ML19305A149
| ML19305A149 | |
| Person / Time | |
|---|---|
| Issue date: | 12/29/1978 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Goller K NRC OFFICE OF STANDARDS DEVELOPMENT |
| References | |
| NUDOCS 7901040194 | |
| Download: ML19305A149 (4) | |
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4r UNITED STATES
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J MEMORANDUM F0PI:
Karl R. Goller, Director, Division of Siting, Health and Safeguards Standards, OSD FROM:
Harold R. Denton, Director Of fice of Nuclear Reactor Regulation
SUBJECT:
EPA ENVIRONMENTAL PROTECTION CRITERIA FOR RADI0 ACTIVE UASTES In response to the request of your memorandum, dated November 20, 1978, same subject as above, we have reviewed the EPA proposed criteria and are submitting the attached comments.
~ Li by i:.
,_ :1,
Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosure:
NRR Comments cc:
E. Case V. Stello R. Mattson R. Boyd R. DeYoung D. Bunch M. Groff lNRR-2657)
R. Vollmer (NRR-2657)
G. Arl otto H. Shapar K. Peterson S. Levine J. Davis W. Dircks J. Collins R. Bangart F. Cardile W. Travers L. Bell 7901040(9 d
lh NRR COMMENTS ON EPA ENVIRONMENTAL PROTECTION CRITERIA FOR RADI0 ACTIVE WASTES 1.
The proposed criteria suffer froa a lack of specificity that will limit their usefulness as guidance to Federal agencies. Without such speci-ficity, it will be difficult for individual Federal agencies to develop policies and standards that are c'nsistent with one another.
Exampl es of terns which require definition or clarification in order to allow a clear understanding of the criteria are as follows:
a.
The terms " hazardous lifetime", "as are necessary", and
" complete isolation" in Proposed Criterion No. 2.
b.
The terms " hazard persistence" and " hazard" in Proposed Criterion No. 3.
2.
The methodology for Criterion No. I which categorizes waste according to its source of production, without reoard to the amount or concentration of radioactivity present, should be reeiamined. ' In practical terms, some mininum level of radioactive content below which any material should not be considered a radioactive waste will have to be defined.
If not, then any iten chat is ever in a location where it may become potentially con-taminated would have to be considered radioactive waste; it could never be shown that there is no radioactivity present; all that could be deter-mined is that the radioactive contamination is below the lower limit of detection (LLD) of the measurement.
Individual Federal agencies would have to develop "de minimus" levels in order to prevent materials with no measureable radioactivity or denonstrated hazard from the necessity of being treated as radioactive waste.
Again, if the EPA criteria do not define a "de minimus" level or an apprcach to use to determine "de mini-mus" levels, then individual Federal agencies will be forced to make this definition and inconsistent criteria may develop. We do not believe that the polic, i requiring exposures to be reduced as much as practicable (undefined in the Issue No.1 Discussion) nec< ssarily precludes the establishment of a "de minimus" level.
3.
Proposed Criterion No.1 is included both on page. 53263 and 53264 of the Federal Register, but the wording differs in one important respect.
On page 53263 Se wording begins " Radioactive iaterials should be con-sidered radioactive wastes requiring control for..."
On page 53264 the wording begins " Radioactive materials should be considered radioactive wastes requiring consideration for..."
This distinction is important and should be resolved.
l
' ' 4.
Proposed Criterion Ho. 2 states that institutional functions should not be relied upon for longer than 100 years to provide complete isolation.
Interim waste storage options now being evaluated could conceivably call for retrievable interim storage of waste for periods of time on the order of 100 years before pe Tnanent disposal. Deconmissionir.g options for nuclear power plants could also cal 1 for mothbal1ing for similar periods of time to reduce occupational exposures during dismantling prior to disposal. These two examples would require a combination of engineering and institutional controls for priods of time which may exceed 100 years in order to obtain the benefits of significant decay of activation and fission products.
It is recommended that an arbitrary limit on the time period for reliance on institutional controls be de-leted, or it is alternatively recommended that a longer limiting time period, such as 200-500 years, would be appropriate for combined insti-tutional/ engineered controls.
5.
Proposed Criterion No. 3 states that the risk assessment should exanine "The potential adverse health effects on individuals and populations for a reasonable range of future population sizes and distributions, and of uses of land, air, water, and mineral resources for 1000 years..."
The uncertainties associated with the assessment of health effects 1000 years into the future would be so large as to make this assessment meaningless.
It is impossible to accurately predict population distribution and land, air, water, and mineral resource use for the year 2980!
It is recom-mended that this factor be deleted from the risk assessment.
6.
Proposed Criterion No. 4 states that risks due to waste management are unacceptable unless it has been justified that further risk reduction achieved by more complete isolation is impracticable on the basis of technical and social considerations.
It is recommended that cost be explicitly stated as a basis for impracticality also.
7.
As explained in the discussion of Issue No. 4, the waste disposal criteria are separated from the production portions of the fuel cycle.
The pro-ductivity associated with any technology, however, may greatly influence the amount of risk society is willing to accept in the disposal of waste from that technology.
Certainly society appears to accept greater risk j
from efficient technology that brings benefits to all than from tech-nology which benefits only a small portion of society.
It is recommended that the productive portion of the fuel cycle be included as an addi-tional factor in detenr,ining the acceptability or unacceptability of radioactive waste management risk in Proposed Criterion No. 4.
b o4 8.
Paragraph c. of Proposed Criterion No. 4 should be reworded to expli-citly state that the probabilities of highly adverse consequences from wastes which pose long-term hazards should be no nore than a small fraction of the probabilities of high consequence events asso-ciated with shorter term productive technologies which are acceptea by society, i
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