ML20205F150

Forwards Rept of Div Review of Document Entitled, Living W/O Landfills by M Resnikoff

ML20205F150
Person / Time
Issue date:	04/26/1988
From:	Knapp M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Thompson H NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20205F142	List: IA-88-361, Advises That Resnifoff Rept Sent to States of Sc,Wa,Nv.Ky,Il & Ny.Rept Contains Many Factual Errors & Incomplete & Misleading Info from Refs Quoted.Suggests That Recipient Consider Publishing NRC Rebuttal to Subj Rept as NUREG ML20205F139 ML20205F150 ML20207N151 ML20207N153 ML20207N156 ML20207N159 ML20207N161 ML20207N164 ML20207N167 ML20207N168 ML20207N170 ML20207N173
References
FOIA-88-361 NUDOCS 8810270552
Download: ML20205F150 (67)

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.APR 2 61938 HEMORA!!DUM FOR: Hugh L. Thcmpson, Jr. , Director Office of Nuclear H'.terial Safety and Safeguards

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FRCit: Malcolm R. Knapp, Director Division of Low-level Waste Managetnent and Decomissioning y 7 F e. 5 ,

SUBJECT:

RESilIX0FF REPORT REVIEW

SUMMARY

j d 1) k Attached is a repdrt of our review of the docurnent entitled, "Living Without Landfills," by Dr. Marvin Resnikoff. The report contains an executive sumary as well as our deteiled coments. .

If you have any questions, please contact me (23339) or Tim Johnson (20558).

(Original Signed by / 1 -

p Halcolm R. Knapp, Director

- Division of Low. Level Waste Panagement and Decomissioning

Enclosure:

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APR 2 61988 ,

MEMORANDUM FOR: Hugh L. Thompson, Jr. , Director Office of Nuclear Material Safety and Safeguards ,,

FROM: Malcolm R. Xnapp, Director Division of Low-Level Waste Management and Decossissioning

SUBJECT:

RESNIX0FF REPORT REVIEW SUtWARY Attached is a report of our review of the docu n nt entitled, "Living Without l Landfills," by Dr. Marvin Resnikoff. The report contains an executive susmary as well as our detailed cossents.

If you have any questions, please contact me (23339,I or Tim Johnson (20558).

Halcolm R. Xn irector Division of Low-Level Waste Manag', ment and Decommissioning

Enclosure:

As stated

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LIVING WITHOUT LANDFILLS

SUMMARY

OF NRC STAFF COMMENTS A. INTRODUCTION In October 1987, Nuclear Regulatory Consnission (NRC) staff received the final version of a report by Dr. Marvin Resnikoff entitled, "Living Without Landfills." In this report Dr. Resnikoff makes recossnendations en the management of low-level radioactive wastes.

Early in the development of this report NRC staff was asked to participate in the project and review an outline of the report. At that time we responded that it would be inappropriate to participate. NRC staff was later asked to review a draft report. In response to this request we providd in June 1987 broad coasnents following a limited review. We concluded that major revisions would be eeded to make the report an objective one. Although the final report addresses our June 1987 coments, the authors response has been to reaffirm his original position without making the recomended changes. We have reviewed each of their responses to our previous coments and believe that the final report continues to contain a large nunter of inaccurate and incomplete statements which lead to inappropriate conclusions and recomendations.

B. MAJOR COMMENTS ON rep 0RT The NRC staff performed a review of "Living Without Landfills" focusing only on the major issues. No atterpt was made to coment on all inac- i curate or inexplete state.ments, As a result of the review the NRC staff I identified significant concerns in the following areas: technical '

information on low-level waste sources; historical experience at comer- 1

, cial low-level waste disposal facilities; analysis of 10 CFR Part 61; discussion of disposal alternatives; and conclusions and recomendations. Below we discuss our major coments in each of these areas of the report, l 1. Low-level Waste Sources The report states that virtually all of the low-level waste activity is generated by nuclear power plants. It states that 99 percent of all low-level waste activity, projected to the year 2079, 9 from

?.his source. This value is used to provide a basis for .L i report's 2

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of the report is left with the impression that all of this waste activity will be disposed in connercial LLW disposal sites. The report also states that greater than 99 percent of the long-lived activity in LLW is contributed by nuclear power reactors.

These statements are used to provide a basis for the report's recossendation that wastes should be stored at nuclear power plants rather than disposed in low-level disposal facilities.

We believe that this reconsnendation is not tupported by the report, since  ;

the statements on the LLW source term do not reflect the actual characteristics of LLW currently being disposed in connercial LLW disposal facilities. Nor do we believe that the report reflects the actual characteristics of LLW expected to be disposed in the future in cossnercial LLW disposal facilities.

LLW disposed in comerchl LLW disposal facilities is disposed according to the classification system in 10 CFR Part 61. This regulation sets l forth three classes of waste (Classes A, B, and C) suitable for near i surface disposal. LLW exceeding Class C concentrations called greater-than-Class.C(GTCC) waste,isconsideredgenerallyunsuitablefor .

near-surface disposal. l Over the last three years, the activity in LLW disposed in comercial LLW i facilities has varied, but has avsraged 414,000 curies per year (749,000 curies in 1985, 234,000 curies in 1986, and 260,000 curies in 1987).

Roughly 75 percent of the activity in waste disposed in LLW sites  :

is generated by nuclear power reactors. The activity in nuclear power reactor waste is dominated by short-lived radionuclides such as cobalt-60 ,

(5.26-year half life). Long-lived radionuclides, such as some transuranic radionuclides or iodine-129, are present in in reactor LLW in only trace quantities, well within the concentration limits for these radionuclides as set forth in the Part 61 regulation. .

Estimates of future waste generation are prone to uncertainties. If the i annual disposed LLW activity is assumed to range between roughly 400,000 I l

. curies and 500,000 curies, then the total disposed LLW activity betm en '

l 1980 and 20 0 will range between 16 million curies and 20 million curies.

Additional wastes, however, may be generated to the year 2020 from decomissioning nuclear power reactors. The timing of reactor decomissioning and dismantlement is difficult to project. Nonetheless,

)j studies performed by NRC (e.g., NUREG/CR-0130, NUREG/Lt-0672) indicate

,' that like current wastes from nuclear reactors, the activity in reactor decomissioning wastes is dominated also by short-lived radionuclides.

These studies indicate that although the LLW activity associated with dismantlingalarge(1200MWe)plantishighwhentheplantisfirstshut down (i.e., between 5 million and 6 million curies), a few years of delay I between shutdown and dismantlement will have a significant effect on this 1

waste activity. NRC staff estimates that thirty years of delay will a

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3 reduce the activity in decomunissioning waste by a factor greater than ten, Much more significantly, the NRC studies indicate that greater than 95 percent of the activity in wastes from dec.munissioning nuclear power i reactors will be found in wastes exceeding Class C concentrations. l Thus, it can be seen that the LLN source term used in the report is i misleading in a discussion of cosmercial LLW disposal. At least two  !

reasons are apparent:  !

First, the report consistently blurs the distinction between GTCC wastes  !

and other wastes, such as Class C wastes, which are considered suitable  ;

for near-surface disposal. Throughout the report, the reader'is left with -l the misleading impression that GTCC westes are now being disposed in LLW 'i sites, and will be so disposed in the future.

In fact -

disposal.nooperatingLLWdisposalsiteisacceptingGTCCwastefor Rather, GTCC wastes are being stored at waste generator facilities. Under the Low-Level Radioactive Waste Policy Amendments Act of 1985 (LLWPAA), disposal of GTCC waste is the responsibility of the ,

Federal government. Thus, we consider it very unlikely that GTCC wastes ,

I will be accepted by States for disposal at future commercial disposal facilities, even if a technical rationale is provided. NRC staff has recosamended that GTCC wastes be disposed in a high-level waste repository .

because of their small volume (2000 m8 projected through the year 2020), l and because criteria already exist for waste disposal in a geologic i repository. ,

6 Second, the report's recommendations for disposal of LLW generated today are principally baseo on conservative, and contradictory, estimates ~of '

waste to be generated in the future from decosuissioning nuclear power reactors. In this regard, we note that more than once, the report voices the expectation that shutdown nuclear reactors will sit for up to 30 years before dismantlement. This contradicts the report's assumption, for purposes of generating LLW activity projections, that all nuclear power reactors are dismantled as soon as they are shut down.

Our studies indicate that, iike reactor wastes being generated today, wastes from decosuissioning nuclear power reactors will be dominated by short-lived radionuclides such as cocalt-60. This means that a few years' delay between reactor shutdown and dismantlement will have a major effect on waste activity. Our studies alf.o indicate that fireatsr than 95 percent of the activity in reactor decommissioning wastes wt11 be contained in wastes exceeding Class C# concentrations. NRC has recossended that such wastes be disposed in a geologic repository. Thus, NRC staff believe that the impact of waste from nuclear reactor decommissioning on LLW dispr. sal facility inventories is much less than that indicated in the report.

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2.2 Hazardous Life To evaluate the significance and impacts of the source term, the report prosents a concept called "hazardous life," *vhich the report defines as the time required for the radionuclides within waste to decay to a multiple of the release limits in 10 CFR Part 20, Appendix B, Table II.

(The report sometimes recossends a value of unity for this multiple, at othertimesavalueof100.) The "hazardous life" concept is recommended in place of the 10 CFR Part 61 waste classification system as the basis for determining the time a waste must be controlled.

We believe that the report provides an incomplete rationale justifying the proposed hazardous life classification system. Some of the factors that the .taff would look for in such a rationale include short and long-term environmental impacts, occupational exposures, and costs.

We also believe that the report applies the Part 20 limits in an inappropriate manner. The Part 20 limits are radionuclide-specific concentration limits for relecse to an unrestricted area from a licensed facility. They serve to limit the dose to an individual, who is assumed to be continucusly ingesting or inhaling the listed radionuclide concentratio6 over a 50-year period. If the Part 20 limits *were to be applied to waite disposal, they wwld properly be applied to limiting environmental r21 eases from the disposal facility. It is therefore constructive to compare the Part 20 limits with the Part 61 disposal facility performance objectives. -

Pursuant to Part 61, a disposal facility must be sited, designed, operated, and closed, end waste must be classified and disposed, so that the Part 61 performance objectives are met. These performance objectives limit pos.sibic 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 objectiver and waste classification system are based on a detailed set of disposal facility pathway analyses which include considerations for radionuclide toxicity, half-lives, uptake factors, projected waste properties, and reference site environmental conditions. Together, they limit doses from potential environmental releases to levels roughly 20 times less than those used to set the current Part 20 concentration limits. (This is 3

based on a comparison of the Part 20 concentration limits which would produce an annual 500 mrem whole bocy dose, to the Part 61 performance objective for environmental release which limits projected annual doses to 25 mrem whole body, 75 mrem to the thyroid, and 25 mrem to any other i organ. In addition, pro reasonably achievable.) Potential jected doses wholemust bodybe reduced doses to antoinadvertent levels as icw as intruder are limited to levels comparable to those used to sat the Part 20 conc' aration limits -- that is, 500 mrem /yr.

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2.3 Historical Experience at Disposal Sites  ;

The report! discusses the site characteristics of the six cosmarcial '

i low-level waste disposal facilities in the United States and the problems which resulted in tte discontinuance of disposal operations of three of  ;

them. The report makes many references to past disposal practices.

activity measumments made on trench sump liquids, and activity detected off-site. The report draws the conclusion that, because problems have  :

been observed in the past, current disposal practices represent a failed technology.

We disagree with these conclusions. We believe trat these conclusions are drawn without full consideration of other information. That is, the low-level waste management regulation, 10 CFR Part 61, was developed to preclude the poor practices of the past which resulted in costly remedial activities. In addition, the three open cosearcial disposal facilities, whose operations are consistent with the 10 CFil Part 61 iequirements, have not observed the probleces associated with the closed facilities. The j report also suggests that activities measured in trench sump liquids .;

represent off-site releases. The report fails to clearly put into )

persNetive the fact that off-site releases fron the closed facilities, despite the poor practices, have been below the release limits'in 10 CFR Part 20 and have, tnerefore, not threatened publ c health and safety. .

2.4 10 CFR Part 61 The re) ort compares the requirements of the 10 CFR Part 61 proposed rule l with tiat published as a final rule. In this dis:ussion the report  !

concludes that the final rule is subst ntially weaker than the proposed I rule. l As an example, the report states that 150-year waste form stability i requirement in the proposed rule was dropped in the final rule. The  !

report is correct in stating that the requirement has dropped; however, it j was replaced with a stability objective of 300 years (10 CFR 161.7).

Detailed guidance for demonstrating a stable waste form, including ismersion and leaching tests, was published in a Technical Positiun.

The report also criticizes the factor-of-10 increase in the Clas: C. limits between the proposed and final rule by stating that ro calculations were performed to justify the changes. In fact, the changes made to the waste classification system in the final rule were made to reflect public comments, as well as a more realistic estimate of impacts from LLW disposal. The changes are based on detailed calculations of the impacts for the disposal of typical low-level wastes (which include long-lived radionuclides) as discussed in the Final Environmental Impact Statement (FEIS) supporting the rulemaking (NUREG-0945). These calculations show that, even if no credit was taken for disposal at greatar depths, or for incorporation of some other intrusion barrier as required in the Part 61

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rule for Class C waste, increasing the Class C limits would result in insignificant additional dose impacts. This is because the incremental waste activities and volumes are small relative to the other wastes. The .

rationale for all other changes is also provided in the FEIS. l 2.5 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 recomendations, the report suggests segregatioit of waste h half-life into three groups (hazardous lives of l 100 years, 300 years, ed greater than 10,000 years). Waste having a hazardous life of structures until 100 years it decays would be "... stored to non-hazardous in eng(ineered levels." The authorabove ground contends j thatthiswoaldincludealmostalllow-levelwaste.) Wastes having a i hazardous life of 300 years would be stored retrievably in d...more l substantial, shielded structures, with leachate collection systems." (The i report states that this consists of utility waste, comprising less than $%

of the total low-level waste volure.) All wastes with a hazardous life greater than 10,000 years (which the report states would include Class C l and GTCC wastes and would cceprise only a few percent of the waste volume) would be disposed in a high-level waste repository.

As discussed in Section 2.2 of this document, we believe that the report provides an incomplete justification for the proposed hazardous life ,

classification system. Furthermore, we note that no methods are suggested by the report or known by the staff for practically segregating wastes I containing many different radionuclides having different half-lives. To l separate mixtures of m ionuclides, we expect that complex isotope j separation processes u ld be needed. While isotope separation is used for smil nuders of isotopes (e.g., cesium-137 and strontium-90 at Hanford), processes have yet to be developed for complete separition of ,

the wide range of nuclides present in wastes produced by many waste i generators.

Above-ground storage is recossended by the report because releases can be essily detected and corrected. The report, however, does not address the issue of increasing institutional comitments or ensuring that institutional control will remain fully effcetive for periods exceeding 100 years to ensure that remedial care activities will take place. In the development of 10 CFR Part 61 the NRC staff conservatively assumed that remedial activities and institutional control could not be assumed to be fully effective for greater than 100 years. Staff then set concentration limits on long-lived nuclides such that an inadvertent intruder would receive a dose less than 500 mrem /yr from exposure to the remaining activity. The increase in the accessibility of above-ground structures to intruders is also treated lightly. NRC staff has recomended below-ground

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I alternative concepts for disposal in part because these structures would be protected from freeze / thaw cycling ar.d acid rain and because a soil  ;

{ cover acts as an additional intruder barrier.

2.6 Conclusions and Recossendations l

. . The report recossends that siting activities for new low-level waste  :

disposal capacity should be halted. Instead nuclear power piant sites  :

should be used for permanent waste storage. (Note: the NRC staff .

considers permanent waste storage to be synonymous with waste disposal.) ,

The report states that be:ause 99 percent of the low-level waste activity l

is from nuclear power plants, all wastes should be stored there. j l The report does not address the question of proliferation of disposal  !

sites nor does it recognize that the siting objectives for a power plant  !

i are very different than for a disposal site. In fact, staff believes that i

few current power plant sites would meet the 10 CFR Part 61 site i suitability requirements. .

The report also recommends storage of wastas in abova-ground structures  !

! with eternal vigilance, and recosunends a Manhattan project II to develop  :

i the. technology for these structures. (tiote: the NRC staff considers i j storage with eternal vigilance to be syr.onymous with disposal.) While  !

i there are radionuclides with long half-lives in low-level wastes, the  :

} pathway analyses performed to support the waste classification system  !

j consider their dose impacts and limit the allowable concentrations for  ;

near-surface disposal. In addition, while above-ground disposal may be  ;

i feasible, the NRC staff considers that below-ground structures will l provida Mgher level of :enfidence that the structures will properly l

. function with service lives of hundreds of years. In addition, i below-ground structures improve the disposal facility intruder protection 1 in the event that institutional control is not able to be consistently j

maintsined, i

3. CONCLUSION i

The report is intended by the Radioactive Weste Campaign "to provide the

) public with rigorously accurate, scientifically impeccable information."

In this goal the NRC staff believe the report falls far short. Instesd, the staff believe that the report's recommendations are based on j inaccurate and incomplete information and analysis.

1 1 This report fails to provide the public with a source of accurate and I objective information which it needs and deserves in making responsible

] decisions regarding low-level radioactive waste management issues.

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.,4 i COMMENTS ON LIVING WITHOUT LAN0 FILLS (Dec. 1987)

NOTE: These comments here assembled based on a limited review by NRC staff of a preliminary copy of the final report. In this review, only the major and e:ost obvious concerns were addressed. Lack of a specific NRC cossent on a particular report subject or statement should not be interpreted as NRC agreement.

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1. Introduction, Column 1, Startin'g 4th Full Paragraph, p.4 The report states that the nuclear industry has presented a self-serving mythology by providing information on the benefici.a1 uses of radioactive materials.

i The irportance to our society of activities which involve radioactive materiels is an issue which can not be disputed. There are substantial benefits which result from the use of radioactive materials for biomedical research, medical use, industrial applications, academics and power L generation. These uses result directly or indirectly in the generation of ,

radioactive wastes and, therefore, the need for disposal capacity. To

'. characterize the benefits of the uses of radioactive materials as "mytholugy" or half-truths is inappropriate.

i For example, consider New England Nuclear and Cintichem, two licensees not normally associated with the nuclear industry. These two licensees

, produce most of the radioisotopes used in biomedical research and medical ,

! applications. Togethe:, these two companies are responsible for 12 percent of the activity disposed of in 1985 and 5 percent in 1906 (Ref.

1). The absence of disposal capacity would adversely affect both of these important licensees and, subsequently, biomedical research and iaadical practices.

2. Introduction, Column 2,1st Full Paragraph, p.4 1 The report states that greater than 99 percent of the activity in low-level waste (LLW) is generated at nuclear This reported 99 percent value is misleading because it (a) confuses power plants. viste generated today with waste projected to be generated far into the future, (b) fails to consider a realistic projection of reactor decevaissioning, and (c) includes wastes which exceed the Part 61 Class C concentration limits.

Nuclear power plants currently ship about 70-80 percent of the activity to low-level waste sites. A review of shipment records indicates that in

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1985, nuclear power plants shipped about 78 percent of the activity an.t! 61

, percent of the waste volume to the coseercial low-level waste disposal

sites. In 1986 nuclear power plants shipped about 73 percent of the activity and 57 percent of the waste volume (Ref. 1). Most of this activity is short lived.

In the future, additional waste will be generated from decommissioning nuclear power reactors. However, we do not expect that waste from this source will is sites. This contribute because:99 p{ercent of the activity a) most reactors sent to low-level will probabl not be waste dismantledwithintheperiodconsideredinthereport;(y)most b radioactivity in decosmissioning wastes is short lived, so that any delay ,

between reactor shutdown and dismantlement will result in considerable decay cf the radioactivity; and (c) greater than 95 percent of the activity within reactor decosmissioning wastes is projected to be contained within wastes exceeding Class C concentrations. Such wastes are considered to be generally unsuitable for disposal in a near-surface disposal facility. (SeeConsents10,35,and38.)

Regarding wastes exceeding Class C concentrations, the Low-level Radioactive Waste Policy Amendments Act (Ref. 2) assigns the disposal responsibility for these wastes to the Federal government. Because of this we believe that it is unlikely they would be accepted by the States The NRC staff has recommended to the at the commercial of Energydisp (osal sites.00E) that these wastes be disposed of in a Department l high-level waste repository (Ref. 3). Including these waste activities L greatly distorts the perspective for evaluating the need for new low-level waste dirnosal capacity. (Also see Consents 18 and 35.)

3. Introduction. Column 1, 2nd Full Paragraph, p.5 The report erroneously states that there is a relationship between the ,

activity within waste generated by Cintichem and that of all nuclear power  :

plants that is a function of the reactor power and is 70,000 to 1. In 1985  ;

and 1986 Cintiches r. hipped 8,000 Ci and 4,100 C1, respectfully. The total  ;

activity shipped from all nuclear power plants in the same years was  ;

580,000 Ci and 170,000 C1 (Ref. 1). The activity ratios for these years /

are 72:1 for 1985 end 41:1 for 1986. Because the production of radioisotopes involves very different operations tian does the production  !

of power there is no simple reactor power relationship between these classes of waste generators.

It should be noted thet the repeet assumes there will be 115 nuclear power plants with each having a power level of 3500 N(t) or approximately 1200 N(e). The total capacity of the 126 nuclear units listed in Reference 3  !

is 116 Gw(e). This is an average of 930 N(e) per unit. The assumption <

used in the report will, therefore, overestimate the totai capacity by about 25 percent.

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tntroduction. Column 2. 1st Para., p. 6 l i

i The report makes a number of questionable statements regarding the i i

characteristics of low-level waste. These questionable statements decrease the value of the report's accompanying policy suggestions. A more realistic description of low-level waste characteristics follows.

1 Nuclear reactorv generate 70-80 percent of the activity within low-level j waste currently d'sposed at cosmarcial LLW disposal sites. (See Cossent j 2.) Furthermore, most of the activity in the waste generated by nuclear 1 reactors is short-lived, having half lives on the order of five years. i 1 i j We expect this situ # tion will continue into the future, at least until the  ;

3 1 year reactors. 2020 andThis even considering is because: w)aste (a most frca decossissioning reacters will probabl nuclear power l i

dismantled within the period considered in the reports (b)most y not be  !

! radioactivity in decosmissioning wastes is short lived, so that any delay

) between reactor shutdown and dismantlement will result in considerable -

! decay of the radioactivity; and (c) greater than 95 percent of the l activity within reactor decossissioning wastes is projected to be l contained within wastes exceeding Class C concentrations.

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! Under the Low-Level Radioactive Waste Policy Amendments Act (LLWPAA) i

! (Ref. 2), disposal of wastes exceeding Class C concentrations is the i

, responsibility of the Federal government. It is unlikely that States will  :

i accept these wastes.for disposal at cosmarcial LLW sites. The NRC staff l i has recosmended to the Departnert of Energy that wastes which exceed the  ;

i Class C limits ha disposed in a high-level waste (HLW) geologic repository l (Ref. 3) i The phrase "even greater percentage of the longest-lived radioactivity is i i generated at nuclear power plants is also inaccurate. Long-lived

. radionuclides are not predominately found in wastes generated by nuclear l

reactors. In fact, long-lived radionuclides are distributed through all l

' of the general categories of waste generators. That is, waste generators such as hespitals, universities, and various industrial operations {

generate wastes containing long-lived radionuclides. The concentrations

, of long-lived and other radionuclides of concern are controlled to safe l 1evels by the 10 CFR Part 61 waste classification system.

i j NRC staff has briefly reviewed the distribution of radioisotopes within i the LLW disposed at the three operating cosmarcial disposal facilities

over the past two years (Ref.1). These data indicate that 260,000 curies

of activity were disposec in 1987. About 6 percent of this activity is

) contained in Class A wastes, about 26 percent in Class B wastes, and about 4 68 percent in Class C wastes. In 1987, about 234,000 curies of LLW l activity was disposed (see Table 1). The activity in the three waste l classes is dominated by short lived radionuclides. After 50 years of j decay, the activity will drop by a factor greater than ten.

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It also appears that eventually, the activity in the waste is dominated by carbcn-14 and uranium and thorium isctopes and daughters. This is interesting since carbon-14 and uranium and thorium isotopes are not normally found in significent levels in wastes from nuclear power plants.

Most of this long-lived activity appears to be contained in Class A wastes.

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5. Chapter 1. Colum 1. 3rd Para.. p. 9 The report states that nuclear reactors produce 99 percent of the radioactivity in LLW. ,

Our review of the report indicates that the statement is based on a number of questionable assumptions regarding the timing and quantity of waste generation. These points are developed further in Cossnents 18 and 38.

Another problem is that the figure is based on the misleading inclusion of

radioactivity within wastes exceeding Class C concentrations. Disposal cf not the States  !

this or waste is Wastes Compacts. the responsibility exceeding of Classthe CFederal government,likely concentrations will be

disposed in a HLW geologic repository. NRC staff has recomended to DOE .

I that COE consider such disposal for this waste (Ref. 4).

6. Chapter 1. Footnote, p. 9 The report stales that HLW is irradiated spent fuel and that transuranic wastes are extremely long-lived.

i As a matter of clarification, in the Nuclear Wasta Policy Act high-level waste is defined as "(A) the highly radioactive material resulting from i i;

the reprocessing of spent nuclear fuel, including liquid waste produced )

dirsetly in reprocessing and any solid material derived from such li

, waste that contains fission products in sufficient concentrations; (quid B)

! other highly radioactive raterial that the Cossnission, consistent with i

existing law, cistermines by rule requires persanent isolation." Thus, high-level waste is not the same thing as irradiated reactor fuel,

although they will be treated in a similar manner for disposal purposes.

1 That is, both will be disposed in a Hui geologic repository.

j l 1 Again as a matter of clarification, while it is true that "transuranic" refers to isotopes having atomic weights exceeding that of uranium, most

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transuranic isotopes are not long lived. The sixth edition of "Table of

, Isotopes " by Lederer, et al. (Ref. 5), lists 112 transuranic isotopes, of

! which only 25 have half lives exceeding one year. In the case of l plutonium, one of the more cosmon transuranic elements, Lederer lists 16 isotopes, of which 7 have half lives exceeding 1 year and 4 have half lives exceeding 100 years.

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7. Chapter 1. Colueen 1 Last Paragraph, p.10 The report presents a correlation of the estimated nuriber of fuel failures at the Callaway nuclear power plant with the total activity in its waste.

The 5800 Ci of activity referenced in the report was obtained from 'the Final Safety Analysis Report (FSAR) the utility submitted as part of their license application. The data provided in the FSAR are values used for design of waste management processing systems. These data are intended to be conservative so that appropriate system components will be properly sized to handle actual radwaste generation. The actual waste generation rates for the Calloway plant in 1985 and 1986, are provided below (Ref.1):

Callaway Waste Generation 1985 1996 3

Volume (ft) 4896 5928

< Activity (C1) 6.4 19.4 .

8. Chapter 1 Fi;ure 1-1, p. 10 l The report state's that components closest to the nuclear reaction will develop the greatest amounc of long-lived radicactive waste.

Components closest to the nuclear reaction will experience high levels of induced radioactivity due to neutron activation. The vast majority of this induced radioactivity will be short lived -- i.e., on the order of 5 -

years or less. However, there will be concentrations of radionuclides of ,

l concern having longer lives. Wastes such as core shrouds are projected to I contain these radionuclides in concentrations exceeding Class C limits.  :

Disposal of LLW exceeding Class C concentrations is the responsibility of

the Federal government.

9. Chapter 1, Column 2, 2nd Full Para., p.11 The report states that a container of urea formaldehyde (UF) solidified l resins at the Three Mile Island nuclear power plant spontaneously j overheated and burst into flames. ,

As a matter of clarification, the Three Mile Island plant has never i solidified ion-exchange resins with UF nor has there ever been any spontaneous overheating or fires in UF solidif hd wastes at that plant.

1 It also might be noted that since the pronmigetion o the Part 61 regulation, UF has not been used as a solidification agent. Current UF formulations have diff;culty meeting the waste form criteria in i 10 CFR 561.56.

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! ~10. Chapter 1. Column 1. 3rd Paragraph, p. 11 l The report states that when resins are solidified with cement they reabsorb water, swell and crumble. It also states that acid Is produced when resins deteriorate.

l Both of these-statements are true, but need to be taken in context. Ion

) exchange resins solidified with cement can crumble upon immersion in.

water. Because of this effect the Technical Position on Waste Form l

! tref formu.6)specifiesa90-day 1smersiontesttoensurethatsolidification l i lations can withstand this effect. Solidification formulations are 1 l being produced which will resist crus 611ng and loss of compressive f

, strength on ismersion. , l Organic ion exchange media can produce acid solutions under high radiation loadings. BecauseofthigtheTechnicalPositiononWasteFormspecifies i an irradiation test to 10 Radsandgecommendslo&dfngssuchthat accumulated doses will not exceed 10 Rads. The 10 Rad level is a conservative value since routinely generated resins do not exceed this level. The value was developed basevi on our experience during cleanup of Three Mile Island, Unit 2, and on testing performed by Brookhaven National Laboratory (Refs. 7, 8, and 9).

11. Chapter 1. Column 2. 4th Full Paragraph p. 11 The report states that vents for high inteprity containers (HIC's) will allow water in-migration and radionuclide eakage.

The vents in the HIC's approved by the NRC are designed to be permeable to gases but not to water so as not to allow. water to enter or exit the HIC.

The vent materials are also designed to resist radiation depradation and chemical effects which could affect their performance over onger time periods.

12. Chapter 1. Column 2, 5th Full Paragraph, p. 11 The remrt states that radiation can embrittle and chemically degrade polyetlylene used in HIC's.

High integrity container topical reports are being reviewed to ensure material compatibility with wastes and the disposal environment. The issues raised in "Living Without Landfills" are ones which have been identified in studies performed by Brookhaven National Laboratcry and funded by NRC (Refs. 10 and 11). These issues are being considered and resolved as part of the reviews of HIC topical reports submitted for NRC approval.

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13. Chapter 1. Column 1. 4th Full Paragraph p. 12 l

! The report references a concept called "hazardous life" and defines it as ,I j a multiple of the maximum permissible concentrations (MPC) in 10 CFR l

< Part 20. l The concepr of hazardous life, as defined in the report, appears to be

! subjective. We note that the report provides little technical rationale

for justifying use of the hazardous life concept as a classification ,

l system. Some of the factors that NRC staff would look for in such a j

) rationale include short and long-term environmental impacts, occupational  ;

exposures, and costs. Another problem is that the auttor is not clear i regarding the value of the MPC multiple. In different places, the report  ;

suggetts values of 100 and unity. l The report dcas not explicitly state the basis for the calculations, l 4 although we sssume that they are based on the values for nuclides soluble t in water, as listed in 10 CFR Part 20 Appendix 8, Table II. Use of the Appendix B limits in this manner prese,nts a technical problem as well as .

an applicability problem. j j The limits in 10 CFR Part 20 based on the assumption of direct in estion  ;

of water and inhalation of air containing radionuclides. These 1 mits are '

i based on the radiation emitted and the radiotoxicity of the specific radionuclides. The pathways used to establish these limits are simple j direct ingestion of water and inhalation of air to obtain a whole body 6 dose of 500 mrem, 3 Rem to the bone or thyroid and 1.5 Rea to any other  !

l organ. The values for unrestricted release (10 CFR Part 20, Appendix B,  !

j of 23 m Ij)of air per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> daassume a 50 year body burden and a continuol Table

] wateratarateof2.21/ day (y(fortheairlimits)(andingestionof 1 for the water limits). Ref. 12). <

\

The 10 CFR Part 61 waste classification system is based on a more detailed  ;

set of pathways, biological uptake mechanisms, and radiotoxicity  ;

parameters that are directly applicable to a LLW disposal faciliv. Nr j example, the agricultural scenarios were not considered in the develope nt  ;

of the 10 CFR Part 20 limits. Because these scenarios may be limiting for certain nuclides in disposal situations due to specific nuclide uptake and concentration properties of edible plants it is necessary to consider them. The 10 CFR Part 61 pathways analyses also allow reasonable credit to be taken for factors which can mitigate exposures to and releases of nuclides. For example, it would be very unit tely for an individual to directly ingest wastes. Realistica1 4 , the nuclides in the waste would have to be mobilized by leaching or degradation prior to ingestion or inhalation. The 10 CFR Part 61 pathway analyses, therefore, result in more realistic estimates of radiologic impacts.

Regarding' applicability, it should'be recalled that the Part 20 Appendix B limits do not apply to concentration limits for possession of radioactive

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material by a licensee. The Appendix 8 limits apply to airborne or waterborne releases to the unrestricted environment from a Itcensed facility. If the Appendix 8 limits were to be applied to low-lev 31 waste i disposal, the proper use would be as limits for release to an unrestricted i environment. To do so, howevtr, would be less conservative than to apply I the Part 61 performance objective, 10 CFR 561.41. for releases from a  !

low-level waste facility to the general environment. This performance l

- objective provides that releases from a disposal facility shall be limited ' r so that the potential dose received by a member of the general public l shall not exceed 25 mres/yr to the whole body, 75 mres/yr tc the thyroid, .

and 25 mrom/yr to any other organ. The performance objective further l requires that reasonable effort should be made to maintain releases to .

levefs as low as reasonably achievable. l 14 Chapter'1. Column 1. 5th Full Paragraph, p. 12 l The report states that fission product gases, Xe and Kr are released from ,

nuclear power plants, can penetrate concrete walls, and can decay into i solid radioactive daughter products. j At nuclear power plants fission product gases released from reactor fuel l are collected and processed in offgan treatment systems. These gases are l not directly released into the reactor building as is implied by the i statements in the report and their solid radioactive daughter products do  !

not represent a significant source of contamination wi, thin the reactor  !

building.  !

i Because of the very short half lives of Kr-90 (33 see) and Xe-137 (3.9 min), very little of these gases is released from the reactor coolant system prior to decay. Therefore, these gasses do not represent significant sources of contamination in the reactor butiding. Referen'ce 13 provides source term values for the containment building of a boiling i water reactor (BWR). No 'ialues are provided for Kr-90 as.it is not .

released because of its very short half-life. Xe-137 can escape fron  ;

reactor coolant system leaks into the BWR containment building at a rate  :

of 45 Ci/ year. These releases would result in a contamination source of 11 uC1/ year of Cs-137. This, therefore, represents an insignificant source of Ch-137 contamination. Tha total noble gas release to the containment building of a pressurized water reactor (PWR) is less than 1 C1/ year (Ref.14). Therefore, the Cs-137 contamination from noble gas decay will be very much smallee for a PWR than for a BWR.

15. Chapter 1. Colusm 2. Paragraph 1. p. 13 The report states that the radioactivity in non-fuel reactor components is extremely long-lived.

In fact, the activity within reactor components and other activated metals is dominated by short-lived radionuclides such as Co-60 and Fe-55.

,n........-....... .. .-. : . . . . .. . . , . . ... .. .. . ...

- 9 '.

Concentrations of long-lived radionuclides such as Ni-59 and Nb-94 are controlled to acceptably low levels through the waste classification system in 10 CFR Part 61.

Another important consideration is the characteristics of the radiation emitted by the radionuclides contained within activated metals.

Initially, when decay is dominated by short-lived radionuclides such as Co-60, ganna radiation levels can be quite high. This is why care is re uired durin handling and disposal of such high ganna wastes. The high ra lation leve s are transitory, however, and in a relatively short period of time, the short-lived ganna emitters decay to negligible levels. Other than Nb-94, a gasma emitter present in activated metals in low  :

concentrations, the remaining activity is dominated by radionuclides such as Ni-63 Ni-59 and C-14. This is significant because these three  !

radionuclides only emit beta radiation, with the result that possible impacts from these radionuclides are dominated by ingestion pathways. Of course, impacts from ingestion pathways are dependent upon the rate that radionuclides will leave the waste fonn, which will be very low considering that most activated metals are composed of highly corrosion resistant materials such as stainless steel and nickel-based alloys.

To illustrate, consider Table 2. It presents the calculated radioactive -  !

decay of a single package of activated metals generated by a nuclear power plant and disposed during 1986. The waste container is 57.5 ft3 in volume and contains thimble plugs and poison rod assemblies. The disposed activity within the container is 6300 C1. The waste is classified as Class C waste, and represents one of the more highly active shipments of ,

wasteactivatedmetalsduring1986(Ref.1). ,

Initially (0 years), the waste container contains 6300 curies of activity.

Co-60 (5.26 yr half life) provides about 22 percent of the activity, Fe-55 (2.6 yr half life) provides 62 percent of the activity, Mn-54 (0.83 yr half life) provides 13 percent of the activity, and Ni-63 (100 yr half life) provides 3 percent of the activity. At 30 years following dispossi, the activity within the container drops to 170 C1, a reduction by a f actor of 37. About 80 percent of is activity is contributed by Ni-63 while Co-60 provides 16 percent of the activity and Fe-55 provides less than 1 percent. By 50 years following disposal, Ni-63 provides 97 percent of the total activity, which has dropped to 120 C1. By 500 years, Ni-63 contributes 78 percent of the total activity, which is 6.9 Ci. By 1000 l years, Ni-63 only contributes 10 percent of the activity. The remainder )

of the 1.7 Ci of activity at 1000 years is principally provided by C-14 (8 l percent), Ni-$9 (82 percent), and Nb-94 (0.1 percent).

16. Chapter 1,_ Table 1-1, p. 13 The table intends to portray the distribution of radioactivity within low-level waste generated to the year 2020, based on information cbtained from the "Updates" document (Ref. 15). A quick review indicates that the

. s 10 '

table includes at least two wasta stieams from decoomissioning nuclear I power reactors: core shrouds and ion-exchange resins produced as part of decosuitssioning operations. The table also refers to a waste stream called "reactor internals," which apparently is also meant to represent waste from reactor decosmissioning, as well as to a waste stream called i non-fuel reactor components. l

We believe that the table is misleading. f  !

Limiting ourselves(a)or the sake

of time, to decosuitssioning wastes, we note the following

most reactors will probably not be dismantled within the period considered in ,

the report; (b) most radioactivity in decosmissioning wastes is short lived, so that any delay between reactor shutdown and dismantlement will result in considerable decay of the radioactivity; and (c) greater than 95 percent of the activity within reactor decosmissioning wastes is projected to be contained within wastes exceeding Class C concentrations.

We also note that the activity in these. waste streams is projected in the "Updates" report (Ref.15) in a conservative manne, particularly for the case of the ion-exchange resins. If these waste teams were as 1

radioactive as projected in Reference 15, then the core shrouds and resins ,

would exceed Class C concentrations. Wastes exceeding Class C concentrations will probably be disposed in a geologic repository. Based i on Reference 15 projections, some of the "reactor components" waste stream L may also exceed Class C concentrations. (SecCoseent20.)

Finally, it would be helpful if the report clarified whether the  :

"hazardous life" values listed in the table are based on comparison with Part 20 MPC or 100 times Part 20 MPC.

i 17. Chapter 1, 1st Column, 1st Full Para., p. 14 j The report states that the technology for segmenting a reactor pressure vessel has not been demonstrated. -

As a matter of clarification, the technology for segmenting metal in

, thicknesses greater than 11 in. is not new. For examole, segmentation of

! non-radioactive metal in battleships is consonly performed. Experiments i have been carried out using different cutting teciniques such as saws and J oxyacetalene torches. An automated oxyacetalene torch has been

demonstrated to be effective in cutting thick metal sections for decosmissioning operations (Ref. 16). i 174. Chapter 1.1st Column, 2nc Fall Para., p.14 l The report discusses wastes from decoamissioning assuming that I dismantlement occurs ismediately folicwing shutdown. Yet, the report indicates on a number of occasions (e.g., see pages 14, 72, and 79) that this is not likely to happen. I l l l

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l A delay of only a few years between shutdown and dismantlement will have a  !

large effect on the radionuclide inventory within decosmissionin '

For example, based on information in NUREG/CR-0130, Addendum 3 (g wastes.

Ref.17) '

and NUREG/CR-0672, Addendum 2 (Ref.18), we estimte that a delay of 30 years between shutdown and dismantlement will significantly reduce the inventory within decossissioning wastes. For Class C wastes, 30 years  ;

decay will reduce inventories by a factor of 19-25. We expect similar reductions in activity for Class A and 8 wastes. !smediate dismantlement of a PWR will result in an estimated occupational dose of 1200 person-Rems ,

(spread over five years) and an estimated occupational dose of 400 '

person-Rens if dismantlement is delayed 30 years (Ref. 19). The average dose to workers during nuclear power plant operations is 500 person-Rems /yr.

18. Chapter 1, 1st Column, 1st Para.. p. 15 At the bottom of this paragraph a statement is made that the total radioactivity within activated metals from reactor decommissioning greatly exceeds that produced annually by a typical reactor. A generation rate of (

2000 Ci/yr is presented for a typical PWR, and this generation rate is compared against 4.6 million curies projected to be generated from decommissioning a reactor. This is a continuation of a discussion started on the bottom left side of page 14 j

. We believe this discussion to be misleading, since it includes much waste u terial, generated as part of reactor decosmissioning, that will exceed Class C concentrations. Studies in NUREG/CR-0130 (Ref. 17) and NUREG/CR-0672 (Ref.18) indicate that roughly 98 percent of the activity in PWR decoanissioning waste, and roughly 96 percent of the activity in BWR decosmissioning waste, will exceed Class C concentrations. This is illustrated in Table 3, which susmarizes information from these two '

sources.

These two sources project a total of 124,000 curies of activity in Class A, B, and C wastes from ismediate dismantlement of a large (1175 MWe)  !

pressurized water reactor; and a total of 295,700 curies of a~ctivity in '

Class A, 5, and C wastes from iseediate dismantlement of a large (1155 l FWe) boiling water reactor. Most of this activity is very short lived and l would be reduced by delaying reactor dismantieoent following shutdown.

Table 4, prepared by NRC staff based on data obtained frem these two sources, illustrates this for Class C waste. A decay period of 30 yedrs between shutdown and disa ntlement reduces Class C inventories by a factor of 19-25.

This informtion can be compared with the report's stated PWR generation rate of 2,000 C1/yr. Assuming no decay between shutdown and dismantlement, 124,000 curies of activity would be generated over the course of the PWR disantlement operation, which is projected to take up to 4 years. This translates to an average of 31,000 C1/yr. Similarly, 1

, l 12 ,

the 295,700 curies projected for BWR deconunissioning averages 73,900 Ci/yr over four years.

If, however, a delay of 30 years is assured between shutdown and dismantlement, which the report indicates is a reasonable assumption, then the 124,000 curies from PWR dismantlement is reduced by an approximate factor of 19 to 6,500 curies. This translates to an average of 1,630 C1/yr over a 4-year dismantlement period. Similarly, the activity from BWR dismantlement is reduced by an apotoximate factor of 25 to 11,800 curies, .or an average of 2,960 Ci/yr.

The above decayed waste activity is comparable to the average annual activity within reactor waste under normal operations. Something over 100 reactors shipped roughly 580,000 curies of low-level waste activ'ty in 1985 and roughly 170,000 curies in 1986. This equates to a rough annual average ranging between 1,700 and 5,800 curies. '

It may also be noted that the first several reactors to be decoamissioned are expected to be low power derenstration units, and the activity ,

contained in the waste from these initial units will probably be lower  !

than that from the large reference units considered in References 17 and  :

18.

l The activity in waste exceeding Class C ccwentrations will also quickly decay with time. Table 5 illustrates this again using inforr.ation for the two reference reactors discussed above (Refs. 17, 18).

19. Chapter 1. Column 1, Paragraph 1, p. 16 ,

The report states that chelating agents he w combined with other nuclides  !

permitting migration from disposal units N offsite.  :

We agree that cosolexing of nuclides with melating agents is an important consideration. h is is why NRC has s areas (e.g.,Refs. 20,21,22and23)ponsoredanurterofstudiesinthese We also note that for wastes containing chelating agents, disposal sites have specific license conditions (Refs. 24, 25 and 26) which require segregation from other wastes. At the humv3 Barnwell site, license I conditions include prohibitior.s against the disposal of wastes containing greater than 8 weight percent chelating ag*nts. The NRC regulation, 10 CFR Part 61, requires a license applicant t.o address wastes containing chelating agents in its application and 10 CFR 520.311 requires waste generators to identify waste shipments containing greater than 0.1 weight percent chelating agents.

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20. Chapter 1. Column 2. 1st and 2nd Full Para.. p. 16 The report contains a discussion which confuses irradiated components l projected to be generated during reactor operations with wastes projected to be generated during reactor decossissioning. l Regarding irradiated components, we note that "Living Without Landfills"  !

pr<ncipa ly considered Referenca 15 when projecting the activity from this t

waste stream. The activity in activated components was given in i Yhiswasdone i Reference so that this15.(asadistributionovergordersofmagnitude.and other) waste stream ci proportioned into the different waste classes. Rather than considering j the distribution in the manner as was intended by the Reference 15 j authors, we expect that the report merely considers the weighted average  ;

concentration for the waste stream. This is significant, since we expect  !

a portion of the waste stream distribution j beclassifiedasGreater-Than-ClassC(GTCd)asgiveninReference15,to waste. If this GTCC waste j activity is included in the report, as we expect it is, then the report  ;

would tend to overstate the activity projectee to be disposed in low-level i waste sites. [

}

The discussion nf decommissioning wastes is questionable for the reasons i given in Cossents 16 and 38. , j i

We finally note that the report states that the activity in irradiated  ;

components and reactor internals is primarily composed of radionuclides i having long half-lives. As discussed in Cossents 15 and it, this is not  !

the case. ,

.  ?

21. Chapter 1. Figures *1-7 and 1 8. pp. 16-17 t The figures present information on SWR decosmissioning wastes and PWR irradiated components.

The activities presented in the graph cppear to be misleading, for the l same reasons as those given in Cowent 20. The activities appear to be  !

dominated by those from wastes exceeding Class C concentrations.  ;

Low-level waste exceeding Class C concentrations is the responsibility of l the Federal government, not States and Compacts siting new disposal j capacity. i

22. Chapter 1. Column 1. 1st Full Para.. p. 17 The report discussaJ the hazards of the disposal of irradiated components, l See Cossents 20 and 21.

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23. Chapter 1. Column 1. Top Two Bullets, p. 18 The report states that non-fuel and decosuiissioning waste radioactivity is very long lived.

In fact, the ma,jority of the rad *oactivity in replacable reactor comporents, as well as in internals genersted as part of reactor decossiissioning, is short lived. See Comments 15 and 18, 24 Chapter 1. Column 2. 1st Full Para.. p. 19 The report statec that dioxin will be produced in the incineration of radioactive westes. .

Dioxin is a generic name for a class of compounds that can be formed as a byproduct of certain chemical reactions and during many combustion and incineration processes. The most consen dioxins are the polychlorinated dioxins (PC00's) of which there are 75 different isomers. The toxicity of dioxins to animal species depends on the number and placement of the chlorine atoms on tie dioxin molecule. The more toxic dioxins have four to six chlorina atoms with the 2,3,7 and 8 positions filled. The simplest is2,3,7,8-tetrachlorodibenzo->-dioxin (1000). Other molecules closely associated with the dioxins are tw polychlorinated dibenzofurans (PCDF's).

While some incinerators have released dioxins, it is important to note that these incinerators have very different designs than those referenced in the report.

The report references two proposed radwaste incinerators, one in North Carolina and one in Pennsylvania. The North Carolina proposal was l recently withdrawn. The incinerator in Pennsylvania is a two-stage  ;

controlled air incinerator. Waste would be ignited and burned in the  !

first stage (primary com6ustion chamber). The gaseous combustion would then pass to the second stage (secondary combustion chamber) where productsI ,

the oxidation process would be completed. These design features will minimize the release of dioxins. Dioxins would be destroyed in the secondary combustion chamber because of the high temperature, high oxygen concentration and adequate residence time of the offgas in the secondary chamber. The secondary chamber will operate at 2100F with a retention time of 1.33 seconds and excess air of about 100 percent. A temperature of 2100F requires 0.040 seconds of gas residence time for 99.99 percent destruction of dioxin.

Materials to be incinerated in the proposed incinerator that could result in dioxin and furan synthesis include benzenes from liquid scintillation fluids and limited quantities of polyvinyl chloride (FVC). Incineration of chlorinated benzenes can yield both PC00's and PCDF's. PVC can be a source of chlorine and on incomplete combustion yield minute quantities of l

,, m. . - - _ _ _ _, --_. _. _ - . . _ _ - - - _ - _ _ .

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! chlorinated benzene which,'as just stated can be a precursor to both l 1 PCDD's and PCDF's. QuantitiesofPVCincIneratedinthePennsylvania i j incinerator will be limited to 5 weight percent. The limit will be  :

) implemented through contract restrictions and shipping manifest  ;

q documentation. This limitation is placed on PVC as an operations i J restriction for economic reasons, however, rather than because of the l environmental concerns for dioxin release. High PVC. levels in the waste l l would result in production of excessive amounts of hcl, which would be >

removed by the primary scrubber and would cause an increase in density of  !

I the scrubber solution. Dilution would be required to maintain an  :

j acceptable density, and the resulting volume of scrub liquor would exceed the volume that could be reinjected <nto the incinerator. ,

1 A second important design feature of the proposed incinerator is that it  ;

j will have a multi-stage air cleaning system, which includes caustic i scrubbing, with the  !'

i approximately 180F.The gases leaving offgas the scrubber will then be heatedsystem slightlyattoaabout temperature 230F of j before entering a HEPA filter / charcoal adsorber/HEPA filter system -

t designed to remove radioactive particulates and radiciodine. This system 3 J

would also remove particulates and flyash on which any dioxins present j would be adsorbed following the cooling steps prior to the filters. The i charcoal would also remove any remaining trace vapor phase diox, ins I l (Refs.27and28).  !

25. Chapter 1. Column 2. 2nd Full Paragraph p. 19 l

1 The report states that NRC regulations allow scintillation fluids to be i discharged down the drain or sent to municipal landfills.

1 '

The NRC regulations, 10 CFR 120.306 allow sein.tillation fluids and animal I j tissuecontaininglessthan0.05aClofH-3 orc-14pergram,tobe j disposed of without regard to its radioactivity. The regulation, however, ,

does not relieve the licensee from regulations governing toxic and hazardous properties of these materia,s. Therefore, se'ntillation fluids and animal tissue containing toxic or hazardous components must bo '

) disposed of in accordance with applicable local, State, and EPA  !

requirements, j l One of the primary reasons the volumes of scintillation fluids have

decreased since 1980 is that most are being incinerated at the Quadrex facility in Florida. These materials are not being released to sewers or mnicipal landfills unless their characteristics a low such disposal under i local, State, and EPA regulations.

! In addition, considerable waste is held for decay. In fact, the practice i J at hospitals and universitiss of temporary storage of wastes containing i short-lived radionuclides has been ongoing for numbers of years, as it i l reduces disposal costs. The ultimate disposition of this stored waste  !

! depends on the radionuclide characteristics. If the waste contains only l

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very short activity livedto dec4ys radionuclide, negligible levels, at which time the waste may bethen the was i disposed by methods other than shipment to a low-level waste site. Much l hospital and university waste, however, still contains longer-lived t radionuclides such as carbon-14. Unless the waste can be dis ,

pursuant to Part 20 (e.g., as BRC waste under 10 CFR 520.306) posed

, the waste '

is shipped to a low hvel waste site.

26. Chapter 1. Column 2. 3rd Full Parteraph p. 19 {

The report states that there is no systematic monitoring or enforcement (

for radioactive materials released to sewer systems. l By NRC and Agreement State regulations, all licensees who release {

radioactive materials are required to monitor their releases and maintain i records of such releases. NRC reviews such records as part of its l inspection program. For licensees who release radicartive materials with  !

a potential for concentration in sewage treatment systems, the NRC has implemented an ins analysis (Ref. 29)pection program which ts of this included program sample identified acquisition one sewerageandThe resu facility with measurable levels. Even though these releases were in l accordance with the regulations, the applicable licensee has implemented a

• program to further reduce releases. l

27. Chapter 1 Column 1. 1st Full Paragraph, p. 20 The report states that tritium wastes from New England Nuclear are in a ,

gaseous form. l Sorm wastes from New England Nuclear used to be in a gaseous form. Now, i however, all tritium wastes are in an aqueous form and are placed in an (

absorbent in glass bulbs. These bulbs are packaged with additional  ;

absorbent in welded aluminum cans and packaged again with absorbent in stainless steel cylinders. These packages have been drop tested without breakage of the glass bulbs or release of the tritium.

28. Chapter 1. Figure 1-14. p. 21 The report presents information on industrial waste generators indicating l that sealed sources represent 32.2 percent of the activity for this group  !

of generators, j The sealed sources referkncad in the figure will probably exceed Class C concentrations. If so, they will most ikely not be disposed at cosmercial 1cw-level waste sites but will be transferred to the Federal government for probable disposal into a HLW geologic repository.

17 ',

29. Chapter 1. Column 1. 1st Para.. p. 22 The report indicates that the average sealed source has an activity of 10 Ci.

As a matter of clarification,10 curie,5 is probably conservatively high.

ItisbasedoninformationfromNUREG/CR-4370(Ref.15) which presents a weightedaverageacrossadistributionofthemaximumallowableactivities anon various sealed source designs. The distribution covered 8 orders of magn tude. In reality, most sea ed sources contain activity in considerably lower quantities than the allowable sealed source design limits.

30. Chapter 1. Column 2. 4th and 5th Full Paragraph, p. 22 The report states that the NRC has no regulations against waste dilution.

The NRC has no specific regulations regarding waste dilution but addresses this practice in the Technical Position on Waste Classification (Ref. 6).

Given the nature of low-level wastes and processing systems, some wastes contain mixtures with varying radiological properties. For example, ion exchange resins in nuclear power plants cosmonly are stored in a single storag1 tank. The recins from several ion exchange beds (commonly with varying activities) are collected there prior to transfer to shipping containers or processing. In this case, the wastes have similar physical characteristics (i.e., all resins) and result in a somewhat homogeneous mix. In this situation the NRC allows mixing because it is consistent with the pathway analyses performed to determine the wasta classification limits. The NRC staff, however, would not allow diluMon by such means as placing a small volute, high activity source in a hrge container (e.g., a 200 ft8 liner) or diluting a highly radioactive component with low activity trash,

31. C_hapter 1. Figure 1-16. p. 23 At the bottom of the figure, a statement is made that "Though waste volume j has declined, total "low-level" waste radioactivity has increased as more ,

reactors come on-line and more oldei reactors discharge used irradiated l components." i l

This statement is not supported by tha figure, which depicts the activity l as fluctuating. The disposed activity was higher in 1977 and 1978, but dropped to lower levels and was reasonably constant between the years 1979 and 1984. The disposed activity increased somewhat in 1985 but decreased sharply in 1986. One of the reasons for this is that activated component wastes are generated on an irregular basis.

As a general consunt, it is not certain that disposed activities in future ,

years will automatically increase. Since disposal site operators assess j

= .. . - > - - . - .

j . .

. i l f 18 ,  !

l j disposal costs based partly on the activity within waste waste generators  !

haveaneconomicincentivetoreducethisdisposedactivIty. Waste )

activity can often be reduced by modifying equipment and procedures. It l 1

j j mayalsobepossibletoreduceactivitiesby)materialsubstitution(e.g.,

use reactor components containing less Co-59 .

l

32. Chapter 1. Fleure 1-17. p. 24 f j The figure states that the LLW volume has declined due to the use of waste >

2 compactors, storage for decay, and deregulation of waste. l As a matter of clarification, in recent years the LLW volume has declined  !

for a nus6er of reasons. We believe that many of these reasons are more

significant than disposal of waste by less restrictive means. (Additional

! information is provided in Cossent 37.) l

. 6

33. Chapter 1. Column 1. 1st Paragraph, p. 24  !

I i 4

The report states that transuranic wastes generated in the West Yelley f

Demonstratica Project (kVDP) will be dispose 6 at a regional or New York l

. State waste facility or remain at West Valley. , j 1 i l . All transuranic wastes generated in WiOP activities will be disposed at a  !

Department of Enerny (D0E) Transuranic Waste Facility. Currently, the DOE i l: lans to dispose o< transuranic wastes at the Waste Isolation Pilot Plant t l p(WIPP)inCarlsbad,NM. .  ;

l 34 Chapter 1. Column 2. 1st Full Para. p. 24 g l E

l The report states that disposal of EW, uranium mill tailings, and weapons l' l production waste is not covered by 10 CFR Pert 61.

l l This is true. Disposal of high-level wastes and uranium mill tailings is l

! not covered under Part 61 but is covered under other NRC regulations. l 4 namely Parts 60 and 40. Disposal of wastes from weapons production, other

than disposal of high-level wastes, is'not licensed by NRC.

35. __ Chapter 1. Coluem 1. 1st Para.. p. 25 The report states that although wastes exceeding Class C cannot be i disposed of at a near-surface disposal facility, the NRC has initiated a '

rulemaking which could make more HLW into LLW.

The Low-Level Radioactive Waste Poli AmendmentsActof1985(LLWPAA) l (Ref. 2) gives the respcasibility of disposal of cosearcially-generated  !

j low-level waste exceeding Class C concentrations to the Federal  !

government. Pursuant to the LLWPAA, States and Compacts do not have to I j accept waste exceeding Class C wastes unless they choose to do so. This l j applies whatever the definiticn of high-level waste. NRC, through a i t

L. - _- - -- - - -

F

j i

. I 19 t

i

! rulemaking or any other action, cannot alter' the provisions of the LLWpAA  !

1 or any other Act of Congress. l i

36. Chapter 1. Column 1.1st Para . p. 26

] l 1 .

! The report redefines the term "hazardous Itfe" as the time for the  !

activity to drop to MPC. j i

Earlier, the report stated that 100 times MPC should be considered a l nonhazardous level. This discrepancy should be explained. See also  ;

Coament 13.  !

37. Chapter 1. Column 1. 4th Para.. p. 26  !

The report states that waste volumes dropped from 92,400 m8 in 1980 to  !

80,000 m8 in 1985 because of waste compaction and the increasing disposal  !

of unregulated waste in landfills and down drains.

As a matter of clarification, from 1980 to 1985, waste volumes decreased  ;

primarily from the administrative volume minimization programs which  ;

reduced the amounts of weste generated. In 1980 many licensees considered [

all wastes within the exclusion area to be radioactive, whether they were i or were not. After 1980 when disposal costs began to rise substantially, licensees began to critically review their programs to reduce costs.

Programs were implemented to segregate non-radtoactive and radioactive materials and administrative controls were placed on operations to reduce- l the unnecessary contamination of non-radioactive materials. '

In 1986, low-level waste volumes decreased more significantly, to i 1,800 000 ft8 (51,000 m8) from 2,680,000 ft8 (76,000m8)in1985. This l drop In waste volume wi.s apparently caused by reasons more significant  !

than disposal of weste by less restrictive means. During 1985 and 1986, f NRC approved one application (in 1985) for onsite disposal pursuant to 10 l CFR 520.302. This application involved less than 10 microcuries of Ir-192  !

(half itfe: 74.2 days). Regarding wastes containing radionuclides below l regulatory concern, during these two years NRC conducted no rulemakings )

al owing disposal uf specific waste streams.  !

f The drop in waste volume has been of interest to States and Compacts. At a recent meeting of the low Leyv1 Radioactivs Waste Forum, a spokesman on behalf of the Nuclear Wasta Brokers and Proc 9ssors Association gave the following reasons for the volume reduction (Ref. 30):  ;

- Supercompactors, which will reduce waste by 21 or 3 times; l

- The elimination of certain procedures for radioismunoassays; l

- Better segregation of contaminated materials, resulting in a higher i prtrcentage of the materials disposed actually being radioactive; l I

e.

20

- Decontamination rather than disposal of certein items such as tools;

- Holding for decay;

- More advanced planning which results in source reduction (exp'ected to be a greater factor in the future); and

- Insurance costs which may drive some smaller generators out of business. -

38. Chapter 1. General Coment. pp. 26 and 27 The report makes some statements regarding the generation of low-level vastes. One is that the activity in low-level waste generated between the years 1980 and 2020 will total a half billion curies, and that 99 percent of this activity will be generated by nuclear power reactors. These statements are questionable, for three basic reasons:

1. The report apparently incorporates a number of questionable assumptions regarding waste generation rates.

2. The report includes wastes exceeding Class C concentrations with wastes to be disposed at commercial low-level waste sites.

3. The report consistently confuses'the two -- i.e., refers to wastes exceeding Class C concentrations as if they were Class C wastes.

The basis for the waste projections is obscure. However, the report apparently assumes a constant source term for waste from reactor operation at the same time that the reactors are decomissioned. On pages 26 and 27, the report mentions a constant source term from nuclear reactors, assuming a constant capacity of 70,000 We from PWRs and 32,000 MWe from BWRs. This results in a constant 102.000 MWe of capacity. Elsewhere, for example on page 28, the report states that 115 reactors, apparently all 1,000 MWe reactors, are constantly in operation. The rvport also assumes that every time a reactor is shut down, another one takes its place. This seems questionable considering the long lead time -- e.g.,10 to 12 years

-- required to site, build, and license a nuclear power reactor.

Regarding wastes from decomissioning, the report does not state how many reactors are assumed to be decomissioned between 1980 and 2020. However.

it appears that the waste projections in the report are based on tne assumption that most, if not all, reactors are dismantled around the year 2000 (or at least prior to 2020). This contradicts statements on pages 14, 72, and 79, which indicate the authors' expectation that dismantlement will not occur until after 2030. For example, page 72 states that "most power reactors will not be deccmissioned until about 30 years af ter reactor clcse down, or about 2030 . . ."

. 21 ,

4 Perhapr the authors believe that even though waste will not be generated >

. until after the year 2030, the fact that nuclear reactors exist results in j a potential source of waste that must be considered as if it were i

generated today. For example, page 28 states that it is "not necessary to

! further assume that reactors are dismantled when decosmissioned, only that I

waste is generated." This is questionablo, since most of the activity in decosmiss'oning wastes is very short lived. A delay of 30 years between ,

shutdown and dismantlement results in a reduction in waste inventory by a '

factor of 30-40.

Perhaps the report is including hardware from possible reactor fuel ,

asse161y consolidation activit' es. Whether the report does or does not i include such material is unclear. In any case, much consolidation -

hardware will probably exceed Class C concentrations. For hardware that

- does not exceed and States Class Ctoconcentrations,lidation are required accept conso hardware waste forit ouestionable whe i disposal. It could be argued that consolidation hardware constitutes a l form of spent fuel. Sure y, hardware is covered along with fuel rods i

, under the DOE standard contract for acceptance of spent fuel for disposal l l into a geologic HLW repository (10 CFR 961). There is a need to clarify, l j however, the status of hardware that has been separated from the fuel rods i by the waste generator. 00E has previously indicated that it will accept i under the standard contract separated hardware as spent fuel (Ref. 31).

Another problem is the report's treatment of wastes exceeding C1sss C

] concentrations (GTCCwaste). The report lumps GTCC waste with other LLW  :

and leaves the reader with the impression that all wastes, including GTCC l

) waste, contribute to the inventory pro,iected to be disposed at low-level '

j waste sites. This is questionable, given the provisions of the Low-level i Radioactive Waste Policy Arendments Act. We believe it unlikely that  !

State will accept waste exceeding Class C concentrations for disposal at j

j cosmercial low-level waste sites. This questionable practice is most '

present when the report addresses wastes from decewnissioning nuclear l

d reactors, )

i

The report confuses the rtader as to the types and classes of wastes to i which it is referring. As one example, the resort confuses wastes

! currently generated with wastes generated in tie future. In some places the report states that currently 70 percent of the low-level waste activity is generated by reactors but that this percentage will raise to

! 99 percent in the future due to reactor decosmissioning. In other places i the report leaves the impression that 99 percent of the low-level waste j activity is now being generated by nuclear reacturs. (The99 percent j nuster is questionable in any case. SeeCoswent2.)

l The report confuses Class C wastes with wastes exceeding Class C

. concentrations. In some places the report talks about wastes exceeding Class C concentrations as if they were identical in radioactivity to Class

)

-m j  !

1 .

i 22 ,

i f

stream greater-than-Class C (GTCC) waste but ends up calling it Class C waste. This example is on page 49. -

The report confuses different weste streams. The practice is to mention l two different wastes stream , either differing considerably in l radioactivity or in the time of generation, as if they were the same waste  !

Stream. This occurs, for example, on pages 16 and 49.  ;

t

39. Chester 1. Colomm 2.1st Para.. p. 26

{

The report projects that one-half billion curies will be generated from l 1980 to 2020. It concludes by saying that while one billionth of a curie l 1s cause for great alem in a laboratory or hospital, one billion curies  ;

is almost too great to comprehend.  !

We believe that these statements are greatly exaggerated. Hospitals l annually perform 10 million diagnostic, therapeutsc, and brachytherapy t procedures (Ref. 59), administering approximately 100,000 curies of [

activity (with substantial benefits to petients) without causing greet l alare. .

j The activity within LLW is also greatly, exaggerated, even when wastes exceeding Class C concentrations are included. As noted in Comment 38, i the basis for the half billion curie value is not clear. It appears, I however, that the report assumes that roughly 100 reactors will be j decosmissioned by the rear 2020, and that each reactor contributes roughly  :

5 million curies of activity as LLW. This totals about 500 million i curies, and the reader is lef t with the impression that this 500 million  !

curies will all be disposed in commercial LLW sites. j

- i This is questionable. As discussed in Comment 34: {

1. It is not obvious that most reactors will be dismantled by 2020.

2. Decosmissioning waste (as is reactor wasta during operations) is i so a few years decay between '

dominated shutdown and bydismantlement short-lived radionuclides,in will result a large reduction in weste I inventories.

2. Wastes exceeding Class C concentrations is the responsibility of the Federal government, not States and Compacts.

For the purposes of coseercial low-level waste disposal a more realistic estimate would be to project the quantity of radioactivity that will be contained in Class A, 8, and C wastes between 1980 and 2020. A rough starting estimate can de obtained by considering the activity in sh<pped LLW over the past few years. Since 1980, disposed activities for the Beatty, Richland, and Barnwell sites have totaled the following:

(V 23 .

Year _ Activity (C1) Year Activity (C1) 1980 333,000 1984 601.000 1981 280,000 1985 749,000 1982 414,000 1986 234,000

• 1983 465,000 1987 260,000 l es 417 000 curies per year. Assumin 500,060 curies per year This avera$ying by 40 years, one obtains 20 mil $1on curies.

and multip Most of this activity will be short lived (see Comment 4).

To this estimate, one must add wastes from dismantling nuclear power

reactors. Projections of the timing of reactor decommissing are uncertain, although the report indicates a belief that few reactors *will J

be dismantled by 2020. Assuming that as a ny as 20 reactors are i dismantled during this period, and that 0.04 percent of the activity from dismantling these reactors is contained in Class A, B, and C wastes, then

, one can calculate: 20 x 0.04 x SE+6 = 4 million curies. This estimate does not consider the potential for radioactive decay to reduce inventories in decosmissioning wastes.

We believe that LLW disposal facilities will neither handle nor release activity levels which are too great to comprehend. Rather, we are confident that LLW dis >osal facilities can be sited, designed, and operated in a manner t1at will protect public health and safety and the environment.

40. Chapter 1. Column 1,1st and, 2nd Para. , p. 27 The report assumes all reactors have a 10'0 Mw(e) capacity and states this assumption will underestimate the activity in decosmissioning waste.

In reality, the radioactivity is probably overestimated. We believe that many reactors will undergo a cooling off period between shutdown and disrantlement, and the decay will red:ce inventories. This decay has not been considered in the report.

Another consideration is that mo:,t of the first reactors to be decosmissioned will probably consist of early, low pcwer demonstration units having electrical capacities considerably less than 1000 MWe, We expect that the Class A, C and C waste activity from decornissioning theselowpowerreactorswIlibelessthanthatforthelater1000MWe reactors. .

l l

i

S 24 .

41. Chapter 1. Column 1.1st Full Pare.. p. 28 In this paragraph, a statement is made that it is "not necessary to further assume that reactors are dismantled when decommissioned, only that l waste is generated."  !

r This is hardly the case. A reasonable decay period between shutdown and  ;

dismantlement of a nuclear power reactor males a significant difference in i radionuclide inventories and concentrations. We estimate, for example, i that a delay of 30 years between shutdown and dismantlement will reduce i radionuclide inventories within Class C low-level decommissioning wastes 'I by a factor of 19-25. l

42. Chapter 1. Column 2. 1st Full Para.. p. 28  !

The report estimates that low-level wasto froe nuclear power reactors,  ;

generated to the year 2020, will still decay to roughly 200 000 curies of )

activity-after 10,000 years of decay. ThisappearstobesIgnificantly I inflated. It is difficult to be more specific, since the report did not l provide the basis for the curve. Based on other sections of the .'eport, i towever, it apnear: that the report includes, as "generated" wastes a  !

very large contribution from r eactor he, missioning wastes, including  !

wastes exceeding Class C concentrat h 4 The reader is left with the l tapression that this "generated" waste will all be disposed in cosmarcial )

LLW facilities sited by States and Compacts.

l This is misleadinjl, first, because (as the report admits) very few [

reactors are likeiy to be dismantled by 2020, and second because disposal t ofwasteexceedingClassCconcentrationsistheresponsIbilityofthe Federal government.  !

43. Chapter 1. Coluem 1. Ist Part... p tg The report asks why move gg percent of the activity from reactors to tn uncontaminated site, when the 1 percent of the activity from non-pcwor j plant generators could be moved to the power plants? One good reason is c as follows: Nuclear power plants are sited in locations were cooling  !

water for electric power production is readily available. These sites I adjacent to oceans, rivers, and lakes may be ir. compatible with the 10 CFR l Part 61 siting requirements for long-tem safe disposal.

l In any case, moving the waste to the power plants would result in a proliferation of low-level waste disposal facilities.

44 Chapter 2. 4th Para.. p. 33 ,

The re rt states that serious problems have caused the Maxey Flats,  !

Sheffi d and West Valley sites to close. l l

l 2f -

i h

i The NRC staff shares the report's concerns regarding past practices and l problems at the above three disposal facilities. NRC staff considered i this experience when developing the requirements in 10 CFR Part 61, which i are intended to prevent a reoccurrence of part problems. It should also  !

be noted that in no case has any release of the small quantities of i activity from these sites threatened public health and safety.

It should also be noted that at Barnwell, Beatty and Hanford, where '

disposal operations are being performed consistent with 10 CFR Part 61, the problems observed at the three closed sites have not occurred. ,

i

45. Chapter 2, Column 1,1st Para., p. 34 _

i The report states that the West Valley disposal site is located in a swamp and that Sheffield was placed on an underground stream bed.  :

i The disposal area at West Valley is located on a feature known as Spitler's Swamp. However, the disposal area does not have the surface ,

water characteristics one associates with a swalup. ,

i The Sheffield facility is located over a groundwater aquifer. However, it l can not be characterized as an underground stream bed.  !

t

36. Chapter 2, Column 1, Last Para., p. 34 l

The report discusses chelating agents in this paragraph., l See Connent 19.

l

47. Chapter 2 Column 2, 2nd Full Pars., p. 34 i The report states that migracion has occurred at the Barnwell disposal  ;

facility.

Although some rovement of tritium has occurred, it is located in the areas  !

innediately adfacent to a few disposal trenches. (SeiComment59.)

48. Chapter 2, Coluutn 1, 5th Full Para., p. 35  !

l The report states that at Maxey Flats plutonium has roved hundreds of feet l and is one of the most toxic substances ever created.-  !

As beena matter in very of clarification, small the p(lutonium concentrations less than detected the limits at Maxey Flats has listed for unrestricted release in 10 CFR Part 20, App. B) (Ref. 32). These levels do not represent a public health and safety hazard (Refs. 33, 34, 35, 36 and 37). NRC staff reviewed the Maxey Flats experience and disposal practices (e.g., see Ref. 38), and factored this review into their development of the Part 61 regulation.

m .

n o

26 .

49. Chapter 2, Colemn P, 2nd Full Para., p. 35 The report states that a seep in a new trench led to the closing of the Maxey Flats site.

As a matter of clarification and as briefly discussed in Reference 38, a combination of events led to discontinued operations at the Maxey Flats disposal site.

50. Chapter 2, Column 2, 4,th Para., p. 35 Concentrations of tritium and Sr-90 are quoted as being substantially higher than offsite MPC levels.

The referenced values were measured in the trench leachate. These values should not be considered as representing concentrations measured offsite which have been less than MPC levels.

53 Chapter 2, Column 1, 5th Full Para., p. 36 The teport references some cost data developed in a DOE report and states that 00E is not anticipating that past problems will be repeated.

• i It should be noted that the 10 CFR Part 61 requirements were developed to preclude reoccurrence of poor past practices. The good experiences at Barnwell, Beatty and Hanford support the effectiveness of the 10 CFR Part 61 requirements. Part 61 requires adequate financial assurance to cover closure and custodial activities during the institutional control period.

52. Chapter 2, Column 1, 6th Full Para., p.36 l l

The report states that the Sheffield disposal facility is directly l licensed by the NRC. l 1

As a point of clarification, it should be noted that the State of Illinois i beetme an Agreement State on June 1,1987 and now has licansing authority over the Sheffield facility.

53. Chapter 2, Column 2, 3rd Full Para., p. 36 The report states that Sheffield Trench 18 intercepts the groundwater table.

Trench 18 does intercept the groundwater table, As a matter of clarification, however, Trench 18 contains 131.3 curies of activity (as of 1976) distributed over 120,655.69 ft3 of waste (averages 1.1E-3 Ci/ft3 or 3.1E-5 Ci/m3). Trench 18 was excavated H a topographic low point on the site and during excavation, a muddy see::: nii. unwu n t.u red. As approved by i NRC the trench was then partially refilled with earth to raise the trench 1

27 ,

bottom above what was believed to be the level of the water table I underneath the trench. Since the final trench bottom was less than a foot above the water table, the' contents of the trench was restricted to very low activity material -- principally dirt conta:ninated from a liquid spill at a nuclear power plant. The water table beneath Trench 18 later rose, inundatingthebottomfewfeetofthedisposedwastecontainers(Ref.38).

54. Chapter 2, Column 1, 3rd Full Para., p. 41 The report states that the State of Illinois is investigating the possibility of, the DOE assuming responsibility for perpetual care of the Sheffield site. .

As a matter of clarification, since the State of Illinois became an Agreement State, transfer of the facility is no longer an option as only sites licensed by NRC are eligible for transfer.

55. Chapter 2, Column 1,1st Full Para. , p. 38 The report states that the West Valley disposal facility is located in Spitler's Swamp.

See Comment 45. .

. 56. Chapter 2, Column 2, 3rd Full Para., p. 38 The report states that the water treatment system at West Valley has questionable effectiveness in the presence of chelating agents.

This stateinent appears to be misleading. All processed water is monitored, and is releared only if it meets site license specifications for release. Therefore, any possible reduced effectiveness of the West Valley water treatment system would have no effect on public safety, since it would be detected by the monitoring system prior to release. j

57. Chapter 2, Column 1, 2nd Full Para., p. 41 1

The report states that the problems of package degradation, trench cover subs % nce and water infiltration at Barnwell are no different from those -

at thu three closed sites, but the results have been different.

We certainly agree that the trench subsidence effects and water infiltration results have been different and substu tially better at Barnwell than at the three closed sites. However, the statement that the problems at Barnwell are the same as at the three closed sites needs clarification (Ref.39). For example, there is no evidence or documentation to the extent of psckagr degradation. Therefore, this stateme'nt is mere speculation. There have also been only 30 cases of

, . - - - - y_p ,

-.-- _ . - , - - - - . , - ---- w.-,-- - - - , ,% , , , . , , -. m , ---r-,,--i-

e , .

28 '.

trench cover subsidence in 57 closed trenches since the beginning of operation in 1971.

Regarding water infiltration, there have been only two brief instances.

These occurred in August 1984 in Trenches 43 and 44 after an above normal rainfall when the water table reached an all time high. Based on water level measurements, the water table may have briefly rose into the five foot separation zone below the bottoms of Trenches 43 and 44.- It cannot be determined from the data whether the water table actually rose above

~

the' trench bottoms. However, measurements following this event detected no migration of tritium or other radionuclides. There have been no cases of water standing in the trenches for extended periods of time (Refs. 39, 58).

58. Q3pter2. Column 1,2ndFullPara.,p.41 The re) ort states that no trench water samp'les have yet been collected even t1ough the mean annual precipitation is over 43 in/ year.

In fact, monitoring sumps have been placed in all trench drains since the beginning of operation. Currentl which samples are taken monthly Ref.(y39).

there are 225 monitoring sumps from

59. Chapter 2, Column 1, 3rd Full, Para., p.41 The report states that at Barnwell, tritium has migrated as far as 75 m from the waste trenches, Co-60 has migrated below Trench 2 and tributyl-n-phosphate (TBP) has been buried and may cause future migration problems.

Tritium has been detected in some wells adjacent to waste trenches but none in wells 75 m from the waste trenches or offsite (Ref. 40). It j should be noted that Reference 40 states that tritium levels 200 ft from 1 the trenches were "near background" levels, not at greater than background l 1evels. This reference also states that lateral migration of tritium was limited to one well located 10 ft. from Trench 8. It should also be noted

-that the reference source for the tritium level stated in the report (116,000 pCi/1) is uncertain. We believe that the report refers to Figure 31 of Reference 40 which presents tritium activity in water extracted from core samples. However, at a depth of 21 meters (68,9 ft.) the highest activity (for Well CN-4) is 11,600 3Ci/1 rather than 116,000 pCi/1. In any case the stated value is less t1an the limit for unrestricted release in 10 CFR Part 20, App. B.

The Co-60 detected was in a sample taken by drilling directly through a waste trench. The Co-60 results are considered to be substantially affected by contamination spread by the drilling equipment as it penetrated the waste. In any case, the detected concentration was very low and shows little movement from one of the older trenches at the site.

. c ....

29 ,

There has been no evidence of TBP in nonradiological groundwater sampling (Ref. 39). It is believed that if TBP was buried prior to 1982 that quantities were so small it would have a negligible effect on the miga tion of Co-60 and Sr-90. There is evidence of small levels of Co-60 in a few trench monitoring sumps but no indication of Sr-90. No detectable levels of either are seen in monitoring wells.

It should also be noted that extensive studies have been and will continue to be performed to define and confine radiological and nonradiological migration (Ref. 37). There are currently 122 onsite monitoiing wells and 60 offsite monitoring wells. Duplicate radiological samples are analyzed by both the site operator and the State of South Carolina. A monthly report is prepared by the State of South Carolina to identify trends and any potential problem areas.

The operster is also performing onging research to determine horizontal and vartical movement, as well'as potential plumes (Ref. 37). This is being accomplished by using a master core program which allows fence diagrams to be drawn in the area of the older trenches and~which shows the reistion of tritium migration with depth. From this, several types of  ;

remedial actions are being studied to prevent any further migration in the l area of the older trenches. The State of South Carolina does not see any potential threat to public health and safety due the current limited movement of tritiu:n.

60. Chapter 2 Column 2, 2nd Full Para., p. 41 The report states that no sampling of trench water ht.s been carried out at the Richland and Beatty sites.

Isamstterofclarification,nosamplingoftrenchliquidshasbeen performed because these sites receive so little rainfall (less than 5 inches / year) that no water is available for sampling. Because there is so  !

little rainfall and the nearest aquifer is 300 ft from the surface, I nuclide migration will be extremely slow. The rate of water flow through i the unsaturated . tone between the disposal units and the aquifer has been estimated to be 0.5 - 1.5 m/ year (Ref. 41).

61. Chapter 2, Column 2, 3rd Full Para., p. 41 The report states that a serious disadvantage to both Beatty and Panford is transportation impacts.

The impacts from the transportation of all radioactive shipments, including waste shi statement (Ref. 42)pments,. For truck was andevaluated van shipments in a final environmental doses to the public impact conservativelyprojectedto1985wouldresultinlessthanonehealth effect per year an'd less than one latent cance'r per year. These are very

q. .

. i

~

l 50 , )

.,9 low impacts which would tend to be reduced further under the planned Compact arrangements.

62. Chapter 2, Column 2, 4th Full Para., p. 41 The report states that 140 billien gallons of liquid waste have been discharged into the ground at Hanford, Savannah River and Idaho.

The disposal of these liquid wastes occurred c,t DOE disposal facilitias (Ref. 43) and not at the Hanford connercial disposal site, which has always prohibited the disposal of liquids. The referenced DOE liquid waste operations bear no resemblance to connercial disposal site operations regulated by the NRC or its Ag nement States,

63. Chapter 2, Column 2, 5th Para. Through Succeeding Paras., pp. 41-42 The report describes hazardous waste disposal facilities and attempts to relate them to radioactive waste disposal facilities.

Problems at hazardous waste disposal sites appear serious, but do not relate to radioactive waste disposal. For example:

a. All radioactive waste sites have been (and must continue to be)  !

located on State or Federal land. No such requirement exist for hazardous waste disposal facilities. State or Federal land ownership ensures more control over and responsibility for long-term monitoring, surveillance, and remedial care.

b. The releases from radioactive waste facilities, unlike thote from some hazardous waste facilities, have' been at very low concentrations and have not threatened public health and safety,

c. Waste form and cperttions requirements at radicactive waste facilities have been more strict than at hazardous waste facilities, i

d. All radioactive material users including waste facilities are licensed. Not all hazardous waste facilities found by the EPA operated under State or Federal permits. l

e. Radioactive material decays while some hazardous substances are very persistent or are stable compounds and elements. j In sunnary, the level of control over radioactive material and waste disposal f acilities has been substantially. higher than that for hazardous wastes. Even during the time of past disposal practices prior to promulgation of the Part 61 regulation, releases were small and did not endanger public health and safety. Because of this control we believe that grouping low-level waste disposal with hazardous wsste disposal is unfair and misleading, f

• e 31 ,

64. Chapter 2, Column 2, 1st - 2nd Full Para., p. 42 The report states that we should probably stop tisinking of so-called secure landfills as "secure" places, that landfills do not prevent wastes from entering the environment.

4 It is true that the LLW regulation 10 CFR Part 61, does not contain a zero release criterion. However, it does establish maximum dose limits to a hypothetical (fenceline) individual to 25 aree/yr (whole body). (This dose rate, incidentally, is about a factor of four less than the increase in annual dose rate (from cosmic radiation) that one would receive merely by moving one's residence from sea level to Leadville, Colorado.) The .

regulation further invokes a reouirement that doses to the public should be maintained below the allowable limits to levels as low as reasonably achievt.ble.

65. Charcer 3, 1st Para., p. 45 The report states that a series of accidents occurred at LLW disposal sites.

l There were some cases of improper waste packaging, including a fire on a i truck shipping waste. However, it should be noted that at no time was the public hecith and safety threatened by any of these incidents.

66. Chapter 3, 2nd Para., p. 45 The report states that compacts are e new and decidedly undemocratic form of government.

We do not understand the basis for this statement. Congress first .

established the concept of regional compacts in the Low-Level Radioactive Waste Policy Act of 1980 (Ref. 44). This concept grew out of the .

traditionally significant role of the States in regulating disposal of low-level waste. In 1985, Congress reaffirmed the concept of State compacts and asproved seven of them. This process has been fully supported by t1e States.

67. Chapter 3, Table 3-1, p. 46 Under the coments related to the Class B and C stability requirements, ,

the report states that 10 CFR Part 61 no longer requires a 150 year time l period and other specific requirements as stated in the proposed rule. l i

The final regulation clearly states a si.ructural stability objective of l

• 300 years for all Class B and C wastes (10 CFR 561.7). Specific guidance fordemonstratingcompliancewiththestability)requirementsisprovided in the Technical Position on Waste Form (Raf. 6 . This guidance maintains a 50 psi compressive strength for solidified products and adds other

I 32 ,

1 specific guidance and test procedures not included in the proposed rule.

i All waste generators producing wastes required to meet the structural stability requirements are using the Technical Position as the basis for demonstrating compliance with the stability criteria in 10 CFR Part 61.

. Under the comments related to chelating agents, the report states that disposal of chelating agent wastes greater than 0.1 percent was prohibited

and that 2 ppb concentrations of chelating agents will allow (Co-60) to

migrate. The proposed rule (Ref. 45) states in a footnote to Table 1 that l

! "Wastes containing chelating agents in concentrations greater than 0.1%  !

are not permitted except as sacifically approved by the Cosmission." It ,

il was intended that exceptions >e granted were the disposal site conditions  ;

enabled the performance objectives of 10 CFR Part 61 to be met. The requirement in the final rule is essentially unchanged except that the  ;

license application review would include a generic determination regarding  ;

the disposal of wastes containing chelating agents rather than the i case-b App l B-110)y-case e (Ref. 46AsstatedinCossent19,thedisposalofchelatIngag.8,p.

determination in the proposed ru ent wastes  !

remains a concern to the NRC. Since disposal site environmental l conditions can significantly affect the movement and retention of .  !

co,plexed nuclides, the NRC will consider the appropriate disposal limits  !

on a site-by-site. basis. It should be noted that some cheiating agents  !

areretainedinsomesoils(Ref.22)andthatmigrationofcomplexed

)

q nuclides is likely to be significantly less than as implied by the report. l 4

1 The report states under the coseents related to financial assurance that f there is no specific requirement for a sinking fund or waste surcharge and  :

, provisions for third party liability. The NRC staff did not provide  !

prescriptive requirements 'oecause there are several financial mechanisms t which are potentially suitable to provide the necessary financial i assurance. In addition, at the time 10 CFR Part 61 was promulated, NRC had no legal authority to require a licensee to establish a fund for l long-term care after a license is terminated (Ref. 46, App. 8, p. B-143).

j Nonetheless, a sinking fund mechanism is currently being used at the three l 4

operating cosmercial disposal sites. Surcharges on wastes provide the l moneys for these sinking funds. These surcharges and sinking funds have (

l been established based on state ownership of the disposal site land. To j i NRC staff's knowledge, all compacts plan to include various fonns of  :

) financial assurance at future disposal facilities. Regarding third party i j liability, the nRC staff is currently avaluating the need for such ,

financial assurance in a study' by ICF, Incorporated.  :

1

! The report states under the comments on the Class C limits that no -

! calculations were performed to justify the increased factor of 10. The l

! waste classification limits are based on a detailed set of pathway )

! analyses (Refs. 46 and 47). Because the pathway analyses performed to  ;

support the proposed rule were overly conservative, NRC staff reevaluated j the analyses and recalculated the Class C limits. The recomputed limits j

} i 1 i

33 .

continue to ensure that the performance objectives in 10 CFR Part 61 would l bemet(Ref46,VolI,p.39).

68. Chapter 3. Column 1. 1st and 2nd Full Para.. p. 47 The report lists several items which reportedly changed from the proposed 10 CFR Part 61 rule to the final rule. It also erroneously states that 10 CFR Part 61 went into effect in 1985.

With the exception of the changes explained in Consent 67, all of the items in the proposed rule that the report regards as significant improvements remain in the final ru b.

The licensing requirements of 10 CFR Part 61 went into effect in January 1983 and the waste generator requirements wen; into effect in December 1983.

69. Chapter 3. Table 3-2. p. 47 ,

l Table 3-2 presents intruder / discoverer doses from a series of I miscellaneous waste streams. The presentation, however, uses the data out of its intended context.

Table 3-2 data were obtained from information p esented la Tables 4.7 94 4.12 of the 10 CFR Part 61 Oraft Environmental Impact Statmnt (DE!$.'

(Ref.47). In the 10 CFR Part 61 DEIS, NRC comparc-d intruder Mpacts associated with disposal, in a group, of a number of high acti,43 erb streams. The purpose of this comparison in the DEIS was to 'onmW that potential impacts due to direct contact with disposed p m m io be reduced by controlling disposal of a few particular waste strcam nuing very high. activity.

In Table 3-2, the report compares estimated impacts from two situations,-

one in which all the high activity "Group 4" waste streams were disposed together, and one in which two of the highest activity waste streams were removed. It illustrates that removal of these two streams, both of which were projected in the DEIS to contain radionuclides in concentrations exceeding Class C concentrations, significantly reduces potential impacts.

We agree; the DEIS used the analysis highlighted in Table 3-2 to help establish the 10 CFR Part 61 waste classification system. The 10 CFR Part 61 rule deems waste exceeding Class C concentrations to be unsuitable for near-surface disposal.

Beyond this, however, the report leaves out the important consideration that the "acta l impacts" after removal of the two greater-than-Class C (GTCC) waste streams should be much lower than those presented in Table 3-2. This is because the 10 CFR Part 61 regulation incorporates, in addition to Class C concentre. tion limits, requirements on waste form and disposal method. Class B and Class C wastes must be placed in a stable

.~

c. a. . c . .. . :. w .. = - . --~ _: - - - x -

34 ,

form. This will tend to make Class B and Class C wastes less dispersive.

In addition, Class C wastes must be disposed at greater depths, underneath other wastes throcch which the intruder would have to dig.

For Table 3-2, on the other hand, the assumstion is that all of the "Group 4" waste streams are disposed together by tiemselves, close to the surface and not mixed with any ots.r waste streams. This is unlikely to occur.

Besides improved waste forms and greater disposal death for class C wastes, there will be a mixing of waste classes whic1 will lwer the average concentrations. That is, Class B wastes will end up being disposed mixed with stable Class A wastes while Class C wastes will end up being mixed with stable Class A wastes as well as Class B wastes.

The report also makes some other erroneous statements. For example, the calculations indicated in Table 3-2 are not for the intruder-discoverer scenario, but are for the intruder-construction scenario, involving an assumed 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> of contact with the waste under dusty conditions. The pathway analyses, for the intruder-construction scenario, involved not only exposure to gacma radiation, but also inhalation of contaminated -

dust. The intruder-agriculture scenario involved ingestion pathways in addition to inhalation and direct exposure pathways.

It might be noted that the report mixes information from two sources. The wastes comprising "Group 4" waste streams were considered in tho~ draft and l final EIS on 10 CFR Part 61 (Refs. 46 and 47), and the wastes were l characterized based on the best information available. One of the waste streams considered was a hypothetical waste stream from routine full-scale decontamination of reactor primary coolant systems. This waste stream was projected to exceed Class C corcentrations, as were the sealed sources referenccd in the discussion. The DEIS discussed at length the uncertainties associated with this decontamination waste stream.

Later data, pres e~nted in the "Update" document (Ref. 15) which "Living Without Landfills" extensively uses, indicates that these earlier projections were very conservative, greatly exaggerating the quantity and radionuclide content of the waste. The report, however, does not reflect this updated information. The report, on page 49, also erroneously ,

confuses these hypothetical decontamination wastes with ion-exchange  !

resins projected tn be generated as part of deconnissioning a PWR, The two waste streams are different.

70. Chapter 3, Column 2,1st Full Para. , p. 48 The report discusses the performance objectives used in the intruder and groundwater pathway analyses and states that, if lower limits were used (for example,1 millires/yr) different waste classification concentrations would result.

, , .,. m. ,

35 ,

The rationale for selecting the dose limits for the 10 CFR Part 61 performance objectives is discussed in Reference 47, Vol 1, Chapter 5.

71. Chapter 3. Table 3-3, p. 48 Table 3-3 presents a PWR decommissioning waste classification.

The information in this table indicates that 98.8 percent of the activity within PWR decommissioning wastes will be in wastes that exceed Class C concentrations. By law, disposal of wastes 6xceeding Class C concentrations and is thesee Compacts. (Also responsibility)of Connent 35. the Federal government, not States

72. Chapter 3, Column 2, 1st Para., p. 49 In discussing the intruder scenarios the report states if a construction crew salvaged the metal in the wastes and sold it to be recycled, population and individual doses would be high.

The intruder scenarios constructed to support the 10 CFR Part 61 rule assume an inadvertent intruder who unknowingly enters the site following  !

the loss of institutional control. Intruders who intentionally enter the site to salvage materials known to be radioactive were not considered.

Considering the uncertainties in intrusion events, it is difficult to predict which events might occur or whether they will occur at all. The NRC staff objective was to use scenarios which were reasonable, and involved productive uses of the site (e.g., home construction, farming).

It was considered that the regulation should be oriented to protecting those individual who unknowingly enter the site, rather than those who puraosefully salvage material or undertake archaeological investigations wit 1out making the effort to determine what previous activitios occurred at the location (Ref. 46, App. B, p. B-38). It was considered unlikely I that salvage operations or archaeological studies would be performed I without some attempt to identify the previous site, activities. l

73. Chapter 3 Column 2, 1st and 2nd Paras., p. 49 The report discusses Class C and Greater-Than Class C wastes.

In these few paragraphs, the report twice confuses Class C wastes with wastes exceeding Class C concentrations. Disposal of Class C wastes is the responsibility of the States, while disposal of waste exceeding Class C concentrations is the responsibility of t1e Federal government.

At the tos of the page, the report refers to PWR core shrouds as Class C wastes, iowever, as indicated in Table 3-3, core shrouds are actually projected to exceed Class C concentrations. Thus, since these wastes are not the responsibility of the States and most likely will not be disposed by near-surface disposal, the argument regarding the 3 Rem /hr dose to an intruder is moot.

e 36 At the bottom of the page, a statement is made that Class C wastes constitute 99.5 percent of the activity within a decomissioned PWR. This is erroneous, as the data clearly projects that only about 0.7 percent of the activity from a decommissioned PWR will be contained within Class C wastes. About 98 percent of the activity, however, is projected to be contained in waste that exceeds Class C concentrations. (SeeComment74.)

74. Chapter 3. Table 3-4, p. 49 Again, by lumping Class C wastes with wastes exceeding Class C concentrations, the Table 3-4 provides a misleading impression of the distribution of radioactivity within light water reactor decomissioning wastes. NRC has conducted a number of studies pertaining to the activities, volumes, and radionuclide content of power reactor decomissioning wastes. Estimates for a large PWR and a large BWR are provided in Table 3 (Refs. 17, 18). '

As can be seen, 96-98 percent of the activity within reactor decomissioning wastes is projected to be contained within wastes that exceed Class C concentrations. Disposal of wastes exceeding Class C concentrations is the responsibility of the Federal government. NRC has recomended to DOE that DOE consider disposal of waste exceeding Class C concentrations in a HLW geologic repository.

It should also be noted that these activity projections are made in a conservative manner. The projections are made assuming that both reactors operate resultingfor in 40 a ayears at an burnup average of 30 effectivecapacity factoryears full power of 75EFPY).

p(ercent, Both reactors are large, 1000+ Mwe units (1175 MWe for the PWR and 1155 MWe for theBWR). In reality, many of the reactors initially projected to be decomissioned will consist of early, low )ower demonstration units.

Total Class,A,.B, and C waste activities s1ould be smaller for these smaller units.

It should also be noted that these activity projections are made assuming that the reactors are dismantled imediately following shutdown. Afa years of decay between shutdown and dismantlement will have a large effect on the activity within the waste. See Coment 18,

75. Chapter 3, Column 1, 1st-4th Para.. p. 50 The report states that the pathway scenarios used to support the 10 CFR Part 61 rulemaking are unrealistic. It also compares a record search to examining deeds from before the arrival of Columbus.

For the purposes of a low-1cvel waste disposal facility, the analogy of searching deeds to the time of Columbus'is inapplicable since time does not march backwards'. No' form of government exist'ed in North America at the time of Columbus and LLW was not being disposed at that time. Today,

. e .

-H 37 -

l 1

.,i however, there are numerous forms of records and many ways of preserving i these records. The fact that deed records exist from the 1700's, as is i acknowledged in the report, gives confidence to the assumption that public I records can survive of time periods of hundreds of years. We expect that the very existence of "Living Without Laiidfills" will help preserve a public record of LLW disposal.

4

76. Chapter 3: Columns 1 and 2. p. 50 The report presents several suggested scenarios involving improper use and control of radioactive materiais, intentional intrusion despite the presence of markers g

,and hazardous waste disposal facilities.

The Juarez and Morocco, scenarios involve improper control of radioactive materials in which several individuals receivec high doses. As a matter of clarification, neither of these events involved waste disposal activities.

In the Juarez incident, a sealed source was diverted from storage. It was not dug up from a LLW site. There is a substantial difference in one's ability to access stored and disposed material, especially for wastes such as sealed sources and activated metals, which will probably be disposed deeper than other wastes. The report states that two people received hand and foot exposures on the order of 10,000 rems. These dose values have never been substantiated. In any case, the report states that the Co-60 source was 0.4 Ci. It was actually a 400 Ci teletherapy source (Ref.' 48).

Co-60 has a 5.26 year half life, and the referenced 400 Ci source, after 100 years, would decay by 19 half-lives, or a factor of 528,000. The 400 j Ci source would be reduced to 0.8 mci.

For the Morocco incident the comparison is again questionable. There is a substantial difference between a situation in which a source is accidentally diverted from a licensed operation and a scenario in which radioactive material is hypothetically excavated from the ground after many years of decay. In any case, Ir-192 has a 74.2 day half life.

One-hundred years after disposal, the Ir-192 source would decay over 492 half-lives.

The stolen tool scenario involved intentional removal of materials by site workers prior to the disposal of wastes. This removal was not related to the placement of markers on closed trenches as is suggested in the report.

The Pharoah's Tomb scenario involved intentional intrusion by individuals who had knowledge of the site and what was located on it, namely jewelry and other extremely valuable materials which were easy to identify and to remove. These materials were furthermore of inmediate value -- i.e., they did not have to be processed through complex operations to recover their worth.

j j

c . _

1

. 1 38 ,

In contrast, we believe that the possibility of "mining" low level waste sites for valuable metals is unlikely. Persons recycling metals and other materials recover materials easy to obtain, not materials that have been buried under several meters of earth. We expect that excavation costs would greatly exceed payback from recycle values because of the small quantity of stainless steel and other highly corrosion resistant alloys and the difficulty of removing them from tons of other wastes.

We might further note that throughout the. report, it is emphasized that only small quantities of activated metals will be d'sposed in low-level waste sites. It appears to be contradictory that large quantities are now referenced in the discussion in this section of the report.

See also Consnent 72 which discusses the reasons why only the inadvertent intruder scenarios were used.

It is the intent of 10 CFR Part 61 to avoid the problems which occurred at the Love Canal hazardous waste facility. The regulation, 10 CFR Part 61, requires site control and a buffer zone to restrict activities on the site. While 100 years was assumed in the analysis, NRC staff expects that if institutional control remains, use restrictions would remain after the 100 year period. Since the land is required to be owned by the State or Federal Government, it is unlikely that complete control of the disposal site would be lost. ,

77. Chapter 3, Column 2, Last Para., p. 50 The report suggests that "long-lived" wastes be removed from the low-level waste stream and handled separately. -

The Part 61 rule, by its waste classification system which establishes limits for radionuclides of concern, including the principal long-lived radionuclides of concern, accomplishes this suggestion.

78. Chapter 3, Column 1, 2nd and 3rd Paras., p. 51 l

The report discusses changes made in the waste classification system from the proposed to the final rule, 10 CFR Part 61.

See Coment 67.

79. Chapter 3 Column 1, 4th Para., p. 51 The report states that changes made to the proposed rule allowed some wastes to drop from Class C to B.

Since the Class B limits were not significantly changed, we believe that as a practical matter, reclassificat'on of wastes from Class C to B has not occurred.

I

3 l

39 -

80. Chapter 3, Column 1, 5th' Para., p. 51 The report states that no NRC calculations were performed to support the increase of the Class C limits from the proposed to the final 10 CFR Part 61 Rule. The report also states, erroneously, that the change in the Class C limit allowed certain decontamination resins, previously exceeding Class C concentrations, to be disposed as Class C waste.

The NRC staff did perform calculations to support these changes. These calculations are discussed in Reference 46, the Final Part 61 Environmental Impact Statement. As part of these calculations, NRC compared the difference in impacts tiat would occur comparing the Class C limits proposed in the proposed rule with the Class C limits established in the final rule. Even if no credit was given for the increased depth of disposal for Class C waste, the difference in impacts between the proposed and final rule was negligible. This is because the change between the proposed and final rule affected very little waste.

Regarding the decontamination resins mentioned in the fourth paragraph', l the change between the proposed and final ruit did not alter the In the analyses in classification the 10 CFR Partstatus 61 DEIS of and these FEIS hyp(othetical wastes.Refs. 46, 47), these wastes were classified as exceeding Class C concentrations. (Later information, summarized in Reference 15, indicates that the radionuclide content of decontamination resins was significantly overestimated in the DEIS and FEIS.) ,

Also see Coment 67.

81. Chapter 3. Column 1, 6th Para., p. 51 i The report discusses the disposal of chelating agents.

See Coment 67.

82. Chapter 3. Column 1, 7th Para., p. 51 The report disagrees with the financial assurance provisions in the rule

and states that it is entirely up to the private insurer whether insurance is provided at all.

The regulation, 10 CFR Part 61, requires the applicant to provide financial assurance but does not specifically require particular mechanisms to accomplish this. The particular mechanism to be used would

be addressed during the licensing process. If the applicant can not ,

i obtain insurance, then he would still have to provide financial assurance l through an alternative mechanism such as a sinking fund. Also see Connent l

67. i 1 i l

I

40 .

83. Chapter 3, Column 2, 1st Full Para., p. 51 The report states that no specific criteria for waste form has been procided nor does the regulation specify a length of time for stability.

Specific numerical guidance for waste from stability is provided in the NRCTechnicalPositiononWasteForm(Ref.6). All waste generators producing wastes required to meet the structural stability requirements are using the Technical Position as the basis for demonstrating compliance with the stability criteria in 10 CFR Part 61. This guidance is substantially more extensive than was provided in the )roposed rule. A 300 year waste form stability objective is stated in tie final rule in 10 CFel 161.7. See also Cossent 67.

84. Chapter 3 Column 2, 2nd Full Para., p. 51 The report states that high concentrations of long-lived nuclides will ,

pose a hazard in LLW disposal facilities for over 100,000 years.

We believe that the 10 CFR Part 61 waste classification system limits the concentrations of long-lived, radionuclides of concern to safe levels.

85. Chapter 3 Column 2, 5th Full Para., p. 51 The report states that 0.05 uCi/gm of H-3 and C-14 can be disposed down the drain.

The requirements for disposal of H-3 and C-14 in sanitary suer systems are given in 10 CFR 520.303. It appears that the report is confusing these requirements with 10 CFR $20.306. It should be noted that these requirements are substantially different and the 0.05 uCi/gm concentrations applies only to H-3 and C-14 in animal carcasses and scintillation fluids. Scintillation fluids containing toluene and xylene, both hazardous chemicals, may not be disposed down sanitary sewer systems in any case.

86. Chapter 3, Column 2, 6th Full Para., p. 51 The report states that NRC has defined away institutionally generated waste problems by establishing a below regulatory concern (BRC) level for scintillation fluids and animal carcasses in 10 CFR $20.306.

The regulation, 10 CFR 920.306, was promulgated because the radiologic impact of disposing of the stated levels of H-3 and C-14 were determined tobeinconsequential(Ref.49). The regulation, however, does not relieve the licenses from regulations governing the toxic and hazardous properties of the materials. (,onsequently, disposal by the sanitary sewer system or municipal landfills must meet applicable local and EPA regulations. See also Comment 25.

41 .

87. Chapter 3, Column 2, Last Para., p. 51 The report criticizes the NRC for allowing NRC licensees to dispose of wastes by land-farming, ash pond disposal, and municipal landfills.

NRCregulations(10CFR520.302) allow licensees to request approval for disposal of certain wastes. Approvals which have been granted involve very low quantities of radioactivity and are only granted following conservative evaluations which show potential dose impacts of less then a few millirem (Ref. 50). No specific approvals for disposal in a municipal landfill have been granted. Disposal of wastes under 10 CFR 520.302 is not considered to be below regulatory concern since specific license conditions are placed on the licensee if he utilizes this disposal option.

88. Chapter 3, Column 2, 2nd - 3rd Full Paras., p. 52 The report states that the Low-Level Radioactive Waste Policy Act (Ref. 44) turns the problem of LLW to the States.

Contrary to the statement, States have traditionally played a strong role in regulating siting and operation of low-level waste facilities. The Low-Level Radioactive Waste Policy Act reaffirmed this traditional role of the States and, in fact, was strongly supported by the States. See also Connent 66.

89. Chapter 3, Column 1, 1st Para., p. 52 Earlier, an impression was given that BRC wastes present a major source of environmental contamination. Here, the report states that only a few millicuries are generally involved. This apparent contradiction should be clarified. The report also states that 20 BRC requests have been granted.

In fact, no BRC requests have been granted at this time other than that which resulted in 10 CFR 520.306. The report is apparently confusing BRC disposal with onsite disposal of low activity material licensed under 10 CFR 520.302. (Also see Coment 87.)

90. Chapter 3, Column 1, 3rd - 5th Full Para., p. 8i2 The report states that NRC may modify its regulations to allow some HLW to be defined as LLW and may allow future rule revisions to slip more HLW into the LLW category.

The NRC staft is developing a proposed rule on the definition of HLW.

However, such a definition would not affect those wastes suitable for near-surface disposal as these wastes are currently defined in 10 CFR Part

61. The disposal of Greater-Than-Class C (GTCC) comercial wastes is the responsibility of the Federal government. This category of waste is defined in the Low-Level Radioactive Waste Policy Amendments Act of 1985

. (LLWPAA) (Ref. 2) using the current 10 CFR Part 61 Class C limits. Future i.

-, , - . - - - - .- -- .---r , _ , , - - - - - - - - - - - - - - - - - -

-- -- --e - - - -- - ,--

42 regulatory actions, if they would occur, would not alter this definition without legislative action since an NRC rulemaking cannot alter the provisions of Congressional law. Becauseghevolumeofcommerically generated GTCC wastes are so small (2020 m through the year 2020 - Ref.

51), NRC staff has recosmiended to DOE that GTCC wastes be disposed in the HLW repository (Ref. 3).

91. Chapter 3 Column 1, 4th Full Para., p. 52 .

1 This paragraph contains several errors. l First, the document referenced in the report is an advance notice of proposed rulemakin and not a proposed rule. Its purpose is to obtain input from the pub ic on the issues to be addressed in the rulemaking.

The purpose of the rulemaking is not to eliminate a "sharp break" between low- and high-level waste, but to create a sharp break. This is principally because of the existence of wastes from reprocessing fuel for defense purposes, which range over a very wide range in concentrations.

This rulemaking will not create additional wastes to be disposed at cosnercial low-level waste disposal sites. This is because the LLWPM sets responsibility for disposal of connercial wastes exceeding Class C concentrations to the Federal government. '

I

92. Chapter 3, Column 2, 2nd Full Para., p. 53 The report tries to imply that the LLWPM transferred general responsibility for LLW disposal from the Federal government to the States.

1 In reality, LLW disposal has been an activity traditionally licensed by the States. This was the case prior to the Low-Level Radioactive Waste Policy Act (Ref. 44), the forerunner of the LLWPM.

The discussion also omits the important provision of the LLWPM which establishes the requirement that cosmercially generated LLW in concentrations exceeding Class C limits is the responsibility of the

> Federal government. States forming Ceepacts are not obliged to accept such waste for disposal. The planned HRC rulemaking on the definition of HLW can have no affect on this provision of the LLWPM.

93. Chapter 4, Column 1, 1st Full Para., p. 60 The report states that medical and research wastes account for a minute portion of the radioactive wastes.

Note that most of the materials used in medical and research applications ,

come from Cintiches and New England Nuclear. These two companies generate I a significant portion of the waste activity. See Connent 1.

I

43

91. Chapter 4 Column 1, 4th Full Para. , p. 61 The report states that BRC levels have been approved by the NRC and that NRC has encouraged a streamlined license approval process.

The approvals referenced in the report were issued under 10 CFR 520.302, not as BRC approvals. See Comment 87.

The NRC staff has published guidance on the submission of BRC applications, as well as guidance on the review process for these applications. This was performed in an manner consistent with the intent of Congress as directed by the LLWPAA (Ref. 1).

95. Chapter 4, Column 2, 2nd - 5th Paras., p. 61 The report states that the dual chamber controlled air incinerator does not work well for radioactive wastes, releases iodine and tritium, and produces hydrochloric acid (HC1) and dioxin.

In fact, the dual chamber controlled air incinerator has been shown to be very effective in incinerating radioactive wastes without significant releases of radioactive or hazardous chemicals. Incinerator tests on this tyse of incinerator have been demonstrated at the Los Alamos National La) oratory (Ref. 52 and 53) and by Aeroject Energy Conversion Company (Ref.27).

The incinerator systems proposed for radwaste applications include charcoal adsorber sections in the offgas system. Charcoal adsorbers are .

extremely effective for iodine removal. While tritium would be released 1 in an incinerator, the quantities of tritium in wastes to be incinerated I will be administrative 1y limited to very small levels and would not result j

. in releases exceeding the limits for unrestricted release in 10 CFR Part 20, App. B. The release of radionuclides is an important area for NRC staff review in processing an incinerator license application.

The offgas systems for the proposed incinerators include a caustic scrubbing solution to neutralize any hcl generated in the incinerator.

These scrubbing systems have been shown to be very effective in neutralizing hcl and in protecting offgas system components from corrosion (Ref. 27).

The dual chamber controlled air incinerator is very effective for destroying dioxins. See Connent 24 1

96. Chapter 4, Column 1, 2nd Full Para., p. 62 The report states that numerous accidents have occurred with incinerator I systems and references incinerator problems at the Nuclear Fuel Services i l

. .w .

O _

44 .

facility in Envin, TN and at the General Electric Company facility in Wilmington, NC.

Fires did occur in the offgas treatment sections of incinerators operated by Nuclear Fuel Services and by the General Electric Company. Both were the result of the carry-over of incompletely combusted waste and/or deficiency of water in the offgas treatment sections. Neither resulted in the release of radioactivity to the environment or exposure of work'ers.

The explosion at General Electric occurred in the shredder section of the incinerator. It was the result of ignition of dust from feed accompanied by an air blockage. There was no radiation exposure to workers or a significant release to the environment. This explosion did not destroy

,the incinerator as is stated in the report.

97. Chapter 4. Figure 4-1, p. 62 The figure shows an incorrect schematic of a controlled air incinerator.

The figure incorrectly shows neutralization of the hot gases downstream of the venturi scrubber. Addition of the caustic solution takes place in a quench vessel downstream of the secondary incinerator chamber. This results in neutralization of any hcl as well as significant cooling.

After quenching the stream passes to the venturi scrubber (Ref. 27 and 53). ,

For this type of incinerator and offgas system, very littie dioxin or I-125 would be released. Note also that I-125 is not significant for wastes from nuclear power plants. The primary source of radioiodine in these wastes is I-131 (half-life: 8 days).

i

98. Chapter 4. Column 1. 1st Full Para. p. 63 l l

The report suggests separating wastes by nuclide half-life'and designing facilities for storage based on these half-lives.

For many waste generators it is practical to segregate wastes by nuclide.

This practice is currently used by many medical, academic and bioresearch licensees for short-lived nuclides. This can be accomplished because the activities in much of the waste from these facilities does not involve mixtures of nuclides. However, many waste generators, such as (but not limited to) nuclear power plants and radioisotope distributors like Cintiches, waste streams contain mixtu es of many nuclides. How nuclide

, separations of these wastes would be practically performed is not identified in the report.

. '. l 1

45 l

l

99. Chapter 4 Column 2, 2nd Full Para.. p. 63 The report states that Class C wastes should be treated as HLW due to the high concentrations of long-lived nuclides.

Contrary to the statement on this page, Class C waste is dominated by very short-lived radionuclides. Long-lived radionuclides are characteristically present only in small quantities. For example, see Cossent 18.

100. Chapter 4. Column 2, 1st Full Para., p. 63 The report states that the air and water release limits in 10 CFR Part 20 are better rules of thust than the 10 CFR Part 61 waste classification system.

We disagree. See Cossent 13.

101. Chapter 4. Column 2. 4th Full Para., p. 64 The report states that H-3 and C-14 in concentrations less than 0.05 uCi/gm are now being disposed down the drain and in municipal .

landfills.

See Corment 85, 102. Chapter 4. Column 2, 1st Full Para., p. 66 The report states that geological siting conditions are not as critical for above ground LLW systems as for below ground systems.

Concrete structures generally fail because of exposure to aggressive environmental elements such as freeze-thaw cycling and acid rain. To design a structure with a high degree of confidence for a service life of hundreds of years, it should be placed below grade so the temperature cycling is minimized and the effects of acid rain are buffered by the soil. If built below the frost line, the structure will be maintained at a constant temperature of about 55F. For concrete structures the geologic siting conditions are more predictable than are the above ground  ;

j environmental conditions. Therefore, the above ground conditions are more critical to the design of concrete structures. It is for this reason the NRC staff has recossended that engineered concrete disposal concepts be placed below grade (Ref. 54).

It should also be noted that above ground structures would likely present an increased risk to an inadvertent intruder because of its easy accessibility and the higher potential for its future usefulness. In

addition, the NRC staff has substantial experience with earth-covered i structures in the uranium mill tailing remedial program.

1

46 ' -

103. Chapter 4. Column 1, 1st Para., p. 67 The re> ort states that the Westinghouse Surepak system placed below grade would se less safe than above ground because water can pass through concrete.

We believe a below grade structure would be preferable to an above ground structure because it improves confidence on long-term performance. It .

would not be directly subject to above ground environmental conditions.

For example, a below grade structure would be subject only to water which percolates to it. Because of facility grading, evapotranspiration and the well drained soils required under 10 CFR Part 61, less water would contact it. An above ground structure would be directly in contact with the rainfall as well as freeze-thaw conditions which have caused concrete structures to fail in the past.

104. Chapter 4. Column 2,1st-3rdFullParas.,p.62 The report states that NRC has not evaluated the potential for hydrogen gas explosions in wastes.

In fact, the NRC staff has evaluated the potential for hydrogen gas -

explosions and has concluded that by limiting the loadings on8 rganic ion-exchange media so that accumulated doses are less than 10 Rads, the hydrogen generation in wastes will not be significant enough to cause

. explosions in LLW disposal units (Ref. 6). The NRC staff has also investigated methane gas generation in wastes due to chemical decompositionoforganicmaterials(Ref.55). Because methane would be generated only under anerobic conditions, sufficient oxygen would not be present to cause explosions.

105. Chapter 4. Column 2, 4th - 5th Full Paras., p.67 ,

The report discusses the Juarez incident and intruder impacts.

See Cossents 72 and 76. Also note that the Juarez, Mexico incident was detected in a shipment of rebar rather than tables. The-problem was identified as the truck was leaving the Los Alamos facility after making a wrong turn onto the site.

106. Chapter 4, Columns 1 and 2, p. 68 The report states that based on the experience at West Valley, Maxey Flats and Sheffield, above ground storage should be used.

We disagree that long-tenn, above ground storage is necessary to protect public health and safety. NRC staff recognized the problems with disposal operations and existing characteristics at the above facilities and considered these experiences when developing 10 CFR Part 61. It should

i .

1 l

47 -

also be noted that the releases from these facilities has been very low  ;

and in no case has public health and safety been threatened.

107. Chapter 4. Column 1, 1st Para. p. 69 The re. port states that NRC should publish a report on "Landfills:

Potential Problem Areas."

A susmary of the experience at LLW dis >osal facilities was published as an NRC contractor report, "Data Base for tadioactive Waste Management,"

NURE6/CR-1759, Vol. 1 (Ref. 38).

108. Chapter 4. Columns land 2. p. 69 The report describes the results of NRC studies on the behavior of waste forms and containers in storage and indicates these same problems exist in the disposal site.

ThereferencedNRCcontractorreport(Ref.56)describespotential problems which can occur to waste forms and containers during both storage and disposal. It should be recognized that the referenced NRC study was performed by Brookhaven National Laboratory and described potential ,

effects which might occur. The effects would be most prevalent in the small percentage of wastes with the highest activities.

Regarding the effects on polyethylene HIC's, NRC staff is considering these effects in its reviews of HIC topical resorts (See Connent 12).

These effects, including embrittlement, would )e more significant in storage than in disposa because of the additional hand 1'ng and potential of dropping HIC's in the removal of the wastes for ultimate disposal at a future time. .

109. Chapter 4. Column 2, 1st Full Para.. p. 70 The report discusses the French earth-sounded bunker disposal facility using references to the 10 CFR Part 61 waste classification system used in the United States. The reader is left with the impression that the French have adopted the same classification system.

As a matter of clarification, the French have developed their own classification system t,ased on the different characteristics of their wastes and on the chsracteristics of their disposal site and disposal method. Also, waste disposed in the tumulus layer must be in a solid, stable, form to minimize subsidence and long-term maintenance.

48 -

110. Chapter 4. Column 1, 1st Full Para., p. 71 The report states that drums placed in the tumulus of La Centre de la Manche disposal facility in France will degrade causing collapse of the clay cap.

All wastes placed at La Manche are either solidified or eLcapsulated with cement. This results in a substantially more stable environment than is implied by the report. NRC staff is unaware of any rise in the groundwater due to the disposal facility at La Manche.

111. Chapter 4. Column 1, 5th Full Para., p. 71 In the discussion of the Ontario Hydro tile holes, the report states that a "drainage system is used to capture leachate." This overstates the case. While it is true that the Ontario Hydro storage area incorporates both an above and below ground drcin the runoff is not nomally captured.

Rather, the runoff from both the surface and subsurface drains is directed to sampling stations for monitoring and possible collection and processing if necessary. The drainage then flows to a gravel lined trench for holdup (and some ion exchange) prior to release to a drainage ditch and ,

ultimately to Lake Huron (Ref. 57). l 112. Chapter 4, Column 1, 5th Full para., p. 72 In this sentence, the report acknowledges that power reactors following shutdown,willbemaintainedforanumberofyearspriortodIsmantlement.

The report also states that dismantlement will probably not occur until af ter the year 2030, a date that exceeds the time covered by the report waste projections by 10 years. (Also see page 79 of the report.) This apparent contradiction should be explained.

113. Chapter 5, 4th Para., p. 77 The report states the,t the calculations and conclusions are based on NRC data.

In fact, the report is based on manipulation of information contained in an NRC contractor report. As we discuss in our previous coments, we disagree with the manner in which this information is manipulated and presented in the report, and with the conclusions drawn.

Specifically, nuclear power reactors do not generate 99 percent of the activity within low-level waste disposed in existing LLW sites. Even far into the future, when waste from dismantling decnnsnissioned nuclear power reactors is considered, we do not expect that nuclear power reactors will generatu 99 percent of the disposed activity. This is principally because 96-98 percent of the activity within wastes from dismantling nuclear power reactors is projected to be in wastes exceeding Class C concentrations.

49 .

Wastes exceeding Class C concentrations will not be disposed in LLW disposal sites but will most likely be disposed in a HLW geologic repository.

Furthermore, nuclear power reactors' do not (and likely will not, even considering decommissioning) produce greater than 99 percent of the long-lived activity within low-level wastes. Waste generated by nuclear power plants is dominated by short to intermediate radionuclides such as Fe-55 (2.6 year half-life), Co-60 (5.26 year half-life), or Cs-137 (30 yearhalf-life). Long lived radionuclides, such as some of the transuranic radiciotopes, are characteristically contained within reactor wastes in only trace quantities. '

113. Chapter 5, Column 1, 1st Full Para., p. 78 The report states that by retaining wastes at 72 nuclear power plant sites, no new disposal sites would be needed.

The effect of this recommendation would be to create 72 new waste disposal facilities located at sites which may not meet the 10 CFR Part 61 site suitability requirements. For exsmple, the requirement, 10 CFR 561.50(a)(5), specifies that a site not be located in a floodplain. Many nuclear power plant sites may have difficulty complying witn this requirement. It should be noted that siting a disposal facility requires the consideration of very different factors than does a nuclear power plant. For example, a disposal facility must provide isolation of wastes for hundreds of years. A power plant must be sited to provide a source of cooling water and have characteristics such that site conditions would not adversely affect the operation of the plant.

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Table 1. Distribution of Waste Volume and Activity by Class '

i 4

l Volume (fts) Activity (C1)  !

1986 Class A 1,740,383(96.4%) 22,500(9.65),

Class B 50,484(2.8%) 84,019(35.9%) ,

Class C 14,131(0.8%) 127,221(54.4%)

Total 1,804.998 233,740 1987 Class A 1,794,207(97.4%) 16,343(6.3%) i Class B 39,428(2.1%) 66,794(25.7%)

l Class C 8,642(0.5%) 176,391(68.0%)

Total 1,842,277 259,528

3 .

51 .

Table 2. Decay of Activity Within Example Activated Metal Shipment 4 Time After Reouction Disposal (yrs) Activity (C1) Factor 0 6,300 -

5 1,900 3.3 10 810 8.8 30 170 37 50 100 51 100 87 73 t

300 23 280 500 6.9 920 1000 1.7 3.700 Table.3 Sumary Distribution of Volume and Activity Within Reactor Deccanissioning Wastes

.l PWR* BWR*

Class A 17,521(98) 18,476(97.5)

-Vol.(m3)((%)

- Act. (C1) %) 36,600(0.7) 13,900 (0.2) l Class B 214(1.2) 373(2.0)

I --Vol.(m3)((%)

Act. (C1) %) 53,100 (1.1) 42,800 (0.6)

Class c

-Vol.(m)(%)s 17(0.1) 53(0.3)

, - Act. (C1) (5) 34,300 (0.7) 239,000 (3.6)

+

Exceeds' Class C I

-Vol.(m3)(%) 133(0.7) 47(0.3) 1 - Act. (C1) (%) 4,784,500 (97.5) 6,301,700 (95.5) 1 Total i

-Vol.(m3) 17,885 18,949 I

. Act. (C1) 4,908.400 6.597,400 I *The reference PWP is a 1175 We (3500 Nt) reactor I

The reference BWR is a 1155 MWe built by W)estinghouse.

(3320MWt reactor built by General Electric.

e O a

52 , ,

a Table 4 Cecay of Class C Wastes from Reuctor Decossissioning Reference 1175 MWe PWR Reference 1155 We BWR Time (yrs) Activity (Ci) Red Fact 0F Activity (C1) Red a Fact 0F 0 34,300 -

239.000 -

i 5 18,200 1.9 123,000 1.9 10 9,870 3.5 64,900 3.7 .

30 1,800 19 9,670 25 50 1,120 31 5,460 44 100 770 45 3,720 64 300 200 170 975 250 500 57.0 600 290 820 1,000 10.9 3.100 _ 68.1 3.500 a

Table 5. Oecay of Wastes Exceeding Class C Concentrations from Reactor Deconnissioning l

1

Activity in Weste Exceedino Class C Concentrations Over Time

Reference !!75 MWe PWR Reference 1155 We BWR

] Time (yrs) Act v' ty (C1) Red Factor {cgivity(C1) Red. Factor I O 4,780,000 - 6,300,000 -

5 2,530,000 1.9 3,230,000 2.0 i 10 1,380,000 3,5 1,710,000 3.7

30 254,000 19 258,000 24 169,000 50 30 147,000 43 100 109,000 44 100,000 63 300 28,300 170 26,200 240 500 8,090 590 7,770 810 1,000 1.550 3.100 1,730 3,500

, , t I

53 l

Deferences

1. Barnwell, Hanford, and Beatty Disposal Site Records,1985 and 1986.

2. Low-Level Radioactive Waste Policy Amendments Act of 1985, Public Law ,99-240, January 15, 1986.

3. Letter frcm H.L. Thompson, Jr., U.S. Nuclear Regulatory Comission, to  ;

A.D. Rossin, U.S. Department of Energy. April 30, 1987.  ;

4 "" 1d c e

Nuclear Power Plants," Nuclear News, Vol. 30, No. 10, f Aq w i 5., Lederer, C.M., et al., Tab _le of Isotopes, 6th edition, John Wiley & Sons,  ;

New York, NY, 1967.  !

i

6. Letter to all Comission Licensees from L. Higginbotham, Final Waste

. Classification and Waste Form Technical Position Papers, May 11, 1983.  !

7. D. MacKenzie, et al., "Pemissible Radionuclide loading for Organic Ion l Exchange Resins from Nuclear Power Plants," NUREG/CR-2830, September 1983. l

8. K. J. Swyler, et al., "Irradiation Effects on the Storage and Disposal of  !

Radwaste Containing Organic lon-Exchange Media," NUREG/CR-3383, October l 1983, f

9. K. J. Swyler, et al., "Assessment of Irradiation Effects in Radwaste  :

Containing Organic Ion-Exchange Media." NUREG/CR-3812, May 1984. i

10. Dougherty, et al., "An Evaluation of the Effects of Gasma Irradiation on '

the Mechanical Properties of High Density Polyethylene," NUREG/CR-3890, 1984. First initial?  ;

11. P. Soo, et al., "The Effects of Environment and Gama Irradiation on the Mechanical Properties of High Density Polyethylene," NUREG/CR-5607, March '

1986.

12. International Comittee or. Radiation Protection Report No. 23 "The  !

Reference Man," Pergamon Press, lo75.  !

t

13. F. Cat.Ile, "Calculation of Releases of Radioactive Materials in Gaseous >

Liquid Effluents from Boiling Water Reactors," NUREG-0016. January 1978.  ;

14 Chandradekaran,T., et al., "Calculation of Releases of Radioactive  !

Naterials in Gaseous and Liquid Effluents from Pressurized Water  :

Reactors," NUREG-0017, Rev.1. April 1985.

l l

I m, . . - - - - - - _ - - - - - - - - - - - - - - - - , . - - - - - - - - . . - -

~ -

• - b r

. .s 54 .

j 15. Ortunali, 0., Roles, G.W., "Update of Part 61 Impacts Analysis

Methodology," NUREG/CR-4370 January 1986.

16. Lundgren, R.A., "Reactor Vessel Sectioning Demonstration,"

j Battelle-Pecific Northwest Laboratory, PNL-3687, Rev.1. September 1981.

q j 17. Murphy, E.S., "Technology, Safety and Costs of Decessissioning a Reference a

Pressurized Water Reactor Power Station," NUREG/CR-0130, Addendum 3, September 1984 l

l 18. Murphy, E.S., "Technology, Safety and Costs of Decosmissioning a Reference j -

Boiling Water Reactor Power Station," NUREG/CR-0672, Addendum 2. September 1984.

l 1 19. Smith, R.I., "Technology, Safety and Costs of Deconmissioning a Reference

! Pressurized Water Reactor Power Station," NUREG/CR-0130. June 1978.

I 20. E. Promuzic, et al., "Scoping Study of the Alternatives for Managing Wa:te

Containing Cheleting Decontamination Chemicals," NUREG/CR-2721, February l 1984

)

j 21. R. Barletta, et al., "Physical Tests on Solidified Decontamination Wastes j from Dresden Unit 1. NUREG/CR-3165, December 1983.

j 22. J. Swenson, "Organic Complexant-Enhanced Mobility of Toxic Elements in 1 Low-level Wastes," NURES/CR 3985, November 1984; NUREG/CR-4435, December j 1985; NUREG/CR-5660, July 1989.

l 23. R. Dayal, et al., "Geochemical Studies of Comercial Low-t.evel Radioactive j Waste Disposal Sites " NUREG/CR-4664, June 1983.

I 24 State of South Carolina Materials License 097.

25. State of Washington Materials License WM-1019-2.

26. State of Nevada Materials License 13-11-0043-02.

l

27. ' Aeroji . Energy Conversion Company Topical Report, "Mobile Volume Reduction

)

j System," No. AECC-4-NP-A, Revision 1, January 15, 1986.

2 l 28. Atomic Safety and Licensing Board Panel Report LBP. 46-40, Docket No.

} 70-364 MLA In the Matter of Babcock and Wilcox Parks Township, PA Volume Reduction Facility, December 23, 1986.

l 29. NRC Inspection Procedure 2800/g, "Reconcentration of Radionuclides in l

Sanitary Sewerage Systems," March 1987.

30. Aften Associates, Meeting Report: Quarterly Meeting, low-levei l Radioactive Waste Forum, Grand Island, New York October 5-7, 1987.

I

s .a u i n.. a ... a .. . n .~.. ~. ..- ~. - . . :-" . - - - - --

c j

,3 :,; )

55 .

01. Letter from Robert H. Bauer. Office of Civilian Radioactive Waste Management, U. S. Department of Energy, to James B. Hall, Director, Utility Nuclear Waste Management Group, September 13, 1985.

32. Kentucky Department for Human Resources, "Project Report: Six Month Study of Radiation Concentrations and Transport Mechanisms at the Maxey flats Area of Fleming County, Kentucky," December 1974

33. "Report of the Nuclear Regulatory Comission Review Group Regarding Maxey F16 ts Kentucky Concercial Waste Burial Ground, July 7,1975," Enclosure in a Ietter from K.R. Chapman, Director, Office of Nuclear Materials Safety and Safeguards to Honorable J.M. Carroll, Governor of Kentucky, '

dated July 14, 1975.

34 "NRC Task Force Report on Review of the Federal / State Program for Regulation of Comercial Low-level hadioactive Waste Burial Grounds,"

NUREG-0217, March 1977.

35. Montgomery, D.M., et al., "Radiological Measurements at the Maxey Flats Radioactive Waste "urial Site - 1974 to 1975." EPA-520/5-76/020, January 1977.

36. Blanchard R.L., et al., "Supplementary Radiological Measurements at the Maxey Flats Radioactive Waste Burial Site - 1976 to 1977,"

EPA-520/5-78/001, 1978.

37. Kentucky Department for Human Resources, "Radiation Concentrations at the Maxey Flats Area of Fleming County, Kentucky, January 1,1975 to December 31, 1975," June 1976.

38. Clancy, J.J., et al., "Data Base for Radioactive Waste Management,"

NUREG/CR-1759, Vol. 1. November 1981.

39. Letter from H.G. Shealy to D.A. Nussbaumer on Resnikoff report coments.

November 30, 1987.

40. Cahill, J.M., "Hydrology of the low-level Radioactive-Solid-Waste Burial l Site and Vicinity Near Barnwell, South Carolina," U.S. Geological Survey, 1 Open-File Report 82-863, 1982. j

41. Brown, D.J., "Migration Characteristics of Radionuclides Through Sediments Underlying the Hanford Reservation," IAEA-ENEA Symposium on the Disposal of Radioactive Wastes into the Ground, May 26 - June 2,1967, Vienna, Austria, ISO-SA-32.

42, "Final Environmental Statement on the Transportation of Radioactive Material by Air and Other Modes," NUREG-0170, December 1977.

. . e

. m -

O 56 ,

43. "Improvements Needed in the Land Disposal of Radioactive Wastes--A Problem of Centuries," U.S. Government Accounting Office, RED-76-54, January 12, 1976.

44. Low-Level Radioactive kaste Policy Act Public Law 96-573, December 22,  !

1980.

45. NRC Proposed Rule,10 CFR Part 61, "Licensing Requirements for Land Disposal of Radioactive Waste," Federal Register, Vol. 46, No. 142, July 24, 1981. ,

l

46. Final Environmental Impact Statement on 10 CFR Part 61, ."Licensing ',

Requirements for Land Disposal of Radioactive Waste," NUREG-0945, November 1982. .

47. Draft Environmental Imped Mment on 10 CFR Part 61, "Licensing l Requirements for Land 01sposo of Radioactive Waste " NUREG-0782, l September 1981.

i

48. "Contaminated Mexican Steel Incident," NUREG-1103, January 1985.

]

! 49. Roche L., "Study of Alternative Nethods for the Management of Liquid l Scintillation Counting Wastes," NUREG-0656, February 1980.  :

I 50. "On-Site Disposal of Radioactive Waste," NUREG-1101, Volume 1 issued March 1986, Volume 3 issued December 1986.

51, I

1 "Reconuendations for Management of Greater-Than-Class-C Low-level  !

Radioactive Waste," DOE /hc-077, February 1987. .,

52. Vavruska, J.S., "Hazardous and Radioactive Waste Incineration Studies at Los Alamos," LA-UR-81-1170, May 1981.

J

53. Neuls. A.S., "The Los Alamos Controlled Air Incinerator for Radioactive  !

Waste," LA-9427 August 1982.  :

54 Pittiglio, C.L., Tokar, M., "NRC Perspective of Alternative Disposal i

Metliods," DOE Low-level Waste Forum Denver, CO, December 1986. '

i 55. Letter froin T.C. Johnson to R.F. Griffiths on flarnable gas generation in  !

LLW disposal facilities September 18, 1985. '

l 56. Siskind, B., et al., "Extended Storage of Low-Level Radioactiva Waste:

Potential Problem Areas," NUREG/CR-4062, Dacember 1985. .

l

57. Memorandum from Roles, et al., to L.8. Higginbotham, U.S. Nuclear

Regulatory Coemission. Novwber 7, 1983.

/ ,

e .-- . _ _ _ _ _

2-r.

57 ,

58. Telephone conversation Between T. Johnson, U.S. Nuclear Regulatory Commission, and Virgil Autry South Carolina Department of Health and Environmental Control December 10, 1987. ,

50 Tse A., "Basic Quality Assurance in Radiation Therapy," Draft Federal Register Notice, U. S. Nuclear Regulatory Cosaission, March 21, 1958.

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Radioactive Waste Campaign "**M!;;"""

625 5,endway,2nd Floor i

July 5,1988 Freedom of Information Officer h Nuclear Regulatory Commission IREE00W Dr INFORMAil0N m ,~ Washington, D.C. 20333 RE UEU j.J(,7 gw g

14. Iwim Dekr Sir / Madam gg Mmo_5mf Pursuant to the Freedom of information Act, 3 U.S.C. 352, as Ro6'"t M**

amended, the Radioactive Waste Campaign wishes to obtain copies of t.;. . m r.1n Iwa.se the iollowing documents:

neute D

, 1) staff response to a request from the State of Michigan c o p ri,w w.a concerning the feasibility of disposing of low-level radioactive vaste at w, % e, , m o. existing nuclear power plants. Notice of this response appeared under P p-r q s.*n NM55 Items of Interest, May 20, 1988.

En Drey c= w= aper:4,ta=== v.s tm. h can.

11) NRC staff comments to the Department of Energy on the ca"" DOE Dry Cask Storage Study. Notice of these comments also

%;,f r,ppeared under NM55 Iterns of Interest, May 20, 1988.

• M 1, e,, ",, ,,, 111) a listing of narnes and addresses of all persons, Inchafing u.a r r.=,,

state officials, and news media, sent copies of comments on the report

%w Living Without Landfills. These comments were first sent to the ra===#Ee n A== *s w mwk Campaign May 23, 1914, and Lubsequently, with attached memo sheet, M*' to state officials and the news media. The Campaign wishes te send keen PoN. Ph D. a response te these NRC comments to this malling list.

c,=e uwwy k"~ R** in addition, as related to request (111), the Campaign requests i

""" ccples of any and all agency records or information, including, but not i

g^* Mh_ e,,,,,,, limited to,, notes, letters, pre 5: releases, memoranda, logs, tapes, t., w transcripts, summaries, interview reports, instructions, agercy analyses, files, charts, photographs, agreements, handwritten notes, studies, data

%.=

.= == sheets, notebooks, bo&s, telephone messages, and any other data 1

{

> o .w w.=, compilations, interim and/or final reports, status reports and any and M'*"' A " ""'" >

• all other records related to item (111). In particular, the Caropeiyi i

• 8"""""' requests all materials between the State of Illinois and/or other states, i and NRC staff which relate to developing comments or respo<44 to d"r"M the Campaign repxt, Living without Landfills,  !

r

% *,,,J, .,,, The Radioactive Waste Campaign, a New York City-based 301 (cX3) public Interest organization doing research and puMic edumtion on radioactive waste nesues, requests that all fees be walved ham ==

"findleg the information can be considered as primarily benefitths the general public." Disclosure of the above-requested information hs in the ptbl e interest because it is likely to contribate significantly to public understanding of the operations and activities of the government. The Canpaign focusses exclusively on "low-level" radioactive waste issues and nuclear transportation issues. We produce slide shows, a quarterly newspaper, the Waste Paper, and books on commercial and military "low-level" waste issues, l.Iving Witjput, I

Landig, and Deadly Defense, respectively.

M/-- 6 / D

I i

l l

The Campaign has the technical competence to research and analyze i Nuclear Regulatory Commission information, has the resources and track record to make this information publicly accessible, and will be providing this information to the pubil: on a noncommercial and below cost basis.

(1) The information requested will be used as background. Depending on the material obtained, the Campaign will pubilih an article in the Waste Paper, and inform local residents. For item (11), the Campaign intends to ,

submit comments to the DOE. For item (111), the Campaign intends to '

formulate a response to NRC comments, and subrr.it these to the NRC malling list requested.  !

(2) The Campalgn Research Dirxtor will review the Agency Information. If the requested material is highly technical, professionals will

' be consulted. Without knowirig the nature of the information possened by the Nuclear 1 Regulatory Commission, the requester cannot state further. In 1 general, if the information warrants it, tne Campaign will hire what professional assistance is needed. j i

(3) The Campalg, researches and analyzes government information and j presents this Information in publicly accessible form. For example, the Campalgn analyud Update of Part 61 Impacts Anahrsis Methodology.

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NUREG/CR-4370, January 1986,, performed calculations, and produced the j

book, Livina without Landfills, partly based on information from the Nuclear 1 Regu:atory Commission contractors. The Research Director, Marvin '

1 Resnikott, holds a Ph.D. In high energy theoretical physics, has exclusively studied radioactive waste issues since 1974, and is widely recognized as gn expert on radioactive waste issues. The Campaign also publishes fact sheets i based on information obtained from the Nuclear Regulatory Commission and '

others.

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(4) Regarding item (111), the public has now been appelned of the 1 NRC's comments, but needs to know the Campaign's response.

persons(5,6) The Waste Paper is distributed directly to approximately 15,000 nationwide.

fact sheets per day. inFurther.

addition, the Campaign distributes approximately 30 Campaign stati reach hundreds of thousands additional persons tkough op Ed pieces and TV appearances. )

(7) The vaste Paper, fact sheets and Livirut Without Landfills book are sold at a nominal fee which covers publication costa, excluding staN time for research and analysis.

by contrhutions from individuals and foundations.The Campaign's sizable deficit la I

(4) No commercial Interest is involved in uds request.

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We Icok forward to a response within ten working days of the receipt of this letter. All correspondence should be sent to the Radicactive Taste >

Campalgn at the above address. ,

Thank you, j 5

snikoff ,

enarch Director i L

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