Selected chapters from:
High-Level Dollars, Low-Level Sense:
Chapter 5: Summary and Recommendations
by: Arjun Makhijani and Scott Saleska
by: Arjun Makhijani and Scott Saleska
There is a fundamental problem with the way in which current government regulations categorize radioactive waste. For example, despite what is implied by their names, the two categories of waste named "high-level waste" and "low-level waste," are defined without systematic reference to their actual radioactivity levels. Instead, they are defined solely by the process which produced them. "High-level waste" is defined as spent reactor fuel, or those wastes resulting from the reprocessing of spent reactor fuel. "Low-level waste" is actually a catch-all category that is defined simply to include all radioactive waste that is not high-level waste, transuranic wastes, or uranium mill tailings.
Thus, the current radioactive waste categorization is in the untenable situation of sometimes labeling as "low-level" radioactive wastes which are actually several times more radioactive than other streams of radioactive waste which the current system labels "high-level." So, for example, the average radioactivity in the most radioactive portion of commercial low-level wastes (at 300 curies per cubic foot) is actually three times more radioactive than the average radioactivity in high-level wastes from nuclear weapons production activities. Even a typical reactor stream of low-level waste, which is routinely buried in shallow land trenches, is significantly more radioactive than some of these military high-level wastes. Many of the longer-lived and more dangerous categories of low-level waste, which is disposed of in shallow land burial, is also more radioactive than transuranic waste, which has been designated for disposal in a deep geologic repository.
A related problem with the existing definitions for radioactive waste is that they are without reference to the longevity of the waste's radioactivity. Both high-level and low-level wastes as currently defined can contain significant quantities of both long and short-lived radionuclides. Since essential aspects of the radioactive waste disposal problem are in large part defined by the longevity of the waste's hazard, this also makes little sense.
2. Existing regulations and plans for long-lived radioactive waste management and disposal are irrational and incoherent.
Improper categorization of radioactive waste has been a principle obstacle to rational waste management policies. A central problem has been the substantial quantities of long-lived wastes involved in "low-level" waste categories. For example, long-lived plutonium-239 and other radionuclides have leaked from the now-closed low-level waste disposal facility at Maxey Flats, Kentucky.
Currently operative regulations for the disposal of low-level wastes, although much-improved since the time of Maxey Flats operation, continue to be fundamentally irrational. They are internally inconsistent, and therefore clearly inadequate. For example, the Nuclear Regulatory Commission (NRC) regulations currently require institutional controls at low-level waste disposal facilities for up to 100 years, because, according to NRC, "low-level" waste classes A and B will decay to the point where they will present "an acceptable hazard" to any later intruder by the end of this time frame. However, this statement is logically and physically incompatible with the numerical limits also contained in those same NRC regulations. In fact, some forms of waste, if retrieved from the disposal site after the 100-year period had elapsed, and then re-buried as if for the first time, would have levels, according to the same NRC regulations, such as to require a 100-year institutional control period all over again. Indeed, even according to the NRC regulation's own definitions of what is "hazardous" and what is "acceptable," wastes could be buried which will be unacceptably hazardous for thousands of years beyond the time when the regulations say they should pose an "acceptable hazard." Hence, the internal inconsistency of the regulations and definitions.
The U.S. Environmental Protection Agency (EPA) has the authority under law to promulgate low-level waste standards, and has actually formulated comprehensive standards for this purpose, but disagreements with the NRC and Department of Energy (DOE) arising due to the fact that EPA's standards are more comprehensive and stringent have prevented their official publication. EPA's low-level waste standards are intended to provide comprehensive and consistent coverage across both commercial and military facilities, and to protect groundwater. Since existing standards are severely lacking in these areas, the lack of EPA low-level waste standards is a serious defect in the U.S. low-level waste program.
While radioactive waste management is a difficult issue by its very nature, it does not have to be irrational. For instance, radioactive waste management in Sweden is based on the principle that radioactive waste disposal methods should be determined by the longevity of the waste. Thus, long-lived wastes (whether they would be considered "low-level" or "high-level" in the U.S.) are slated for disposal in a deep geological repository. As a consequence, fully 40 percent of the volume slated for disposal in Sweden's projected long-lived waste repository consists of reactor wastes which would be considered "low-level" in the U.S.
3. The Department of Energy's management of the repository program for long-lived radioactive wastes is exacerbating these problems.
The U.S. Department of Energy is responsible for developing geologic repositories for high-level and transuranic wastes. Over the past 15 years, timetables for both of the DOE's major repository programs have slipped and costs have escalated. For example, an operational repository for high-level wastes is now, according to DOE projections, twice as far away as it was in the late 1970's, and projected disposal costs grew by over 80% between 1983 and 1990.
Despite the existence of at-reactor and onsite storage options for nuclear wastes and repeated failure within its repository program, a sense of urgency continues to pervade the U.S. attitude towards long-lived radioactive waste disposal. The nuclear industry in particular is anxious to have in place a program which will allow the government to take the waste out of their hands. As one nuclear utility executive recently put it, the government should take charge of spent fuel waste by 1998 (a target date in the 1982 Nuclear Waste Policy Act), and, he said, "I don't care where you put it."
This situation is exacerbated by lack of NRC and EPA standards for repository disposal which correspond to longevity of the wastes and the health threats posed by many long-lived radionuclides.
4. Taken as a whole, current policies entail high risks in terms of both economics and environmental protection.
Economics
On the high-level waste side, where $3 billion has already been spent on a program for geologic repository disposal, projections of disposal cost per ton have increased by over 80 percent since 1983 (in constant dollars), from $179,100 per metric ton, to about $325,000 per metric ton.
The cost of the WIPP repository program, which should be more stable since the program is further along,shows similar increases. In just two years, the DOE's cost estimates for the five-year period including the first several years of WIPP operation have more than doubled, from $531 million in 1989, to around $1.1 billion in 1991.
Seven hundred million dollars have already been spent on development of the low-level waste disposal sites according to fundamentally inadequate environmental standards. Most of these sites will likely miss legal deadlines established for their availability. Additional billions are being spent and will have to be spent to fix the problems from past shallow-land burial of low-level wastes at both commercial and military sites.
For instance, at the contaminated commercial low-level waste ¬disposal facility at Maxey Flats, Kentucky, when the clean-up is finally done, and all the costs accounted for, final disposal costs for wastes disposed of there may well be 10 to 50 times greater than the original disposal rates. At West Valley, New York, the bill for combined high-level waste management and remediation of problems with low-level waste disposal is now estimated to cost between $2.4 and $3.4 billion.1 These wastes resulted from a reprocessing plant for plutonium extraction which originally cost $35 million and was supposed to be a commercial, profit-making operation.2 Finally, a large proportion of the $150 billion cost of clean-up of the nuclear weapons complex sites is due to environmental threats created by dumping of radioactive and mixed wastes into the soil and the high-level wastes now sitting in 228 large tanks at Hanford and the Savannah River Site.
Billions of dollars have been or are slated to be spent stabilizing uranium mill tailings and preventing radium-226 and thorium-230 from getting into the groundwater. Yet, such programs are limited to 1,000 years of environmental protection, despite the fact that hazards will persist for the several hundred thousand years which will be necessary for the thorium-230 to decay substantially.
Environmental Protection
On the high-level waste side, the DOE's program has become environmentally more risky due to the reduction in the number of potential repository sites to be characterized to one, despite its greater cost. The selection of Nevada as the only site to be characterized came about as a result of a process that, in part, started with the fact that the government already controlled the land, and ended in a decision in which politics overwhelmed science.
The doses from vitrified military high-level wastes alone, a small portion of the total radioactivity proposed to be disposed of could far exceed allowable standards due to the potential incompatibility of glass with the Yucca Mountain hydrogeological conditions.
The huge inventories of transuranic wastes in the form of contaminated soil which will be left unaddressed by the WIPP program means that this program is guaranteed to be a failure from the point of view of isolating transuranic wastes from the human environment. Moreover, the small proportion that may be disposed of in WIPP is by no means assured of isolation from the human environment even for a few thousand years, much less the hundreds of thousands of years it will remain threatening.
Likewise, despite huge cost escalations in the development of low-level waste disposal sites (unit disposal costs for some disposal sites in the 1990s are projected to be 600-700 times 1975 disposal costs), these still entail huge environmental risks for future generations because of the fundamental inadequacy and irrationality of the underlying regulations.
In sum, for a host of fundamental reasons, it is highly unlikely that minimization of risk to future generations or wise use of financial resources can be achieved under the present approaches for management of any category of nuclear waste. Far more likely is waste of money coupled with a festering problem, and potentially increasing risks from inappropriate policies.
Recommendations
The management of long-lived, highly radioactive waste has no safe or simple solution. It is a difficult, messy and costly problem. We have created a problem which will be a source of substantial risk to future generations, whatever we do today. It is therefore imperative that society minimize the generation of further long-lived radioactive wastes. Almost all long-lived wastes, in terms of the quantity of radioactivity involved as well as the physical volume, come from nuclear power and nuclear weapons production. The problem of the management of long-lived radioactive wastes makes it incumbent upon us that any further generation of long-lived wastes from these two sources, about which there is no social consensus, be subjected to careful scrutiny regarding the potential for phase-out. Generation of long-lived wastes from medical and research facilities should also be minimized by use of shorter-lived isotopes and substitute processes to the extent practicable.
It is of vital importance that we address the problem of the wastes which already exist with the greatest scientific and technical integrity so that future generations may be protected to the greatest extent possible. Steps must also be taken in the interim to see that the present generation does not suffer large releases and contamination due to accidents or poor interim management.
Based on the above findings and these general considerations, we make three overall recommendations regarding the U.S. radioactive waste management system: change radioactive waste classifications so that all long-lived wastes are managed according to an integrated hazard-and-longevity-based approach, re-structure the program for disposing of these newly defined long-lived wastes, and provide for extended onsite storage of wastes in the interim while the long-term problem is being addressed. Each of these entails a number of sub-recommendations, which are discussed below along with some of their ramifications. 1. Change how radioactive wastes are defined, and reclassify radioactive wastes and their disposal according to longevity and hazard level.
Since many of the problems of the current waste management system are due to the underlying fundamental inadequacy of waste definitions, an integrated approach which entails redefining wastes according to their longevity is needed. This includes reclassification of considerable quantities of commercial and military wastes that are now considered "low-level" into the long-lived category. Long-lived should be appropriately defined such that wastes containing significant quantities of cesium-137 and strontium-90 are considered long-lived. Evidently, what constitutes "significant" must be determined by health-based criteria and this must be the subject of careful scientific study and broad democratic debate.
An important consequence of this is to expand the amount of waste being sent to a repository. By analogy the Swedish approach, we expect that approximately 225,000 cubic meters of commercial reactor waste now considered low-level would go to a deep repository. Depending on the emplacement density of this waste, we expect that this amount would require an additional 140 to 1,200 acres of repository space in addition to the approximately 2,400 acres already needed for spent fuel and reprocessing wastes. Although this does not include the consequences from reclassifying military low-level wastes, it is indicative of the scale of the problem.
The DOE made a partial step in this direction when it decided in 1970 to reclassify some of its "low-level" wastes as transuranic wastes and dispose of them in a repository. However, the application of this principle has been seriously deficient. First, the repository selection, characterization, and testing has been flawed. Second, the volume of wastes which fall into this category is far larger than the proposed repository in New Mexico will be able to accommodate.
2. Restructure the entire long-lived waste management and disposal program.
The present process of site selection and characterization for the high level and transuranic waste repositories has been compromised both technically and institutionally. It has become necessary to abandon it. The low-level waste disposal site selection programs, are a welter of confusion based on an irrational NRC waste classification scheme that mixes intensely radioactive long-lived waste with short-lived waste, and the absence of any applicable EPA standards at all. There is no provision for long-term isolation of the long-lived components of uranium mill tailings.
The present programs for selection of disposal sites must be abandoned and replaced with an approach to long-lived waste management and disposal that has technical integrity and institutional competence.
Regarding the programs established for each of the categories of radioactive waste, our suggested alternative approach entails:
At a minimum, no siting, construction or operation of new low-level waste disposal facilities should be allowed to proceed in the absence of comprehensive EPA standards for low-level waste disposal.
Addressing related institutional and policy issues entails a number of other steps, including:
(This includes the creation of new institutional arrangements for managing the research and development needed to create a program for long-term management of long-lived wastes.)
3. Provide for extended onsite storage of long-lived radioactive wastes at the point of generation as an interim management step.
In order to accommodate the needs of a restructured development program for long-term waste management, extended onsite storage will be needed for various categories of waste. This would include:
Combined with onsite storage and deferral of decommissioning for nuclear reactors, a restructured long-lived waste disposal program will allow time for development of careful and sound understanding of geology and climate in selection of a disposal option, development of waste forms with better isolation characteristics and research on new technologies. This will allow the science to be done in parallel with the politics, in contrast to the present program where politics and policy goals in areas other than public health and environmental protection have tended to dominate.
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Last Updated October, 1996
1. Cost estimates provided to Senator Daniel Patrick Moynihan (D-NY) by aides to Secretary of Energy James Watkins, as reported in Douglas Turner, "Cost of West Valley Nuclear Clean-up Soars," Buffalo News, Section B, p. 1 (February 21, 1991). Reference courtesy of Carol Mongerson, Coalition on West Valley Nuclear Wastes, East Concord, New York.
2. Carter 1987, p. 98.