Comments on Disposition of Radioactive Metals PEIS

November 5th, 2001

Dear Department of Energy (DOE):

I am utterly opposed to ANY more release of ANY radioactive materials to the general consumer site-place. The DOE can't seem to keep radioactive contaminants out of our water, air, soil or bodies even when that is your explicit goal. Every DOE site in the United States is killing people. And that's when rad-waste is 'contained'.

It is absurd to think that radioactive materials can be released into the marketplace in a controlled manner. Inevitably, such materials will be used in dangerous ways, such as children's toys, household and healthcare items, and it will be too late to reverse the process.

The general public has made it clear time and time again that WE DO NOT WANT RADIOACTIVE CONTAMINANTS ANYWHERE NEAR US! The issue is not how inconvenient or expensive that might be for the DOE, but how it impacts the lives of our children and future generations. We are tired of having this issue trotted out every few years, and rushed through a few poorly planned public meetings. It affects everyone. Please start working on a real plan, based on long-term health and safety, and stop making nuclear waste!

All options listed in the draft scope of the PEIS allow radioactive metals out. All options allow other radioactive materials out of DOE and contractor sites into everyday commerce. This is irresponsible and misleading to the public. An option must be added that completely prohibits release of all contaminated materials and wastes from DOE and contractor sites. No 'release' practices are acceptable.

The PEIS should cover all radioactive waste and materials released for disposal or recycle or reuse from any part of DOE sites. A real alternative option should prohibit all such releases.

DOE must include in any viable environmental study the evaluation of health effects, pain and suffering, costs and concerns by all exposed and potentially exposed members of the population in this and all future genertations. It must include projection of synergistic health effects (from being exposed to radioactive and other poisons simultaneously). It must include evaluation of impacts of reduced immunity due to low, continuous doses.

* * * *
The DOE has been "releasing"/dispersing some radioactively contaminated materials into general commerce for decades:

Mixed radioactive and hazardous wastes have gone to facilities designed to take only hazardous materials. An early 1990's temporary moratorium on releasing mixed wastes was subsequently silently lifted (allowing contaminated materials out again).

Radioactive concrete, metal, soil, plastics, chemicals, asphalt, buildings and properties and more have been permitted to be released from DOE controls on a "case-by-case" basis at the discretion of the DOE field office managers, regional DOE offices and, in some cases, DOE Environmental Health officials at headquarters.

Sometimes the materials would be released directly to unlicensed waste facilities or recyclers; sometimes they would go to Nuclear Regulatory Commission and NRC Agreement State-licensed processors who can then release them.

The DOE did the right thing when it placed a moratorium on the release of volumetrically contaminated metals in January 2000 and a suspension on the recycling of potentially surface contaminated metals in July of 2000. But, although these were steps in the right direction, some metals and all other types of contaminated materials continue to be released.

ALL releases should be stopped indefinately, until a viable study has been done on ALL cumulative health and environmental impacts of the proposed action.

Sincerely,
 
Jennifer Olaranna Viereck, Director