Post comments here:
https://www.regulations.gov/document/NRC-2011-0012-0205
The following comment was left at the NRC web site, with confirmation code msw-80eh-o2ex:
We strongly oppose NRC-2011-0012-0205, which would modify current regulations for radioactive waste disposal and redefine low-level radioactive waste to cover some Greater-Than-Class C (GTCC) waste including "... certain transuranic wastes." If this proposal is approved, the modifications to Part 61 of Title 10 (Energy) of the Code of Federal Regulations (CFR) would allow these transuranics, including Plutonium to be disposed of as Low Level Waste (LLW), while at the same time allowing " ... higher concentrations of waste, providing new alternatives for safe low-level waste management."
Redefining GTCC waste makes the problem of radioactive contamination in the environment worse, not better, and these "new alternatives" should be abandoned now (rather than losing track of the waste's location and composition 500 (or 10,000 or more) years from now).
Existing and proposed Part 61 regulations are supposed to protect the environment for AT LEAST 10,000 years, but only require the waste to be protected from "intrusion" for the first 500 years. The oldest pyramids are nearly 5,000 years old. One would think a society with five millennia to perfect containment, that ALSO chooses to work with plutonium — the most toxic (carcinogenic, mutagenic, etc.) and insidious (human senses cannot detect radiation) — element ever conceived, discovered, or created — could — and would — be able to create and guarantee the workability of 10,000-year containment. Or know not create the mess in the first place.
Plutonium-239 has a half-life of 24,100 years and radioactive materials are considered dangerous for at least 10-20 half-lives. The possibility of using low-level radioactive waste facilities to store GTCC waste that includes transuranics means that the waste would remain hazardous for hundreds of millennia. By then any "near-surface" containment might well be fully exposed through surface erosion, earthquakes, thermonuclear war, or under water, or in the middle of a city or farm. The proposed regulation ignores this reality, and states that: "The disposal depth will need to be maintained for as long as the waste is hazardous."
What are the design criteria for something that needs to contain lethal poison essentially forever, and what types of intrusion will it be protected from? The regulations describe intrusion by humans (whether deliberate on inadvertent), but it's easy to envision an animal intruding into a structure where concrete was cracked (perhaps by a tree root and/or an earthquake and/or the degradation of the containment caused by the radioactivity contained within) in far less than 500 years. The proposed regulations defer actual rules with vague statements such as: "Depending on the characteristics of the GTCC waste, an applicant would be able to identify in the technical analyses those additional barriers or performance characteristics that are necessary to provide protection, such as a greater disposal depth or an intruder barrier of greater longevity."
One reason the Nuclear Regulatory Commission (NRC) is proposing changes to Part 61 is: " ... GTCC waste streams are stranded at operating reactors, sealed-source facilities, and Department of Energy (DOE) facilities." At the same time, the NRC describes the proposed changes to Part 61 as providing: " ... a clear licensing pathway for the back end of the fuel cycle." and a solution for: "... all nuclear waste except spent nuclear fuel and high-level radioactive waste." This statement makes it clear that the NRC recognizes that there is not even a plan for disposing of spent nuclear fuel and yet, the agency continues to promote its role in "... activities [that] will help reestablish the United States as a global nuclear energy leader".
America can lead the world in nuclear technology by properly guarding future generations against the mistakes we have made today, and by not continuing to make more nuclear waste with no safe solution possible.
We incorporate by reference and adopt as our own the comments submitted by Fred Schofer (https://www.regulations.gov/comment/NRC-2011-0012-0213 tracking #: msi-z9bz-26ms)
Sharon and Ace Hoffman, Carlsbad, California USA
(All quotes are from the docket materials at:
https://www.regulations.gov/document/NRC-2011-0012-0205)
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Contact information for the author of this newsletter:
Ace Hoffman
Carlsbad, California USA
Author, The Code Killers:
An Expose of the Nuclear Industry
Free download:
acehoffman.org
Blog:
acehoffman.blogspot.com
YouTube:
youtube.com/user/AceHoffman
Email: ace [at]
acehoffman.org
Founder & Owner,
The Animated Software Company
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