[greenyes] Act Now! Stop Radioactive poisoning of Recycling! Nuclear Regulatory Commission rulemkg.

["Diane D'arrigo" <dianed@no.address>]

RadiationThreat: NUKE WASTE to MAKE TOYS, TOASTERS & TOOTHBRUSHES?!

NOW is your chance to tell the Nuclear Regulatory Commission how much
nuclear power waste YOU want in unrestricted or ?restricted? commercial
daily use! And in your local landfills as if it were normal trash.

On Feb 28, 2003, the US NRC published in the Federal Register a notice
of rulemaking on ?controlling the disposition of solid materials.? (68
FR 40: 9595-9602). The comment deadline is June 30, 2003.
Public Meeting to be held at NRC headquarters in Rockville MD on May 21
and 22, 2003. THIS IS THE ONLY PUBLIC MEETING FOR THE SCOPING PERIOD.

Although the ?solid materials? upon which NRC is focusing could be
contaminated with plutonium-239, strontium-90, cobalt-60 or any
radionuclide from nuclear power production, NRC likens the dilemma of
what to do with them to any other industrial or household cleanup
effort.

SUGGESTED ACTIONS:
* Send Comments, Resolutions, etc to NRC and cc: US Reps & Senators
* Write Letters to Editors, * Get articles in newsletters, * Circulate
flyers
* Get group statements and send them in.
*Contact your local recyclers to get them to comment
*Call out the dogs!

HOW AND WHERE TO COMMENT:

By June 30, 2003, send your written comments, resolutions and any other
creative responses to the US Nuclear Regulatory Commission at

Email Address: secy@no.address

Mail Address: Secretary, US Nuclear Regulatory Commission, Washington,
DC 20555 Attention: Rulemaking and Adjudications Staff

Upload onto the NRC website at
http://ruleforum.llnl.gov/cgi-bin/rulemake?source=SM_RFC&st=ipcr

Be sure to send a copy to us here at NIRS (dianed@no.address) and to your
elected local, state and federal officials and decision makers.

Encourage them to comment by the June 30 deadline too?ideally along with

laws or resolutions requiring licensed regulatory control over all
radioactive waste and contaminated materials.

CONTENT: THE CHOICES:
NRC is offering 5 alternatives for radioactive waste ?

1. Continue unrestricted release using measurement-based guidelines.
Keep releasing radioactive materials into commerce on a case-by-case
basis, through license provisions and through the licensed processors
and facilities.

2. Continue unrestricted release in a more comprehensive way- setting
unverifiable ?dose-based? levels that the nuclear generators will
calculate.

3. ?Conditional Use?
Radioactive materials could be released but would supposedly have
restricted uses that would allegedly give lower doses than fully
unrestricted release. There would be no follow-up to guarantee that the
material remained in the ?restricted? or ?conditional use as long as the

radioactivity is present.

4. Disposal in EPA-regulated landfills.
These include regular garbage dumps and hazardous waste dumps, neither
of which are regulated for radioactive materials.

5. Disposal in NRC or Agreement State licensed radioactive disposal
sites.

In addition to the methods (Alternatives 1-4 above) for releasing
radioactive wastes into commerce, NRC also wants comments on how much
radiation dose we want to receive from deregulated waste.  Since various

pronuclear committees have chosen 1 millirem/year as a ?trivial? dose,
even though that dose can never be verified or proven trivial, NRC wants

to know what we think about that ?or if we might want more or less
radiation dose from deregulated radioactive wastes and materials. The
Feb. 28, 2003 Federal Register notice is vague about what a 1 millirem
dose criterion means?whether it is per waste type, per item, per
facility, and how many of these ?negligible? doses we can get, but it
refers to other NRC documents for more discussion.

Keep in mind one of NRC?s goals is to reduce regulatory burden on
stakeholders, which really means on nuclear waste generators. You could
give NRC your opinion on this.

NIRS' POSITION is that the burden of calculating dose and determining
where each waste goes is greatly reduced if the waste is simply treated
as nuclear waste and not released at all. As we have commented many
times to NRC and DOE and DOT and EPA on this topic, we call for all
radioactive waste and any materials contaminated with radioactivity from

the nuclear fuel chain to be kept regulated in specifically licensed
facilities with the goal of isolating it from the environment and
preventing human (and other species) exposure.

BACKGROUND:  The Nuclear Regulatory Commission has been trying for
nearly twenty years to legalize deregulating nuclear waste. But the
American public has stopped them over and over. So, having won the last
few rounds, we have the opportunity to fight again. This time the NRC is

coming in with rigged and biased studies and policies of nuclear
promoters around the world (that in many cases NRC helped write or fund)

that claim to predict the doses the public will receive from the nuclear

waste that gets made into cars, chairs, baby strollers, walls or
hip-replacement joints. These are intended to provide ?scientific
justification? for allowing nuclear waste to go out of regulatory
control and into the marketplace.

The public is being asked to tell NRC what the ?scope? (range of issues)

to be addressed should be. For example, should radioactive concrete be
used to make basements or just bridge abutments? How much radioactivity
should be permitted in the metal used for pipes, dental braces,
intrauterine devices, belt buckles, frying pans and tableware? Should
radioactive soil be used for agricultural land or playground fill?
Should radioactive asphalt be used for parking lots and bike paths?

NRC plans to make a regulation to be added to its radiation standards
that sets a legal range of public exposure to deregulate nuclear waste
and sets a standard that will allow radioactively contaminated solid
materials to be released from regulatory control.

Metal and concrete are the largest volumes of materials threatened but
other materials are also being deregulated, including but not limited to

soil, asphalt, building rubble, equipment, tools, glass, plastic, paper
and sites themselves.

Although the rulemaking applies to waste generated by all commercial
nuclear waste generators and licensees, nuclear power reactors and their

support facilities along the fuel-chain generate the vast majority (in
volume and radioactivity) of nuclear waste contaminated with
long-lasting (into the millions of years) radioactivity.

To justify releasing and reusing contaminated radioactive metal and
concrete, NRC is relying heavily on an SAIC (Science Applications
International Corporation)--produced document (NUREG 1640). It was
generated by SAIC for NRC while SAIC was fulfilling a $286 million DOE
contract to recycle radioactive metal from nuclear power and weapons
fuel enrichment. Although the company was let go when the conflict was
made public, NRC is still using this document to justify this
rulemaking.

MORE INFO:
Contact Diane D?Arrigo at NIRS dianed@no.address, 202 328-0002 ext 16
NIRS website (being updated) www.nirs.org/radrecycle/recyclehome.htm

Federal Register notice:
http://ruleforum.llnl.gov/cgi-bin/downloader/SM_RFC_lib/515-0045.htm?printable=1

nrc website:
http://ruleforum.llnl.gov/cgi-bin/rulemake?source=SM_RFC&st=ipcr