[ RadSafe ] Re: Understanding negligible dose

[BLHamrick at aol.com]

In a message dated 2/23/2005 12:47:57 P.M. Pacific Standard Time,  
dckosloff at firstenergycorp.com writes:

Even  some (mostly) honest  congressmen understood the issue.  That is  why
they initially passed a law that required the NRC to push  implementation of
the BRC regulations.   Then the grotesquely  dishonest "public interest"
groups, the fraudulent press and some of the  dishonest congressmen took
public control of the issue and shoved it up the  NRC's opening that
Congressmen and "news" story tellers generally can't  tell from a hole in
the ground.


I fear that NRC is prepared to repeat history with the Control of Solid  
Materials (CSM)rulemaking.  It is, in many respects, another BRC.   Without 
meeting the public concerns, and anti-nuclear propaganda head-on, this  effort will 
fail as well, or make things much worse than they are.
 
The major failing is in not making it plain, up front, that radioactive  
materials have been released to public landfills and for recycling for  decades.  
The CSM rulemaking would do nothing more than codify the  standards that have 
been used over decades.
 
The public comments (around 2,000, I think) consistently repeat the refrain  
"do not de-regulate radioactive wastes," giving the clear implication that the 
 public copying these remarks from a few anti-nuclear sites are under the  
impression that these materials have been prohibited from landfills and  
recycling before this time.  Not true.  The public needs to be told  that in very 
plain language.
 
Virtually all radioactive materials licenses for unsealed radioactive  
sources (let's skip the NPP licensing issues for now)  have some upper  bound for 
contamination in unrestricted areas, and these limits are also used as  limits 
for unrestricted release of materials, equipment, wastes, etc.   These limits 
are generally quite low, but non-zero, and have been used for  releases for 
over 50 years, with some ratcheting down across time.
 
I fear that NRC may be on the verge of effectively prohibiting all release,  
and virtually eliminating the standard conditions relating to contamination in 
 unrestricted areas and release of materials for unrestricted use.  This  
could be avoided if the agency had the political will (in my opinion) to come  
out once and for all, and say they're not "de-regulating" these materials,  
they're codifying the release criteria that's been in effect for over 50  years.  
And, to tell the public that although BRC failed as a general  policy, it 
continued, pretty much unabated, on a license-by-license basis.   In other words, 
BRC was not something "new" at the time, so when NRC was told to  halt BRC 
efforts, they went back to doing what they always had, which was to  authorize 
the releases on a "case-by-case" basis through license  conditions.  Nothing 
changed, and the only bad result was that it  perpetuated the uncertainty and 
occasional inconsistencies associated with  non-codified release criteria.
 
I fear, based on the information presented in public meetings over the last  
year or so, that the NRC staff is preparing to close off all avenues of 
release,  in a draconian step to appease the un- or ill-informed, to no one's real  
benefit, and without ever taking the courageous step of telling the 
lay-public,  your comments are welcome, but they only have value where they are 
factually  correct.
 
Barbara L. Hamrick, CHP, JD