuclear waste, nuclear waste to landfill, plutonium, public endangerment, public safety, radioactive waste, recycling of nuclear waste, recycling of radioactive waste, releasing dangerous radionuclides to environment, Texas, unlined trenches, US EPA, US NRC, WCS
While it appears a waste of time to comment to the USNRC, comments become public record. As such, they can be used in future legal proceedings against the NRC-US government. Additionally, future generations, if there are any survivors, will know that people cared and tried. The Nuclear Regulatory Commission should change its name to Nuclear Regurgitation Commission, because they directly and indirectly encourage the leaching, leaking, spewing, and even exploding, of nuclear waste into the land, air and water of America, and ultimately of the world. Depending on location, this also impacts other countries such as the Canada, Mexico, and via the Gulf Stream and air currents, Europe, and even the Arctic. “Low-Level Radioactive Waste Disposal; Reopening of Comment Period” Comment Now! Due Sep 21, 2015 11:59 PM ET Proposed Rule Posted: 08/27/2015ID: NRC-2011-0012-0165 Comment here: http://www.regulations.gov/#!docketDetail;D=NRC-2011-0012
Burial of Radioactive Waste in the WCS Nuclear Waste Dump in west Texas, USA This looks well-organized and sophisticated compared to the Energy Solutions dump in Clive Utah.
Large Nuclear Components-Metal Parts Energy Solutions Clive Utah
No burial of radioactive waste should be allowed, period. Although the WCS nuclear dump sounded great on an earlier version of their website, the concrete lining, thick or thin, will crack from both age and dry-wet shrinkage; cracking and swelling of the underlying clay. Cracking due to wet-dry shrinkage could happen quickly. Routine readers have learned that radiation speeds up concrete degradation, too. Concrete itself is permeable. Even underground structures generally leak, and require some pumping to keep dry (e.g. parking garages, tunnels, etc).
Worse, the proposed NRC rule allows “increasing the amount and longevity of radioactivity that goes into shallow land burial. The proposed rule would allow even longer-lasting waste into unlined soil trenches“ (See Arrigo comment below). NUCLEAR WASTE IN UNLINED SOIL TRENCHES!
Radioactive waste with short-lived radionuclides can be held in containment until it is non-radioactive, more cheaply, as well. Radioactive waste must be monitored in proper, retrievable, containment and not buried. Leaks can then be stopped before they occur, or before they reach the outer environment. Burial speeds up the degradation process of any containment and keeps it from being monitored. As well as leaking into the environment, it can catch fire and explode. When they speak of monitoring they are speaking of monitoring the radiation leak rates. There should be no radioactive leaks! Furthermore, it can be presumed that as in the case of operating reactors, that the leak measurements are in concentration, rather than amount. To the extent that they are measured in mSv (mrem), assumptions are made regarding local food habits, and the radionuclides move in waterways, and air, allowing for dilute and deceive measuring scams – whether in concentration or Millisieverts (mSv) – Millirems. It is important to recall that radioactive half-lives are half of half of half, etc. so that even radioactive cesium 137, half-life 30 years, stays in the environment for over 300 years.
1 half life = 50% left
10 half life = 0.097% left
20 half life = 0.0001% left
The 5 mSv per year of radioactive leaching into the environment is intentional, known, and planned leaking. It is not whoops events like at WIPP. It is 20 times higher than that allowed by the EPA for operating nuclear reactors (0.25 mSV), 33 times greater than proposed for Yucca Mountain (0.15 mSv), and 50 times the international “constraint” standard for public exposure to prolonged component of long-lived radionuclides of 0.1 mSv (ICRP 103, p. 116). By conservative estimates, it would lead to 1 excess cancer per 25 people, assuming lifetime exposure.
There is an apparent trend, likely to increase with dismantlement of old nuclear power stations, to declare radioactive waste non-radioactive, i.e. “exempt”. This has apparently been sneaked into this proposed rule. The whereabouts of exempted radioactive waste is no longer monitored and it may end up anywhere. This will probably include foreign nuclear power stations, as the US government appears hell-bent on making America into a world nuclear dumping ground. Taxpayers need to learn the tax long-form and figure out how to legally pay as little tax as possible to the government, using tax-exempt deductions. The most recent import of radioactive waste to America, of which we are aware, is Swiss nuclear waste (spent fuel). Rather than take it to one of two radioactive waste process and storage facilities one hour away, the Swiss paid over 10 million US dollars (10 million Swiss Francs) to send it to South Carolina, where it will apparently initially be put in a spent fuel pool. The US itself spends about 2 billion dollars per year on this program to dump high level nuclear waste on America under bogus claims of non-proliferation. For 2016, only, $1.9 billion was requested by the US DOE for so-called nuclear nonproliferation activities, where the US runs all over the world taking the HEU radioactive waste of other countries, to supposedly reduce global stocks of weapons-useable nuclear materials. Processing in Tennessee means that some of the radioactive materials end up in the Nolichucky River, which goes to the Tennessee and part goes to the Ohio R., the Mississippi R. and out to the Gulf of Mexico below New Orleans and part splits off to the Tennessee Tom Bigbee waterway and also ends up in the Gulf of Mexico. Due to the Gulf Stream, and air currents, some of the radionuclides will return to European senders. This $1.9 billion is not free money. It’s from taxpayers. http://www.energy.gov/articles/energy-department-presents-fy16-budget-request In short, the US taxpayer has been paying billions to dump nuclear waste on themselves for years now!
“Processing” of this foreign nuclear waste creates additional “streams” of “low level” and transuranic radioactive waste. Diane D’Arrigo of the NIRS points out that this foreign nuclear waste may be buried in shallow dumps: “High level radioactive waste from reprocessing of irradiated fuel—dubbed “Waste Incidental to Reprocessing” or even other high level waste could theoretically be disposed in shallow land burial grounds.”(See Arrigo comment below). Another shocking example is that the US imported German radioactive waste to burn in Tennessee, presumably because the incineration standards are weaker. And, why didn’t they send it to the new plasma furnace just across the border in Switzerland, if Germany lacks an incinerator? Some self-proclaimed anti-nuclear activists become apoplectic over the alleged impacts of this highly filtered, sophisticated, Swiss plasma furnace that supposedly melts, rather than burn, low level radioactive waste, but emit not a peep about the impacts of sending German radioactive waste to be burned, barely filtered (if at all), and/or dumped on America. Incineration ash must be disposed of, too. In this instance the Germans were to take the ash back, but radiation still goes into the air during incineration.(On the other hand, many brave and honorable Germans have spoken up against these policies.) Standards matter from both a legal and health perspective.
In the 1980s and early 1990s Martin Marietta, now Lockheed Martin (current contractor at Sandia Labs), sent nuclear waste to be illegally incinerated throughout America, to increase their profits. There were Congressional hearings. Some Sandia (Lockheed Martin) workers are behind an attempt to increase legal radiation exposure levels for the general population to 100 mSv per year, which is 400 times greater than the US EPA standard of 0.25 mSv per year and 5 times higher than the internationally recommended exposure for nuclear workers of 20 mSv per year. The 100 mSv will mean an estimated 80 more cancers per 100 people in the US population. That comment deadline is in November.
The proposal today is about raising radiation exposure of the general population to 5 mSv per year, upon radioactive waste dump closure, meaning one extra cancer per 25 people, assuming a lifetime of exposure. Some experts think it would be double this amount.
One type of waste taken by the WCS (radioactive waste) land fill is “Specifically exempt items manufactured under a specific license that authorizes the transfer to exempt persons“ http://www.wcstexas. com/facilities/site-capabilities/
“ “Below Regulatory Concern-” deregulates, exempts and releases radioactive waste and materials from radioactive regulatory control. NRC under its 10 CFR 20.2002 process allows radioactive waste, material and sites to be managed without radioactive regulatory controls on a case by case basis… call on NRC to stop treating nuclear waste, property and materials as if not radioactive whether it goes to solid, hazardous or other facilities and especially if it is allowed into the recycling streams or is released for unrestricted or restricted use.” (Diane D’Arrigo comment, see more below)
Diane D’Arrigo, of the NIRS, one of the foremost experts on the topic, submitted a comment on behalf of over 100 organizations. The entire comment is found here: https://miningawareness.wordpress.com/2015/09/09/us-nrc-low-level-nuclear-waste-proposal-33-x-higher-than-high-level-dumps-removes-state-rights-to-protect-people-environment-comment-by-sept-21st-11-59-pm-et-ny-dc/
We encourage you to both write in support of Diane D’Arrigo’s comment, as well as writing something as long, or as short, as you want, in your own words. If it’s too long you will have to attach a pdf, however.
“Comments of Over 100 Organizations* to NRC on 10 CFR 61 Proposed Radioactive Waste Disposal Regulations Federal Register / Vol. 80, No. 58 / Thursday, March 26, 2015 / Proposed Rules 10 CFR Parts 20 and 61 [NRC–2011–0012; NRC–2015–0003] RIN 3150–AI92 Low-Level Radioactive Waste Disposal AGENCY: Nuclear Regulatory Commission. ACTION: Proposed rule.”
p. 1 “New NRC so-called “Low-Level” Nuclear Waste Dump Rules Would Allow More than 33 Times Higher Radiation than High Level Dumps! And 20 Times more than from Operating Nuclear Power Reactors!”
“The proposed regulations allow more than 33 times higher radioactive releases and exposures from so-called “low-level” radioactive waste dumps than from a high level waste dump formerly proposed at Yucca Mountain. Federal regulations (1) for a high level waste repository allow the site to release radioactivity that would deliver doses of up to 15 millirems/year (2)” [0.15 mSv per year] “for the first 10,000 years. From 10,000 to 1 million years, the annual dose limit is 100 millirems” [1 mSv].“The NRC proposed regulations allow 25 mr/year” [0.25 mSv] “during operation but up to and beyond 500 millirems per” [5 mSv] “year from so called “low-level” radioactive waste disposal sites. The proposed rule allows so-called “low-level” nuclear waste disposal sites, after closure, to emit more than 20 times more radioactivity than operating nuclear power reactors (3) under the Environmental Protection Agency’s regulations. 1 in 25 adults exposed to 500 mr/year” [5 mSv per year] “will get cancer, (4) assuming a lifetime dose (which is permitted by the rule).”
Page 2: … The proposed rule makes the existing 10 CFR 61 even worse and makes radioactive waste dumps more dangerous. The current rule does not require isolating the waste for the entire time it is radioactively hazardous but the proposed rule enables increasing the amount, radioactivity and longevity of the waste while removing dose limits “based on technological and economic considerations.”(5)
It dubs future populations “intruders” and allows unlimited doses in the future from nuclear waste generated and buried today.
The proposed rule allows private dump-operators to do “black box” calculations to allegedly justify putting whole new kinds and amounts of radioactive wastes to existing waste sites, clearly a conflict of interest—profit for them and not in the interests of the public or environment. It overrules states that have or might set stricter than federal standards for public and environmental protection. NRC appears to be lowering its own federal standards for public and environmental protection and for democratic participation, possibly in order to facilitate weaker standards at one or more existing radioactive waste facilities. At a time when NRC should be enforcing its own administrative and technical regulations, it is weakening them…. ”
“10 CFR 61.55 Definitions: The A, B, C, >C waste classifications in 10 CFR 61.55 make assumptions that have never been publicly accepted but have become the norm. We continue to oppose the use of those misleading classifications, thus are more strongly opposed to allowing even more longer lasting and hazardous radionuclides into 10 CFR 61 disposal sites. For example, there is no level of plutonium that is “safe” or acceptable. Yet Class A waste, supposedly only dangerous for 100 years, the shortest lasting and least concentrated class, includes plutonium-239, hazardous for a quarter to half million years, up to 10 nanocuries per gram, with no limit on the number of grams. It also includes iodine-129 hazardous for 160 to 320 million years. Clearly adding the proposed DU which decays into other, even longer-lasting radioactive elements, with its long decay chain has no business in 100 year Class A disposal.”
“Make a goal of isolating radioactive waste, not legalizing releases. Do not increase allowable radioactive releases or the projected doses to people during or after the operational period. Under the existing 10 CFR 61 the sites can legally leak into “the general environment in ground water, surface water, air, soil, plants and animals,” an amount calculated to deliver up to 25 millirems to the whole body, 75 millirems to the thyroid and 25 millirems to any other organ of the body of members of the public, annually” [0.25 mSv; 0.75 mSv, and 0.25 mSv].By adopting the 10 CFR 20 definitions of radiation dose (doing away with organ dose limits), the proposed rule increases the radioactivity per millirem for many of the radionuclides. The proposed rule makes this much worse, as it allows not 25 but up to 500 millirems (EDE) or more per year, from a closed site. The unspecified doses are based on technical and economic considerations of the waste site operator. See the proposed 10 CFR § 61.42. 500 millirems/year” [5 mSv per year] “is an amount that is expected to cause cancer in 1 in 25 exposed (6), clearly an unacceptable risk from closed nuclear waste sites. This is criminal…
The existing radioactive waste sites have historically leaked – some in less than 20 years and well before site closure….
No Preemption of State Authority; Require States to Regulate as Strictly as NRC –
The proposed rule supersedes the rights and authority of states to set more protective standards for facilities in their boundaries…”
“…NRC should drop the proposed requirement that all provisions of the new rules be adopted verbatim, Level B Compatibility, by Agreement States. The ‘Low-Level’ Radioactive Waste Policy Act and its Amendments (PL 99-240) makes states responsible for so-called “low-level” radioactive waste that is generated within their boundaries (although the provision requiring states to take title to the waste if disposal was not provided was overruled by the US Supreme Court in 1992). NRC should not undercut states by preempting their ability to set standards that are more protective than federal requirements. This undercuts states’ ability to be responsive to its citizens and residents.
NRC should retain and expand the ability for states to be more protective, to regulate more strictly than the federal 10 CFR 61 regulations.….
Rather than relaxing standards and advocating for more hazardous and long-lasting waste going into waste sites, the US NRC, at minimum, should be enforcing the existing requirements and regulations and holding states to those.
In cases in which the state or states that are increasing the risks to the public or providing weaker protections that 10 CFR 61 currently allows, NRC should assert its authority to maintain federal standards and require Agreement States to do so. This rulemaking appears to be an effort by NRC to join the lower common denominator,…
“Below Regulatory Concern-” deregulates, exempts and releases radioactive waste and materials from radioactive regulatory control. NRC under its 10 CFR 20.2002 process allows radioactive waste, material and sites to be managed without radioactive regulatory controls on a case by case basis. Applications for these exemptions are not easily publicly available thus devoid of necessary options for public input and intervention. We are not aware of public reporting of 10 CFR 61.6 applications and call on NRC to stop treating nuclear waste, property and materials as if not radioactive whether it goes to solid, hazardous or other facilities and especially if it is allowed into the recycling streams or is released for unrestricted or restricted use.
DELETE the added phrase in proposed rule under §61.7 Concepts …“Alternative methods of disposal may be approved on a case-by-case basis as needed under § 61.6.” (Page 9 of the Comparison between Current Rule Language and Rule Language in Proposed Rule, “Low-Level Radioactive Waste Disposal” (80 FR 16082)). The NRC”
“must not forget that the American public and our elected officials have repeatedly rejected the deregulation of nuclear waste. It should not be inserted into this rule which is about licensed radioactive disposal. The proposed rule re-asserts the publicly rejected concept of deregulation and we demand the deletion of this and any provisions that allow for manmade radioactive waste, materials, emissions and practices to be released from radioactive regulatory control. Deregulation, release, exemption, clearance and deminimus are completely unacceptable.
DELETE the existing § 61.6 Exemptions 7 from the regulations. If it is retained, at minimum, CLARIFY that there is must be advance public notice, comment and opportunity for hearing, adjudicatory hearing and intervention, as with other license amendments and changes in regulations. Public notice, comment and opportunity for intervention should be required for any and all exemption, clearance, release of radioactive waste or materials from radioactive regulatory control.
– We oppose increasing the amount and longevity of radioactivity that goes into shallow land burial. The proposed rule would allow even longer-lasting waste into unlined soil trenches than the current regulations—waste that will be dangerous much longer than the sites will be controlled or monitored. These include:
– Plutonium-239 (240,000 to 480,000 year hazard) and iodine-129 (160 to 320 million year hazard) from nuclear power reactors are already allowed in set concentrations in dumps that can be institutionally controlled for up to just 100 years. Sierra Club and other public interest and environmental groups have called for limiting the waste that can go into these dumps to that which is hazardous for 100 years or less. Pennsylvania extended the institutional control period so if a facility is opened in that state, the site would be tracked longer than NRC assumes. Rather than consider the public demands for letting only shorter-lasting waste into the burial grounds, NRC is now opening the door to very large amounts of long-lasting waste and waste that gets more radioactive as it decays into other more radioactive materials. We direct that NRC analyze and adopt stricter disposal site requirements, keeping long-lasting waste out of shallow burial sites.
– Uranium, referred to as Depleted Uranium (DU) after much of the uranium-235 is removed to make nuclear power and weapons fuel, because it is “depleted” of that one isotope, is biologically hazardous and radioactive due to all the other uranium isotopes present and the decay products of those isotopes increase in radioactivity over time. Thus DU can deliver increasing doses to the public, giving the peak or highest dose in more than 2 million years. (See http://www.deq.utah.gov/businesses/E/EnSolutions/depleteduranium/ and http://www.healutah.org/campaigns/nuclear-utah/nuclear-waste/ ) ”
“7 Existing regulation: 10 CFR § 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.”
“We support HEAL Utah, Institute for Energy and Environmental Research’s (IEER) and all other technical comments throughout this entire rulemaking process against allowing DU into shallow land burial sites and opposing its de facto inclusion in Class A with no justifiable, technical analysis. NIRS and IEER challenged the commercial generation of more DU during the licensing of the LES uranium enrichment facility now operating in New Mexico. We continue to hold that DU is not “low-level” waste or Class A, and that there is no safe permanent way to “dispose” or isolate it from the public and the environment. Because of the longevity of the hazard, it must be considered high level radioactive waste, or at least Greater than Class C, unsuitable for shallow land burial. We oppose the default and pretense NRC is making to allow it into shallow land burial where it cannot be isolated for the length of it hazard.
– “Dirty” DU: So-called Depleted Uranium or DU could have and has had fission products present which exacerbate the health effects even further. Uranium recovered from the reprocessing of highly radioactive irradiated nuclear fuel, became highly radioactive and was sent back through enrichment facilities without notifying or protecting the workers from this deadly additional hazard. The DU generated during that subsequent enrichment processes was contaminated with fission products as well as the heavier transuranic residue that came with the “dirty” uranium. Absolutely no calculations have been done for this rulemaking by NRC nor are there requirements for disposal licensees to include such information in their Performance Assessments.
This is a clear example that the process will not protect the public and environment. There is no justification for failing to incorporate this reality into the rulemaking, further discrediting the inadequate assessments of harm this proposed rule presents.
– High level radioactive waste from reprocessing of irradiated fuel—dubbed “Waste Incidental to Reprocessing” or even other high level waste could theoretically be disposed in shallow land burial grounds. Commercial reprocessing is not happening now in the US and NRC should not change its rules to accommodate reprocessing.”
Blended waste and Averaging
Years after the 1982 rule10 CFR 61 was adopted, NRC reinterpreted that rule to mean that classifying of waste (into A, B, C or >C) should be done at the point of disposal. This facilitated all sorts of waste processing, largely done in Tennessee but also in other states including Ohio. This has led to unnecessary transport and routine radioactive releases to the environment around processing facilities. A disturbing idea is being considered of bringing waste to disposal sites and then mathematically averaging the amount of radioactivity with the amount of radioactivity already at the site to allow much more radioactivity and higher concentration waste to be buried. We object to these practices.
– NRC is not abandoning the A B C and >C concentration tables 10 CFR 61.55 but providing many other methods to comply and apparently leaving it up the waste operator, not the state or the public.
– NRC creates and exacerbates a serious conflict of interest by encouraging and permitting profit-making dump-operators to do their own computer models and projections to allow more radioactive and longer lasting waste into trenches. NRC’s claim that computer- generated “Performance Assessments” can predict a “Safety Case” is false. Increasing hazards does not provide greater protection.”
– NRC admitted that it had not considered that some uranium is laced with fission products. As we stated above, some reprocessed uranium was put through uranium enrichment facilities….
– NRC admits that Waste Incidental to Reprocessing possibly could go to shallow land burial.
– Greater-that Class-C waste and Transuranics above 10 or 100 nanocuries per gram, previously guaranteed NOT to go to these facilities would be allowed.
– Dump operators will make more money; generation of more new waste will be encouraged; the public will not be protected. The NRC, some Agreement state regulators and the waste site operators are making no “safety case” for us, the public.
– NRC’s proposed rule would allow higher amounts of radioactive exposure –higher doses and in some cases, unlimited radiation doses to the public, as mentioned above.
– First, this done by “updating,” using a different way to calculate doses which allows more radioactivity per millirem or unit of dose for many of the radionuclides. Depending on which radionuclides are being considered, there can be different amounts in each new millirem EDE (the ‘updated’ dose units) than in each of the existing millirems in the current rule. Neither of these are ever measured, verified or enforced. They serve to justify allowing more radioactivity in the waste and waste sites. We oppose the adoption into 10 CFR 61 of the 10 CFR 20 methods of dose calculation in all cases that increase radioactivity per millirem, or increase allowable concentrations, releases and exposures.
– Second, NRC is increasing and allowing unlimited millirems/year. The existing rule limits doses to the public during operations to 25/75/25 millirems per year and does not expressly specify higher amounts post-closure. This would be an enormous relaxation of the standards and must be dropped.
NRC opening these sites to DU is a mistake since the radioactivity/radiation levels will rise over time. At one time DU was expected to be part of wastes that should be permanently isolated from our environment like irradiated fuel. NRC should adopt that plan for DU.
– Radiation is more dangerous for females, youth, and threatens the reproductive stage of the human and other life cycles. The proposed rule ignores the now-known reality that external ionizing radiation causes 50% more cancer and fatal cancer in female adults compared to male adults and 7 times”
“… Juvenile females are not a “subpopulation” they are an inextricable link in the human lifecycle. There is no biological “Reference Man” who did not come from someone who was in this most sensitive age group. NRC continues to unacceptably ignore non-cancer health effects, synergistic effects with other toxic exposures and reproductive effects.
NRC should not “update” the radiation dose part of this regulation 10 CFR 61 by incorporating its 10 CFR 20 standards because those are less protective than 10 CFR 61 current limits. Any change should “update” the scientific reality that radiation is more harmful than previous assessments identified and reduce allowable releases and exposures.
NRC is failing to protect the reproductive phase of the human lifecycle (and that of all other species as well)… Radiation is clearly being found to be more harmful every time it is reviewed (rather, each batch of new data shows that regulators have failed repeatedly to honestly report the true hazards of ionizing radiation) yet NRC stubbornly moves to let the radioactive pollution levels rise as it increases allowable concentrations and emissions into air and water and doses to this and future generations. Scientifically, it is unacceptable.
There is no meaningful limit on the Performance Assessment. Allowing the option of the waste site operator choosing his or her own allowable dose level, means pretty much any kind of waste can go to these sites. This is worsened by the fact that allowable dose limits are used for calculations only, never enforced or verified; It is not scientifically justifiable for NRC allow Performance Assessments and Safety Cases to be done by those who stand to profit, inevitably allowing more dangerous and long lasting wastes into shallow land burial sites.
It is a conflict of interest to allow those who profit from disposal, the waste site owners and or operators, to do essentially “black box” calculations to allow more dangerous nuclear waste into their own facilities. The rule should not have this provision and any provision it does have should have a requirement for public notification, comment, intervention and intervenor funding.
– The Emergency Access Clause, Section 6 of the Low Level Radioactive Waste Policy Act, provides that in emergency situations, operating nuclear waste facilities could be required to take waste not normally designated or intended. We have always contended” […]
“that sites must not be required, forced, or allowed to take wastes for which they were not originally intended or characterized. The proposed regulations could do the exact opposite, provide for any kind of radioactive waste to be accepted. Under the Environmental Protection Agency’s Protective Action Guides, such facilities could be expected to take large amount of waste from emergencies. States should not be forced to accommodate the nuclear industry polluters in this way. It is time for the federal regulators to adopt a role of incentivizing waste reduction, not the opposite.
-Performance Assessments are tools that can easily be used to justify polluting practices and facilities, not just radioactive. They are not practically transparent or reviewable by the public. We support HEAL Utah’s comments on 10 CFR 61 against Performance Assessments.
Performance Assessments are only predictions and especially not trustworthy when carried out by those who stand to profit from the conclusions.
Both the current and proposed 10 CFR 61 allow for unlined soil trench burial of radioactive wastes that will inevitably leak out. Both fail to protect the public.“…
The original, uploaded by Diane D'Arrigo of the NIRS:
ID: NRC-2011-0012-0158 Tracking Number: 1jz-8k63-8p5e
Document Information Date Posted: Aug 26, 2015 RIN: 3150-AI92
Original includes organization names, followed by e-mails about contaminated DU: http://www.regulations.gov/contentStreamer?documentId=NRC-2011-0012-0158&attachmentNumber=1&disposition=attachment&contentType=pdf
Supplementary materials: http://www.regulations.gov/contentStreamer?documentId=NRC-2011-0012-0158&attachmentNumber=2&disposition=attachment&contentType=pdf
[Note that the BEIR report agrees with the figures given by Diane D’Arrigo. And, according to the BEIR report, almost half, of these 1 in 25 who get cancer (morbidity), will die of cancer (mortality). These fatal cancers will shorten life by 14 to 15 years, on average, i.e. before or close to retirement (life-shortening effects). According to some German and British experts, the rate of cancers (morbidity) and deaths (mortality) is estimated as double this amount. According to BEIR, a lifetime of 1 mSv per year leads to an estimated 1019 cancers per 100,000 females, and 621 cancers per 100,000 males. Weighted for the US sex ratio of 0.97, this is .8 per 100, that is 8 per 1000, or almost 1. For 5 mSv multiply by 5 and you get 4 cancers per 100 or 25 (https://en.wikipedia.org/wiki/List_of_countries_by_sex_ratio).A good ballpark figure is 1 cancer per 100 people for each 100 mSv of exposure. Once again, weighting for US sex ratio of .97, per 100 mSv, the BEIR report gives a 1.142% chance of cancer or leukemia for the general population. In utero exposure excess cancers may be detected as low as 10 mSv. See “Beir VII: Health Risks from Exposure to Low Levels of Ionizing Radiation“, (2006)