---------- Forwarded message ----------
Date: Mon, 18 Dec 2000 17:32:39 -0500
From: diane d'arrigo <[log in to unmask]>
Reply-To: [log in to unmask]
To: Jim Riccio <[log in to unmask]>
Subject: ALERT:DOT Ok-ing Weakened Global Regs:Paves Way for Atomic
Waste+Materials in Everyday Items and unrestricted commerce
ALERT:DOT Paves Way for Atomic Waste/Material in Everyday Items: Ok-ing
Weakened Global Regs
The DOT is re-classifying some radioactive materials as "not
radioactive" for transportation purposes. By exempting some of every
radionuclide from regulations and labeling, DOT is enabling radioactive
material to enter the marketplace and daily-use items and raw materials.
The US Department of Transportation (DOT), as of January 1, 2001, is
adopting, by reference, International Atomic Energy Agency (IAEA)
-suggested regulations, ST-1, that include
NEW EXEMPTIONS OF RADIOACTIVE MATERIALS AND WASTES from labeling and
regulation and other
WEAKENING OF NUCLEAR TRANSPORT REQUIREMENTS.
This is just one of several problems with the radioactive part of the
DOT's proposal. DOT is amending its Hazardous Materials Rule (HM-215D)
for international commerce. NIRS has only reviewed some of the
radioactive provisions. We have not reviewed the rest of the changes
regarding hazardous chemical transport. DOT is adopting this as of Jan 1
2001 for international commerce, unless public opposition is voiced
loudly NOW. Both DOT and the Nuclear Regulatory Commission plan to
announce adoption of these nuclear regulations and exemptions for
national commerce (within the US) in the spring of 2001.
DOT Notice of Proposed Rulemaking: 65 Federal Register
205:63293-63435, Oct. 23, 2000
Harmonization of With United Nations Recommendations (IAEA ST-1),
International Maritime Dangerous Goods Code (IMO DGC) and International
Civil Aviation Organizations Technical Instructions (ICAO TI): Proposed
Deadline for public comment: Received by DOT by 5 PM Friday, December
22, 2000
Docket # RSPA-00-7702 (HM215-D)
Mail Address for comments: Dockets Management System
(2 copies are requested) US Dept of Transportation
Room PL 401
400 7th Street SW
Washington, DC 20590-0001
Website Address for Electronic
Comment Submission**: http://dmses.dot.gov/submit/BlankDSS.asp
[** doesn't always work-
http://dmses.dot.gov/submit/Comment.asp?session_id=65132
Email contact to be announced]
Fax Comments to: 1-202-366-3753 FAX
Phone Number for DOT Docket office: 1-800-647-5527
Actions Suggested:
--Comment to DOT by December 22, 2000.
--Contact DOT Secretary Rodney Slater to let him know what DOT is
doing-helping the nuclear industry release and recycle nuclear power and
bomb waste into daily commerce and household items.
--Demand public access to proposed regulations-actual documents being
adopted "by reference"
Ask for printouts of the ST-1, the ICAO Technical Instructions and the
IMO Dangerous Good Code pertaining to transport of radioactive materials
and wastes.
--Send copies of your comments to your local, state or federal officials
(such as emergency responders, governor, elected reps and senators) from
yourself and your organizations.
DOT Proposed Rulemaking:
The proposed rule (HM-251 D) is an amendment to the Hazardous Materials
Regulations which covers both radioactive and hazardous materials
shipments and applies to International Transport. Both DOT and the US
Nuclear Regulatory Commission will be moving to adopt this and more for
Radioactive Transport Within the US in the Spring of 2001.
As part of a larger set of changes to the Hazardous Materials
Regulations, The DOT is
exempting quantities and concentrations of radioactivity in shipments
and packages,
The exempt concentrations (being adopted by reference and listed in
Table I of ST-1) were derived by nuclear proponents, to legalize the
release and recycling into general commerce of radioactive wastes from
nuclear power and weapons facilities around the world. They claim that
the levels of contamination will pose a "trivial" risk, not worth the
resources to regulate.
Under the guise of "harmonization," international radioactive transport
regulations are being changed to allow unregulated transport of
radioactive waste and materials from nuclear power and weapons into
unrestricted commerce, raw materials and consumer goods. The change is
"needed" because the UN International Atomic Energy Agency is
encouraging release and recycling of nuclear materials as if they were
not radioactive. The current international transport regulations (SS-6,
which are currently "harmonized" around the world) require labeling and
regulatory control of the materials.
Two new columns are being added to the chart of radionuclides (isotopes
of radioactive elements). Column 3 lists Exempt Concentrations. These
are the very same concentrations that the nuclear establishment is
trying to get adopted in every country to allow radioactive waste
release and recycling. US DOT and the rest of the world all currently
have a uniform exempt concentration for any radioactive materials (70
becquerels per gram). NIRS does not support any level of exemption, but
this is the existing world value. Now, based on "science," the nuclear
establishment wants to change these numbers-and well over half of them
GO UP, thereby increasing the exempt concentrations for the majority of
radionuclides.
In addition, Column 4 has been added to exempt given amounts or
quantities of radioactive materials in entire shipments. There are no
exempt amounts currently in the DOT or international codes. There should
be NO EXEMPT AMOUNTS added to these tables. Further, the amounts listed
appear to have the potential to result in doses near or exceeding
allowable worker inhalation doses in the US. (Internationally, workers
are limited to lower doses than in the US.)
Since the US NRC refers to DOT regulations for some of its labeling
requirements, these DOT exemptions may have greater ramifications than
DOT alone.
The US does have some differences in its existing code from the
International regulations. It is imperative that the US DOT reject the
exemption provisions in ST-1 for international commerce, and for
commerce within the US.
OTHER ISSUES of CONCERN IN ST-1
High level radioactive waste:
Already inadequate criteria for Type B containers, used to transport
irradiated fuel, are being reduced further.
Uranium Hexafluoride:
Packaging requirements for Uranium Hexafluoride are being weakened.
NIRS Conclusion: We demand that there be no reduction in current
protections and that current protections be increased if they are
changed. NIRS opposes any changes that increase allowable concentrations
or amounts of unregulated radioactive materials. We oppose any changes
that weaken already existing standards, even though we may be critical
of those existing standards. Greater public knowledge, involvement and
access to rulemaking are essential.
More Information:
Diane D'Arrigo, [log in to unmask]
Nuclear Information and Resource Service 202 328-0002 ext. 16
</XMP>
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