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NIRS: 1999 Radioactive Metal Recycling ALERT
public comment deadline 7/5/99

CMEP: Rad Metal 2/98 Update
Public Citizen's Critical Mass Energy Project

Hello All:
          We are happy to report that the US Environmental Protection Agency received just over 150 letters in response to their proposal to allow the reuse of radioactive metal for consumer products. Only one or two of those comments were from companies. The majority of the letters told EPA that consumers do not want any radioactivity in their products. This is an amazing show of our cohesiveness on this issue--considering we only had 3 very busy holiday months to organize. Way to go!
          EPA is in the process of analyzing the letters and will determine if they will go forward with a formal rulemaking process within two months. EPA has admitted that the number of negative comments will influence this decision.
          Furthermore EPA is still taking comments despite the formal closure of the comment period on January 31 1998.
          Therefore we should not let up on our pressure to prevent the release of this harmful metal into the public realm. Please continue to send comments to John Karhnak Please also copy your letter to me
          Jessica Vallette (
          Keep up the excellent work!

Direct your comments or questions:
Public Citizen's Critical Mass Energy Project
215 Pennsylvania Avenue, SE
Washington DC 20003
phone: 202-546-4996   fax: 202-547-7392

Date: Sun, 28 Dec 1997 01:25:05 -0600
From: John Bailey <>
Subject: Stop Recycling Radioactive Scrap Metal
Organization: Public Citizen

Help Stop the Recycling of Radioactive
Scrap Metal Into Consumer Products
WE NEED YOUR HELP NOW !   The nuclear industry and their government allies are at it again! They want to recycle radioactive metal scrap from nuclear power plants and DOE weapons facilities into household items. Citizens must act now to stop this sham recycling scheme.

WHATS HAPPENING :   The DOE has a huge stockpile of radioactive scrap metal.

One proposed method is to recycle it into consumer products. Before DOE can proceed with this irresponsible plan, they need the Environmental Protection Agency (EPA) to set standards. EPA has begun this process by writing a Preliminary Technical Support Document and the Preliminary Cost-Benefit Analysis. These documents look at the feasibility of recycling radioactive scrap metal into consumer products. This is the beginning of a rule making that could result in radioactive metal being made into strollers, appliances, bed frames, belt buckles--anything made from metal. These documents are available on their website:

BACKGROUND :   Throughout the 1980's, the Nuclear Regulatory Commission in conjunction with the Department of Energy (DOE), sought to deregulate radioactive waste and call it "below regulatory concern". Under this scheme, roughly 30% of the nation's "low-level" radioactive waste could be treated as normal garbage and disposed of in municipal solid waste landfills or incinerators. Furthermore it would have allowed production of consumer goods from these materials, most frequently through recycling the waste.

WHAT   YOU   CAN   DO :   The public is being asked to review and send in their comments on these documents by January 31, 1998. Please edit the attached sample letter to make it be your own (if nothing else fill in your name+addr at top), print it out and sign it, and mail copies to both John Karhnak at EPA and John Bailey at ILSR. These letters will demonstrate to the EPA and the DOE that the "stake holders" are not just industry organizations--this action would adversely effect all life on Earth, including human beings living in the western hemisphere. EPA must be told to set a standard that would not raise the "background" level of radiation that everyone is exposed to. Tell them to set a zero tolerance level. By doing so, we might be able to stop this process NOW.

Your Name
Your Address
Your Daytime Phone (optional)

John Karhnak
US EPA Cleanup and Reuse Center
401 M Street, SW (6602J)
Washington, DC 20460

Re: Radioactive Metal Scrap Preliminary Technical Support Document and Preliminary Cost-Benefit Analysis

Dear Mr. Karhnak:

I am writing to express my concern about the Environmental Protection Agency's (EPA) proposal to allow radioactive metal scrap into the consumer market. It is my understanding that this material could be "recycled" into strollers, appliances, bedframes, beltbuckles--anything made from metal. I am opposed to any recycling of radioactive materials, including metal, into any consumer products. All radiation and radioactivity should be isolated from the environment forever. EPA must set a zero tolerance standard for radioactivity in consumer products.

Furthermore, this comment period was not publicized and the timing did not consider the general public's ability to comment during the busiest holiday season of year.

Regulations should not be used to legitimize recycling of these materials into consumer goods. The amount of radiation that Americans are exposed to today is continually increasing as a result of nuclear power generation, nuclear weapons production and testing, and other events. Now the US government wants to increase our exposure further by allowing companies to profit from recycling these materials? The US government is supposed to protect its citizens from harm, not secretly increase our exposure to these dangerous materials.

Americans have repeatedly expressed our outrage at these proposals. Not so long ago, Congress had to step in and force the Nuclear Regulatory Commission and the Department of Energy to back off from their "below regulatory concern" activities. I hope we don't have to go down that route again.

Please protect our children from radioactive products. Don't allow radioactive materials to be made into consumer products.

Your Name                                   

Cc: John Bailey
       Institute for Local Self-Reliance

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