Sierra Club Conservation Policies
Low Level Radioactive Waste
- The public policy goals regarding "low-level" radioactive waste should be the
termination of production of fuel cycle wastes and the isolation of such wastes in the
safest and least environmentally damaging way achievable.
- Congress and the Nuclear Regulatory Commission (NRC) should exclude from their
definition of "low-level radioactive waste" any waste having a hazardous life*
greater than a 100-year institutional control period.
a. Wastes with a hazardous life of less than one year shall be stored at the place of
use or distribution until the end of that hazardous life.
b. Wastes with a hazardous life between one and 100 years shall be stored in
specifically licensed facilities. Such waste shall not contain more than 10 nanocuries per
gram of transuranic elements. Deliberate use of dilution to reduce the concentration of
radioisotopes is unacceptable,
c. Wastes with a hazardous life greater than 100 years should be treated as
- "Low-level" wastes, as presently defined by the NRC, should be isolated by
technology that results in zero-release of radioactivity over the hazardous life and one
that minimizes inadvertent intrusion. Reliance cannot be placed on continuation of the
present hydrogeology of sites. This is particularly true because global climate change
will alter sea level and water tables. It is therefore essential that the waste be
enclosed in a multi-barrier, water-impermeable system using materials with proper chemical
and environmental stability. Whatever substances are used must be rigorously characterized
regarding stability, impermeability and resistance to the radiation levels and chemicals
that will be encountered.
- Federal sponsorship of generator-funded research and development should be provided for
new engineered, site-specific waste isolation techniques. These techniques shall have the
necessary water impermeability and structural resistance to seismic and other events to
ensure isolation of the stored wastes for their full hazardous lives.
- Sea, freshwater or space disposal of radioactive wastes should be completely prohibited.
III. Institutional Issues
- Monitoring and the possibility of corrective action should be maintained prior to and
for as long as socially possible after site closure.
- Source and volume reduction of radioactive waste streams should be required, providing
that reduction techniques and policies do not result in release of radioactivity to the
environment or other adverse environmental and health impacts.
- Siting and technology choice processes should provide full public participation through
public notification of meetings, open meetings, access to documents, and procedures in
conformity with the Federal Administrative Procedures Act. There should be opportunity for
full litigative participation in all licensing actions.
- State health, siting and other laws more stringent than federal law or compact provision
should not be preempted.
- Compact commissions, if any, and state waste management authorities or personnel should
be prohibited from accepting private donations or grants. Petition and recall procedures
should be provided for compact commissioners.
- An environmental and health impact statement should be required for each radioactive
waste storage, treatment or isolation facility. Pre- licensing baseline health studies and
ongoing health monitoring studies should be required at all radioactive waste storage,
treatment, and isolation sites.
- Compliance with compact, federal and state guidelines and regulations should be
facilitated by the enactment of strong, clearly defined penalties and disincentives for
compliance failure by generators, processors, transporters, and radioactive waste storage
and isolation facility builders and operators. During facility operation, the site
operator should assume liability by means of rebuttable presumption in law.
- No state should be required to take title to, possession of, or liability for
radioactive wastes in the absence of full authority to regulate their generation.
IV. Financial Issues
- The full cost of LLW isolation and monitoring should be borne by the generators of the
waste. An extended care fund, paid for by charges imposed on generators, should cover the
costs of site cleanup, decommissioning and active long-term monitoring, storage and
- A long-term liability fund, paid for by charges imposed on generators, should compensate
for personal injury and property damage in the event of leakage and provide the maximum
third party liability insurance. During operation, cleanup, and decommissioning, the site
operator should assume full liability through means of rebuttable presumption in law.
- A fair and equitable mechanism for shared liability should be established among party
- Disposal fees should be based on volume, radioisotope concentrations, and hazardous life
of the wastes.
V. NRC policy on 'Below Regulatory Concern'
The Sierra Club urges Congress:
- to repeal provisions of the Low-Level Radioactive Waste Policy Amendments Act of 1985
that require establishment of deregulation of some "low-level" nuclear wastes;
- to remove federal preemption over radiation standards and radiological safety
regulations so that states may set standards and regulations that exceed minimum federal
- to revoke existing 1986 and 1990 Nuclear Regulatory Commission policy statements on
Below Regulatory Concern and Expanded Exemptions of Practices.
The Sierra Club recommends that radioactive material and wastes that the NRC,
Department of Energy or other agencies classified as radioac- tive materials or low-level
radioactive waste as of January 1, 1989, shall continue to be classified as radioactive
materials or low-level radioactive waste, to be isolated only in facilities licensed
specifically for that purpose. The Sierra Club recommends that radiation- generating
practices of licensees, including brokers, not be deregulated.
*Hazardous life -- the time required for the concentration of radioactive materials
within a package to decay to the maximum permissible concentrations given in 10 CRF 20,
App. V, Table 11.
Adopted by the Board of Directors, March 16-17, 1991 [replaced polices of May 1983 and
Incineration of Combustible Low-Level Radioactive Waste
The Sierra Club finds that present incineration technologies for Combustible Low-Level
Radioactive Waste (CLLRW) have not been demonstrated to provide adequate protection for
human health and the environment. Until improved incineration methods are proven safe, we
propose that alternate procedures, based on three subgroups of CLLRW, be instituted to
reduce the dispersal of significant amounts of radionuclides into the environment. The
three groups are Short Half-Life Radioactive Waste (SHLRW), Long Half-Life Radioactive
Waste (LHLRW), and Biological Radioactive Waste (BRW). Because of the biohazard, only BRW
may be incinerated.
- SHLRW is characterized as containing radionuclides with half-lives equal to or less than
tritium (12.3 years). It can be highly compacted and consists mainly of such dry materials
as mops, protective clothing, paper and rags. This waste should be compacted, placed in
above-ground storage, and remain in unleachable and noncombustible packages until the
curie burden has decayed to a nonhazardous level.
- LHLRW contains radionuclides of half-lives greater than tritium, shows little
compactability, contains by far the largest curie burden, and consists primarily of
ion-exchange resins (used to decontaminate reactor and fuel pool coolant), chelated
sludges, and filters. These wastes should be reclassified as high-level radioactive wastes
and isolated accordingly. They shall be stored at the site of origin, without leaching or
volatilizing to the environment, until final isolation.
- BRW contains both short and long half-life radionuclides, has the smallest curie burden
by orders of magnitude, contains mainly animal carcasses, and is unique in that it
provides both biological and radiological hazards during waste management. BRW may be
incinerated provided the following specific conditions are achieved:
a. Double or triple chamber controlled air combustion incinerators are employed near
the site of generation;
b. Only biological materials, containing no chlorinated hydrocarbons, are burned;
c. All tritium is condensed, captured, and placed in monitored surface storage as in 1
d. All particulates and carbon-14 shall be captured, placed in unleachable packages,
and treated as high-level waste as in 2 above. Until these conditions are met, BRW shall
be separated into short and long half-life groups. Both groups will be packaged for
storage in gas-tight containers and sterilized. The short half-life groups shall be
treated as in 1, the long half-life as in 2.
Adopted by the Board of Directors, May 2-3, 1987