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Radioactive Waste in Household Products

NIRS 12may03

RADIOACTIVE Waste and Materials to make HOUSEHOLD ITEMS ?

The Problem:

Radioactive waste from nuclear weapons and nuclear power are being "released" and used to make everyday household items, building materials, and more. "Standards" are being developed to dramatically increase the amount of radioactive material "recycled" into the marketplace.

Who is Doing This?

-Nuclear power industry and nuclear weapons contractors -US Government: Dept. of Energy, Nuclear Regulatory Commission, Environmental Protection Agency, US Department of Transportation -Tennessee Department of Environment and Conservation -United Nations International Atomic Energy Agency -European Commission -Other nuclear nations' governments and industries

What Can You Do?

Demand the US and International governments PROHIBIT RELEASE of radioactive wastes and materials from nuclear power and weapons into the marketplace.

Contact your elected leaders and tell them to stop the nuclear industry and government agencies from poisoning us with ANY level of non-naturally occurring, involuntary or preventable radioactive contamination.

Nuclear Information and Resource Service (NIRS)
1424 16th Street NW Suite 404
Washington, DC 20036
202-328-0002; 202-462-2183 fax
www.nirs.org
dianed@nirs.org

Radiation Threat:
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:

HOW AND WHERE 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, 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 where 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:

EXCERPT from the NIRS WISE
Nuclear Monitor #577 November 22, 2002

nirsnet@nirs.org; www.nirs.org

US Nuclear Regulatory Commission Resumes Rulemaking Legalizing Radioactive Waste Dispersal into Consumer Products, Building Supplies, Regular Dumps

Has radioactive waste from nuclear power and weapons gotten past the detectors at recycling facilities and made it into our daily-use items, garden soil, basement cement, kids' toys, zippers, frying pans, car, bed, furniture, tableware, prostheses, jewelry and more? Is it being trucked to the community dump or incinerator to leak into the water table, drinking water, air and environment?

BACKGROUND

This could be happening now, because some radioactive materials are already being permitted out into commerce in the United States and Europe.

In the US, the

  1. Nuclear Regulatory Commission (NRC), through case-by-case permits and provisions in some licenses, is letting nuclear waste be treated as if it is not radioactive; letting nuclear reactors send waste to regular dumps and release for "recycling" into consumer goods;
  2. Agreement States like Tennessee give permits to companies to "process" and/or release radioactive materials into the marketplace or send them to landfills not originally intended to take nuclear wastes. The waste is mainly from the operation and decommissioning of Department of Energy (DOE) nuclear weapons sites, DOE's contractors and NRC-licensed nuclear power reactors and Agreement State licensed radioactive waste generators;
  3. already-lax NRC decommissioning standards are being misused to justify relatively high levels nuclear materials being sent to regular garbage landfills and normal recyclers. The California Department of Health Services has approved public exposures from each truckload of decommissioning waste to be as high as the annual dose from an operating nuclear power facility. (This was challenged successfully in state court, appealed and upheld, but state legislation to expressly prohibit nuclear contaminated materials in recycling and unlicensed facilities was vetoed.);
  4. Department of Energy allows all types of radioactive materials except some metals to be released through its secretly adopted internal orders, DOE 5400.5.

In Europe the European Commission has mandated that all members adopt European Council Directive 96/29/ Euratom of 13 May 1996 "laying down basic safety standards for the protection of the health of workers and the general public against the dangers arising from ionizing radiation."[1] Not all countries have adopted the provisions on radioactive clearance and some have adopted stricter standards. It appears that Euratom, the European Atomic Energy Agency, has the authority to set across the board radiation standards for the whole European Union. Some countries have refused to adopt the portion of the Directive that permits "clearance" of nuclear materials from regulatory control; some of them have adopted stricter and different standards. The actual status of the adoption of the clearance provision by each country is not known at this time, even by the Commission. Yet it is touted as an international standard that the US should adopt.

But the existing EU policy that allows the clearly-pronuclear Euratom Agency to set radiation standards for all of the European Union (EU) is being challenged. EU member countries (the majority of which are not pronuclear) and their trading partners should not have to accept, as dictum, lax radiation standards developed behind closed doors with no public process by Euratom.

The effect of the Euratom Directive promoting the "clearance" or dispersal of nuclear wastes into commerce is impacting not only Europe. The US Nuclear Regulatory Commission, having been unsuccessful in making such a policy for the US thus far, is now using the existence of the Euratom Directive as an indicator of European support for the unpopular concept.

NRC has been looking to the European Union, the International Atomic Energy Agency, the Department of Energy and the National Academy of Sciences to build public confidence in the nuclear industry's plan to get rid of its waste cheaply.

The US Nuclear Regulatory Commission (NRC) hired the National Academy of Sciences, National Research Council to give credibility to the practice of selling or donating radioactively contaminated metals, concrete, soil, plastics, asphalt and other solid materials into the regular marketplace as if they are not radioactive. The resulting report,[2] did not do that. The committee, despite its heavy weighting in favor of the nuclear power industry including radioactive wastes generators, declined to endorse the free-release of radioactive materials, thoroughly criticized NRC's efforts over the past 16 years to do so and advised them to work more sincerely to build public trust and genuinely incorporate "stakeholder" concerns. A new NAS committee has been formed.

CURRENT NEWS

On November 6, 2002, the NRC announced that it will proceed to make a rule regarding deregulating or "releasing" nuclear waste from regulatory control. To prevent arousing public concern about radioactive materials being deliberately released from regulations, NRC titled the rule "Control of Solid Materials." The "enhanced participatory" rulemaking is to take 3 years and the schedule will be out in January 2003.

NRC claims it will seek broad public participation. However, one step of the National Environmental Policy Act, publication of an Advanced Notice of Proposed Rulemaking for public comment and meetings, will be skipped to avoid duplication of previous efforts. Paradoxically, the public meetings that NRC held in 1999 were boycotted by the public and environmental groups because NRC refused to consider keeping all nuclear waste under regulatory control (the only publicly acceptable policy)[3]. At that time the Commissioners had directed the NRC staff to make a rule that ".allows quantities of materials to be released." Now, NRC wants to rely on those meetings and that input as public information on the proposed rulemaking. It seems more likely that they really don't want to hear from the public.the very people that will be exposed to radiation as a result of this policy.

NRC claims it will consider a "broad range of alternatives" including unrestricted release of radioactive waste into everyday commerce, restricted release for specific practices for the first use and requiring licensed disposal. However, the NRC Commissioners directed the staff to ".reiterate the Commission's continuing support for the release of solid material."[4] So once again we face a rulemaking with a predetermined outcome.

NIRS questions what is "enhanced" about this rulemaking: NRC is cutting off public input, relying heavily on four documents[5] which had nearly NO public input and has already decided to release some contaminated materials. The only question is how much contamination they will decide they can get away with letting out. We may never know what that amount is since it will vary greatly, be applicable to an unlimited number of radioactive waste streams and too expensive to even try to measure.

Interestingly, the industry is building its own detection equipment and developing its own science of radiation detection. This makes it enormously difficult to independently assess.

The NRC's previous efforts to deregulate radioactive "wastes, materials, emissions and practices" were the "Below Regulatory Concern" policies of 1985 and 1990. These were revoked by the US Congress in 1992 due to public opposition and inadequate technical support. This time the NRC is expending significant staff and contractor time and resources to produce technical reports that claim to be able to estimate the doses to the public from unregulated all the various nuclear contaminated materials that will be unleashed on the public. If risk or dose based standards are adopted, we will never know how much exposure we receive because they will be neither verifiable nor enforceable. In addition, there is no limit to the number of different, multiple exposures we and future generations will receive because the standards intend to provide across-the-board exemptions for many types of wastes from all kinds of nuclear waste generators.

The contractor NRC hired to produce key technical documents[6] projecting doses from radioactive metals, equipment and concrete, Science Applications International Corporation (SAIC), had to be let go for having a blatant Conflict of Interest. While SAIC was supposedly objectively and scientifically developing "safe" standards for NRC to allow radioactive materials into commerce, personal use items, raw materials and unregulated disposal, they were working for the Department of Energy at Oak Ridge as one of the main contractors for the largest radioactive metal "recycling" contract in the country. So, as they were making money based on how much radioactive material they could "recycle," they were making more money setting the levels of "acceptable" exposure from that very practice. Even though they were removed from the contract, NRC continues to use the documents they produced during this conflict.

The recycling portion of that contract was halted in the year 2000 when the Department of Energy placed bans on the recycling of volumetric and some surface contaminated metals. The draft Programmatic Environmental Impact Statement that could reverse those bans or make them permanent is now expected in early 2003.

One additional complication is that the US Environmental Protection Agency is in the process of developing a rule that would exempt mixed (radioactive and hazardous) waste from radioactive regulations so long as it is managed as hazardous waste. An existing EPA conditional exemption allows mixed waste to be treated as radioactive only.

ACTION NEEDED

->Sign on to the petition and resolutions against release of radioactive wastes. ->Get your organizations, local & state gov'ts to sign on or pass resolutions and laws. -> For more information on the NRC's rulemaking the website is: http://ruleforum.llnl.gov/cgi-bin/rulemake?source=SM_RFC&st=ipcr
NIRS website: www.nirs.org  (See Campaigns 2nd listing)

PETITION TO STOP USE OF RADIOACTIVE WASTE IN CONSUMER PRODUCTS

We, the undersigned, call on the United States President, Vice President, Congress and all federal, state and international regulators and legislative bodies to recapture, stop, and prevent release/clearance/recycling/dispersal of radioactive wastes and materials into consumer products and the environment.

We support regulation and isolation of radioactive wastes from nuclear power and weapons. We oppose the use of radioactive materials and wastes

in consumer products and building materials including but not limited to metals, concrete, plastics, glass, paper, wood, soil, and equipment.

We call on the US Nuclear Regulatory Commission (NRC) to reverse its efforts and expenditures to release radioactive wastes and to initiate a policy requiring regulatory control and isolation of all radioactive wastes. We demand the recapture and recall of radioactive materials and wastes that have been released into the marketplace.

*We call on the US Department of Transportation & NRC to reject the proposed exemptions for radioactive materials in transportation regulations, which would permit transport of various amounts of all radionuclides without labeling, regulation or tracking.

We call on the US Department of Energy to halt all releases of radioactive wastes and materials into the marketplace or regular trash, to recapture that which has been released and to immediately revoke their internal orders allowing radioactive release. Expand the ban against radioactive metal recycling to prohibit all radioactive dispersal to commerce.

Name/Organization Address Phone/Fax E-mail (clearly, for alerts on this)

Forward filled petitions to NIRS/1424 16th St.NW # 404 Washington, DC 20036/202-328-0002; dianed@nirs.org; website: www.nirs.org

Resolution/Statement Against
Radioactive "Recycling" and Deregulation

Be it resolved that the undersigned entities hereby support a prohibition on deregulation of radioactive wastes and materials.

This includes any and all deregulation of radioactive wastes and materials for "clearance," "release," "recycling," "exemption," listing as "below regulatory concern," or any other legalistic mechanism that could result in the dispersal of nuclear wastes and materials into public commerce, unlicensed disposal, or designation and treatment as non-radioactive.

Such practices pose an indefensible hazard to public health and the environment for current and future generations.

Since there is no safe level of ionizing radiation, nuclear power, weapons and mining wastes should not be forced on an unknowing, nonconsenting public.

Radioactive waste should not be treated as an asset or a commodity, and must be contained and isolated from the public and the environment for its entire hazardous life, at the expense of the waste generators.

Contacts: Diane D'Arrigo, Nuclear Information and Resource Service, dianed@nirs.org and David Ritter, Public Citizen's Critical Mass Energy and Environment Program, dritter@citizen.org Sign on online at http://www.citizen.org/cmep/energy_enviro_nuclear/nuclear_waste/low-level/recycling/articles.cfm?ID=8417

[To view a partial list of signatories thus far, go to this URL: http://www.citizen.org/cmep/energy_enviro_nuclear/nuclear_waste/low-level/recycling/articles.cfm?ID=8753]

BACKGROUND and UPDATE:
Radioactive Waste Dispersal into Consumer Goods and Raw Materials

Radioactive waste from the nuclear power industry and nuclear weapons contractors is being released into the general materials recycling stream and used to make everyday household items, building materials, and more.

Rather than prohibiting and preventing nuclear waste from getting into the marketplace and daily-use items, 'standards' are being developed to dramatically increase and legalize the amount of radioactivity dispersed into the marketplace. The US Department of Energy (DOE), US Nuclear Regulatory Commission (NRC), US Environmental Protection Agency (EPA), US Department of Transportation (DOT), Tennessee Department of Environment and Conservation (TDEC), United Nations International Atomic Energy Agency (IAEA), European Commission and other nuclear nations' governments and industries appear to be actively promoting radioactive "recycling" or dispersal.

The materials being dispersed include radioactive metals, concrete, plastics, wood, asphalt, soils, equipment, and more. Once these materials enter the general recycling stream they are no longer traceable to their sources. In the absence of sophisticated, expensive detection equipment, the public will have no way of knowing which items may be contaminated. Manufacturers and workers will be unaware if the materials with which they are working are radioactively contaminated.

No safe dose vs "acceptable" legal dose

The potential impact on public health is enormous because there is no safe level of exposure to ionizing radiation. Low-level radiation damages tissues, cells, DNA and other vital molecules, causing programmed cell death (apoptosis), genetic mutations, cancers, leukemia, birth defects, and reproductive, immune and endocrine system disorders. Long-term exposures to low levels of ionizing radiation can be more dangerous than short exposures to high levels. The practice of releasing and dispersing radioactively contaminated materials in general commerce will result in random poisoning.

Some of the Congressional focus, unfortunately, has been on setting standards rather than prohibiting release of contaminated materials. Your Congressmembers need to hear from you.

Government agencies are legalizing dispersal of radioactive materials by setting "acceptable" levels of exposure, which cannot be verified or enforced. If there was a safe or legal level of radiation exposure, would you trust the DOE and the nuclear industry to release only as much contamination as would lead to that dose?

In 1992, Congress revoked NRC policies that declared some radiation exposures "below regulatory concern." Current government efforts are dressing up the rejected "below regulatory concern" policy by applying the environmentally friendly sounding term "recycling."

DOT sneaks in codification of "BRC" or radioactive release and "recycling" levels, simply denying their importance.

The US Department of Transportation in 2001, published its final rule on international radioactive transport exempting quantities and concentrations of hundreds of radionuclides from DOT regulatory control. The upshot is that DOT will no longer regulate international shipments into, out of or through the U.S. if the shipper claims that the radioactive materials are less concentrated or in amounts less than those listed in the new rule. The exempt concentrations are the same as those that the International Atomic Energy Agency (IAEA) wants to use to "clear" or "release" radioactive wastes and materials into general commerce and recycling. Previous uniform international nuclear transport regulations that require labeling and regulation of radioactive materials are being changed around the world (with the US leading the way), to allow deregulated radioactive waste to move through commerce unimpeded and without public knowledge. The new regulations introduce the concept of exempt amounts of radioactivity per 'consignment' and increase exempt concentrations for most of the hundreds of radionuclides.

In mid-2003, the US DOT and US NRC plan to finalize the same or similar regulations for all domestic nuclear materials transportation.

Internationally, the IAEA, through its affiliation with the United Nations and its transport organizations (International Maritime Organization and International Civil Aeronautics Organization), is working to get all UN member nations to adopt the industry/IAEA- developed transport recommendations (referred to as TS-R-1 or ST-1), which will open the doors between nations for international commerce in contaminated materials and consumer goods. If the exemption tables in the IAEA recommendations are adopted internationally, preventing the spread of contaminated household items and raw materials will be more difficult than it is now.

DOE is releasing radioactive materials; has bans on some radioactive metal recycling; is expected to publish draft Environmental Impact Statement in Spring 2003-probably to reverse the existing bans.

Although the Department of Energy (DOE) quietly continues to release and 'recycle' some radioactive materials into general commerce, there has been a halt, since 2000, on the recycling into open commerce of some potentially radioactive metal. An Environmental Impact Statement (EIS) is being carried out by DOE's Environmental Management Office to review some aspects of the DOE radioactive "release" and "recycling" policy. DOE has still not answered important questions about the conflict of interest and predetermined outcome of the EIS. DOE wants the scope of the EIS to cover only surface contaminated radioactive metal that is now in designated radiological control areas, but the public is calling for a full review of all DOE's potentially contaminated materials and wastes, not just metal in certain areas. The DOE's internal orders allow radioactive materials, including metals, to be released into regular garbage or recycled into commerce without public knowledge and/or meaningful record-keeping.

DOE has a "Center for Excellence" in radioactive recycling based in and funded through its Oak Ridge, Tennessee site budget. The Center has been smoothing the way for "recycling" into unrestricted commerce of "slightly contaminated" radioactive materials such as copper from throughout the DOE complex. DOE tried to start letting potentially contaminated metals out while its Environmental Impact Statement on that very issue is underway. After public and steel industry pressure, DOE now claims not to be recycling metal from its radiological control areas.

NRC announces public comment period on proposed rule to legalize release of radioactive wastes.

The Nuclear Regulatory Commission (NRC) hired the National Academy of Sciences (NAS) to provide credibility and recommendations on streamlining the release of radioactive materials from regulatory control. The report came out calling on the NRC to do a better job of involving the public in the process if they want to proceed with letting nuclear waste out as if non-contaminated. NRC holding a meeting at its headquarters on May 21-22 but no other public hearings on the issue and is claiming that this is an "enhanced participatory rulemaking." The Nuclear Regulatory Commission proposal was published on February 28, 2003 in the US Federal Register giving the public until June 2003 to comment.

The NRC currently allows some radioactively contaminated materials to be released, reused, "recycled," or otherwise treated as if they were not radioactive through provisions in licenses and case-by-case evaluations. States, like Tennessee, have issued over a dozen permits to companies to "process" and release radioactive materials into regular commerce. So, as with DOE nuclear weapons sites, commercial nuclear licensees can do either or both: 1) directly release some radioactively contaminated materials into commerce, recycling or unlicensed landfills; 2) send radioactive materials to processors to treat and then release into the marketplace.

Contacts: Norman Mineta, Secretary of Transportation US Dept of Transportation, 400 Seventh St. SW, Washington, DC 20590

Secretary of Energy Spencer Abraham, US Department of Energy, 1000 Independence Ave SW, Washington, DC, 20585 The.Secretary@hq.doe.gov

Chairman Richard Meserve, US Nuclear Regulatory Commission, Washington, DC 20555 chairman@nrc.gov

For the greatest impact, your local, state and federal elected officials need to hear from you! Representative ______, US House of Representatives, Washington DC 20515 Senator __________, US Senate Washington DC 20510. Congressional switchboard: 202-224-3121, 202-225-3121. (Faxing is better than mailing to Congress these days.)

For more information contact Diane D'Arrigo, Nuclear Waste Project Director

Nuclear Information & Resource Service, 1424 16th Street NW, #404, Washington, DC 20036; 202-328-0002 ext 16; fax: 202-462-2183; dianed@nirs.org; www.nirs.org

Updated March 2003

[1] Official journal NO. L 159 , 29/06/1996 P. 0001 ? 0114; 396L0029

[2] The Disposition Dilemma: Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities, National Academy of Sciences © 2002, Board on Energy and Environmental Systems, Committee on Alternatives for Controlling the Release of Solid Materials from Nuclear Regulatory Commission Licensees, March 2002.

[3] "This level should be based on realistic scenarios of health effects from low doses that still allows quantities of materials to be released. The rule should be comprehensive and apply to all metals, equipment, and materials, including soil. If problems that would delay completing the rulemaking arise in certain categories of solid materials, then a decision can be made to narrow the scope of the rule." Excerpted from STAFF REQUIREMENTS - SECY-98-028 - REGULATORY OPTIONS FOR SETTING STANDARDS ON CLEARANCE OF MATERIALS AND EQUIPMENT HAVING RESIDUAL RADIOACTIVITY, June 30, 1998.

[4] SRM Staff Requirements-SECY-02-0133-Control of Solid Materials: Options and Recommendations for Proceeding, Oct. 25, 2002.

[5] American National Standards Institute N13.12 published by the Health Physics Society "Surface and Volume Radioactivity Standards for Clearance, 1999; US Department of Energy Internal Order 5400.5 (and possibly DOE's Environmental Impact Statement apparently intended to reverse the existing DOE ban on recycling some radioactive metals from DOE sites; International Atomic Energy Agency Clearance Recommendations; European Council Directive 96/29/Euratom of 13 May 1996. These documents, with the exception of the ongoing DOE Programmatic Environmental Impact Statement (PEIS), were generated by nuclear promoters without input from the public. The DOE had hired SAIC to do the PEIS but let them go due to the same Conflict of Interest problem that forced NRC to terminate their contract.

[6] NUREG 1640, Volumes 1 &2, Radiological Assessments for Clearance of Equipment and Materials From Nuclear Facilities.

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