Document 4279

I
IF) ýftG-ws
P KAAS
IEN Cý,qo S\A Ae-
If
COMMENTS FOR. THE WORD OONCBRNIN
(R~t thece followiuag -*Aneiea)
T.
( i)
Pamnela Blockey-O¶Brieu
D23 Golden Valley
7631 Dallas Highway
Doglsvll,A 014USA
R8EA-99-6283 (Wu440':
DOT ftmeacroh and' Special Frvgrama Adhinistiratiofl
fwrouff Material Regulationsi Compatibility with, the
Regulations~of ther' Intiornational Atomie Energy Agency,.
"'NCKETfS UNIT,.
US Department~ of Transportation
4W4 Swventh St. r SM.W.OK~
Wasingtbn4 DC 2IU590ý.OOý
2.
TIM FULLOWING REFORMS
PVf4O
i~N[
Niiwdear Regulato2!y Commission
10) CFR Pat ?t,.C0Mpati~d.Iity with IANA
frvpot~ton
e. tyr standar~w (Ts.4e-4)wt
Ottherr Transportat'ion3f
Alttftn RIL3a[IN
pr~o
~3)
USNRC
July 31, 2002 (10:33AM)
OFFICE OF SECRETARY
RULEMAKINGS AND
ADJUDICATIONS STAFF
AND ADJUDICATIONS SrAFY
3%Drat- EwRnd=unteatd lssessnent( of )fajcc
&2e
Rul
sPo&oa
Heyi~iozr' of 10 C1PR Part- 7T
Dramft Report fBo Comment),
DRaFT NUwv/c"I-?tW
I~hz1TdMaking and, AdLju.dicationw Stlaff
Offiica ýof' th? Sbmeta2?y,.
US NRC,, Washington,,DC 203555,.OO1
IMuft:Ralty Alialyaiia off XWjor
Ravi sainl of 10) C'R, Part4 71
Dthaft Reporti fbir Coinmeilty
ftbialjaking and' Adjudications- Staff
Office of~ thece Secretary,,
US NRCJ,. WavbingtbinjDG 2f555-Q0011
Dwtcr tk9e fiat that everryoner bau beewi such busy., buWy 31t~ etyn
0I~1t
to pzrodiie a set, of-, reglatiaonff that will meet- with the- approval of theF- Atomini
all
with
planet'
theLpave,,
to
quest
their
ih
att, thw, International Atomicm En~ergy Agency)
time
everyone
aavdmg
Ilkproduce
can
things raxdioactive that the nuclear fuel cycle
over'
many
so
are
therwaspapev
(zyseC' included) bji rolling my comment s into one:
not hae-ý
lapping areas- between a~ll dbcuznents fbr cozwaekt listed above*That way,. one-, dbew
tke
dIOome
t~ha
to
apply
th read frbw sts,, of do cumelt s.- If something d6es riott
AlonEV
racipientt of thi conmment haw,"prepared, just go to the sections that do apply.,
a start,
Thr'
too.
over-haul
the:
the way eiveriyonec involved will learn that the- lAEA neeft
asdai~syta
itf is anti-Democratic,. Mm loody, dkre the77 decide to just' go
isf
below, & certain activity level everyone, should just say its not radioactive? Tkat
EXDmI1I0N~
ND
gieed.of
not sc3ience., or' common senset that!*s- J~unacy. Lunacy in the service,
FMSAT, NO ECEIEPTIONS. How anyone would trusti tfne IAEM anyway ia beyond me& These
Konstant~in&
clowns -epeoifically Director General M~ix- of Sweden,. Deput~y Director General
Saf GtYr
Nuclear
of
Director'
andi
General.
of tbe. thea USSR and, Assistant Deputy Director
hot1I&
acidentý
Chernobyl
-thwafter
Roman of the USA - at. Kiew and tken in Moscow:
milk or- eat let~thuee,
& press, comlferelice at & time TV warned Kiev residents, not to drink
Children were- to be kept indoorsp, buildinge werer being hosed down, and. pzreparation1B
7em~cf_ SE-CY.-06 7
SE i.- 2.
2
mere• being madt (very latt in the piece to be sum) to evanuati all school cahilden
and] pregnant women. At the, IAEA p rmss, conference) according tb the report W Maw
Cbx.bbyL
Radio May 9th, 1986, eited by Hhnews and Boj cun in their outstbinding book*Tka
od
youterdWv
Kiev
in
we
W
:
things*,. IARs Mix, saidJ - among other
M
lif
seeme& to us to be ouyite usual and nomal.
There were many people, on theý sfteets.
In KIew they were• preparing- for- a bcyale, race. We wer shown ai monument dedicated
taerem In other°-vrds,. what w am
th the SecondJ 1Wbrld War. Va smwmany tkourise
quitenormal*.
p roves that life-is
radioactive exposure- on to Rossn, en& Psen had3 nathinW
questionsabout
paueed&
HEfr
i
on- off te
y except that 'vw hoam been toldl that' xeduiaLmtme
siagniftc&nt
of Kie,. ikicludin children. kave indicated nothing- to suggest any
aiting the ske? Mos•sw• Radio
d6ttdinent to health', according to Haynes and Bo j cn
and that area got Wpoo0
kilometer
square
800
report. XKiov city boundarieal enclosed
ain
as the Wihnd
CUriew dumped on it andmthe radioiodines alto at as high their
in
working
employees
rotate
to
radeease .. Lagtrn farm directorsý werw ordered
2hytomyr twar• tke
contaminated fields across the oblast-w of Kiev,. Chernihiv an&)
aeast
l
conta
was
milk
officially designated'. contaminated zone. Fooct and
food intercepted
area but th
at farms , in
lAZA ihn iba report said nothing about contaminated
Iodine-431
storage or at processing plants - some of the milk containing
felt tke I--3T hal
was -utamed into cheese to be held until the Soviet Government all
things nuclearpt•m•
to-,push
d1mcyed snfficiently,. ThbL lAB hasAa written mandate
and
del
and!
,
on
research
aesi:st
and?
IASA fbx eemople ie Wb. %incourage?
Md,V
intS3iLWr•ls
the
proidsionm&...fb"
practtLL application of atbmic energy, make
on,. and, dbvelopumnt and pramUcaL
equipmnmrt and) facilities: toameet the-needs' of researah
It is am autonomoum organization
report)
annual
applicationd of wtomic energy;-..ew (IAZA thiecai"h
of psycholbOgica- ago
Incidne-ce.
about
blathere&
mhich
Le
outfiti
T%+m iig t
tho radiation exposure-.." vhem dismsing.
a P, whick could not, however -'bw relatd
when in fact dim to varjoug sidiew
the consequences 'of Chernobyl in their 1997 Report,
and behavioral- effects
am& observationsi radiation has been shown to inducs functional
Eni
neflesw
too, including motor -ftfects,emotionality9, impairenut' of nervous
of
Effect's
(Biologiml
monkeys
like
activity and deficits in learning* in animals
a
Sciences)
of
Academy
National
Council
Ionizing Radiations Yv National Research
to
effecte
seriouwC
causes
it
plus
things,
well as brain tumors"7 and a host of other
the
of
Co-.discoverea
the
quotes
To
2
not
it
the central nervous system - how could
on tW processes fbr sep.
fissionability of Uranium-233, thee holder of two Pattnts3
products of irradiated (spent) nuclear
erating plutonium f%om the uranium and fission
person who established' the,
ftAl, the thek nuclear chemist an medical doctor, thw
Livermore:National
Biomedical Research Division at the Atomic Energy Commissions
the Professor
director,
first
its
as
served.
and
Laboratory, (at the AEC8s request),
in general,
tJohn W. GofiMe
Emewitus of Molecular and Cell Biology -namely Dr.
causes, as it
It
manner.
destructive
ionizing- radiation affects living organisms in a
away of electrons from the
ripping
the
organisem%
living
of
goes through the cells
thus altering those atoms and mol
molecules or at-oms in which they are present and
electrons from atoms and
eculjes to some other form•. In addition to ripping away
energy state in the molemule
molecules, it can often displace electrons from one
occurritl&
to another.. All of these have the effect of altering the naturally
Aun further i Im answer
1978)
Testimony,
(Court
organism..N'
substances in a biologimsal
was:t Aat standards- In
to questions by the Court- concerning exposure, the Qaestion
Nftclear
your vtemj. would not permit people to die with regard" to reLeases from the
= rehlase, Qdestiont Zero radiation. -nd& that
Ael Cycle ? Gofman rep' lied t
would keep people from dyingV
iewthe only standard, o.... ft, . G•ofran repliew: That
transport etc.releases radiation
fuel
Thafa&ct of the matter isithat spent
yes. sir.
cycle. OVW, 50 years ago-- great
ae does- every other aspect of the nuclear fuel
measurement SI is named) pointed out that
radiolbgist,. RM. Sievertý (after whom the
(See Bertell t "No Lmediate Danger)
ttke~re is no known tolerance level for radiation'
called&
there is no damage-sometimes
level below which Atomic
being a the
that
useless
level
so
is
Agency
Energy
"" tolernce
International
Goodhess,
sehold.
.-.
34
anwenti"ret enrickhent plant was muggWbd into Paidstan from West Germany bemwr
':in WA
t
1977 and 1980 and that occurred (too*z1at*Rj, Crlw SegaPDr. IdUohardlf
UTought*) :Imdlr,- the iSafeguard* ilposedi by, theeVi i
Ww
whAo
PM
Int~a0diona3L Atbeio Earg Agwa.' (A West German oeurt convicted Al heeai Migze
a six monstk suspended sentenoe, accood
off the d*ed and ke was fined $1%WO and gi.n
EketWIAUA in itw relentless quest to kelp nuclearise
ing to Sgan andiTuroo.)
*e!globa wee considered tbiwl-. Uggering effest&:resnlting from the nua•ear fuL
cyle t This kugeEamountaof ocal and gas fired electricity production tooran emryeous diffusion//enrichment plants like Peducaks,, or 'to rm'w thsi US
1xhing from-.•
Dept,- of Basgy' s 3)0 uquareemile, nuclear nightmae the Sevannak River Nuclear- Sitvs"?
Thw-ataggering qaantities of toxic chemicals involved in processing/ilsprocessiwg
nuclear usel/ir-adiated 0spent0fuel - I guess they just love all those chlorides,.
the tri-butyl phosphate, hydrazines eta - and the yumm mercry eand those aoids,
-endationn
r
endatins sould we I Uhless tko
Trut tb• IAZ and its r
morkersw the
thee
ws
puhliomc
the
and
msgilnly jinwe...proteotion to tke environment
answer is- a Hil 3NO 1 Not in thisalifetimfe.
Ialw dkdto. taw
TkereashouI);bs MASSIVE security retated changeew iw tae proposedl
tw ts
years-priorfor
raised
repeatedly
have
potastial'.for terrorism -- an is0WI
tke
of
fact4
Til
NOWZ.
iticomporated
be
should
Se&* 1 tr catastrophe - theekagee
of Staff
w
Chief
J1oiwt"
thea
of
Head
was
kho
whoa
Shelton
matter i s, s I wrot* to General
be
also
ill
it
inside
cask
a
overpask-ane
as
eweponsexist that can go through
casks
roh-as a Milan anti-tank weapon.. Tra•s-port Vekialis for the,la
blavtI Oymi
should hawe side rails added a.foot higer than the ca.k..
. .ic. co
ar solid$.
.
on
theeside towards the public with fire",retardant( an&dbullet-prof materbli perhaps
the
ago *at smaller eams) so that if attacked, the detonation begins: extbrior tb
;M1oWNUOOIS
the
imbeee
cuak as much as possible e. Thefbýwet
tb rudi bactilme DU
inir.U. td~pped'-. aimuor-gibr.3ing iinsponr7 is also pyrrophoric,,
it all inr ken
breathed
Vetlerans
mwr
Gulf
thm
(Tij.
aik often.i•J:te, d
%kht -*
or trainV or
thruokws.
dbdikcatbd
on
be
shoul)d
shinIV
].L
*
thw radiatio- uinkness).
small PwaiiwS
transporting
other 'v.hiolba/conveywaxss, ua dtluw -dihcluding-.those
teh
sized packages - fremi commercial or governmeat sectors, MUST bee tbratiein
In
tral
aDAWW
shouli
and
meaOsnw
sammity
iW
iitI
hards of radiation expo surec
vskicidb-a
otm'keeW
t
back
and
front
eescort
am,
plus
oak,
the
in
*5 company of anorther
awW-bearing "Keep' back, :•,1ioactive:Materail TransportP sgns,. pluw.mU vwdble
should have such plaaards (or stencilling of the words in indelible ink whia1rimst
oth
beetouched up every few months for pikagesa hard to placard) as skould all
ogk
mustW.'ube
conv9e&uoes with radioactive materials on board. A n isoaw that
in that every agenc
ONLY AS ANY ATW
pe
can am longe WIE,IT' IS A L33 TO MIIN R&DIOACTI IWATElA
AVING A SPECIFIC ACTIVITY GREATER THAN 0,002 mioroCuribw (70 Bq)
grsmn(or 20eMSpiaoCuries per gram, acording. to thw NRG)'h,
sources it wmrks
If one looks, ut other"
out to 27O pico~uries per gram (Which one is it
11)
but'- inany
If
event one must 3hok at what that becomes when multiplied by differentfactors..
on Kg (t0OO
grams ) all of a sudden you are looking at 70)000 Bqv if it's ae.
thousand Kilos, suddenly its
an
7140Wý000 Bq.por *=G4
it isaun oeptable,. There is no such thing
This.is an outrageous situation
at& ttiVil mount of rvAioactivity, it
all adds up_-andi thee cumulative' effects can be devastatin g.
Aong the most serious- effects of radiation exposure are DNA d~ma et qutk
!;highly unlikely tkat & dose thre&hol&d existw for-thav initia
ISCEAR 1993 a"It
k9a a
molecular damagee to DNA,, because a single track from any ionizing radiation
directly in, or
finite probabdlity of producing a sivsablb cluster of atomi -damage
daumage,
near the DNA. 0nlV if the resulting moleculbr- damag.e plum' any associated
could. tkere be any
from the same trask,, were always repailed with total efficiency
effec*s
possibility of a dose threshold for consequent cellular effects....**biologicL from
originatt
that
changes
DNA
weebelieved to arise predominantly from residual
that
Iell
the
radiation damage to ohromosomal DNA. Itl i&,the repair response of
The majority of damage is. repaired, but it is tke riaining"
determines its fatbe
athat is then considered responsible for' dell
unrepaired or misrepaired damage
4
changes.N
killing, chromosomal aberrationso mutationsi transfdrmationsfa and cancerous
follows
uiat
and
quetv
UNSCEAR
above
the
(both
AndI further - this time from Gofxat
Cancer
-of
Pathogenesis
the
in
Proeadurea.
are- from GOfran t "Radiation from Medical
reLaion
ionizing
of
source
the
1
and Ischeiaic Heart Disease" -;- anbby the way,,. whatever
an
rays
gma
Z-rays,
from
d6se
raidiation
tea damage occurs) who Atatasi:The
beta particles
cells3
iWe delivered bb high speedf, electrons travelling through human
doses, it means
and creating primary ionization tracks.. Whenever there is An radiation
Tkere ar
cells and cell-nunlcbi arer being. traversed by electron- tranks.that am
roughly 675million typical cella in T cubic centimeter."
that no matter
Vist I am. getting at is this a not only have we known for decades
, the effects
effects
no
or
few
are
there
pretend
how hard the nuclear maniacs try to
a
is no d
there
which
below
dose
no
arecreal and last for generations and thereeis
over
transported
to
are,
sources,
all
from
but-unbelievahie Curie quantities total
The
ionizing radiation.
the next years one way or the other, and they all give off
all types of• radiation,
casks. /packages for irradiated "spent" nuclear fuel stream
for during transport
also
are
allowed
doses,
particularily gamna and some neutron.
rates-allowed] by NRC
dose
surface
AVERAGE
many)
with overpack for some casks (perhaps
hour of
are,40mO= an hour neutron + g-,ma on-the side and 16 mr.m an
in real life
radioactive decay heat- ladies
some at inlet and outlet vent dncts, (Yes, they give off
and am outrage) am thm NBC
thinks
public
the
and gentlemen that is WAY ABOVE vhat2
grovelling beform
give. anyone who does a little grovelling) an exention)and if NRC is- thope wa•sels of
two9p
case)
the
(usually
the nuclear inddstry at the same time)
Congress ta geot even
greed so they don'tl go- running to w3 gullibleh nuclear illiterate
Orr one cask system, one
worse than what they want from NRC, the results are awful.
where-the original
facilities
oL the Holtec types, one that is shorter and for use at
design genious*
of the plant diftn tmake the doors big enough for clearance into
at
made allowr 5U mrm/hour
out- of the fuel handling area/building,. and the cbanges
Fbn. yearE the public thought the
ducts..
inlet/outlet
the
at
the sides and 45v mrem an hour
but! againAt' theeaforementioned•'
the casks gave off 10 mrem an hour which was bad enough,
reason allows the
bizarre
some
for
DOT
that
fact
the
that
to
its &:nightnarei. Add
level by the time utt
contamination on a cask at the start to reach a stagger4ing
decontamination stops
reaches its destination - which should be changed to require
finally found out in
en route.- and the situation worsens. Then throw in that they
of contt.ena
Nrope that for years shipments often had a removable (1) level
regulatbry limits
IAEA
of
exeedance
an
to
up
of
cars
rail
and
on spent fuel packages
Aftorr estimating the occupational and public dbsesý
&$ &&-much as a factOr of 1OIX.
authorities concluded't hat
according to the NRC Proposed Rule, the European transport
In other words, the bmt~rdb•
these incidents did not have any radiological consequence.
news reports and many sacentists
lied . As I speak three languages, I read some of the
From what NRC writes,
and doctOrs were very angry at the position taken by officials..
of the spent
contact
by
the European officials believed the contamination was caused
Now if that is
pool.
storage
fuel package with contaminated -Mter from the spent fuel
from
it fell
ii
truth
the
the case that they said that, they obviously wouldn't know
is-auled
everything
Heaven engraved on a tablet, - it is a requirement that after
is no way that the same•
out of the spent fuel pool, it must be decontaminated. There
All of this
years.
mistake could have been repeatedly made all over Europe forpenetrating than
more
is even
leads to the fact that gamma radiation - and neutron of the greatest epedemiologist
X-rays, and dUe in particular to the outstanding work
effects on children exp
of the last •sotUry, Dr. Alice Stewart, we know the ghastly
osed in the womb to radiation is a major cause of childhood cancers and leukemia,
of the develloping
and due to other studies we know of the terrible vulnerability
Any pregnant woman who is near any transport or
embryo and fetus to radiation.
a postal worker, a passerby or
package giging off radiations whether the woman is
any women of childbearing
whatever, or a radiation worker (The Devil only knows why
it should be forbidden, totally)
age are allowed to work around any radiation source,
quot& Dr, Alice Steura
any woman who could be pregnant,. will be exposed and,*
and, site of Wtadpolb, yoWiv going to be espesimlfly
s te .lshp
"*1WMOk r
..
to mutagemic hits.. If a; hi occuni in. aý tissue? tbiatlw going ta fbrm an essential
component of the body such as the lungs or intestine, you won't survivei This iw wky
chi3AI•en do not get cancers in these organs - these children don'T get bairn." Sk* goew'
come about .ShW,
on to discuss how childhood -as appossed to adult - types of cancers
e? cel ity the
da8a
also discusses the fact that if it is a germ cell thatsw been
suffevr from
will
child
the
oearies or testes - sn&'that germ cell later forms a child,,
que te
up,
showing
bfnnr.
an inherited abnormality, or-it may skip-a few generations
for
trouble
potential
as
lurk
"Oncm, youllve fed defective seeds into the. gene pool, they
sewets
and the
the £futureM." (From "Thm' Woman Who Knew, Too Much - Dr6. Alice Stewrt backdiop, it.
this
all
Read it, and weep.) Aganatit
of radiation.* by Gayle•!Gteene.
anyone to any additional radiation dose, o=r to
expose
to
criminal
la;and would be
allow averaging, or to maintain
declare that there should be exemtions of any type, or-to in a regurgitated version
bring,
there is such a thing as a "negligable risk" , or to
name) rules
(same thing, new
ot,NRC a, infamous BIE(Below Regulatory Concern) and ERROR
this is another attempt
appears
it
they tried to pass against massive opposition - and
control. This
regulatory
warrant
to exempt pagea of contaminants by saying they don't
SAFETY
BASIC
a
used
IARA
It says the
is.wrong, a&moral and scientific disgrace.
.,below4
Protection-65
:Radiation
with
STANDARD - or BSS (more like BS) - in accordance
a total
by
followed
is
That
.
which reporting isF not required in the European Directive
result
a
as
publicthe
to
nightmare-which includes them saying they evaluate: "exposure
of that gem ? For' onew thing,
of disposal in a public landfill". Where are? the details
, which can already dump
materials
a city can have hundreds of useres of radioactive
who came up with allowing
idiots
certain quantities in local landfills because of the
to air - add the new
releasing
it,. so they are already leaching to groundb'ter and
over time in the
dumped
being
up
excedt proposals and millions of Curies could wind
and induwbries
US cmmmunities
local landfill.. Acoording tO the.EPA, by the mid 19901'w queTWs wlkh great majority
amdl
disposed of waste in some 93000 landfills nationwideof groundwater
haonb "
of these landfills ar8- current or'potential sources
Of
nationwide.
xo•uc1t
on
Millions of people in suburban and rural areas rely
AND ME gat
.
STXAR LA,TNvALINO ,WVIDZ,NJf,'H
th, States, AKMCANVZUATTWYvDDN
The States with lowest ground•,ater
60% to7h% of their drinking water from groundwater.
water from groundwater, ihelUdef
their
of
49%
get between 25% and
requirements still
New York, Georgia, South Carolina
in those are MarylandVirginia Pennsylvania and
water from groundwater , like', Nw
and others. Some States get 75%to TOO* of their
not only from chemical
MeoEco and Florida . Much groundiater is already contaminated,
radioactive contamination thanks
contaminantst pesticides, herbicides etc, but also
River Nuclear Sit-) or
to Dept. of Energy weapons/lab sites (eftgi The Savannahincrease the existing problems,
commercial sites. Dumping to landfills would massively groundwater plumes travel
as all landfills eventually leak and their contaminated
landfills are located so that
for miles endangering countless people even more, Many
one wants g additional exposuurep
surface runoff goes into area streams as it is. No Strontium-90, combined with itsý
yet it says they may transport up to 200 Bq/gram of regulations. No4 Strontium-90
decay product of Y-90 before becoming subject to the to the baby's teeth and boned.
migrates to bone and during pregnancy is transferred
And what is all that about a 5 rem
Y-90 is an extremely powerful hormone disrupter.
NO exemptions, no exceptions.
dose to the skin. Are they nuts 7 (Yes)..
If one does not know what the activity
i
Concerning various other issues
Regarding all the Ai and A 2 values annd
is in something, it should not be shipped.
some level. Wrong. Ask
many other issues, it pre.supposes that people can resad&t
need to be kept as well
units
The Curie/mrem etc. old
groupd like "Literacy Action".
to events,(and
respond
to
as that is about the only thing that people who may have
with
emergencies
in
about
many others)understand to some extent - chaos could come
under
brought
be
All the ores should
the use of unfamiliar terms/measurements etc.
living
the
have contaminated
regulation because disgusting companies like Cabot who
documents and caused huge'
NRC
to
according
daylights out of areas in Pennsylvania
sludges and contaminated dirt,
safferring in humans and animals alike with their ores'.
huge physical quantities and
all of which should be regulated. Such outfits deal in
61
its a classic situation of what can happen if you look at something gram by gram when
a company deals in thousands of kilos. They had transport situations where there waa
contamination up to Canada.. There are also old mining sites whwre wh at was mined left
behind hundreds of millions of tons of radioactive tailings that give off radon gas
which need cleaning up/stabilizing etc. Nat.Irally occurring radioactive materials
even if not intended to be processed for their radioactive components (like all that
slag and-sludge companies want to offload on Chinaor Taiwan according to import/export:
applications for example) MUST be regulated with no exemptions.
It is stated that IAEA adbpted values based on recommendations by the-International
Commission on Radiological Protection. All sorts of agencies and groups base their
recommendations on the closed Club of good 01' boys who operate under no oversight by
according
the public/independant scientific groups etc. The ICRP is- the group, who,
Chernobyl
or
Hiroshima
of
victims
with
to reports does not consider direct experience
ago
years
who
criminals
the
are
ICRP
The
or other contaminated victims as necessary.
damage.
genetic
of
knew
they
though
even
set the allowable doses to sperm and ovum
and member of
According to Dr. Bertell in "No Immediate DangenU RBitsh MWE Member
.
most important oonsatdration la the genera
::*
thee ICRP ]or. B.. Mole) sted
accepted value judgement that early embryonic losses ar
oonmern.'
of, little
personal or amcmial
There? must be- millions oft women worMýdde whop, undbr guaranttew of immunity
from prosecution , would subject that odious. person to, their own form of Judgementfbr
Butt that' I? the-ICR?. Whera? was the ICR? during
such. coldhearted,nruel lyihg words.
off
worldwide ? PVrtesting in font'
contaminants
a1ll the nuclear bomb testing raining
busy
government buildings: and the press worldwide perhaps? N ct bloody likely, Itoo
at
mdwing
wear
they
level
theE
that
1965
in
stating
pimping for the nuclear industry
energy programm
that time Upromid1es reasonab1a• Matitude fbr theD expansion of atomia
in the foreseeablw, future6.
Almot every agency -and many others- around the world
CommissiomI
rely on things- ICE? says as well as the truly awful Atomic? Bomb CasuaLty
founded on- lousy
Retiation Effects Reaearch Fbundktion Hiroshima• studiea, am& dhtai
time thousands
Filrat they wait fire, years after dropping THE BOMB dfingW which
science.
cat
coniavea
donIt
people
or
d6formed,
are
or
live
die, children are! born and don't
away
enough
were far
rall, illness and shock and unavailing grief numbs survivors who
are oompromisedý.
to-,surviveaand had pretty good immune sytems to start with, but now,them to be a•
d•clreal
who
foreigners
of
bunch
&
Into their shattered lives comes
garbage, teyr
representative population ,. ýnormal population. This-was of course some
level dim
wre' psychologically damaged from trauma and physically damaged at (and many just did
to their exposure.. Tha people interviewing whoever could be found
not participate) were mainly the nuclear physicists, health physicists, ra•Dtiologists
haw stated
not doctors of medicine trained in evaluating human health. Dr. Stewart
researchers,
thAse
that people were reluctant to talk about personal problems with
subjects and
women in particular, and Japanese midwives who acted as links-between
tb socially
the ABBC held back reports of stillbirths, malformations etc. nmt wanting
yourselves
Ask
stigmatize Japanese families and bring more of the ABOC attention.
a bunch of f'bregnerr
who read this, how willing would you be to share anything with and, family and, your
who obliterated thousand of civilians, non-combatants,, friendson where you happened to
entira-hometown, and tha reason you survived was mainly based
oo-operatý&.
be at the time ? Yout& tell them to go tO hell. Or you wouldn't redlly
dcing-their
is
Soawhen everyone
I'y,:knova survivars. I agr ee with Dr. SteWart•
poisons, rpmember that
radioactive
terrible
most
the
concerning
little calculations
Atomic Bomb
the
the effects, were far, far worse and the data is a mess. Ymrthermore,
- which
Casualty Commission ww funded entirely by the Atomic Energy Commission
Commission after
later became FRn/1DeP arrtment' of Energy and the Nuclear Regulatory
Evem theorigion of the word Wdbse" seems to
& disgusted Congress split it up.
absorbed you're damage&l
have been forgottema Radiation absorbed dose. Once it's
- or about one
Onea tad creates roughly one billion ionizations per cubic centimeter
and NONE of it is
damage
gram of tissue .(IEER).. The bottom line is i there is always
incomprehensible.
How, MO-99 got a 20 Curie exception to begin with is
acceptable.
kidney
Molybdenum affects the eyes, respiratory system, blood, and can cause liver and
controlled.
be
should
and
dangerous
its
damage - toss in that its radioactive and
7
Just because a major manufactirer and user of californium-232 comes whining about costs
d to lowereing exposure etc. dbes't mean they too should get an exception.
roaat•
For-ona thing they could shove an overpack around the existing packs they use to reduce
exposure. They also don'Ctunderstand radioactivity based on what is said - it dbasnat
five to
mattemrWHAT is-done to something radioactive , you could boil it in oil or set
hl•f
many
going to give.off radiation through
it, or dump it in water and it is still
lives,. let got s a& year half-life, so that means it has a full radioaectivWmasmardoue
its poket into a river
life fbi' about 2 tbcD52years. Drop one of those sources out of
stops contaminating
at the bottom of a gorge, and youtve got a long wait before it
water and fish.
4
tight*'
All p askages should be double packed/ have-.overpacks,. not just strong
ozW
how rbg
ma~tter-'
ft
shie3kAdiddly.
ften't
~to
actual shielding material - 8
for Plutonium regardlessi.
,.bm
smal. There should be absolutely no removal of double packs
fissile material. I 8I1
Therwe shoulAdbe absolutely no exeptions or exemtions regarding
an exemption. That stuff
could not believe that some bozo must have given uranyl nitrate It. sbhoul" be higdy
is unbelievable in its health effects and envronmental effects.
It must be heavily shielda
regalated. Depleted uranium should also be ftrrmmares regulated.
that in case of an accident
It La. outrageous that everyone seems p-zWre&d to believe
toc individiul organs including
itt is O.K.. fbr people to be exposed to 5 Rboto-to 50) Raw
control if nee& bw to
the skin.. - It' - not. Improverthe shielding, and use remote
wLth better shielding also.
help packageo wat needs to be shipped and provide workers
-Radioactiv Ya•tifl'o so that
All p1.kages1, no matter the size must be- labele&' Mgwo-
must lvWyx
iwrkerw, and the public know to stay away from it. ShippiW dbeariptionsg
not need3 to
dbew
One' also
stste it isaradiotaive material. That must not be rmved•
Thera nust
story.
of
defineftadioactivem - if its radioactivw* that is what it is, end
ear Surfacm Contaninated•
bee NO antkorization to transport unp xed Low Specific Activity
stuff in tank contain
the
Objects- unpackaged,.or unshieldbd. It must bwe forbidden to put
For-the love of God, don't
ers,, freight containers and metal intermediate bulk containers. ED WkY shoulffl ANY
you all understand you'll contaminate those containers too ? An&
5-3, oir 0-44
or- poor contaminated: animal tissue be exemted.
(Still dbing- those foul, anim"a
2.)
tortuiring studies I see4i. Isn't 50 7ears ofi them enough
packagecylinder/cWnister
Hexafluoride
Uranium
shoul&.AfY
hell
of
Nod:war thisL-ide
can be added- using
overpacks
be allowed ,to be excmupted from tkermal test requirements
notorious
the
like
robotic type equipment to lower worker doses. Not that outfits
it. The National
of
look
the
by
United States Enrichment COrp. care much about the workersliberal the good old Nktional
Geographic Magazine, July2002 issue - not known for being
rusting cylinders. Wftdo
Geographic - khs great shots taken from the air of all those
We do not need to be emniching
nott need to facilitate international transport of U4
enough weapons of mass destruction
or otherwise using it in any form whatsoever. Wo hs
out theik rA
spewing
and enough decaying., dcirepit, eabrittled nuclsar power plants
DU containitigweapons
enough
ioactive poisons to air, soil and water already.. And we-hvre
and bulletts ..
the BarW squad - t
NO AIR-TRANSPORT, NO SHIP TRANSPORT, Just because theo Death Of
It- mean it
dfet
DOE - is inme enough to have shipped spent fuel by air saltady
fuel, or hi-.
spent
radioactive
skould be allowed. It must be bannedmi.. To ship doadly,
that eveyone'
fua•
mix)
livel waste, o=' the, MOX (Mixed Oxide fuel i.e. uranium/plutonium
from putting
squad
Earth
the)
is fighting DOE and NRC over anyway to prevent the Death of
Savwabf
facility at the
(or- rather is ghastly contractors) a Mixed Oxide fuel fabrication
the greatest wate•
over
and
River Nuclear Sitla over an earthquake zone, unstable soils,
iL truly nuts..
air
by
recharge area in the southeastern seaboard - to ship that stuff
on landin-andi b•mnut
an air collision. Imagine at JFK a transport crashes
IMa
Murphy's Lawi, ftwther
Think
calculations.
usual
the
into flames. Don't! give me any of
the use of commerc&X airporti fbr
allow commercial air transport,. n
more4 NV
Iff you all think you have & problem
any rwdioactive transports. It shouldn't go by ai..
and'WIPP etc.. NOW,
anYdtYccw1Mountain
fuel
with ad-verse publicity concerning spent
eo1
of
just• wait until air transport of deadly, radioactiVe spent fuel makes the cover
worldwide.
TIME magazine and the evening news
,t th
Thm TS-R-4 uses a,'term signifying a limit to contamination - accordingby
desired
be
to
lot
a
leaves
Ivat Environmental assessment done for NRC (which
again
onen
and]
valueai
guidAnce
consLders them!
I'
the way) the usual, murderous 'MM
factors
rand sovial
everything only has to be kept "as 'low as reasonable, soonomie
being taken into ancountt".
that one day ther will be trials
It may note heppen in my lifetime, but I am convinced
Trials, and: it will izrlude
of this entire Nuclear Mafie similar the thew Nuremberg weaponeer and wahea desner,
every animal torturing pseudo-scientist,. every nuclear
not to mention the IAEA and the Death Of theEarth bysuad.
licensees conaerning• event,
There should beIMMEDIATE notification of the NRC to 60 days.. I's
called sendinxg
notification requirements -not' allowing them 30
week.
w'
within
sent
can be
a Fax and also picking up, the phone4 An updhtebe included in provisions for' a doubl&.
Vitrified high level waste absolutely SHOULD
form.. If breached by explosives,
overpack. This; is dne to what is in this vitrified
some extent (it is in molten glws)
orr' some accident, the contents could shatter to
safety..
and recontainment would be hell. Double containers improves
certificate holders
cask
and
There, shoulkilbe absolutely no allowing the licensees
Spent Fte~l
Indbpendant
relativa'to
to perform minor ohanges. tests and experiments casks
approval..
NRC
prior
without
Storage installations'.a (SSI Is) or spent fuel ISFSI sittation is handled and it
I have read some of the ways that the cask and to grasp that these containers are
must, be far sAricter - these people do not seemthe dbath of a five county area or
meant to contain and control the equivdalnt of,
extent possible. There needk to
more, d6pending on the situation, to the greatest
jail these, idiot'
NRC must be.able- to
be ASKE Codb standards, PLUS NRC oversiot.
for error on this one. CO holdbra
if they don't get; it right. Thereiswno room
and so must cask manufacturers..
and CoG applicants must be held accountable,
be onsite at every single nuclear
A full time Authorized Nuclear Inspector should
being, that Ghings are constantly falling
facility in the country. One of the-reasons
get repaired (or are not repaired)
ap art, cracking, etc. etc. and the way they
Dockets. Fbwthermore, the spent' fuel
is frequently hai*-raising. Read the individual it would help giard against corrup
because
projects office needs the extr& oversight
corners.
tion and cutting
in the tests themselves. Theresseems
The' deep immersion test issue is inadequate
the water 'Isshielding effects shouldt
to be no understanding of the fact that because an unshielded mess of spent fu•L
bedlscounted, because it won't happen
in something like this : HISSSS-B001
rods in a ruptured cask in water, will result
he
water)ful of.debrss
BOWK.. End'of story., Bubbling, boiling radioactive
by
crossings
water
and
boat,
by
fact is,. sp-ent fuel should not be transported
untruea
totally
is
routes. It
road or rail should all be upgraded along transport
plaze near or over deep water,
takes
to say thatsLo a scenario where a severeaccident
unlikely and possibly beyond
(resulting in the package in the water) is extremely
write this read 7 A train went itrtc
reasonable credibility. Don't the people who
past. Furthermore, the Airforce lost an
the water on the Gulf Coast in the recent
Island in about 1 5 feet of mud and
atomic, bomb off the goast of Georgia near Tybee
ex-GIA and Airforce people ar& STILL
that was decades ago and everyone, including
called the Tybee Bomb. It. .s near Savannah..
trying to locate the bloody thing. It's
aone off the' New;JerseW
one of the first thermonuclear bombs. There'
Actaially it's
try and get it removed. The, One that kit
coast also. Maybe you all up in DC should
had no plutonium pit on board in
the poor guys house in the Carolinas fortunately
"beyond reasonable credibility$'
the weapon, but it ruined his life. Nothing is
"Good Handling Practices for
What on earth is United States Enrichment Corporations
up the rusted containers they have.
Uranium Hexafluoride ?1" They can't even clean
makes millions and millions
They don't know the meaning of the words. This'outfit
and should be made to upgrade
of dollars. It can easily afford massive improvements
a catastrophic accident.
all its packaging etc.. now, before there is
safety incex in the shipping dbsThere should be an inclusion of the criticality
-
Thw "FISSILE" label is inadeqvat suand sshould;
cription for fissile material packages..
99.9 % of the population probably has absolutely no ideai what that
have, morer on it.
means. Additie• radiation symbol, tho.words "Very dgerous, Rdioactivei Kemapr f
away from public and animals. Guar-d at all times."
All radioactive material must be controlled, including ores etc. containing naturally
occurring radionuclides, because they are shipped in large amounts. Mill tailings,
contaminated earth, conorzte% rubble, other debris and. activated material at low lpecific
activity levels must be regulhted and not excempted in any way. If not, that plant you
bkty for your mother might have been planted in contaminated soil.
materal
RAdLoactive substances on the surface of a&non-radioactive material, makes that
radioactive, therefore should be controlled.
and
Most shippers., handlers and emergency responders need extra tuainingpersonnel
inspector
NRC
an
and
and they don't understand radiation hazards. A DOT
ecuipment,
it comes into each
should check every fissile material package/shipping cask etc. as
handlers and respon
state along its shipping route in the presence of the aforementioned handling severely
in
ders. By the way, the only hospital in the world with expertise
know what to do.
contaminated people is in Japan. There is no way local hospitals
with cask weeping.
Oncw again, casks should be de-contaminated along the route to deal
aircraft. ThaO is
There should be no fissile material packages whatsoever on passenger
worse. It must
even
is
on
an outrageous suggestion. The fact that it is already going
be stopped.
should never
The, issue of economic impacts to NRC licensees or DOE or. DOD contractors
profits,
massivw
for
ba the issue,, safety should be the issue. They all got into it
can
staff
top
theiir
in particular where NRc licensees like utilities are invoved costs.
take a pay cut and the owners can do a bit of belt tightening to offset
type- packaging and:
Everything, from highway shipments to every type of industrial
be marked "RADIOACTIVE.
package wntaining radioactive Class seven matierials MUST albo
DANGER". This is so people can stay away from it.
some international
Contamination jhould include the word "'NEUTRON" as, well. If
or type etc., by air,
shipments are made anyway of radioactive material at any level
fly over should be
will
overflight approval from the government of every country it
reqiired,,
Wardit-g that
The-DOT definition of Quality Assurance is pathetic. It shoul& includý
officers and
sp-_cifies the use of oversight by health physicists, radiation safety
plus the use
nuclear engineers and ASME controllers, as well as DOT and NRO inspectors,
of the most up-to-date radiation detectors&.
too.
Enriched "heels" of solid uranium hexafluoride should have an overpack objects should
Contaminated
Exrnal d>se rates for Low Specific Activity and Surface
not exceed ONE MILLIREM A YEAR, at 3'meterre,
others, nothing- radioactive
Thereý should be no mixing of fissile material packages with
as amimals,fish,
conveyance
shouldibe tranported on the same conveyance or in the same
listed
exposurew'
birds or' members of the public. Under DOT'w Segregation Distances"
like
its-;
ews
.F=or
to crews, is dlsgraceful. And likewise the exposures to passengers
getting about 49 chest X-rays a year.
contamination resulting
An issue that has not been raised) is the issue of rail-bed
at Oak Ridge and
happened
has
from the transports repeatedly irradiating them. It
TN who
in &Erin
Services
att that pustule on the surface of the earth*Nuclear Fuel
added
be
can
shielding
contaminated the Clinchfield railyard. Perhaps additional
beneath the railcars.
Each licensee whose reactor produced spent fuel and
Another issue is Surety bonds.
should post &
is shipping it or any other high level waste or transuranic waste
cleanup would cost
cash amount in case of accident equivalent to what DOE calculated
I remember correctly.
them. For Spent fuel it ranged up to around 20 Billion if
for example would have* no
Company
Southern
The sum should be at least $ 10 Billion..
and more on TV.
that
have
they
problem with that as they are always boasting
being run over by
Beforw I forget : the crush test. It should be able to withstand
s freight train or'a tank depending on size.
lamented severe data• limitations
I noticed that in the Draft Regulatory Analysis they
J)u
Nevadh
concerning radioactive materials shipments. Considering that the State of
I am
ages,
for
shipments
has been running maps,trin and truck routes and estimated
fuel
spent
of
amount
amazed.. NRC also has information on the absolutely staggering
rods at each reactor.
Ask them.
cost the licensees,
I also noticed that a bit concern was how much everything would
stricken nuclear industry. Everything nuclear ia a huge cash cow.
the poor poverty
could be out is the
It is massively taxw-payer subsidized to boot. One cost that
I see n= reason
of hourly payments that seems to be $77 an hour and up.
estimates
real world, for exampla Wa
wy they should not be paid the same as people in the
good pay in the real world- say
widowed single mother of two working in a store for
cut costs.
$8 to 103 for that sort of Job, per hour. That would
a&"market driven" transportation
The State of Nevada maintains that the DOE plans
subcontractors. Many will never
system that will rely on regional contractors and
DOT and NRC should oppose that
have had anything to do with radioactive materials.
year long courses should be met
and if it happens anyway, requirements for special
and subconttractorsinvolved in shipping
for all radioactive waste/spent fuel contractors
and handling.
shipments should be made only in off
All transport routes should bypass towns, and
teams from NRC and DOE should go with
peaknon-rush hour times an&i emergency response
Rsil crossings and intersections
every spent fuel shipment in accompanying vehicles.
high level waste shipment should be
a mile ahead of and behint each spent fuel and
minutes ahead of each shipment, for
closed off by authorities county by county ten
security and safety reasons.
most lethal material ever . Material which
A final thought. You all are regulating the!
due to the long lives of these
affects and will continue to affect people forever
just another
come across as if it's
deadly matbrials. Yet the proposed Rules etc..
will be real
it
God
by
but
to you,
day at the office for you. It is all not real
that you are regulating something
with the firs- accident.You must never:forget
first place - the detrious of nuclear weapons
that should never have been created in the
the strictest rules ever written - no kowv-tDwing
and nuclear power. These Rules must be
take into account the effects to the
to industry on this one - because they must
affected by radiation : babies, children
most vulnerable among us and those most seriously generations. Just this once5 DOT and
and pregnant women . In other words, the future
regulations powerful protection of People
NRC can do the right thing and make these
and the environment.
Pamela Blockey- O'Brien..
~bT~VV,
ZIAQ
UNIVERSITY OF CALIFORNIA, BERKELEY
S•
DAvis I mvua,(•osu LOS
May 11,
•
n
IAz
,o
• SAM ThAJ8,3"C0
.
SUITA
*,TA
•AM"A
1999
LETTER OF CONCERN.
To Whom It
B
.
A
9
May Concern:
During 1942, Robert H. Connick
and I led the "Plutonium
Group" at the University of California,
managed to isolate the first milligram Berkeley, which
of plutonium from
irradiated uranium.
(Plutonium-239 had previously been
discovered by Glenn Seaborg and
Edwin McMillan.)
During
subsequent decades, I have studied
the biological effects of
ionizing radiation --- including
the
by the radioactive decay of plutonium.alpha particles emitted
By any reasonable standard
no safe dose, which means that of biomedical proof, there
just one decaying radioactive
atom can produce permanent mutation
in a cell's genetic
molecules.
My own work showed this in
Srays,
and beta particles (Gofman 1990: 1990 for xrays, gamma
"Radiation-Induced
Cancer from Low-Dose Exposure").
For
alpha
particles, the
logic of no safe dose was confirmed
experimentally
in 1997 by
Tom K. Hei and co-workers at Columbia
University
College
of
Physicians and Surgeons in New
York (Proceedings of the
National Academey of Sciences
April 1997, "Mutagenic Effects (USA) Vol.94," pp.3765-3770,
of a Single and an Exact Number
of Alpha Particles in Mammalian
Cells").
It follows from such evidence that
citizens worldwide
have a strong biological
basis
produce an appreciable risk of for opposing activities which
plutonium and other radioactive exposing humans and others to
fact that humans cannot escape pollution at any level.
The
exposure to ionizing radiation
from various natural
sources --- which may well account
for a
large share of humanity's inherited
afflictions
--is no
reason to let human activities
INCREASE the exposure to
ionizing radiation. The fact that
ionizing radiation is a
mutagen was first demonstrated
in
1927
by Herman Joseph
Muller, and subsequent evidence
has shown it to be a mutagen
of unique potency. Mutation is
the basis not only for
inherited afflictions, but also
for cancer.
Very truly yours,
Professor 'neritus
of Mo ecul
and Cell Biology
CEM=
`