Ten
Commandments of Radioactive Waste
Blue Ridge Environmental Defense League Board of
Directors approved this policy at its 9/18/99
meeting
1. So-called low-level radioactive waste is a
complex mixture of waste streams that should be
dealt with separately. Radioactive wastes should
not be mixed indiscriminately together, but
should be separated by half-life, decay energy,
mobility, and potential for biological uptake. In
general, the separated waste streams should be
dealt with differently.
2. North Carolina should not attempt to deal with
all wastes at one stroke, in a single facility,
and by a single method. Short-lived medical
wastes can be stored to decay. Reactor wastes,
including decommissioning wastes, pose a
long-term problem of national character and may
ultimately require deep geological storage.
3. In seeking to determine how wastes should be
handled, North Carolina should concentrate first
on wastes produced under state license. It may be
more appropriate to regard wastes produced under
federal license as a federal, rather than a state
or local, responsibility.
4. North Carolinians must be protected from the
risks associated with potentially inadequate
regulatory oversight. The state must insist on
its ability to set stricter than federal
standards. In addition, citizens should have the
statutory right to use citizens suits to force
licensee compliance with radiological standards,
when regulatory oversight is inadequate.
5. Dilution and/or release, including sanitary
sewer disposal or incineration, are generally
inappropriate methods for handling radioactive
waste.
6. Disposal options alone cannot solve the
radioactive waste problem. Minimization of
produced waste volumes and activities is
essential for long-term solutions. North Carolina
should adopt a state policy opposing activities
which increase radioactive waste volume or
hazard. For example, under such a policy
the state should officially oppose the use of
plutonium fuels in nuclear reactors, since
plutonium fuel use would increase the hazard and
volume of expected radioactive wastes.
7. Any effective state policy must include
disincentives for waste production. An effective
state policy could include incentives, such as
time-limited tax credits, for development and
permanent adoption of technologies and processes
which do not produce radioactive waste.
8. Any radioactive waste treatment or disposal
facilities licensed by the state must isolate the
waste for the full hazardous life of the
waste. Legislation implementing the state
policy should establish that users of such waste
treatment or disposal facilities retain title to
the waste and remain jointly and severally liable
for environmental effects of the facility.
Legislation implementing the state policy should
further establish a rebuttable presumption that
the operator and users of radioactive waste
treatment or disposal facilities are responsible
for radioactive contamination within five miles
of the facility and of transportation routes to
the facility: that is, near waste treatment or
disposal facilities. Courts would presume
that the operator and users were responsible for
any radioactive contamination, unless the
operator and users could prove otherwise.
9. The costs of radioactive waste treatment or
disposal, and the cost of any radioactive
treatment or disposal facility, are primarily the
responsibility of radioactive waste generators
and, as such, should be borne by the generators.
North Carolina taxpayers are not responsible for
providing relief to waste generators. Regulatory
agency fees should be high enough to cover
reasonably expected inspection costs. Violation
of state license conditions should result in
required posting of a secure bond; repeat
violations should result in loss of state
license.
10. Consistent with the above objectives, North
Carolina should not license any facilities with
the potential to become regional, multi-state, or
national disposal sites. North Carolina policy
should not allow waste generators to import waste
from other states for disposal.
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