Your representatives are killing you and yours. wake up!:

[NOTE from Helane Shields, sewage sludge researcher, Alton, NH:

Official EPA policy is to dispose of radioactive landfill and Superfund leachates in sewage treatment plants around the country. As indicated below **, the EPA and NRC acknowledge that the wastewater treatment process reconcentrates the radionuclides from the landfill (and Superfund) leachates in the sewage sludge "biosolids" which is then spread as "fertilizer" on agricultural land in Rural America -- or, in the case of "Class A" sewage sludge "biosolids" compost and/or pellets -- sold by the bag at nurseries, garden shops, hardware stores, WalMart, Home Depot and other retailers around the country for use by home gardeners -- with no warnings as to the contents.]


Contact EPA Today to STOP Radioactive Waste >From Going to Regular Landfills.

Send in Your Comments by May 17, 2004.

EPA Proposed New Rule:
Nuclear Power and Weapons Waste to go to Regular Landfills & other "Non-Regulated Management"

Comments due to EPA by May 17, 2004
Email to: a-and-r-Docket [at] epa.gov
Attn: Docket OAR-2003-0095

or upload them onto EPA's website http://www.epa.gov/radiation

The US Environmental Protection Agency is proposing a new rule (68 FR 22:65120-65151, Nov 18, 2003) that would allow nuclear and mixed waste to go to places that are not licensed for radioactive materials. The goal appears to be to "redefine" radioactive materials, no matter what their source (nuclear power, nuclear weapons, naturally occurring or other), based on EPA-calculated and projected risks. The new category of nuclear materials (once called BRC or Below Regulatory Concern) would supposedly not need radioactive regulatory controls. EPA does not consider all the potential health effects of radiation and hazardous materials in estimating the risks. They have never demonstrated the accuracy of their predictions. (See "Summary of EPA Proposal" below for more details.) EPA’s rule threatens to preempt and supercede existing state laws that prohibit nuclear waste in solid waste landfills or other sites. VT, ME, OH, WI, IL, MN, CO, OR, PA, CT, WV, NM, IA, are among states that have passed such laws and regulations. OK, GA and VA passed resolutions in one or both houses and counties and towns in many other states have resolutions against this action.

TAKE ACTION!

1) Send a letter to the new EPA Administrator Mike Leavitt and encourage him to withdraw EPA's proposed action. leavitt.michael [at] epa.gov

Administrator Mike Leavitt, US Environmental Protection Agency, 1101A,
Ariel Rios Building, 1200 Pennsylvania Avenue N.W. Washington, DC 20460

2) Send comments to EPA and get organizations and landfill boards to do so at:

a-and-r-Docket [at] epa.gov
Docket No. OAR-2003-0095.

The proposal is on the EPA website http://www.epa.gov/radiation.

3) Let your elected officials know how you feel about these dangers by sending them a copy of your letter to Secretary Leavitt and telling them about your opposition to the federal rules that would deregulate and exempt nuclear materials from regulation.

For more information contact:

Diane D'Arrigo, Nuclear Information and Resource Service (NIRS), 1424 16th Street NW Suite 404, Washington, DC 20036,
MAILTO dianed [at] nirs.org, 202 328-0002 ext 16.
See NIRS website under Campaigns at http://www.nirs.org for more info and actions. The proposal was published Nov 18, 2003 at 68 FR 22-65120-65151.

Summary of EPA Proposal

1) First, EPA would allow mixed radioactive and hazardous wastes to go to facilities permitted for hazardous waste only (RCRA C hazardous waste dumps & processors).

2) Second, radioactive waste (not mixed with hazardous) could be permitted to go to places that do not have radioactive licenses or regulations, such as regular garbage dumps or incinerators or hazardous sites. Since the nuclear waste would no longer be regulated for radioactivity, it could go to regular recyclers. EPA justifies this by claiming they will provide an acceptable level of protection >from radiation risk. It seems obvious this would be a problem for communities around the waste sites, many of which already leak.

3) Third, EPA suggests that a “non-regulatory approach� to management of radioactive waste is an option and requests creative ideas for “partnering� with waste generators or other schemes to relieve the regulatory burden. Nothing would prevent radioactive materials from going to recycling facilities and being mixed with the normal recycling streams which are made into everyday household items like toys, cookware, personal use items, cars, furniture and civil engineering projects like roads and buildings.

4) This dangerous proposal dovetails neatly into the US Nuclear Regulatory Commission's rulemaking to deregulate and release radioactive material from control, ironically called "Control of Solids." The NRC is considering several options for nuclear waste deregulation including continuing the current case-by-case release procedures, starting new release procedures that are based on projected risks, sending the waste to sites that are not licensed for nuclear materials. NRC is claiming they could approve "restricted" release of nuclear waste meaning certain conditions would apply but that NRC would not enforce them--someone else, as yet un-named would.

The upshot is that NRC and EPA are joining forces to allow nuclear power and weapons waste which is now generally required to be regulated and controlled, to be released to waste sites and processors never designed to take radioactive materials and to the marketplace where it will come into routine daily contact with us, our kids and environment.

5) To make matters even worse, the US NRC and US Department of Transportation on 1-26-04 finalized new transport regulations (TSR-1) that would exempt various levels of hundreds of radionuclides from regulatory control in transit. This will make it easier for NRC and EPA to deregulate nuclear wastes since they will no longer require regulation, labeling or control as radioactive material during transportation. (This is especially distressing in light of increased security concerns about transportation of nuclear materials that could be used for dirty bombs. More unregulated nuclear materials will be on the roads, rails, barges and aircraft.) NIRS is challenging DOT & NRC on this.

6) Finally, the Department of Energy is in the process of a Programmatic Environmental Impact Statement on releasing radioactive materials from its sites. In 2000, DOE halted the commercial recycling of potentially radioactive metals from certain contaminated area on its sites, but could resume it. DOE continues to allow radioactively contaminated metals out for unregulated disposal and to allow other radioactively contaminated materials out for recycling or unregulated disposal—soils, concrete, asphalt, plastic, wood, equipment, buildings, sites and more. EPA’s Nov. 18, 2003 notice would help legalize DOE’s release of nuclear weapons wastes from regulatory control.

7) EPA’s rule threatens to preempt and supercede existing state laws that prohibit nuclear waste in solid waste landfills or other sites. VT, ME, OH, WI, IL, MN, CO, OR, PA, CT, WV, NM, IA, are among states that have passed such laws and regulations. OK, GA and VA passed resolutions in one or both houses and counties and towns in many other states have resolutions against this action. Notify your state and local officials to comment and uphold your protections against nuclear power and weapons wastes!


** 3.3.1 Reconcentration of Radioactive Materials at POTWs ("POTW" = publicly owned sewage treatment works)


The purpose of wastewater treatment facilities is to reduce or remove pollutants from wastewater in order to ensure adequate water quality before the treated effluent is reused or discharged to surface waters. The removal of radionuclide contaminants by various wastewater treatment processes and the usual association of these contaminants with solids can cause the concentration of the contaminants to increase, or reconcentrate, in sewage sludge and ash. Radioactive materials disposed of into the sanitary sewer in dilute form may become reconcentrated in the sludge solids during different stages of wastewater treatment and sludge processing, in a manner similar to some heavy metals.

http://www.iscors.org/sewageguidance06-2000.htm


United States Environmental Protection Agency United States Nuclear Regulatory Commission June 2000
Guidance on Radioactive Materials in Sewage Sludge and Ash at Publicly Owned Treatment Works


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