Radioactive Household Items? Comment to NRC by DEC 22, 1999!!
Tell the NRC what you think about Radioactive Household Items and Atomic
"Recycling" into the marketplace, regular landfills and our lives!
THE PROBLEM: The Nuclear Regulatory Commission (NRC) is scheming with
the nuclear industry and its allies at other federal agencies, like the
EPA and Dept. of Energy (DOE) to "RECYCLE" RADIOACTIVE WASTE INTO
HOUSEHOLD PRODUCTS! This saves the nuclear power industry and DOE
weapons contractors money by allowing them to "sell" radioactive waste
to be used in our homes, schools, cars, workplaces, and more. Although
the government already allows atomic waste into commerce on a
case-by-case basis, the NRC is now legalizing routine release of massive
amounts of radioactive metal, concrete, plastic, soil, and other
material from commercial nuclear power and weapons sites, directly and
via commercial processors, into daily-use items.
THE PROCESS: COMMENT to NRC by DECEMBER 22, 1999.
To make a new rule legalizing radioactive waste "recycling" or
"clearance" into the marketplace, the NRC is required by the National
Environmental Policy Act (NEPA) to consider all potential impacts and
options. The NRC Commissioners have clearly directed the staff (6/30/98
Staff Requirements Memo) to "promulgate aregulation that allows
quantities of materials to be released." The "scoping" process required
by the NEPA expires on December 22, 1999. This is the time when the
public has the chance to tell the NRC what should be considered in the
rulemaking. NIRS and Public Citizen have requested a minimum 8-month
extension for public comment.
It is extremely important that the NRC hear from the public during this
time. Let NRC know how you feel about any level of radioactive
"release," "clearance" and "recycling." Demand that the NRC prohibit
radioactive releases and recapture the nuclear waste already let out. It
is your chance to inform the NRC about the amount of radiation you and
your family and progeny are willing to take so that the nuclear waste
generators can save money. (For more information: 64 Federal Register
35090 June 30, 1999-the issues paper which NRC staff developed to
"discuss" the various ways to dump nuclear waste into commerce.)
WHAT YOU CAN DO:
->COMMENT TODAY-or ASAP before Dec 22 for yourself and your
organizations.
(You can use our sample below, which was presented on behalf of over a
dozen national and international organizations to NRC on Nov. 1, 1999.)
CC: US Reps and Senators.
->Get resolutions or letters from groups or local government entities to
submit to NRC. Again cc your Congressperson and Senators and state and
local officials.
-> Request an extension on the comment period for "scoping" this
rulemaking so organizations and governments have time to learn and
respond and have legal standing.
WHERE/HOW TO COMMENT:
Mail your comments by December 22, 1999 to
NRC Chairman Richard Meserve/U.S. NRC/Washington, DC 20555
Attention: Rulemaking and Adjudications Staff
or
Email the comments to avc@nrc.gov
or
Submit electronically through the NRC's website:
http://ruleforum.llnl.gov/cgi-bin/uploader/SM_RSC_public
In order to submit comments through the website, you must save your
comments in your files and remember the file name. Go to the NRC
website. Fill out all of the fields they request. Hit the BROWSE button
on the NRC website and find your file. Attach it.
SAMPLE STATEMENT:
Dear Chairman Meserve:
I am writing to call on the Nuclear Regulatory Commission to isolate
radioactive wastes and materials and anything they contaminate, no
matter what level. The radioactive legacy of atomic energy and weapons
production should be isolated from the public and the environment.
The NRC should also extend the comment period on releasing radioactive
waste into commerce to at least September 2000. This issue is too
important to act hastily upon and it should be fully debated by the
public. The public has spoken repeatedly before on this issue and needs
time to be informed that subject is open again or still.
NO MORE RADIOACTIVE RELEASES
We still do not want nuclear power and weapons wastes "released,"
"cleared," deregulated, exempted, generally licensed, designated "de
minimis," "unimportant," "trivial" or BRC-below regulatory concern, or
by any other creative, direct or deceptive means, allowed out of nuclear
facilities and into the marketplace or the environment, at any level.
TRACK AND RECAPTURE ALREADY-RELEASED RADIOACTIVE WASTES
The current methods of releasing radioactive wastes from commercial
licensees and weapons facilities must immediately cease. No future
radioactive releases should be permitted and a full accounting and
recapture of that which has already been released should commence.
PREVENT AVOIDABLE RADIATION EXPOSURES and RISKS
Using radioactive wastes in consumer products poses unnecessary,
avoidable, involuntary, uninformed risks. The consumers, the producers,
the raw materials industries don't want these radioactive wastes or
risks.
COMPUTER MODELS NOT ACCURATE, RELIABLE, VERIFIABLE
It is not credible to believe computer models can calculate and
accurately predict any or ALL of the doses to the public and the
environment from all of the potential radioactivity that could be
released over time. Projections of "acceptable" or "reasonable" risks
from some amount of contamination being released are meaningless and
provide no assurance. Monitoring for the specific types and forms of
radioactivity that could get out can be very expensive and tricky to
perform. Hot spots can sneak through. We can't trust the nuclear
generators to monitor their own releases.
EXPENSIVE TO MONITOR; IMPOSSIBLE TO VERIFY OR ENFORCE RELEASES
No matter what level the NRC sets for allowable radiation risk, dose or
concentration, it will be difficult to impossible to measure, verify and
enforce. Who is liable if the "legal" standards NRC intends to set are
violated? For decades the public has clearly opposed releasing
radioactive materials into commerce. We continue to do so.
EXISTING RADIATION DOESN'T JUSTIFY DELIBERATE ADDITIONS
Naturally occurring background radiation cannot be avoided (except in
some instances for example, reducing radon in homes) but its presence in
no way justifies additional, unnecessary, involuntary radiation
exposures, even if those exposures might be equal to or less than
background. Nor does it justify shifting the economic liability from the
generators of radioactive wastes and materials to the economic and
health liability of the recycling industries, the public and the
environment.
SUPPORT METAL INDUSTRIES' "ZERO TOLERANCE" OF CONTAMINATION
We fully support the complete opposition and "zero tolerance" policies
of the metal and recycling industries, the management and the unions. We
appreciate their efforts, not only in opposition to legalization of
radioactive releases, but in their investment in detection equipment and
literally holding the line against the radioactive threat to the public.
They should not have to be our de-facto protectors. The NRC, DOE and EPA
must act to prevent the dissemination of radioactive wastes into
recycled materials and general commerce. The problems that have been
experienced by the steel recycling industry with "generally-licensed
sealed sources" getting into their facilities and costing tens of
millions of dollars to clean up should serve as a warning not to let any
other radioactive wastes and materials out of regulatory control.
US AGENCIES MUST PREVENT FUTURE AND RECAPTURE PAST RELEASES,
PUSH INTERNATIONAL PROHIBITION
The fact that radioactive waste is already getting out should not be
used to justify legal levels allowing more out. The NRC, EPA and DOE
should prevent future and correct past releases. The fact that other
countries are releasing radioactive materials into the marketplace is no
excuse for us to legalize it. The United States should take the lead in
preventing contamination of the international marketplace. We protect
ourselves best by not facilitating international radioactive commerce.
The fact that it is difficult and expensive to monitor and detect
radiation does not justify its release. It is all the more reason to
prevent any wastes getting out, so we don't have to check routinely for
contamination. The nuclear industry and regulators should be aware of
what materials at reactor and weapons sites are wastes and which have
been contaminated. Those materials must be isolated, not released, at
any level.
NRC HAS CLEARLY DECIDED TO RELEASE-THIS MUST BE REVERSED
The mindset of the NRC appears convinced that it should legalize
radioactive wastes being "recycled" into the marketplace. The NRC has
stated in its Staff Requirements Memo that the standard must allow
"releases" to take place and that all radioactive materials will be
eligible for "clearance." This means that the NRC is not seriously
examining all of the options available, such as non-release, even though
the National Environmental Policy Act (NEPA) requires all options to be
considered.
NRC CONTRACTOR (SAIC) HAS CLEAR CONFLICT OF INTEREST
Furthermore, the NRC is relying on a private contractor called Science
Applications International Corporation (SAIC) to prepare the technical
basis for the proposed regulation. This is a blatant conflict of
interest. The NRC has not publicly disclosed the relevant economic
interests of SAIC. The NRC has not notified the public that SAIC has
simultaneously been working with or for other corporations with
substantial economic interests in the Commission's determinations in
this rulemaking. In particular, since mid-1996, SAIC has been the
teaming partner of British Nuclear Fuels, Ltd. (BNFL) under a quarter
billion DOE contract for recycling unprecedented amounts of contaminated
radioactive metallic waste from the Oak Ridge TN uranium enrichment
buildings. This situation calls into question the legality of the entire
NRC process.
EXTEND COMMENT PERIOD
Since NRC is attempting to cover its requirements under NEPA to
establish this radioactive "release" rule, the public comment period
should be extended to allow the public the opportunity to hear about and
comment on the proposal.
In conclusion, we call on the NRC to serve the interests of the public
instead of the nuclear industry and
#1 prohibit the release of radioactive materials into commerce,
landfills and incinerators
#2 identify, track and recapture the radioactive waste that has already
been released from nuclear power and weapons facilities by federal and
state regulators
#3 give the public at least 8 more months to comment.
Sincerely,
WHERE/HOW TO COMMENT:
Get your comments to NRC by December 22, 1999 by mail or e-mail to:
NRC Chairman Richard Meserve/U.S. Nuclear Regulatory Commission
Washington, DC 20555/Attention: Rulemaking and Adjudications Staff
or
E-mail your comments to avc@nrc.gov
or
Attach your comments file through website at
http://ruleforum.llnl.gov/cgi-bin/uploader/SM_RSC_public
For more info look at the NIRS and Public Citizen's Critical Mass Energy
Project websites: www.nirs.org and www.citizen.org/cmep/
NRC has a website for this rulemaking:
http://ruleforum.llnl.gov/cgi-bin/library?source=*&library=SM_RFC_lib&file
=*
Contacts: NIRS 202-328-0002 ext. 2 or Public Citizen 202-546-4996.
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