On August 13, 2015 the Nuclear Regulatory Commission held a briefing on the issues surrounding greater-than-class C radioactive waste. IEER’s Dr. Arjun Makhijani, Ph.D., gave a presentation which covered the following issues:
(Download Arjun’s presentation here and see other presentations from the briefing)
- The current 10 CFR 61 revision proposal, to have a period of performance of 10,000 years and allow site-specific performance-based evaluation in place of conformance to waste concentration limits, is fundamentally deficient, made much worse by the potential inclusion of GTCC waste in shallow land burial, including potentially large amounts of depleted uranium.
- 10 CFR 61.55(a)(3)(iii) and (a)(4(iv) should be tightened to require that all wastes with concentrations greater than Tables 1 and 2 (column 3) SHALL be disposed of in deep geologic burial without exception. The word “transuranic” should be removed from Table 1.
- 10 CFR 61.55(a)(3)(iii) should be expanded to include curie and concentration limits for ALL long-lived radionuclides (half-lives >10 years). Depleted uranium and recycled uranium are like transuranic waste (or GTCC) for disposal purposes and should be governed by a requirement for repository disposal.
- The NRC proposal to revise 10 CFR 61.41 to eliminate organ doses under the guise of modernizing the science is a disingenuous deception of the public. It is nothing less than an egregious relaxation of the standards. The current dose standards should be tightened by the incorporation of drinking water rules by reference.
- My comments on the proposed LLW rule revisions are the basis of a large part of my presentation here and should be referred to as you review my remarks.