ML20151Y054
| ML20151Y054 | |
| Person / Time | |
|---|---|
| Issue date: | 06/09/1988 |
| From: | Nussbaumer D NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| To: | AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20151Y016 | List: |
| References | |
| FOIA-88-361 NUDOCS 8808260208 | |
| Download: ML20151Y054 (8) | |
Text
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JOH09iWB Ref: SA/Khs ALL AGREEMENT AND NON-AGREEMENT STATES STATE LIAISON OFFICERS COMPACT DISTRIBUTION NRC COMMENTS ON REPORT ENTITLED "LIVING WITHOUT LANDFILLS" Enclosed for your information is a sunnary of MRC staff connents on Dr. M.
Resnifoff's report entitled, 'Living Without Landfills". The conclusion of the NRC staff review is as follows "The report is intended by the Radioactive Waste Campaign 'to provide the public with rigorously accurate, scientifically impeccable infomation.'
In this goal the NRC staff believes the report falls far short.
Instead, the staff believes that the report's recorrnendations are based on inaccurate and incomplete information and analysis."
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Donald A. Nussbaumer, Assistant Director for State Agreements Program State, Local and Indian Tribe Programs
Enclosure:
As stated 9
8808260208 880808 PDR FOIA RESNIKOBB-361 PDR
1 LIVING WITH0 LIT LANDFILLS j
StMMARY OF NRC STAFF COMMENTS A.
INTRODUCTION In October 1987, Nuclear Regulatory Cosmission (NRC) staff received the final version of a report by Dr. Marvin Resnikoff entitled, "Living In this report Dr. Resnikoff ukes reconsnendations Without Landfills."
on the unageinent of low-level radioactive wastes.
Early in the developinent of this report NRC staff was asked to At that participate in the project and review an outline of the re NRC staff was later asked to review a draft report.
request we provided in June 1987 broad coseents following review.
Although the final report addresses our June report an objective one.1987 corsnents, the authors response has been to re We have reviewed each of their without seking the recoernended changes.
responses to our previous corsnents and believe that the final report continues to contain a large number of inaccurate and incomplete statements which lead to inappropriate conclusions and recossnendations.
B.
MAJOR COMMENTS ON REPORT The NRC staff performed a review of "Living Without Landfills" focusing No attempt was made to cossent on all inac-only on the m jor issues.
As a result of the review the NRC staff curate or incomplete statements.
technical identified significant concerns in the following areas:
information on low-level waste sources; historical experience at cossner-cial low-level waste disposal facilities; analysis of 10 CFR Part 61; discussion of disposal alternatives; and conclusions andBelow we recossendations.
areas of the report.
1.
Low-Level Waste Sources The report states that virtually all of the low-level waste activity It states that 99 percent of is generated by nuclear power plants.
all low level waste activity, projected to the year 2020, is this source.
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2 recorpendation that wastes should be stored at nuclear power plants rather than disposed of in low-level disposal facilities.
We believe the 99 percent value is misleading in a discussion on cossnercial low-level waste management principally because it includes Greater-Than-Class C (GTCC) wastes which are considered in the Part 61 regulation to be generally unsuitable for near-surface disposal.
The discussion does not reflect the actual radionuclide activities in wastes currently being disposed, the fact that GTCC wastes are not being shipped for disposal to cornercial low-level waste disposal facilities, or the NRC staff reconnendations on the disposition of GTCC wastes.
The report furthermore blurs the significant distinctions between Class C and GTCC wastes, including radioactivity content and disposal methods.
GTCC wastes are currently being stored at waste generator facilities; the operating low-level disposal sites are not accepting GTCC wastes for disposal. Under the Low-Level Radioactive Waste Policy Amendments Act of 1985 (LLWPAA) GTCC wastes are the responsibility of the Federal government.
It will be, therefore, unlikely that these wastes would be accepted by States for disposal at future cornercial disposal facilities even if a technical rationale is provided.
NRC staff has reconr. ended that GTCC wastes be disposed in thg high-level waste repository beca,use of its small volume (2000m projected through the year 2020) and because criteria already exist for waste disposa! in a geologic repository.
Another problem is that the report's 99 percent value is based on some highly conservative, yet contradictory, assumptions. The 99 percent value is based on the inclusion of wastes from decossissioning nuclear power reactors several years in the future, coupled with the assumption that all nuclear power reactors are dismantled as soon as they are shut down.
Elsewhere, the report voices the expectation that shutdown nuclear power plants will sit for up to thirty years prior to dismantlement. This is significant since the great majority of the radionuclides in power reactor decosmissioning wastes will have half-lives of about 5 years or less. A few years of delay between shutdown and dismantlement will therefore have a significant effect on radioactivity in decosmissioning wastes. (It can also be noted that greater than 95 percent of the radioactivity in wastes from decossissioning nuclear power reactors will be in wastesthatexceedClassCconcentrations.)
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3 As another point, the report indicates that greater than 99 percent of the long-lived activity in LLW is contributed by nuclear power reactors. No basis for this statement is presented.
In any case we believe that the statement is questionable.
LLW generated by nuclear power plants is, in fact, dominated by very short-lived radioisotopes.
To evaluate the significance and impacts of the source ters, the report presents a concept called "Hazardous Life," which the report defines as the time required for the radionuclides within waste to decay to a factor of 100 times the release limits in 10 CFR Part 20, Appendix B, Table 11. The terni is recessnended in place of the 10 CFR Part 61 waste classification system as the basis for determining the time a waste rest be controlled.
We believe that use of the Part 20 limits in this manner is The Part 20 limits are radionuclide specific questionable.
concentration limits for release to an unrestricted area from a licensed facility. They serve to limit the dose to an individual, who is assumed to be continuously (over a 50 year period) ingesting or inhaling radionuclides at the listed concentration.
If the Part 20 limits were to be applied to waste disposal, they would properly be applied to environmental releases from the disposal facility.
It is therefore constructive to compare these limits with those in 10 CFR Pcrt 61.
Pursuant to Part 61, a disposal facility must be sited, designed, operated, and closed, and waste must be classified and disposed, so that the Part 61 performance objectives are met. These performance objectivas limit possible releases to the environment so that a member of the public will not exceed a prescribed dose limit, and also serve to limit the dose to a potential inadvertent intruder.
The Part 61 performance objectives and waste classification system are based on a detailed set of disposal f acility pathway analyses which include considerations for radionuclide toxicity, half-lives, and reference site uptake factors, projected waste propertiesTogether,theylimitdosesdueto environmental conditions.
potential environmental releases to levels roughly 20 times less than those used to set the current Part 20 concentration limits.
Potential doses to an inadvertent intruder are limited to levels I
comparable to those used to set the Part 20 concentration limits.
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Historical Experience at Disposal Sites 2.
The report discusses the site characteristics of the six low-level waste disposal facilities in the United States and the problems In the report many which resulted in the closure of three of them.
i references are made to past disposal practices, activity measurements made on trench sump liquids, and activity detected
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off-site.
The report draws the conclusion that current disposal practices represent a failed technology. Conclusions are drawn, however, That is, the without full consideration of other information.
low-level waste management regulation, 10 CFR Part 61, was developed to preclude the poor practices of the past and costly remedial In addition, the three open consnercial disposal activities.
facilities, whose operatinns are consistent with the 10 CFR Part 61 requirements, have not observed the problems associated with the closed facilities. The report also suggests that activities The measured in trench sump liquids represent off-site releases.
report also fails to clearly put into perspective the fact that off-site releases from the closed facilities, despite the poor practices, have been below the release limits in 10 CFR Pert 20 and have, therefore, not threatened public health and safety.
3.
10 CFR Part 61 The report coepares the requirements of the 10 CFR Part 61 proposed In this discussion the rule with that published as a final rule.
report concludes that the final rule is substantially weaker than that proposed. As an example, the report states that 150 year waste form stability requirement in the preposed rule was dropped in The report is correct in stating that the the final rule.
requirement was dropped, however, it was replaced with a stability objective of 300 years (10 CFR 161.7).
f Detailed guidance for demonstrating a stable waste form, including ismersion and leaching tests, were published in a Technical position which has been aoopted as a requirement by all oper by a factor of 10 by stating that no calculations were performed to sites.
l The changes made to the waste classification justify this change. system in the proposed rule were made to reflect The changes are based on a more realistic waste source term.
detailed calculations of the impacts for the disposal of typical low-level wastes (which include the long-lived nuclides) and are discussedintheFinalEnvironmentalImpactStatement(FEIS) l l
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5 supporting the rulemaking (NUREG-0945). These calculations showed that, even if no credit were taken for disposal at greater depths, or incorporation of sore other intrusion barrier as required in the Part 61 rule for Class C waste, there would be insignificant dose impacts in increasing the Class C limits, this is because the incrementally added waste activities and volumes are small relative to the other wastes. The rationale for all other changes are also discussed in the FEIS.
4.
Waste Management Alternatives The report discusses alternatives for volume reduction, segregation of wastes by half-life and engineered disposal concepts, and concludes that wastes should be compacted and segregated by half-life with wastes stored in above ground facilities designed for the waste's hazardous life. As an integral part of developing major recomrrendations, the report suggests segregation of waste by half-life into three groups (hazardous life of 100 years, 300 years, and greater than 10,000 years). Wastes having a hazardous life of 100 years would be "stored in engineered above ground structures until it decays to non-hazardous levels '
(Presumably, this would includealmostalllow-levelwaste.) Wastes having a hazardous life of 300 years would be stored retrievably in "more substantial, shielded structures, with leachate collection systems."
(Thereport states that this consists of utility waste, comprising less than 5%
ofthetotallow-levelwastevolume.) All wastes with a hazardous life greater than 10,000 years (which the report states would include Class C and GTCC wastes and would comprise only a few percent of the waste volume) would be disposed in a high-level waste repository. The report is silent on disposal of waste having a "hazardous life" between 300 and 10,000 years.
The report provides an incomplete rationale justifying the proposed hazardous life classification system.
Some of the factors that could be considered in such a rationale include, relative to Part 61, short and long-ters environmental impacts, occupational exposures, and costs. No methods are suggested by the report or known by the staff for practically segregating wastes containing many different radionuclides having different half-lives.
In order l
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6 to separate mixtures of radionuclide we would expect complex isotope separation processes to be needed. While isotope separation is used for small numbers of isotopes (e.g., Cs-137 and Sr-90 at Hanford,) processes have yet to be developed for complete separation of a wide range of nuclides such as those present in wastes produced by many waste generators.
Above-ground storage is recomended by the report because releases can be easily detected and corrected. The report, however, does not address the issue of increasing institutional comitments or ensuring that institutional control will remain effective for periods exceeding 100 years to ensure that remedial care activities In the development of 10 CFR Part 61 the NRC staff will take place.
conservatively assumed that remedial activities and institutional Staff then control could not be assumed for greater than 100 years.
set consentration limits on long-lived nuclides such that an inadvertent intruder would receive less than 500 mrem /yr from The increase in the accessibility exposure to the remaining activity.
NRC of above-ground structures to intrudors is also treated lightly.
staff has reconnended below-ground alternative concepts for disposal in part bscluse these structures would be protected from fr< eze/ thaw cycling and acid rain and because a soil cover acts as an additional intruder barrier.
5.
Conclusions and Reconnendations The report recossnends that siting activities for new low-level waste disposal capacity should be halted.
Instead nuclear power plant (Note: the NRC sites should be used for permanent waste storage.
staff considers permanent waste storage to be synonymous with waste The report states that because 99 percent of the disposal.)
low-level waste activity is from nuclear power plants all wastes should be stored there.
The report does not address the question of proliferation of disposal sites nor does it recognize that the siting objectives for In fact, a power plant are very different than for a disposal site.
staff believes that few current power plant sites would meet the 10 CFR Part 61 site suitability requirements.
The report also recomends storage of wastes in above-ground structures with eternal vigilance and recoseends a Manhattan Project to develop the technology for these structures.
(Note: the NRC IIstaff considers storage with eternal vigilance to be synonymous While there are nuclides with long half-lives in withdisposal.)
low-level wastes, the pathway analyses performed to suppo'rt the
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waste classification system consider their dose impacts and limit In the allowable concentrations for near-surface disposal.
addition, while above-ground disposal may be feasible, the NRC staff considers that below-ground structures will provide a higher level of confidence that the structures will properly function with service lives of hundreds of years. In addition, below ground structures also improve the disposal facility intruder protection in the event that institutional control is not able to be consistently maintained.
C.
CONCLUSION The report is intended by the Radioactive Waste Campaign "to provide the public with rigorously accurate, scientifically impeccable information."
- Instead, In this goal the NRC staff believe the report falls far short.
the staff believe that the report's recommendations are based on inaccurate and incomplete information and analysis.
This repo*t fails to provide the public with a source of accurate and objective information which it needs and deserves in making responsible decisions regarding low-le'41 radioactive waste management issues.
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