[greenyes] Oppose EPA Proposal to Weaken Rad Waste Standards!

["Maine, Bruce" <Bruce.Maine@no.address>]

Forwarded from the RADMETAL listserv:

The U.S. Environmental Protection Agency (EPA) has issued an advance
notice of proposed rulemaking regarding the "management and disposal of
low-activity radioactive waste" that creates the possibility for
dangerous nuclear waste to be disposed in dumps and landfills that are
not licensed for or designed to contain it. This would permit certain
radioactive wastes to be treated as if they were actually
non-radioactive, and therefore exempt from standards designed to isolate
and contain radiation, and prevent forced radiation exposures to the
public.

Tell the EPA to retract this harmful, regressive policy!  The deadline
for submission is midnight on March 17.*  Submit prepared comments to
the EPA via Public Citizen's Web site at this URL:
http://action.citizen.org/pc/issues/alert/?alertid=5325981

(Sample comments are available on this page, which you may send as-is
or modify if you so choose.)

Why would the EPA, the primary federal agency with the stated mission
"to protect human health and to safeguard the natural environment,"
actually suggest that we roll back existing regulations on the
management of nuclear waste materials? One major reason that the agency
would suggest that a "non-regulatory approach" for managing nuclear
waste be considered is that such an approach could save the nuclear
industry millions of dollars, since it always costs less money to dump
nuclear waste in a regular community landfill (where your household
trash is sent) than it does to properly store the waste in a licensed
facility. The EPA worked with the Nuclear Regulatory Commission (NRC) --
the federal agency charged with regulating nuclear reactors, materials,
and wastes, which originated the reckless concept that some nuclear
wastes are "Below Regulatory Concern" -- in developing this proposed
rulemaking. This could explain why the EPA is interested in "partnering"
with nuclear waste generators to find creative ways to ease the
"regulatory burden" on such companies. The NRC has developed a
reputation as an agency that coddles the industry it is supposed to be
regulating. If the EPA works with the NRC on nuclear waste matters, a
move towards deregulation should not be unexpected.

There are several distinct problems with EPA's rulemaking proposal:

(1) It introduces an option to allow mixed radioactive and hazardous
wastes to be dumped in facilities that have permits only for hazardous
wastes. This is unacceptable, since hazardous waste dumps are not
designed to isolate and contain radiation, and there has not been
substantial research into how radioactive and chemical pollutants react
synergistically in the environment and the human body.

(2) It introduces an option to allow radioactive waste (that is not
mixed with hazardous) to go to sites that do not have licenses or
regulations for handling it, such as standard garbage dumps (sometimes
known as "sanitary landfills"), incinerators, or hazardous sites.
Without maintaining specific, stringent regulations at facilities that
can accept radioactive waste, adjacent communities face the hazard of
radioactive contamination, as many existing facilities leak.

(3) The EPA's "non-regulatory approach" to managing waste by
"partnering" with nuclear waste generators works to protect industry,
not the public. EPA's notice of proposed rulemaking does not describe
how nuclear fuel cycle radiation will be isolated and contained from the
environment and human contact for its entire hazardous lifetime.
Further, the notice does not explain how the newly suggested approaches
for managing waste will serve to further the EPA's mission "to protect
human health and to safeguard the natural environment," whereas it is
clearly noted that simplification and reduction of the "regulatory
burden" are desired goals. No regulatory barriers are described that
would prevent the nuclear wastes at issue from going to recycling
facilities and contaminating the recycling streams which feed the
production of everyday household items like cookware, toys, cars, and
furniture. No barriers are described that would keep commercial projects
such as roads, bridges and buildings free of this contamination.

(4) The EPA's proposal merges with, and would facilitate, the NRC's own
rulemaking to deregulate and release radioactive waste materials from
control, a process ironically called "Control of Solids." The two
agencies are working to redefine radioactive materials/waste, using
industry-friendly science that plays down health and environmental
concerns, so that waste which has heretofore been regulated and
contained can be released to unlicensed landfills, incinerators or even
recyclers, where it would have routine contact with the public and the
environment.

Two other agency-based campaigns of regulatory rollback will also
increase the risk of forced radiation exposures to the public:

1.The NRC and the Department of Transportation have recently finalized
new transport regulations that will exempt various levels of hundreds of
radionuclides from regulatory control during transit. Any wastes that do
not require regulation, labeling, manifesting, or other controls during
transport will be easier for waste generators to get rid of, after the
wastes leave the point of production. Considering heightened terrorist
concerns in a post-9/11 world, it is particularly disturbing that
additional unregulated materials could be on roads, rails, barges and
aircraft, providing further fuel for dirty bombs.

2.The Department of Energy is in the midst of a Programmatic
Environmental Impact Statement to address the release of radioactive
metals from its sites.

Right now, it is important that you send your comments to the EPA so
that the agency terminates any plans to foster deregulation of
"low-activity" radioactive wastes, and dump them in landfills. Submit
comment to the NRC here:
http://action.citizen.org/pc/issues/alert/?alertid=5325981

Public Citizen's full comments to the EPA will be posted soon on our
"Radioactive Recycling" Web site:
http://snipurl.com/50ba

* The EPA comment period may be extended, per requests from Public
Citizen and other groups.  We will notify you in this eventuality.

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