HomeMy WebLinkAbout38-Public Comments
NIRS RADIATION ALERT and UPDATE (1/2004)
Nuclear Power and Weapons Waste to go to Regular LandfIlls and other Non-Regulated
Management
Environmental Protection Agency joins Nuclear Regulatory Commission, Departments ofEuergy
and Transportation in Deregulating Radioactive Waste
Comments due to EPA by March 17,2004
Email to: a-and-r-Dockel@qla.gov
The US Environmental Protection Agency is planning to make a new rule that would allow nuclear waste to
go to places that are not licensed for radioactive materials.
The goal appears to be to redefine radioactive materials, no matter what their source (nuclear power, nuclear
weapons, naturally occurring or other), based on EP A-calculated and proj ected risks. The new category of
nuclear materials (once called BRC or Below Regulatory Concern) would supposedly not need radioactive
regulatory controls. EP A does not consider all the potential health effects of radiation and hazardous
materials in estimating the risks. They have never demonstrated the accuracy of their predictions.
1) First, EP A would allow mixed radioactive and hazardous wastes to go to facilities permitted for
hazardous waste ouly (RCRA C hazardous waste dumps and processors).
2) Second, radioactive waste (not mixed with hazardous) could be permitted to go to places that do
not have radioactive licenses or regulations, such as regular garbage dumps or incinerators or
hazardous sites. EP A justifies this by claiming they will provide an acceptable level of protection from
radiation risk. It seems obvious this would be a problem for communities around the waste sites, many of
which already leak.
3) Third, EPA suggests that a non-regulatory approach to management of radioactive waste is an
option and requests creative ideas for partnering with waste generators or other schemes to relieve the
regulatory burden. Nothing would prevent radioactive materials from going to recycling facilities and being
mixed with the normal recycling streams which are made into everyday household items like toys, cookware,
personal use items, cars, furniture and civil engineering projects like roads and buildings.
4) This dangerous proposal dovetails neatly into the US Nuclear Regulatory Commission's rulemaking
to deregulate and release radioactive material from control, ironically called "Control of Solids." The
NRC is considering several options for nuclear waste deregulation including continuing the current
case-by-case release procedures, starting new release procedures that are based on projected risks, sending
the waste to sites that are not licensed for nuclear materials. NRC is claiming they could approve "restricted"
release of nuclear waste meaning certain conditions would apply but that NRC would not enforce
them--someone else, as yet un-named would.
The upshot is that NRC and EP A are joining forces to allow nuclear power and weapons waste which is
now generally required to be regulated and controlled, to be released to waste sites never designed to take
radioactive materials and either deliberately or unintentionally to the marketplace where it will come into
routine daily contact with us, our children and environment.
4F .;:,Y
7-.J. '1-06
5) To make matters even worse, the US NRC and US Department of Transportation are on the verge of
tin"li7.ing new transport regulations (TSR-l) that would exempt various levels of hundreds of
radionuclides from regulatory control in transit. This will make it easier for NRC and EP A to deregulate
nuclear wastes since they will no longer require regulation, labeling or control as radioactive material during
transportation. (This is especially distressing in light of increased security concerns about transportation of
nuclear materials that could be used for dirty bombs. More unregulated nuclear materials will be on the
roads, rails, barges and aircraft.)
6) Final1y, the Department of Energy is in the process of a Programmatic Environmental Impact Statement
on releasing radioactive materials from its sites. In 2000, DOE halted the commercial recycling of potentially
radioactive metals from certain contarrinated area on its sites, but could resume it. DOE continues to allow
radioactively contaminated metals out for unregulated disposal and to allow other radioactively
contaminated materials out for recycling or unregulated disposal--soils, concrete, asphalt, plastic, wood,
equipment, buildings, sites and more. EPADs Nov. 18,2003 notice would help legalize DOEDs release of
nuclear weapons wastes from regulatory control.
ACTIONS:
1) Send a letter to the new EP A Administrator Mike Leavitt telling him what you think of the EP A's
proposed action, encouraging him withdraw it.
Administrator Mike Leavitt, US Environmental Protection Agency, 110 lA,
Ariel Rios Building, 1200 Pennsylvania Avenue N.W. Washington, DC 20460
leavitt.michael@eoa.gov
2) Comment to EP A and get organizations and landfill boards to do so at
a-and-r-Docket@eoa.gov
The proposal is on the EPA website (www.eoa.gov/radiation)and will be oosted with comments on NIRS
website (www.nirs.org) soon.
3) Tell EP A we need a 6 month extension to run their ideas by our communities that will be impacted.
4) Let your elected officials know how you feel about these dangers by sending them a copy of your letter to
Secretary Leavitt, comments to EPA, NRC, DOT and/or DOE and telling them about your opposition to the
federal rules that would deregulate and exempt nuclear materials from regulation.
For more information contact:
Diane D'Arrigo, Nuclear Information and Resource Service (NIRS), 1424 16th Street NW Suite 404,
Washington, DC 20036, diimed@nirs.org, 202 328-0002 ext 16
See NIRS website under Campaigns at www.nirs.org for more info and actions.
This is the NlRS E-Mail Alerllist.Youareonthislistbecauseyousigneduponourwebsite.ataNIRStableataconcert.onapetition.ar
directly to NIRS. Your name and addresa are never sold, nmted, ar traded with anyone far any reason.
For address changes or to unsubscribe, just send an e-mail to nirsnet@nirs.org. If you have friends or colleaguell who would like to be on this
list, have them send a note to nirsnet@nirs.org