ML19343D029
| ML19343D029 | |
| Person / Time | |
|---|---|
| Issue date: | 04/06/1981 |
| From: | Felton J NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Honicker J AFFILIATION NOT ASSIGNED |
| References | |
| FOIA-81-90, FRN-45FR70874, RULE-PR-150, RULE-PR-30, RULE-PR-32, RULE-PR-70 NUDOCS 8104090099 | |
| Download: ML19343D029 (1) | |
Text
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' E NUCLEAR REGULATORY COMMISSION 1b e
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Ms. Jeannine Honicker bd-362. Binkley Drive IN RESPONSE' Nashville, TN 37211 TO FOIA-81-90
Dear Ms. Honicker:
This is in further response to your letter dated November 11 1980, in j
which you requested pursuant to the Freedom of-Information Act, copies
- i of comments and NRC's responses to the comments on proposed exemptions-l for smelted alloy published in the Federal Register on October 27, 1980.
In a telephone conversation on March 30, 1981 with Mary Jean Raphael of f
my staff, you requested copies.of the approximately 27 comments on the Draft Environ:nental Statement.
Please find enclosed a copy of these comments.
' i This completes action on your request.-
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Sincerely.
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Felton, Director-Division of Rules and Records
.0ffice of Administration
Enclosures:
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Nuclear Regulatory Co= mission c, Ohf Tashin6 ton, D. C. 20555 f,
Attn:
Docketing and Service Section N
Re:
Proposed amendments to Farts 30, 32, 70 and 150 of the URO regulations Gentlemen:
We do not want to cook in radioactive frying pans, sit in radioactive chairs, ride in radicactive automobiles, or live with the constant uncertainty that anything we buy say contain parts of your worn out white elephants.
You were able to build nuclear power plants without overwhelming public opposition because they were out o f sight., out o f mind.
Also, the true costs and dangers were not known in the beginning.
Now that you are proposing to bring their remains into our kitchens for perpetual care *, you are about to feel the wrath of the women of America.
I urge you to.icsediately rescind your proposal to recycle metal from the gaseous diffusion plants and in the future, nuclear power plants, to be used in any number of consumer goods, such as unlabeled radioactive frying pans, belt buckles, coins, furniture, appliances, tin cans, copper water pipes, automobiles, and even iron tonic.
We do not want our homes to become your radioactive garbage du=ps.
I feel that your environmental statement is incomplete in its claim that that will be no additional cases of cancer from the return of this radioactive caterial to the market place.
Ts be cospletely accurate the conclusion should read, "There will be no additional cases of cancer that can be proven to have been cauced by returning recycled radioactive metal to the =arket place."
Cancers, leukemias and birth defects don't come with handy labels disclosing their origin.
Buried deep in your environmental statement, NURr3 0518, are two very significant para 5raphs.
"The potential doses are all based on conservative, yet reasonable, assumptions applicable to the situation being evaluated.
As a result, the esti=ated doses are conservative; i.e., they are maximized.
However, the assumotions used in constructing enosure situations limit the accuracy of the renorted doses."(emphasis added)
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9 J. Honicker co==ents on radicactive metal recycle - - page 2
" Average doses to the total body are estimated in all cases considered.
Except for doses to skin and bone, the total-body dose is a conservative estimate of potential doses to organs by external radiation.
This is not true for radionuclides taken into the body by inhalation and ingestion.
Doses to =ost internal organs will exceed those to the total body if the radionuclides are inhaled or ingested in the form (either soluble or insoluble) that results-in uptake in a specific organ.
In situations where airborne radionuclides are present, inhalation is the critical exposure pathway."
Why were only average doses to the total body considered in all cases?
Please redo your environmental state =ent including the following information:
Eone doses from all pathways from all radionuc' ides involved; Organ doses, both from inhaled and injested radiation from each radionuclide involved; (be specific and list each organ, and each radionuclide)
Take into account that some seg=ents of the population, such as the very young, the very old, and the unborn, are more radiosensitive than other segments; Define whether members of certain races will be = ore adversely af fected than members of other races; Give biological ef fects of uranium, technetium-99, neptunium-237 and plutonium; Define numerically the threshold dose, below which no da= age can occur, not an " acceptable level" (acceptable lache spec-ificity);
On July 29, 1978, I filed a 152 page-petition that has be.ame known as the Honicker vs Hendrie case.
This references studies and HRC documents that indicate that for each day th nuclear fuel cycle operates, on the order of 100 people in future generations will suf fer cancer or birth defects.
Your reply to this-petition was that you would take appropriate action at a reasonable ti=e.
The Denton Memorandum, issued as the response to the petition, but which does not constitute an appropriate action, stated on page-79, "?oture discoveries in the l
cure of cancer and genetically related diseases, and genetic engineering may negate many of these ef fects."
It has now been approx 1=ately 21 years, and you have not taken the appropriate action. Now you give the public only 45 days to comment on your proposal to promote trade in radioactive garbage.
l please explain why the deadline for co==ent on the proposed changes to the regulations is Dece=ber 11, 1980, (today), but the deadline for co= ment on the draf t environmental statement, NUREG 0518, is listed on the cover sheet as December 22, 1980.
If your decidion is not to reject the opetion of recycling radioactive =etal into the market place, then I suggest that you reply to each person or group that com=ents on both the proposed ammend=ents and NUREG 0518.
Please publish the co==ents and responses in a Final Environmental I= pact Statement.
Then open th-hearing process.
Allow every person who wishes to participate to be a party to the proceedings, bepause all of us are af fected by the outcome of yaur decission.
Hold hearings in many locations, so that nobody will have to travel more than 50 miles to attend or participate.
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J. Honicker co==ents on radioactive metal recycle - - pase 3
-The environ = ental statement listed Oak Ridge, Tn. as the site for the smelting process.
It did not list who would own or operate the facility.
A cost benefit analysis abould disclose who pays the costs and takes the risks and who reaps _ the benefits and Till a separate i= pact statement be issued for the pro fits.
smelting facility? -How will the addition of this waste affect White Oak creek? What populations take their water from down-streas from the' discharge point of the liquid af fluents? ~
Since Oak Ridge is already the site of cuch nuclear industry _ activity, and is.the site cf the pro.
posed Clinch River Ereeder Reactor, how can the epa standards for radiation be met for people in that crea if ~this smeltering facility adds radiation to the air and water? How will this' affect the taxpayers
-of the state of Tn?
Ihat additional services will the state be expected to provide, and_what will these services cost? Who will-be responsible for the conitoring?
Who will pay for it?
In conclusion, I urge you to reanalyze your data, rethink your plan, and reject your proposal to recycle radioactive =etal for reuse as unlabeled consumer products.
Under the freedom of information act, please send me a copy of each comment that you receive on this proposed action, and your response to each comment.
I further request that fees be waived.
Respectfully submitted du-,nM ;~ue d
Jeannine Honicker e
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