Radioactive Waste Management Policy has only three categories:
- Waste Production
- Waste Storage
- Waste Disposal
Waste Production is the generation and collection of waste products from the mining, processing, fabricating, handling, decommissioning and contaminating of the derivative desired infrastructures and products. Note that decommissioning is a Waste Production activity and not a stand-alone waste production process. Waste minimization is an over-riding consideration in the Radioactive Waste Management Policy, particularly under the Waste Production category where the vast balk of the waste is produced.
Waste Storage is the temporary and safe containment of the waste products until appropriate waste disposal facilities are built and enter operation.
Waste Disposal is the active construction, operation and ultimate closure of approved facilities to permanently and safely contain and isolate the radioactive waste for the long-term protection of the people and environment.
As mentioned previously, decommissioning is a Waste Production process. It is not, and should not be, a Waste Disposal process and should not be confused as such by poor language. Great pains are made to define the term “In-situ Decommissioning” in which “… some or all of the radioactive contaminants are disposed of in place, which may result in the creation of a waste disposal site.” If it is disposed in place, then it “is” a disposal site, not “may create a disposal site.” The discussion of “In-situ Decommissioning” should be retitled as “In-situ Disposal” and should be solely discussed under the Waste Disposal process.
The discussion of decommissioning research and development (R&D) legacy sites uses the weak argument that their initial design and construction did not consider decommissioning as part of the design process. This does not prevent the taking of proper action to remediate this historical omission. Proper engineering plans and designs for remediation options should be undertaken and be impartially reviewed and evaluated before any decision for In-Situ Disposal is ruled upon to eliminate bias. The current unavailability of an operating disposal facility should not be a consideration as this does not pertain to other non-R&D legacy facilities.
Waste minimization is briefly discussed since decommissioning will, not may, produce radioactive and other hazardous wastes which must also be disposed, not hidden under the guise of the weaker term, managed.