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.
* Sign the Statement of Opposition on Public Citizen's webpage
http://www.citizen.org/cmep/energy_enviro_nuclear/nuclear_waste/low-level/recycling/
*Contact your local recyclers to get them to comment
*Call out the dogs!
HOW AND !QW! 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@nrc.gov
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@nirs.org) 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 !QW! 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@nirs.org, 202 328-0002 ext 16
NIRS website (being !QU!d) 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
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