Um, since some of the audience here is—includes medical professionals, I wanted to take an opportunity to debunk a myth that new radioactive waste dumps are needed, and also that release levels, ah, or clearance levels or deregulation is necessary for continuing medical research and treatment and diagnosis. These false claims are routinely made to justify ah, new dumps or practices for the nuclear power industry, and what I ah, will mention that there’s a--a booklet in the back of the resources that New York City PSR put out which talks about the real fraction that comes from medicine and research and how medicine and research is reducing the amount of waste that it does create. But a—a really important point is that most medical procedures, ah, that involve radioactivity don’t use radioactive materials that come—X-rays, that mammograms, cancer treatments using linear accelerators use machines or instruments that create the beam—turn the machine on, the beam is created. Turn it off—there’s no waste.

There are—ah, so, that’s the major way that most of us receive radioactive medical procedures and those are completely independent of whether or not new dumps are created or other ah, practices are opened up for the nuclear power industry. There are some radioactive isotopes that are used in diagnosis, treatment and ah, research. The most common isotope that’s used in ah, medicine in small hospitals is Technetium 99M or [metastable?] which has a six hour half-life. So, it’s not going to be detectably radioactive for even a week. Ah, it’s a very short lasting isotope and it’s used, um, for most of the, ah,--most of the image—some of the imaging of body parts. Ah, other isotopes such as Thallium 201, Gallium 667, Xenon 133, are used for—also for treatment and diagnosis. Um, iodines 131 and 123—they have half lives in the range of hours to days. So, they can be isolated for the 10 or 20 half lives and usually the concentrations in medicine are so low that they only need to be ah, isolated for less than 10 half lives, ‘til they’re no longer detectably radioactive and then they can be treated, um, as regular waste, ah, or if they have other ah, hazardous or biological components treated that way. However, the point that I’m trying to make is that for treatment diagnosis, there’s no real ah, need for nuclear dumps or nuclear p—proced—exemption principals, ah, deregulation, more than it’s already in existence, anyway.

Ah, and then for the Carbon 14 and Tritium that are used in research, the longer lasting elements, they occur in very small amounts, very small fractions of a curie. It’s why they’re used. It’s because they’re so powerful in detection in research and those do need to be managed responsibly. I don’t like the fact that they’re allowed to be poured down the drain and incinerated in mo—and New York City doesn’t allow incineration, but a lot of parts of the country, but there management ah, places where this material is managed and again, are not dependent on a—on a nuclear waste dumps.

I took advantage of the opportunity that we’re at the New York um, ah,--we’re involved with physicians here and medical professionals because I feel like, ah, this community is being used as a foot in the door for reactor dumps. It’s a way to buy public acceptance for dumps and for um, a higher level exemption levels.

Ah, so I want to, ah, compare that—what I’ve just described as the um, medical waste—medical nuclear waste with the bulk of the so called low level radioactive waste that ah, is in the national waste stream. And if you look at the national picture and you include decommissioning of nuclear reactors, 97s to 99% of the radioactivity that will be—that is in and will be in the nuclear ah—in the low level radioactive waste stream is from nuclear power.

And the isotopes, the concentrations, are much more dangerous and troublesome than from medicine, as you know. We’ve talked about plutonium. This is in so-called low level radioactive waste. So is iodine. Not just the iodines that are short lasting for medical procedures, but iodine 129 with a sixteen million year half life.

Ah, so low level radioactive waste includes the resins and filters in sledges for cleaning the reactors’, ah, cores—the water that circulates around the cores, the m—um, same elements that are in high level waste. When they leak out of those rods that Marvin showed in his, ah, picture of the fuel rods, those same elements that are high level in the rods are so-called low-level in the water. They filter it, those filters go into unlined soil ditches, according the federal regulations and can be released, um, into the environment at acceptable leak rates.

The um, tons of metal—the—the miles of piping in the nuclear power plants, which become activated ah, after years of neutron bombardment--ah, activation products like nickel 59 with an 80,000 year half life, niobium 94 with a 20,000 year half life, cobalt which is shorter lasting but very intense—these isotopes are also from the so-called low level radioactive waste stream. I know most of you have prob—if you’ve ever heard me speak, this is probably all I ever say, but I want to convey that information to make the comparison that what we’re talking about when we’re talking about, ah, ah, low level radioactive waste is not low risk.

And then, the high level waste, ah, well, I’ve made the distinction of a high level waste as the irradiated fuel, the liquid and sludge from reprocessing, the salad they hope to convert that into. And then low-level waste being everything else and now the new category—not so new really—ah, is—used to be called below regulatory concern. It’s now got a new name called "clearance levels." Ah, the federal government, the nuclear industry, the Department of Energy in the United States and internationally are pushing now for international ah, release levels which will allow the deregulation of radioactive—first metals and then other materials, concrete, plastics, from the nuclear weapons complex, from the nuclear power industry into the environment. They haven’t been able to get any new ditches in the last few years. Ah, they haven’t been able to get high level dumps, so, ah, some place like New York don’t let, ah, incineration occur. Ah, so, what’s going to happen? They’re trying to spread this stuff out, consider it a resource and ah, choose some level—any level, pick a level—below which the material does not need to be regulated and release it into the market place.

Ah, needless to say, the metal workers, the people that handle metal, are not very happy about this for both economic and health reasons. Ah, the general public has spoken about this a number of times. I know in my years of working on the nuclear issue, that this is the third round of fighting this same battle, so in essence what we’re doing now is ah, h—recycling the old recycling battle, and is, [I’ll call Judy Tricle?] ah, all we do when we’re in these fights is we can keep fighting these fights--um, it’s like a TV game show: Whenever we win, we win the right to come back and play the game again. And every time we win, we get to just keep fighting, and every time we lose, we really lose. So, we can’t afford to let that happen. So this is the third or fourth round. We’ll just have to do it again, and again, and again.

It was made clear—it was made clear to the nuclear regulatory commission after its DRC policy was revoked by congress in 1992, ah, NRC held a series of, we dubbed them, "error meetings." They were enhanced rulemaking on residual radioactivity. People probably in this room, around the country, ah, participated in about five different three day meetings around the country, making it abundantly clear to the Nuclear Regulatory Commission and the industry that the level that’s acceptable for release—the level to which we must clean up sites, to release from regulatory control—is existing—pre-existing background—that we don’t add additional radioactivity. We’ve made that clear. That is what the public believes. The heck with this balancing junk! Because once you get into the balancing and you decide that something’s OK—one level’s OK—there’s no enforceability, there’s no verifi—fi—verifiability. Ah, what we’ve got to do is take the best care of what we have created and stop creating more.

Ah, so, the, ah, I just wanted to run through who the—what—what the situation is now—why is this, um, issue being recycled back again? Um, the Nuclear Regulatory Commission has announced that it is going to do an enhanced rule-making on making a rule-making on ah, setting clearance levels. They have already decided that the amount—that there should be some amount of radioactive material that will be released. The rule making should focus on codified clearance levels above background for unrestricted use that are adequately protective of public health and safety and the level should be based on realistic scenarios from low doses that still allow quantities of material to be released.

The rules should be comprehensive and apply to all metals, equipment and materials, including soil. And if problems occur in making a really broad rule, well then narrow it for now, and just get something in place.

So the Nuclear Regulatory Commission is now inviting us to participate in deciding how we’re going to make this rule that they’ve already decided will be diametrically opposed to what we told them in an extensive process in 1993. That’s where the NRC is at and it is my ah, position that this process is completely ignoring, ah, what we have told them before, and I can’t imagine any of us with the time and resources—ah, limited time and resources that we have, sitting around talking to the NRC again and telling them this over and over again. Ah, it’s important that it happen. I think that what we need to do is dust off all the rules and regulations that we got past the last two times around, ah, get them re-codified, um, and let the local, state and federal regulator know that this is not an acceptable path. Um, let our Environmental Protection Agency actually had considered doing a rule making on clearance levels or deregulation and they decided that they’re not going to do it right now, and instead what they are doing is helping custom agents ah, to figure out what levels are OK for import and export of waste in the practical reality. Meanwhile, in Europe, the ah, internat—the IAEA ah, has a proposed, ah, policy and the European union is in the process of being urged to adopt some clearance levels or deregulation levels—contamination levels, maybe call them—ah, which have not been codified yet in any country that I know of. So, on one hand we’re being told, all the other countries are doing it, we better set some levels so that we can be more protective. On the other hand the same thing is being told to all of the other countries. So, we’ve got every ah, opportunity now to expand ourselves and be a more international movement and make a clearer statement about continuing to regulate the radioactive materials that the weapons and power complex have created.

Um, now what’s actually happening with the Department of Energy is that ah, there are releases already being done. There are releases on a case-by-case basis from each field site, um, around the country. And these decisions, along with some of the commercial waste that are trickling out, are based on an Atomic Energy Commission recommend—ah, regulatory guide from 1974 which sets an allowable surface contamination level—certain number of disintegrations per cubic whatever per minute, and—I’ve got those numbers if anybody wants the specifics—but they’ve got a set allowable contamination level that is already being used by the Department of Energy. What the, ah, association of radioactive metal recyclers would like to do—ARMR, which is the group of companies that are trying to come in and make some money off of gutting the weapons complex, processing the metal to a level that they can get released—they want to be able to make a profit. At this point it is, um, not economically profitable to release radioactive metals into the market place, but, if we could just set a level, some level, ah, of allowable release, then we could make it economic and ah, th—this is the perspective of both the Department of Energy and the metal processors, ah, and there are as I, ah, have learned, about 30 or 40 companies around the country that are, ah, new industries that want to do various different types of acid etching or—or cleaning or smelting or melting and one of the projects—one of the big projects that--the bellwether for this is the Department of Energy’s contract with British Nuclear Fuels at Oak Ridge—to clea—to ah—I don’t want to say clean up, because it’s not a total cleanup project, it’s a—a gutting of three, ah, big, massive, uranium enrichment ah, facilities and ah, processing the metal from those facilities.

One of the potential ah, buyers for that metal is a company that makes nickel cadmium batteries—that would take the nickel from the uranium enrichment complex and actually recycle it into batteries that could be used in the market place. There’s also talk about cars. I mean there’s really no limitation once material is released. Ah, there’s nothing that would prohibit it from being used in kids braces or frying pans or cutlery. That’s not an exaggeration. Once it’s released from regulatory control, there’s no regulatory control.

And one of the ways that we stopped this last time—the ah, last round of this—was ah, an actual revocation of the Nuclear Regulatory Commission’s policies on below regulatory concern in 1992. Ah, one of the ways that that happened is that local communities and states said that they’re not going to let the materials be deregulated within their borders. Ah, people got good neighbor agreements with landfills and with other facilities to not take contaminated material. Ah, what the nuclear industry and the federal government have done now is wised up and said well, you know, we have to get the states on our side, and so, there is, ah, an organization of state regulators—the Conference of Radiation Control Program Directors—it’s comprised of the state regulators in different states and they, on their own, are proceeding to make regulations on radiation some of which very badly need to made, but the process ah, that they are proceeding with to deregulate or to—to—actually to regulate naturally occurring and accelerator produced radioactive materials or NORM, is ah, setting levels—th—they’re in the process of setting some kind of a level that will be acceptable so that then the federal agencies can adopt what the state agencies or what these members of state agencies have ah, chosen is the allowable contamination level.

And so I’m ah, cautioning people that we do need to work on both the local--on all three, the local, state and federal level to be clear with our elected officials and with these, ah, regulatory agencies or so-called regulatory agencies that we deal with that the message is no contamination, or whatever the message is that you choose to give. I encourage you to ah, make it known.

And the other um, way that the um, federal agencies are working more closely together this time is through a very secretive inter-agency scientific committee on radiation standards. It—they have a committee on what they now call clean metal, instead of radioactive metal, scrap metal recycling—they’ve renamed it, ah, the clean metal c—ah, committee to set standards that all of the different ah, federal agencies will use in coordination to allow for this deregulation.

Ah, I will stop here. I think I’ve made all the points I wanted to make. I’ve pointed to the targets that I want to see, I’ve said who’s doing what. I hope that people, especially those who have been in it before, will add this to your list of important tasks to work on. I hope that those who have not been active on this issue will be in touch and we can try to figure out a way that we can convey, ah, the message from the public to the regulators and so forth that we don’t want radioactive metals in our day-to-day lives—radioactive metals and other materials. And to remind, we have won this battle before. We can do it again and it’s just unfortunately going to mean having to work again, and it’s nothing we’re averse to, so, thanks.