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Radioactive zippers and silverware? Tell DOE: No Way]

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  • scotpeden@cruzio.com
    web banner 6930 Carroll Avenue, #340, Takoma Park, MD 20912; 301-270-6477; nirsnet@nirs.org [ mailto:nirsnet@nirs.org ]; www.nirs.org [ http://www.nirs.org ]
    Message 1 of 1 , Dec 22, 2012
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      6930 Carroll Avenue, #340, Takoma Park, MD 20912; 301-270-6477;
      nirsnet@... [ mailto:nirsnet@... ]; www.nirs.org [
      http://www.nirs.org ]


      *Nuclear Weapons Waste in Your Silverware, Pants Zipper, Baby Toys?
      ACT NOW to Prevent Radioactive Metal being Added to Everyday Recycling
      Tell DOE what you think by Feb 9, 2013*


      December 21, 2012

      Dear Friends,

      It may be the Holiday Season, but it's also turning out to be a very busy
      season for those of us concerned with nuclear and radiation issues!

      *The latest outrage:* the Department of Energy (DOE) is considering a plan
      to allow radioactively-contaminated metal from nuclear weapons facilities
      to be "recycled." This would allow this toxic metal to be mixed with clean
      recycled metal and enter into normal commerce-where it could be turned
      into anything from your next pants zipper to baby toys.

      *Read enough? Then act now here. Tell the DOE that the American people do
      not want radioactive metal in the marketplace.* [
      http://org2.democracyinaction.org/o/5502/p/dia/action/public/?action_KEY=12406
      ] Comment deadline is February 9, 2013.

      *Background*
      This DOE action is just the foot in the door….if it's allowed to occur,
      expect more efforts to deregulate radioactive materials from both DOE and
      NRC.

      We've fought this battle before. In the late 1980s, NRC adopted a policy
      it called "Below Regulatory Concern (BRC)," that would allowed about 30%
      of the nation's "low-level" radioactive waste to be treated as normal
      garbage and dumped in landfills, be burned in incinerators, and yes, be
      recycled into consumer products. According to the NRC's own calculations,
      its BRC policy posed a 1 in 286 risk of fatal cancer over a person's
      lifetime.

      NIRS and our allies responded with one of our largest organizing campaigns
      ever. Grassroots activists succeeded in getting hundreds of towns, cities
      and counties to adopt anti-BRC resolutions. The texts of those resolutions
      were sent up the chain to Governors, state legislators and
      Congressmembers. They responded: 15 states passed laws banning BRC within
      their borders. Hearings were held in the House and in 1992, Congress
      officially overturned the BRC policy.

      But both NRC and DOE have been trying to implement the concept piecemeal
      ever since. In the late 1990s, DOE proposed a similar program to
      deregulate radioactively contaminated metal. Instead, DOE was forced to
      suspend the idea indefinitely-a suspension that stands today and that DOE
      is now trying to lift. Even DOE admits this program was defeated due to
      "public concern."

      Nothing has changed since 2000 that would justify lifting its current ban.
      Rather, just the opposite: since then the National Academy of Sciences has
      acknowledged that there is no safe level of radiation exposure, and we've
      learned that women are even more vulnerable to radiation than men (while
      children have long been known to be more vulnerable than adults). The
      DOE's proposal flies in the face of what our society values most:
      protecting our children. It must be stopped before it starts.

      *Act now: Tell DOE to withdraw its proposal.* [
      http://org2.democracyinaction.org/o/5502/p/dia/action/public/?action_KEY=12406
      ] At the same time, point out that DOE cannot take shortcuts; implementing
      this proposal would require preparation of a full Environmental Impact
      Statement-something DOE is trying to avoid.

      For those who would like still more information, see below for links to
      the DOE's Federal Register notice and other info sources, plus some more
      technical issues related to the proposal.

      We hope you have a wonderful holiday season! Note that NIRS will be closed
      from December 23-through January 1 and we won't be answering the phone.
      Urgent messages can be sent via e-mail to nirsnet@... [
      mailto:nirsnet@... ].

      We are continuing our holiday fundraising drive and are now about halfway
      to our $25,000 online donation goal. *Please help us reach this necessary
      goal with your end-of-the-year tax-deductible donation*. You can donate
      now here [
      https://org2.democracyinaction.org/o/5502/donate_page/support-nirs ], or
      after you take action. Or you can send a check to NIRS, 6930 Carroll
      Avenue, #340, Takoma Park, MD 20912.

      Thanks for all you do, and let's stop this irresponsible DOE idea before
      it starts!

      Michael Mariotte
      Executive Director
      Nuclear Information and Resource Service
      www.nirs.org [ http://www.nirs.org/ ]
      nirsnet@... [ mailto:nirsnet@... ]

      *Stay Informed:*

      *NIRS on the web *(stay up-to-date with the Nuclear Newsreel section on
      the front page, featuring the day's most interesting news on nuclear power
      and other energy issues)*:* http://www.nirs.org [ http://www.nirs.org/ ]

      *NIRS on Facebook:*

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      [
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      ]

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      *More information: *
      DOE's federal register notice is here [
      http://www.gpo.gov/fdsys/pkg/FR-2012-12-12/pdf/2012-30028.pdf ] (pdf).
      DOE/EA-1919 DOE/NNSA Programmatic Environmental Assessment of Recycle of
      Scrap Metal Originating in Radiological Areas is here [
      http://energy.gov/nepa/downloads/ea-1919-draft-programmatic-environmental-assessment
      ].
      A 2007 list of talking points on a previous incarnation of this effort--a
      PEIS never conducted--most points still relevant is at
      http://www.nirs.org/radwaste/outofcontrol/appendix_k.pdf [
      http://www.nirs.org/radwaste/outofcontrol/appendix_k.pdf ] [Note that
      since that list was written DOE changed replaced Order 5400.5 with 458.1
      which was done largely to pave the way for the sending radioactive metal
      into the marketplace. In addition, DOE has chosen to do a less rigorous
      analysis, this Environmental Assessment with 30 day public comment instead
      of an Environmental Impact Statement with at least 60 days for public
      comment and possible hearings.]

      DOE claims it considered three options but chose the first:
      (1) Lift the suspension on potentially radioactive metal; allow it to go
      to commercial recycling if it meets DOE "authorized" contamination levels.
      (2) Treat the metal as waste and dispose of it in radioactive, industrial
      or solid waste landfills [sending radioactive materials to landfills never
      intended for radioactive waste is unacceptable.
      (3) Keep it in storage at DOE sites.

      DOE makes some incorrect assumptions in its EA 1919 environmental
      assessment. These include:

      1) Metal from radioactive areas of atom bomb factories is not "clean;"

      2) There is no safe level of radiation exposure, so no amount of
      radioactive contamination is okay, not even a "millirem" per year
      [Millirems are calculations of radiation dose and cannot be measured,
      verified or enforced. Millirems are an expression of biological damage to
      tissue from radiation, not a measurement of radiation released.]

      3) DOE has no limit on the number of loads of metal it can release, so
      there can be multiple exposures, thus many millirems of exposure;

      4) DOE does not consider that exposures can go on for years from a watch
      or jewelry or tableware or other items, leading to many millirems for many
      years; a millirem per year over 30 or 70 years is 30 or 70 millirems which
      is not trivial;

      5) DOE would "authorize" sending radioactive metal into everyday
      commercial recycling if it is contaminated at levels that were adopted
      nearly 40 years ago (in Atomic Energy Commission Regulatory Guide 1.86)
      based on the detection capability of 1974-vintage radiation detectors.
      Although DOE touts that it will only allow the public to be exposed to 1
      millirem per YEAR per load of released metal, the old regulatory guide
      allows contamination that gives doses of a .2 to 1 millirem per HOUR (p 30
      footnote (e) of EA1919). These contamination levels are not based on
      health effects. They were chosen to decontaminate rooms and buildings
      before being occupied and were never intended for constant intimate
      exposures to people of both genders and all ages.

      6) DOE says it will report every release but it would be via the Annual
      Site Environmental Report (ASER for each of many nuclear weapons sites)
      published well after the end of the year when the material will be
      long-gone into the marketplace. DOE refuses to report on a
      continuously-updated, easily-accessible web site.

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