VLLW: "Very Low Level Radioactive Waste" = Very Large Lies, Very Long Lasting
October 21, 2020
Dear NRC Commissioners and Staff:
I object to the Nuclear Regulatory Commission's (NRC) proposed reinterpretation of the rules which would allow radioactive waste to go to persons and places without radioactive licenses Docket NRC 2020-0065. Do not release radioactive waste to places without nuclear regulatory control. Do not give "specific exemptions" to entities to take radioactive waste, regardless of what other permits they might have for other kinds of waste.
Keep nuclear waste out of our communities, solid and hazardous waste landfills and incinerators, processing and recycling centers. I especially object to sending nuclear waste to hazardous waste sites because those sites are not designed to isolate radioactive materials and the combined health and environmental effects of both hazardous and radioactive materials could be exponentially worse than each on their own. Rachel Carson warned about the synergistic effects of radiation and toxic chemicals in her iconic book Silent Spring, credited by many as launching the environmental movement in the early '60s.
I object to the illegal, immoral way the NRC is trying to effectuate this radical change in radioactive waste policy. NRC is procedurally attempting to bypass normal rulemaking procedures of both NRC and the Administrative Procedures Act; and in practical terms, proposing a change in policy that will make it difficult, or even impossible, for the public or state regulators to track radioactive waste. This so-called "very low-level waste" or VLLW is really a very large lie about nuclear waste, as it could result in release of intensely radioactive waste despite NRC’s claimed "intent." The proposal is clearly designed to circumvent over a dozen state laws requiring regulatory control over all levels of radioactive waste in their states.
Fortunately for a few of us, some states will not allow the release of nuclear waste to regular trash, recycling, incinerators or hazardous facilities. But for the majority of the country, it will be virtually impossible to track what happens with potentially ALL of the nuclear power waste other than irradiated (spent) fuel. In fact, once NRC puts this interpretation in place, states could be able to virtually deregulate radioactive waste disposal as well, meaning that the concerned public must be ever-vigilant to every action of both federal and state regulators who could be releasing nuclear waste with no public notice.
NRC is proposing to allow same amount of radioactive emissions from unregulated "specific exempt" sites as from operating nuclear power reactors and waste dumps. This is unacceptable and furthermore, no amount of "millirems" is acceptable because they are not verifiable, enforceable or necessary.
Reject the VLLW proposal and all others that would release nuclear waste from radioactive controls. Keep nuclear waste under lock and key and out of solid and hazardous waste sites, whether landfills, incinerators, or recycling.
Sincerely,
Kevin Kamps
Radioactive Waste Specialist
Beyond Nuclear
7304 Carroll Avenue, #182
Takoma Park, Maryland 20912
admin
Here is the introduction NIRS put at the top of their webform for sending comments to NRC:
Tell the Nuclear Regulatory Commission and Your Senators: NO nuclear waste in your local landfill
The US Nuclear Regulatory Commission (NRC) is trying to slip a big one past us: They want to do away with the need for nuclear licenses to dump nuclear power waste. In other words, there would be no more regulatory controls over Very Long-Lasting Waste (VLLW).
The NRC wants to let nuclear waste go to your local landfill if the landfill operator wants it—without telling you. They would be glad to send it to hazardous waste sites not fit for nuclear waste as well, making those dumps even more hazardous. It could end up in recycling, reuse or other waste streams, too.
As the nearly 100 nuclear power reactors close in the decade to come, their owners want to save money by dumping thousands of tons of radioactive garbage–concrete, metal, soil, asphalt, equipment, pumps, pipes, plastics and more–by pretending it is not radioactive. Don’t let them get away with it. Tell the NRC and your senators you say NO to VLLW and deregulation of nuclear waste.
admin
NIRS NEWS RELEASE--Thousands Oppose Nuclear Waste Going to Regular Landfills
For Immediate Release--Contact
Diane D'Arrigo, Radioactive Waste Project Director
Nuclear Information and Resource Service
dianed@nirs.org; 202-841-8588
https://www.nirs.org/wp-content/uploads/2020/07/Telebrief_VLLW-landfills_2020-07-15.mp3
Thousands Oppose Plan to Let Atomic Waste Go to Regular Landfills,
Incinerators, Recycling
October 21, 2020 Nearly 10,000 comments were submitted by today's deadline to the US Nuclear Regulatory Commission (NRC) against its plan to deliberately allow nuclear waste, mainly from nuclear power reactors, to go to regular garbage dumps and other places that do not have radioactive licenses.
The proposal, NRC-2020-0065, Transfer of Very Low Level Waste to Exempt Persons for Disposal (VLLW), has been renamed by opponents Very Large Lies about Very Long-Lasting nuclear Waste.
NRC proposes to "reinterpret" its own rules that have always required radioactive waste to go to places with a nuclear license. NRC would allow massive amounts of the radioactive concrete, soil, metal, wood, plastic, asphalt, equipment, piping, resins, chemicals, oil, rubble, demolition waste and reactor parts from nuclear power to go out with the regular trash to any place NRC grants a "specific exemption." It could go to hazardous waste sites that are not designed for radioactive waste making them much more dangerous. It can take years to get a nuclear license, and there are four licensed sites in the U.S., in Washington, Utah, South Carolina, and Texas.
There is no requirement for public notice, no verifiable or enforceable limits and, despite NRC mislabeling the waste VLLW, the waste could be very radioactive and long-lasting with dozens of cancer-causing radionuclides like plutonium-239, cesium-137 and strontium-90.
The "exempt" landfills would be allowed to expose the public to as much radiation as operating nuclear power reactors and licensed nuclear waste sites--a level that can give cancer to 1 in every 500 people exposed over their lifetimes, according to Environmental Protection Agency calculations.
The opposition comes from entities rarely in agreement--national, regional and local public interest and environmental groups; waste management organizations; state officials who certify solid and hazardous waste sites and are responsible for air and water quality; state and regional agencies and organizations responsible for nuclear waste; local townships; a labor union; a radioactive waste company that took over a decade to get an NRC license; national organizations of state nuclear officials and regulators; environmental justice groups supporting residents of communities around existing solid and hazardous waste sites; and thousands of individuals.
Those commenters oppose the proposal for many of the same reasons. The NRC is trying to bypass normal rules for changing federal regulations: NRC claims it is merely "reinterpreting" longstanding regulations, not actually changing them. After 80 years of requiring anyone possessing manmade nuclear waste to have a license authorizing them to store or dispose of radioactive materials and waste, the NRC wants to authorize it to go to places without a license by changing the guidance, not the actual rule.
Many oppose shifting liability and responsibility to landfills that don't have protections for nuclear waste, nor the knowledge, equipment or experience to manage, monitor and control it. Some groups argue that licensed sites should increase their protections--but instead NRC would weaken protections with this proposal. Licensed nuclear waste sites could actually lose business if the waste goes to regular trash instead of into their trenches. One company supports the change because it runs non-nuclear landfills that could take much of the radioactive waste. The new interpretation would "streamline" (do away with) the case-by-case analysis needed for exemptions to dump at their sites.
There is no definition, limit, or enforceable description on the kinds or amounts of radwaste to be let out of regulatory control. While some in the industry want NRC to define a new category of radioactive waste that could be so released, the majority of commenters do not want any amount of nuclear waste to be released from regulatory control. They say, the nuclear industry created it--keep it regulated.
There is even a question as to whether the "exempt" sites could import foreign nuclear materials or waste, referred to as "transboundary" waste.
The change could also confuse and violate U.S. Interstate Radioactive Waste Compacts' authority over moving waste within the U.S.
“It is outrageous that the Trump Administration is trying to make us all “glow-in-the-dark” before he leaves office by de-regulating nuclear waste," states Jane Williams, executive director of California Communities Against Toxics. “These de-regulated materials find their way into the scrap metal stream and from there enter into our homes in metal consumer products.”
"Since there is no safe level of radiation exposure, all industrially generated nuclear waste needs to be isolated, not dispersed into landfills, air, water and possibly even recycled consumer goods," Diane D'Arrigo of Nuclear Information and Resource Service stated. “The big concern is the radioactive danger to current and future generations and the unlimited amount of radioactivity released to the environment. Most commenters don't like that there is no public notice or opportunity to even know if their local landfill gets ‘exempt’ authorization from NRC.”
"This is not the first or last time the nuclear industry and its regulatory agencies have tried to let manmade radioactive waste out of control--to go to places that are not licensed for nuclear materials," D'Arrigo said. "They keep changing the name so it looks like a different plan, but the bottom line is the same--nuclear power makes more waste than it can afford to isolate. From 1986 to 1992 it was ‘Below Regulatory Control’ or BRC but Congress rejected and overturned the BRC policies. Then it was called ‘deminimus.’ The Department of Energy tried ‘Beneficial Reuse’ of nuclear weapons radioactive metals and wastes. In Tennessee. it is Bulk Survey for Release (BSFR). Every time the public has found about these proposals-in the making, they have fought and stopped them. The only way to get this passed is to sneak it through. And that is what the NRC is attempting with its VLLW plan.”
Dan Hirsch, Committee to Bridge the Gap, former director of the Stevenson Nuclear Program at University of California Santa Cruz and nuclear expert commented, "The NRC seems intent on changing its own name to Nuclear DEregulatory Commission."
"This proposal is sure to spawn fly-by-night dump operations on vacant lots, in urban renewal excavations, and on brownfield sites of old factories," said Terry Lodge, Toledo-based environmental attorney. "As usual, the poor and most vulnerable populations will be the collateral damage from this dark atom that was supposed to save us."
If the vast majority of the ~10,000 commenters get their way, this VLLW plan will go into the waste dump.
--30--
An audio teleconference on VLLW featuring each of the quoted experts can be accessed at
https://www.nirs.org/wp-content/uploads/2020/07/Telebrief_VLLW-landfills_2020-07-15.mp3
admin
Public Employees for Environmental Responsibility (PEER) also put out a press release:
https://www.peer.org/deregulation-rad-waste-disposal-plows-ahead/
| Deregulation of Rad Waste Disposal Plows Ahead - PEER.org
The Nuclear Regulatory Commission is deregulating disposal of radioactive waste, allowing commercial nuclear reactors to dump radioactive waste, except spent fuel, in local garbage landfills.
www.peer.org |