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Sierra Club Conservation Policies

Low Level Radioactive Waste

I. Goals

  1. 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.
  2. 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 "high-level" wastes.

II. Technology

  1. "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.
  2. 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.
  3. Sea, freshwater or space disposal of radioactive wastes should be completely prohibited.

III. Institutional Issues

  1. Monitoring and the possibility of corrective action should be maintained prior to and for as long as socially possible after site closure.
  2. 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.
  3. 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.
  4. State health, siting and other laws more stringent than federal law or compact provision should not be preempted.
  5. 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.
  6. 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.
  7. 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.
  8. 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

  1. 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 health/environmental studies.
  2. 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.
  3. A fair and equitable mechanism for shared liability should be established among party states.
  4. 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:

  1. 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;
  2. to remove federal preemption over radiation standards and radiological safety regulations so that states may set standards and regulations that exceed minimum federal ones; and
  3. 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 December 1984]

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.

  1. 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.
  2. 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.
  3. 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 above; and

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

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