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Stop Exposure to Recycled Nuclear Waste- Comment to

NRC-legislators-papers

 

 

 

The Nuclear Regulatory Commission (NRC) is testing the political winds for

our tolearance for re-using some radioactive materials in consumer products.

Nuclear waste keeps on piling up and there is not enough room to put it.

They

will call it " low level waste " that will take years to cause illness and

death.

But these people have to die sometime, they'll never be able to prove it

came

from radioactive exposure if the NRC and the Environmental Protection

Administration (EPA) spreads around enough grant money to fund extensive

research

projects at major nuclear,military contracting and educational institutions.

Letters to the Editor of your local newspaper is important. If they get

enough mail,

they will print some of it.

arnold

 

 

[ Go to this URL for an interactive Web version of this action alert:

http://www.citizen.org/cmep/energy_enviro_nuclear/nuclear_waste/low-evel/rec

yc

ling/articles.cfm?ID=8960

]

 

Stop Radioactive Materials Deregulation and Recycling!

 

May 22, 2003

 

The U.S. Nuclear Regulatory Commission is Determined to Recycle

Radioactive Waste! It's Time to Collect our Forces and Demand a

Permanent End to this Outrageous Practice!

 

On February 28, 2003, the U.S. Nuclear Regulatory Commission published

a notice in the Federal Register (68 FR 40: 9595-9602) calling for

stakeholder comments on the proper scope of its proposed rulemaking on

" controlling the disposition of solid materials. "

 

Don't be fooled, however: " control " has nothing to do with what they're

>planning. It's about deregulating nuclear wastes. This is the primary

rulemaking to determine whether or how NRC-licensed facilities (i.e.,

commercial nuclear power reactors) can incinerate, " release, " " reuse, "

or " recycle " many forms of nuclear wastes-metal, concrete, soil,

plastics, chemicals, etc.-thus allowing them to end up in your local

landfill, incinerator, or even in common consumer products that you find

on your local store shelves!

 

Tell the NRC to PROTECT the public by requiring the ISOLATION and

proper disposal of all radioactive waste!

 

SUBMIT YOUR COMMENTS TO THE NRC BY JUNE 30, 2003:

 

Mail: Secretary, U.S. Nuclear Regulatory Commission, Washington, DC

20555. Attention: Rulemaking and Adjudications Staff.

 

Web: Upload comments via the NRC's rulemaking Web site at:

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

 

SUGGESTED COMMENTS:

 

[View a draft of Public Citizen's comments to the NRC here:

http://www.citizen.org/documents/radrecyclingrule.pdf ]

 

The scope of the U.S. Nuclear Regulatory Commission's (NRC) proposed

" rulemaking on controlling the disposition of solid materials " should be

reatly limited to only those regulatory options which would strictly

prohibit the deregulation of any solid materials with detectable

radioactivity, and require that such materials be disposed of only in

secure, licensed facilities that are designed to isolate such

radioactive waste from humans and the environment.

 

The NRC accepts the validity of the linear, no-threshold (LNT) model of

>human exposure to radioactivity, which holds that " any increase in dose,

no matter how small, results in an increase in risk " to human health.

But despite this, the Commission is obstinately pursing a contradictory

proposal that would, in fact, result in exposing the public to greater

doses of radioactivity! This sentiment is revealed in the statement of

NRC Chairman Richard Meserve, contained in the NRC Commission Voting

Record of October 25, 2002, in which he advised that " it would not be

appropriate to mask the Commission's continuing support for the release

of solid material. " It is a travesty of proper government regulation

that the NRC is pursing, in effect, a subsidy worth billions of dollars

that rewards waste generators for irresponsibly scattering their waste

into the unregulated environment and ducking responsibility for any of

the consequences.

 

Under absolutely no conditions should nuclear waste with detectable

radioactivity be deregulated and allowed into general commerce.

Therefore, the current scoping process, which offers for serious

consideration several alternatives that would allow such a dispersal of

radioactive waste, is an affront not only to human health and ecological

integrity, but also to the duty of the NRC.

 

The NRC's mission to " ensure adequate protection of public health and

safety " can only upheld by establishing permanent policy wherein all

radioactive material waste is restricted from general commerce and

required to be disposed of in an NRC- or Agreement State-licensed

low-level waste disposal site, best articulated as " Alternative 5 " in

the notice published in the Federal Register on February 28, 2003.

 

MORE ACTION:

 

SIGN your organization on to the Statement Opposing Radioactive

" Recycling " and Deregulation of Nuclear Wastes by providing your name,

position, the name of your organization, its address, telephone and fax

numbers to Joe Malherek at jmalherek or 202-454-5109. View

the statement here:

http://www.citizen.org/cmep/energy_enviro_nuclear/nuclear_waste/low-evel/rec

yc

ling/articles.cfm?ID=8417

 

 

REQUEST a Public Citizen activist kit on this issue, and press your

local government (city councils, state legislatures, etc.) to pass a

resolution opposing radioactive " recycling. "

 

SEND COPIES of your comments to your elected state and federal

officials to call their attention to the NRC's shirking of its duty to

protect the public from exposure to hazardous radioactive materials

produced by the nuclear industry. Find out how to contact your federal

elected officials here: http://www.congress.org/congressorg/home/

 

WRITE letters to the editor and submit articles to your local

newspaper. Make the public aware of this very public issue!

 

MORE INFORMATION:

 

View a draft of Public Citizen's comments to the NRC here:

http://www.citizen.org/documents/radrecyclingrule.pdf

 

View the Federal Register notice calling for comments on the proposed

rulemaking here:

http://a257.g.akamaitech.net/7/257/2422/14mar20010800/edocket.access.gpo.gov

/2

03/03-4752.htm

 

 

Check the NRC Web site for updates on this rulemaking process:

http://ruleforum.llnl.gov/cgi-bin/library?source=html & library=SM_RFC_info &

file=news & st=ipcr

 

 

BACKGROUND INFORMATION:

 

While the NRC currently allows the deregulation of " slightly

radioactive " materials to occur on a " case-by-case " basis, their goal is

to " standardize " the practice, thus making it easier and cheaper for the

nuclear industry to dump tons of nuclear waste onto the public. While

the NRC officially agrees with the basic scientific principle that any

amount of radiation poses real health risks to humans, they are

simultaneously caving in to nuclear industry influence, and attempting

to set arbitrary and dangerous " standards " that would allow us to be

regularly exposed to additional radiation risks.

 

Clearly, the only way for the NRC to fulfill its stated mission to

" protect public health and safety " would be for the agency to prohibit

any radioactive waste from being " released " from strict control. There

is no " acceptable " level of radioactivity that could be added to the

many industrially-produced objects we come in daily contact with.

Products created wholly or partially from radioactive waste materials

are not labeled, and consumers will have no way of knowing (without

using a sensitive radiation monitor, and possessing expertise in its

use) if products that they acquire are free of nuclear contamination.

 

The NRC isn't alone in promoting this-the U.S. Department of Energy and

the Department of Transportation are also involved, as is the

>Environmental Protection Agency.

 

Details on the NRC Rulemaking Process:

 

· According to its notice in the Federal Register, the NRC is

" conducting a rulemaking to evaluate alternatives for controlling the

disposition of solid materials with no, or very small amounts of,

radioactivity resulting from licensed operations. " Officially, it is

considering five alternatives for proper disposition of radioactive

materials in this scoping process:

 

- Alternative 1: " No Action: Retain Current Approach of Allowing

Unrestricted Use Using Measurement-based Guidelines. " This alternative

would allow radioactive waste to be deregulated and possibly recycled as

currently done on a case-by-case basis.

- Alternative 2: " Dose-Based Regulation or Unrestricted Use. " The most

liberal of the alternatives, this would establish a standard of

radioactivity below which materials that are contaminated would be

cleared for release from regulatory control, whereupon they could be

incinerated, sent to municipal landfills, or recycled.

- Alternative 3: " Conditional Use. " Under this alternative,

radioactive material could be released from regulatory control, but its

further use would be restricted to certain industrial uses deemed to

adequately limit potential public exposure.

- Alternative 4: " Disposal of Solid Materials in EPA-Regulated

Landfills. " In this scenario, solid radioactive material would be

restricted from general commerce, and would be required to be disposed

of in hazardous waste facilities not designed to keep radioactive

materials isolated or contained.

- Alternative 5: " Disposal of Solid Materials in AS [Agreement

State]-Licensed LLW [low-level waste] Disposal Sites. " The most

restrictive of the alternatives, this option would prevent the dispersal

of radioactive waste into commerce and unregulated facilities.

 

· Despite a National Academies March 2002 report urging the NRC to

approach the issue cautiously; begin a broad, deliberative process;

review some of the science; and work to overcome a " legacy of distrust "

with the public, the NRC has chosen to charge ahead with a rulemaking.

Chairman Meserve has clearly stated that he believes " it is important to

maintain momentum on this issue " and that " it would not be appropriate

to mask the Commission's continuing support for the release of solid

material.... "

 

· With these biases, it is unlikely that the NRC is currently planning

on establishing a policy of " no-release " with the radioactive waste

materials at issue.

 

· Despite the National Academies report recommendation that the NRC's

decision-making process should demonstrate " the willingness and

commitment of the USNRC to establish and maintain a meaningful and open

dialogue with a wide range of stakeholders... " the NRC's current

rulemaking schedule contains only one public workshop on the issue.

Considering that radioactive " recycling " impacts the entire country, a

more appropriate method for public interaction on the issue would be to

hold hearings in every state.

 

 

 

 

 

 

 

 

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