Comments due to EPA next week

[goldinem@SONGS.SCE.COM]

Okay folks,  I know there's been at least one note on this list encouraging

comments to the EPA (thanks Barbara Hamrick), but I'll be more blunt:  it's

time to put up or shut up.  There are well over a thousand radiation

protection professionals on this list, some of whom ocassionally complain

about not being heard in the grand scheme of things.  The EPA requested

comments from the public on alternatives for disposal of low activity

radioactive waste.  Comments are due this coming Monday, May 17.  EPA made

it very easy by providing an electronic docket so you can submit comments

anonymously over the internet, or by email, or snail mail, or fax, or even

hand delivery.  So here's your chance.  I'd bet the vast majority of

comments to date (you can view what has been submitted) are from the scared

and confused public or from members of activist organizations who fight

tooth-and-nail against the use of radioactive material for any purpose.

With that said, here is the information you need to submit comments

followed by some thoughts I plagiarized from other more deliberate and

thoughtful sources.  By the way, I suggest you go to the EPA website (see

below) and take a look at some of the comments - they're mostly short and

typically rail against the "deregulation of deadly radiation."



“Approaches to an Integrated Framework for Management and Disposal of

Low-Activity Radioactive Waste: Request for Comment” (68 FR 65120, November

18, 2003)



   Five methods to submit comments:



   EPA Preferred Method:  Electronic Docket.  Go to

   http://www.epa.gov/edocket   (this is an anonymous docket)



   Email:  send email comments to:  <a-and-r-Docket@epa.gov    Attention

   Docket ID No. OAR-2003-0095.  Email addresses are included as part of

   the docket.



   Mail:  Comments to Air and Radiation Docket, Environmental Protection

   Agency, EPA West Room B108, Mailcode: 6102T, 1200 Pennsylvania Ave., NW,

   Washington, DC 20460    Attention: Docket ID No. OAR-2003-0095.



   Fax:  (202) 566-1741, Attention Docket ID No. OAR-2003-0095.



   Hand deliver to Air and Radiation Docket in the EPA Docket Center, EPA

   West Room B108, 1301 Constitution Ave., NW, Washington, DC 20004.

   Attention Docket No. OAR-2003-0095.  Hours: 0830- 1630 M-F.



   Points to consider:



*  Support the U.S. Environmental Protection Agency’s (EPA’s) pursuit of

disposal alternatives for “Low Activity” radioactive waste, as discussed in

the Advanced Notice of Proposed Rulemaking (ANPR)

*  Disposal of low level radioactive waste (LLRW) is headed for a crisis

situation in the near future:

      * Since passage of the 1980 Low Level Radioactive Waste Policy Act,

not one additional regional LLRW disposal facility has opened in the US.

      * The regional LLRW disposal facility in Richland, Washington

currently accepts commercial waste only from member states of the Northwest

and Rocky Mountain Compacts.

      * The only LLRW disposal facility licensed and open to accepting all

classes of commercial LLRW from around the country is in Barnwell, South

Carolina and it will close to all customers outside of the Atlantic Compact

on June 30, 2008.

      * Envirocare of Utah is not a regional facility and accepts only a

subset of Class A LLRW.



*  Are there safe alternatives for the disposal of subclasses of LLRW and

other radioactive wastes (such as technologically-enhanced naturally

occurring radioactive materials) other than disposal at a licensed LLRW

facility?  The answer to that question is “Yes.”  For example, the

protective barriers at Subtitle C, Resource Conservation and Recovery Act

(RCRA) disposal facilities provide comparable protection for hazardous

materials and for many subclasses of radioactive wastes.  Other facilities

such as former mining sites may be useful as well.

*  In particular, mixed low level radioactive waste should be considered

for disposal in RCRA Subtitle C facilities.

*  The thousands of businesses, universities, research institutions, and

nuclear power plants in the US are the focus of activist organizations that

object to the use of radioactive materials in any form, sometimes even

medical treatment.  The risks to public health from proper, regulated

disposal of waste materials are miniscule and greatly outweighed by the

benefits to society from the use of these materials.



Eric M. Goldin, CHP

<goldinem@songs.sce.com>

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