We recognize that there is little agreement on how to proceed, and have therefore endorsed the idea of establishing an independent commission to conduct a comprehensive review of US nuclear waste policy. This commission should include broad public participation and should begin with an examination of the current waste classification system. The establishment of such a commission has been endorsed by dozens of public interest groups and elected officials.

IEER's own recommendations, based on our extensive review and analysis of nuclear waste issues, are given below.

1. Change how radioactive wastes are defined, and reclassify radioactive wastes and their disposal according to longevity and hazard level.

Many of the current problems with radioactive waste management stem from a flawed waste classification system (see Centerfold). A system based on the longevity and hazard of the radionuclides in the waste would not only reduce risks of potential exposure to the environment and the public, but also help provide consistency among and within the agencies and regulations that determine how waste is managed.

Existing Nuclear Regulatory Commission (NRC) and Environmental Protection Agency (EPA) regulations for transuranic wastes implicitly define "short-lived" wastes as those which contain elements with half-lives of somewhere between 5 and 20 years. This would be a good starting point for public debate defining this crucial term, because it is preferable to store "short-lived" wastes to decay. The radioactivity of a radionuclide declines by about a thousand-fold in ten half-lives and by about a million-fold in twenty half-lives. Experience indicates that it would be imprudent to rely on institutional stability for more than 100 years, or at most 200 years. Therefore a definition of "short-lived" somewhere in the range of 5 to 20 years seems reasonable both from a technical and institutional viewpoint.

"Long-lived waste" should be defined to include radionuclides with relatively short half lives that decay into elements with long half-lives (see "The Curious Case of Curium" box). Under such a system, considerable quantities of military and commercial waste now considered "low-level" would be reclassified as "long-lived" waste, and would, in turn, require more stringent management.

2. Provide for extended on-site storage of spent fuel and other highly radioactive wastes at the point of generation (or in some cases close to the point of generation) as an interim management step, and defer reactor decommissioning in parallel with interim storage.

On-site storage will be required to help accommodate a restructured program for long-term waste management and to accomplish other health and environmental goals. It should include:

• Planning for 50- to 100-year at-reactor storage of spent fuel in dry casks, since a sound long-term waste isolation option will not be available for many decades. Consideration should be given to shifting this waste to a site near the reactor in exceptional cases, such as that of the Prairie Island Power Plant located on a small island in the Mississippi River in Minnesota. Funds for extended on-site storage should come from the Nuclear Waste Fund, provided that utilities agree to a restructured radioactive waste management program, and abandon their support of the current flawed Yucca Mountain program and withdraw their insistence on an interim centralized storage facility for spent fuel.

• Strengthening NRC on-site storage rules to take earthquake and other risks better into account, and to ensure that casks are used only after rigorous safety certification is complete.

• Deferring decommissioning of shut-down nuclear reactors by 50 to 100 years to allow for radioactive decay that will lower radioactive waste volumes; reduce risk to decommissioning workers; and integrate on-site storage with a realistic time frame for radioactive waste disposal.

• Enforcing progress on long-term management of nuclear waste to ensure that interim on-site storage does not become permanent on-site storage.

• Rejecting any proposals for a centralized Monitored Retrievable Storage facility.

• Putting radioactive wastes, including military high-level, long-lived low-level, and transuranic wastes, into forms that will minimize risk to workers and residents from interim on-site storage, and that will not compromise in any essential way long-term management programs which may be put into place.

3. Restructure the entire long-lived waste management and disposal program.

The present programs for selection and characterization of disposal sites for low-level, high-level, and transuranic wastes have been seriously compromised both technically and politically and must be abandoned. They should be replaced with an approach to long-lived waste management and disposal that has technical integrity and institutional competence. Our suggestions for restructuring the existing programs for radioactive waste are as follows:

All wastes: Establish reasonable, and enforceable rules for segregating long-lived radioactive wastes from short-lived wastes to the extent possible, and minimize generation of long-lived wastes.

Spent fuel and high-level reprocessing wastes: Cancel the current high-level waste repository development program, including further consideration of Yucca Mountain. The repository siting program should begin again with basic consideration of geology and rock types, as well as consideration of alternative approaches, such as sub-seabed disposal. Simultaneously, research and development should be pursued on engineered barriers to waste migration (including research into mimicking how natural radioactive materials are contained for long periods of time in certain kinds of geology).

Transuranic wastes: The Waste Isolation Pilot Plant repository program should be canceled and the process for long-term transuranic waste management should be integrated with the long-term high-level waste management program.

Low-level wastes: Cancel the siting for new low-level waste sites and reclassify low-level wastes, as discussed above. Store short-lived low-level wastes until the radionuclides have decayed (that is, for approximately ten to twenty half-lives). Consolidate medical and research radioactive wastes at storage locations such as closed reactor sites.

Uranium mill tailings:

1. Continue management under the Uranium Mill Tailings Reclamation Act with better controls.
2. Assess the feasibility of separating radium-226, thorium-230, and toxic metals from uranium mill tailings to enable their integration into the long-term management program for high-level waste.

Depleted uranium: Put into stable forms. In particular, convert uranium hexafluoride into oxide forms for storage.³ Manage in the same way as transuranic waste (as part of the high-level waste program).

Mixed wastes: Explore environmentally acceptable ways to neutralize the non-radioactive components without substantially increasing radioactive waste volume, and, preferably, reduce radioactive waste volume at the same time.

4. Restructure the institutional arrangements and policies for regulation and long-term management of long-lived highly radioactive wastes.

• Remove DOE from the long-term waste management program. Establish an independent radioactive waste management authority for repository and other programs that does not suffer a conflict of interest between nuclear power and weapon production and environmental and health protection. New institutional arrangements should be made to create a program for long-term management of long-lived wastes.

• Implement policies that provide incentives to minimize further production of long-lived radioactive wastes. Specifically, when the federal government accepts spent fuel (at the appropriate time), it should be limited only to that generated by existing nuclear power plants. This agreement should not extend to any new nuclear power plants or to spent fuel produced as a result of license extensions for existing power plants. (See endnote #5 in main article.)

• Establish consistent, health-based standards to govern nuclear waste management and disposal, irrespective of the process that produced those wastes. These standards should protect future generations by setting strict limits on contamination of the environment, including stringent limits on groundwater contamination. The duration of the standards should correspond to the period of time over which a risk of doses in excess of standards persists.

• Ensure that the institutions responsible for waste management understand and welcome public participation in decision-making.

1. IEER's recommendations are based on our 1992 report, High-Level Dollars, Low-Level Sense.

2. See A. Makhijani and S. Saleska, The Nuclear Power Deception.

3. For more on depleted uranium and uranium hexafluoride, see "Dear Arjun" in SDA Vol. 5 No. 2.