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BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE July 29, 2002 On behalf of the Board of Directors of the Blue Ridge Environmental Defense League with members in Virginia, North Carolina, and South Carolina, we submit these comments. General Comments We call upon the NRC and DOT to maintain and improve the standards of radiation protection embodied in current US law. We oppose international harmonization with standards which are less rigorous and less protective of public health. Harmonization must not become an excuse for reducing the levels of protection in present standards. There must be no increase in radiation exposure to the general public or transportation workers. We call for real-world testing of all transport package designs instead of computer modeling. Finally, we call upon NRC and DOT to retain double-walled Type B containers. The introduction or expanded use of less protective single-wall storage or transport containers is not an acceptable alternative. Specific Comments Issue 1: Nuclide-specific Exemption Values The current HMR standard of 70 Bq/g (0.002 microcuries/g) should be maintained as the minimum standard for the protection of public health and transport worker safety. We oppose the replacement of this easier to monitor, specific activity standard with an impossible complex of radionuclide specific values per the IAEA’s TS-R-1 for the following reasons: a) There is no radiation risk level which is sufficiently low as to be of no regulatory concern, b) There are no collective radiological impacts which are sufficiently low as to be of no regulatory concern, and c) No one will be able to determine if proposed exempt sources are safe. Issue 2: Naturally Occurring Radioactive Materials Uranium and thorium levels in phosphate, gypsum, and coal cannot be considered safe because they are naturally occurring. From a public health point of view, there is no need to determine whether alpha emissions above the 70 Bq/g (0.002 microcuries/g) threshold are naturally occurring or man-made, their effect on somatic cells and germ cells is the same. The NRC, DOT, and the IAEA have not made a substantial case regarding the shipment of ores and fossil fuels with regard to radioactive levels of naturally occurring radionuclides. Frankly, we doubt that such a case could be made or that continued industrial use of these materials requires a reduction in the HMR standard. We hereby request that NRC and DOT provide us their analysis of the regulatory burden of radionuclide HMR on the fertilizer, construction, and fossil-fuel energy industries. Issue 3: Changes in A1 and A2 Values The proposed shipments of radioactive wastes to a repository should not be the occasion for a reduction in the standards of radiation protection during transportation. On the contrary, the possibility of 90,000+ shipments calls for an increased radiation protection standard. We oppose the weakening of the present standard. Issue 4: Communication Changes The words “radioactive materials” should not be removed from shipping placards. Many emergency response personnel are volunteers who lack special HMR training but who could nonetheless be called to an emergency scene. Additional requirements notwithstanding, the plain English warnings are unmistakable and clearly warn first responders in less well trained department to take appropriate steps in the event of a transport accident. We would only add that multiple language warnings be added for regions where significant segments of the population speak, for example, Spanish or French. Issue 5: Low Specific Activity Materials ands Surface Contaminate Objects We oppose creating a new class of radionuclides shipments in which the activity is distributed throughout the material and in which the specific activity does not exceed 30 times the activity concentration exemption levels. The admittedly large volume and/or size of LSA and SCO materials calls for continued reliance on industrial packages, with appropriate and necessary safeguards. Issue 6: Uranium Hexafluoride We oppose the relaxation of testing for radioactive transport containers. TS-R-1 allows a national regulatory authority to waive the thermal test for packages designed to hold more than 9000 kilograms of UF6. The drop test, minimum internal pressure test, and the hypothetical accident condition test must be accompanied by the thermal test for assurance of public protection in the event of an accident. Issue 7: Air Transportation Requirements Air transport of plutonium and other radionuclide should be prohibited under any circumstances. Low Dispersible Materials is a faulty concept with regard to air transport and should be abandoned. Issue 8: Fissile Material Package and Transport Requirements Transport and storage on so-called spent nuclear fuel and fissile materials should not be “harmonized” with a watered down international standard. The Type B(DP) package as proposed does not provide an adequate level of public protection from radiation hazards. In closing, I request that your agencies inform me before any action is taken on the matters outlined in these comments. Respectfully submitted, Louis Zeller Nuclear Campaign Coordinator
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