IEER’s Comments on Unique Waste Streams Rulemaking, Docket ID NRC-2011-0012
To the Nuclear Regulatory Commission, from Arjun Makhijani
June 18, 2011

The rule change started as a modification of 10 CFR 61.55(a)(6) to accommodate unique waste forms. It has now transformed itself into a vastly expanded scope of a revision of the entire 10 CFR 61 rule, including radiation protection provisions for public health. The proposed changes rely on the Final Low-Level Waste EIS that is almost 30 years old (the Final EIS, NUREG-0945 was published in November 1982). The cancer risk factors, many dose conversion factors, and the dose estimation models changed very substantially since 1982. For instance, the fatal cancer risk factor used is 1×10-4 per rem (p. S-7, Vol. 1, NUREG-0945, 1982). The current EPA cancer risk factor, published in Federal Guidance Report 13 is nearly six times as large: 5.75×10-4 per rem. Current practice would use RESRAD (Onsite) for estimating doses, while the NUREG-0945 uses models that go back to the punch card age of computers and radiation science that is from the 1950s. There is no intent in the proposal to protect children, as required by a presidential executive order that has been in effect since the Clinton Administration (Executive Order 13045). We believe that the proposed revisions are not only without adequate public notice and technical preparation and rely on an obsolete EIS but they are also in violation of Executive Order 13045…

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