Resolution on Nuclear Recycling, passed by the Board of Trustees of Temple
Beth El
The Temple Board, meeting on December 21, 1999, passed the following
resolution:
Whereas the Department of Energy has a problem of what to do with radioactive
metal and,
Whereas the DOE has a plan to dispose of the radioactive metals such as
nickel, copper steel, and aluminum and,
Whereas the DOE wants to recycle these metals to save money and,
Whereas these metals could be manufactured into everyday household products
and,
Whereas these products could be computers, pots, pans, forks, eyeglasses,
children’s braces, jewelry, zippers on clothing, furniture
such as bed frames and desks and,
Whereas some of the most dangerous radioactive materials may be the metals
people unintentionally ingest and,
Whereas Karl Morgan, the father of Health physics, is particularly concerned
about dental fillings and,
Whereas many scientists fear the release of hot metals into the product
stream can cause a health hazard and,
Whereas Richard Clapp, associate professor of environmental health, Boston
University, has said this is the legacy of an industry gone mad, and
Whereas this is already happening in Taiwan and,
Whereas people in Taiwan are living in apartments built with contaminated
recycled waste and,
Whereas the waste has come from the United States
Therefore be it resolved that Temple Beth El of Greater Buffalo, heir to a
tradition of stewardship of Creation, emanating from the Book of Genesis, and
who recognizes the gravity of our ecological problems and our moral
responsibility to take action
- Call on the United States President, Vice President Gore,
Congress and all
federal, state and international regulators to recapture, stop, and prevent
the release and recycling of radioactive waste and materials into consumer
products and the environment;
- Call on the US Nuclear Regulatory Commission to reverse its efforts and
expenditures to release radioactive wastes and to initiate a policy requiring
regulatory control and isolation of all radioactive wastes;
- Call for the recapture and recall of radioactive materials
and wastes that have been released into the marketplace;
- Call on the US Department of Energy to halt all releases of radioactive
wastes and materials into the marketplace, to recapture that which has been
released and to revoke the radioactive Recycle 2000 policy immediately.
Background message:
Message-ID: <383CFA81.8A05334D@igc.org>
Date: Thu, 25 Nov 1999 03:59:45 -0500
From: diane d'arrigo
Reply-To: dianed@nirs.org
Organization: NIRS
ALERT: Radioactive Household Items? !!
Comment to NRC by DEC 22, 1999!!
Tell the NRC what you think about Radioactive Household Items made from
"recycled" nuclear power and weapons waste!
THE PROBLEM: The Nuclear Regulatory Commission (NRC) is scheming with
the nuclear industry and its allies at other federal agencies, like the
EPA and Dept. of Energy (DOE) to "RECYCLE" RADIOACTIVE WASTE INTO
HOUSEHOLD PRODUCTS! This saves the nuclear power industry and DOE
weapons contractors money by allowing them to "sell" radioactive waste
to be used in our homes, schools, cars, workplaces, and more. Although
the government already allows atomic waste into commerce on a
case-by-case basis, the NRC is now legalizing routine release of massive
amounts of radioactive metal, concrete, plastic, soil, and other
material from commercial nuclear power and weapons sites, directly and
via commercial processors, into daily-use items.
THE PROCESS: COMMENT to NRC by DECEMBER 22, 1999.
To make a new rule legalizing radioactive waste "recycling" or
"clearance" into the marketplace, the NRC is required by the National
Environmental Policy Act (NEPA) to consider all potential impacts and
options. The NRC Commissioners have clearly directed the staff (6/30/98
Staff Requirements Memo) to "promulgate a regulation that allows
quantities of materials to be released." The "scoping" process required
by NEPA expires on December 22, 1999. This is the public's chance to
tell the NRC what should be considered in the rulemaking. NIRS and
Public Citizen have requested a minimum 8-month extension for public
comment.
It is extremely important that the NRC hear from the public during this
time. Let NRC know how you feel about any level of radioactive
"release," "clearance" and "recycling." Demand that the NRC prohibit
radioactive releases and recapture the nuclear waste already let out.
This is your chance to inform the NRC about the amount of radiation you
and your family and progeny are willing to take so that the nuclear
waste generators can save money. The proposed rulemaking is in the
Federal Register [FR] at 64 FR 35090, 6/30/99-It is the issues paper
which NRC staff developed to "discuss" the various ways to dump nuclear
waste into commerce.)
WHAT YOU CAN DO:
-->COMMENT TODAY-or ASAP before Dec 22 for yourself and your
organizations.
(You can go to the NRC website to view their proposed discussion paper
64 FR 35090, 6/30/99 and/or use the Sample Statement below, which was
presented on behalf of over a dozen national & international
organizations to NRC on 11/1/99.) CC: US Reps and Senators.
-->Get resolutions or letters from groups, stores, or local government
entities to submit to NRC. Again, cc your Congressperson and Senators
and state and local officials.
--> Request an extension on the comment period for "scoping" this
rulemaking so organizations and governments have time to learn and
respond and have legal standing.
WHERE/HOW TO COMMENT:
Refer to NRC's Radioactive "Release" rulemaking 64 FR 35090, 6-30-99
ATTN: NRC Rulemakings and Adjudications Staff
1) Mail your comments by December 22, 1999 to
NRC Chairman Richard Meserve/Attention: Rulemaking and Adjudications
Staff
U.S. NRC/Washington, DC 20555
or
2) E-mail the comments to secy@nrc.gov
(NRC would like, but does not absolutely require, email comments to be
followed up with hard copies via mail or fax)
or
3) FAX to NRC Rulemakings and Adjudications at 301-415-1101
or
4) Submit electronically through the NRC's website:
http://ruleforum.llnl.gov/cgi-bin/uploader/SM_RSC_public
In order to submit comments through the website, you must save your
comments in your files and remember the file name. Go to the NRC
website. Fill out all of the fields they request. Hit the BROWSE button
on the NRC website and find your file. Attach it.
SAMPLE STATEMENT:
Dear Chairman Meserve:
I am/We are writing to call on the Nuclear Regulatory Commission to
isolate radioactive wastes and materials and anything they contaminate,
no matter what level. The radioactive legacy of atomic energy and
weapons production should be isolated from the public and the
environment.
The NRC should also extend the comment period on releasing radioactive
waste into commerce to at least September 2000. This issue is too
important to act hastily upon and it should be fully debated by the
public. The public has spoken repeatedly before on this issue and needs
time to be informed that subject is open again or still.
NO MORE RADIOACTIVE RELEASES
We still do not want nuclear power and weapons wastes "released,"
"cleared," deregulated, exempted, generally licensed, designated "de
minimis," "unimportant," "trivial" or BRC-below regulatory concern, or
by any other creative, direct or deceptive means, allowed out of nuclear
facilities and into the marketplace or the environment, at any level.
TRACK AND RECAPTURE ALREADY-RELEASED RADIOACTIVE WASTES
The current methods of releasing radioactive wastes from commercial
licensees and weapons facilities must immediately cease. No future
radioactive releases should be permitted and a full accounting and
recapture of that which has already been released should commence.
PREVENT AVOIDABLE RADIATION EXPOSURES and RISKS
Using radioactive wastes in consumer products poses unnecessary,
avoidable, involuntary, uninformed risks. The consumers, the producers,
the raw materials industries don't want these radioactive wastes or
risks.
COMPUTER MODELS NOT ACCURATE, RELIABLE, VERIFIABLE
It is not credible to believe computer models can calculate and
accurately predict any or ALL of the doses to the public and the
environment from all of the potential radioactivity that could be
released over time. Projections of "acceptable" or "reasonable" risks
from some amount of contamination being released are meaningless and
provide no assurance. Monitoring for the specific types and forms of
radioactivity that could get out can be very expensive and tricky to
perform. Hot spots can sneak through. We can't trust the nuclear
generators to monitor their own releases.
EXPENSIVE TO MONITOR; IMPOSSIBLE TO VERIFY OR ENFORCE RELEASES
No matter what level the NRC sets for allowable radiation risk, dose or
concentration, it will be difficult to impossible to measure, verify and
enforce. Who is liable if the "legal" standards NRC intends to set are
violated? For decades the public has clearly opposed releasing
radioactive materials into commerce. We continue to do so.
EXISTING RADIATION DOESN'T JUSTIFY DELIBERATE ADDITIONS
Naturally occurring background radiation cannot be avoided (except in
some instances for example, reducing radon in homes) but its presence in
no way justifies additional, unnecessary, involuntary radiation
exposures, even if those exposures might be equal to or less than
background. Nor does it justify shifting the economic liability from the
generators of radioactive wastes and materials to the economic and
health liability of the recycling industries, the public and the
environment.
SUPPORT METAL INDUSTRIES' "ZERO TOLERANCE" OF CONTAMINATION
We fully support the complete opposition and "zero tolerance" policies
of the metal and recycling industries, the management and the unions. We
appreciate their efforts, not only in opposition to legalization of
radioactive releases, but in their investment in detection equipment and
literally holding the line against the radioactive threat to the public.
They should not have to be our de-facto protectors. The NRC, DOE and EPA
must act to prevent the dissemination of radioactive wastes into
recycled materials and general commerce. The problems that have been
experienced by the steel recycling industry with "generally-licensed
sealed sources" getting into their facilities and costing tens of
millions of dollars to clean up should serve as a warning not to let any
other radioactive wastes and materials out of regulatory control.
US AGENCIES MUST PREVENT FUTURE AND RECAPTURE PAST RELEASES,
PUSH INTERNATIONAL PROHIBITION
The fact that radioactive waste is already getting out should not be
used to justify legal levels allowing more out. The NRC, EPA and DOE
should prevent future and correct past releases. The fact that other
countries are releasing radioactive materials into the marketplace is no
excuse for us to legalize it. The United States should take the lead in
preventing contamination of the international marketplace. We protect
ourselves best by not facilitating international radioactive commerce.
The fact that it is difficult and expensive to monitor and detect
radiation does not justify its release. It is all the more reason to
prevent any wastes getting out, so we don't have to check routinely for
contamination. The nuclear industry and regulators should be aware of
what materials at reactor and weapons sites are wastes and which have
been contaminated. Those materials must be isolated, not released, at
any level.
NRC HAS CLEARLY DECIDED TO RELEASE-THIS MUST BE REVERSED
The mindset of the NRC appears convinced that it should legalize
radioactive wastes being "recycled" into the marketplace. The NRC has
stated in its Staff Requirements Memo that the standard must allow
"releases" to take place and that all radioactive materials will be
eligible for "clearance." This means that the NRC is not seriously
examining all of the options available, such as non-release, even though
the National Environmental Policy Act (NEPA) requires all options to be
considered.
NRC CONTRACTOR (SAIC) HAS CLEAR CONFLICT OF INTEREST
Furthermore, the NRC is relying on a private contractor called Science
Applications International Corporation (SAIC) to prepare the technical
basis for the proposed regulation. This is a blatant conflict of
interest. The NRC has not publicly disclosed the relevant economic
interests of SAIC. The NRC has not notified the public that SAIC has
simultaneously been working with or for other corporations with
substantial economic interests in the Commission's determinations in
this rulemaking. In particular, since mid-1996, SAIC has been the
teaming partner of British Nuclear Fuels, Ltd. (BNFL) under a quarter
billion DOE contract for recycling unprecedented amounts of contaminated
radioactive metallic waste from the Oak Ridge TN uranium enrichment
buildings. This situation calls into question the legality of the entire
NRC process.
EXTEND COMMENT PERIOD
Since NRC is attempting to cover its requirements under NEPA to
establish this radioactive "release" rule, the public comment period
should be extended to allow the public the opportunity to hear about and
comment on the proposal.
In conclusion, we call on the NRC to serve the interests of the public
instead of the nuclear industry and
#1 prohibit the release of radioactive materials into commerce,
landfills and incinerators
#2 identify, track and recapture the radioactive waste that has already
been released from nuclear power and weapons facilities by federal and
state regulators
#3 give the public at least 8 more months to comment.
Sincerely,
WHERE/HOW TO COMMENT:
Get your comments to NRC by December 22, 1999 by
Mail to:
NRC Chairman Richard Meserve/Attention: Rulemaking and Adjudications
Staff
U.S. Nuclear Regulatory Commission
Washington, DC 20555
or
E-mail your comments to secy@nrc.gov
Or
FAX to 301 415-1101
or
Attach your comments file through website at
http://ruleforum.llnl.gov/cgi-bin/uploader/SM_RSC_public
For more info look at the NIRS and Public Citizen's Critical Mass Energy
Project websites: http://www.nirs.org
and http://www.citizen.org/cmep/
NRC has a website for this rulemaking:
http://ruleforum.llnl.gov/cgi-bin/library?source=*&library=SM_RFC_lib&file=*
Contacts: NIRS 202-328-0002 ext. 2 or Public Citizen 202-546-4996.
More info:
Nuclear Regulatory Commission CONTROL OF RELEASE OF SOLID MATERIALS
site with links to other sites concerned with control of
solid waste
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