Re: Comments due to EPA next week

[BLHamrick@AOL.COM]

In a message dated 5/12/2004 12:56:50 PM Pacific Standard Time, 

goldinem@SONGS.SCE.COM writes:

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

comments to the EPA (thanks Barbara Hamrick)...

Thank you, and may I take this opportunity to support Eric's "put up or shut 

up" suggestion.  There are, as Eric notes, over a thousand radiation 

protection professionals subscribed to this list.  It is incumbent upon each and 

everyone of us to offer our comments to the EPA on this very important issue, 

especially in light of the very large number of comments from members of the public, 

who have been subjected to a campaign of gross disinformation by many 

anti-nuclear activist groups, stating such things as "A speck of dust could guarantee 

you cancer" (in a CBS news segment discussing the potential of using a 

moisture-density gauge as a terrorist weapon).  These comments, which generally 

constitute the entirety of the public's education on radioactive materials, scare 

them, and do not inform them in the least about the real risks of exposure to 

radiation and radioactive materials.



There really is no excuse not to at least look at what the EPA is proposing, 

and offer a professional perspective on the questions they are posing.  



As Eric notes, there are many easy ways to get your comments in by May 17, 

including via the national HPS website.  If you are a member, try visiting 

http://congress.nw.dc.us/hps/home/.  If you do not agree with the HPS position, you 

may still submit your own personalized comments via links at this website.



The EPA ANPR is asking questions about potential alternatives for the 

disposal of a broad category of wastes that they tentatively identify as "Low 

Activity Radioactive Waste" (LARW), which may be a subclass of Class A LLRW, or only 

include TENORM, or Low Level Mixed Waste, dependent upon the comments and 

suggestions they receive.



First and foremost, what the EPA needs to formally recognize is that 

radioactive materials licensees across the nation dispose of LARW everyday at 

landfills, because virtually every license that includes authorization for unsealed 

sources includes some type of commitment to "unrestricted area" release values 

that generally apply to the release of equipment and debris for reuse, recycle 

or disposal.  Who among us is not familiar with the old NRC Regulatory Guide 

1.86 values (or some modernized version from NUREG 1556) commonly used to 

release equipment, etc., from a restricted area?  The public deserves the chance to 

understand these longstanding practices too, but they will not, unless and 

until  WE explain them to them.



In the end, it should be the professionals that inform the process and 

decisions made, but that can only happen if you, as professionals, read the ANPR, 

and provide the EPA your professional opinion.  



It is our government, but if don't participate, we get exactly what we 

deserve.



Sincerely,

Barbara L. Hamrick, CHP, JD