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Blended Waste Talking Points

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Blended Waste Talking Points Questions for Utah Division of Radiation Control officials on their decision to allow blended waste disposal in Clive 1. Did Utah regulators consider how blending disposal would increase the total load of radioactivity at the Clive site? Did regulators consider Studsvik’s earlier claims that disposal of blended wastes at Clive was unsafe? The company which is now seeking to blend waste with EnergySolutions – Studsvik, a Swedish nuclear services company – just last year told Utah regulators that Clive was not a safe location for disposing of blended waste. A news story quoted company counsel Joseph DiCamillo, “Studsvik believes it is important that the NRC recognizes that blended waste presents saFety and environmental issues that are more challenging than" the waste EnergySolutions normally takes at Clive. Earlier, Studsvik lobbyist Randy Horiuchi said blending was just a way For EnergySolutions to slip hotter waste into the Clive site, calling it "a disguise -- a Fake nose and glasses." In addition, Studsvik did preliminary analyses suggesting that bringing blended waste to Utah will result in a massive increase in radioactivity which arrives each year at the Clive site. Its analysis, entitled “Estimated Increase in Radioactivity with Downblended Waste Resins at Clive, Utah Facility” is based upon data From the Electric Power Research Institute, the journal Radwaste Solutions and from EnergySolutions itself. It concludes that blended waste, under various scenarios, would result in an annual increase in this kind of nuclear power plant waste brought to the Clive site of between 700 and 844 percent. 2. Did the Division consider the positions of Gov. Herbert and the Radiation Control Board – and their own positions from 2010 — before approving EnergySolutions’ blending proposal? In issuing this approval, the Division is acting against the Radiation Control Board, Gov. Herbert – and even the Division’s own statements From last year. Former Division Executive Director Dane FinerFrock commented on a draFt U.S. Nuclear Regulatory Commission memo on blending nuclear waste in Jan. 2010. In those comments, he wrote, “Utah is opposed to waste blending as the intent is to alter the waste classiFication For the purposes of disposal site access.” At a Radiation Control Board meeting in Jan. 2010, DEQ chieF Amanda Smith discussed FinerFrock’s comments. The meeting minutes notes, “Ms. Smith said the Division shared the comments and position on waste blending with the Governor’s OfFice. The Governor agreed with the Division’s comments.” Finally, the Utah Radiation Control Board adopted a policy statement in April 2010 that says, “The Board is opposed to waste blending when the intent is to alter the waste classiFication For the purposes oF disposal site access.” Since then, Board members on several occasions this summer asked Division stafF whether EnergySolutions’ proposed SemprasaFe scheme serves any purpose other than to avoid Utah’s ban on hotter than class A wastes. Division stafF said no. HEAL Utah * www.healutah.org * 801-355-5055 824 South 400 West, Suite B111, Salt Lake City, Utah 84101 3. Why isn’t the Division ordering EnergySolutions to conduct “a site-specific performance assessment” before it rules on whether it’s appropriate to accept blended waste at the Clive facility? Isn’t this what the Board envisioned in February? Isn’t this clearly what the NRC is planning on requiring states to do, based on its ongoing memos and rule-making on blended waste and unique waste streams? The Radiation Control Board in February passed a rule (Rule R313-25-8) which orders applicants such as EnergySolutions to conduct a detailed technical review (“a site-speciFic performance assessment”) oF “unique” waste streams, wastes which considered back in 1982 when the NRC developed its rules on low- level radioactive waste. The NRC itself explicitly considers blended waste to be a unique waste stream and is in the midst oF developing rules to address it. As a Feb. story indicated aFter the board passed its rule: “Board Chairman Peter Jenkins noted that the NRC still considers large quantities oF blended waste a "unique waste stream" and that, under the board's new regulation, EnergySolutions will have to demonstrate that the blended waste will stay put over the long run before it can come to Utah.” 4. Why aren’t Utah officials ordering a “case-by-case evaluation of blended waste,” as federal guidelines require? In its Feb. 14 document seeking Utah regulatory approval, EnergySolutions selectively quotes From an Oct. 2010 NRC memo on blended waste in order to imply that Federal oFFicials endorse the company’s approach. The part of the NRC memo the company omits, however, requires them to do a site-speciFic technical review. The company quotes the NRC memo saying, “disposal Facilities may saFely accommodate an increase in the amount of disposed waste at or just below the Class A limits.” However, EnergySolutions Fails to acknowledge the sentence which comes immediately before that one: “The guidance would recommend a case-by- case evaluation of blended waste for each site that plans to accept this type of waste For disposal.” 5. Why aren’t Utah officials ordering EnergySolutions to conduct detailed intruder scenarios? Lastly, the recent NRC blended waste memo also calls For detailed intruder scenarios, assessments oF what could happen many years From now when the Clive facility is closed. What risks are posed iF a Future individual or community seeks to settle, explore, drill, mine, Farm or engage in other activities at the Clive site? SpeciFically, the Oct. 2010 NRC memo calls For “a site-specific intruder analysis, which is a risk-informed, performance-based approach to addressing blending, would be mandated in the rulemaking For unique waste streams…Under this approach, disposal of large amounts of blended waste would have to be evaluated for intruder protection on a site-speciFic basis.” HEAL Utah * www.healutah.org * 801-355-5055 824 South 400 West, Suite B111, Salt Lake City, Utah 84101 .
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