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=============== Electronic Edition ===============

---September 19, 1989---
News and resources for environmental justice.
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet:


It is now clear that American industry and its acolytes in government have hit upon a major strategy for solving the nation's problems of chemical contamination. Increasingly, industry and government are learning to define old problems in new ways, and in the redefinition the problems disappear. Barry Commoner has called this "linguistic detoxification" and it has now been elevated to the level of major policy in William Reilly's EPA.

Take, for example, the problem of regulating benzene. The EPA has recently announced that it is acceptable to kill one in every 10,000 Americans exposed to benzene. (See RHWN #95; referring back to #95, EPA has adopted method "C.") Thus the problem of having to exercise tight control over benzene has been defined away by simply declaring that it's not a problem to kill large numbers of people. (If all Americans were exposed to the allowable limit of benzene, 24,300 would die a slow, painful death each year, victims of benzene-induced cancers, according to EPA's calculations.)

As we saw a few weeks ago, Newsweek magazine, which often echoes the sentiments of those who make industrial decisions for America, declared it should be national policy to "forget Love Canal" because Superfund sites are "boring." (See RHWN #139.) We will see later this fall how Mr. Reilly's EPA comes out on this issue when it publishes a "comprehensive" Superfund cleanup plan, including a definition of "how clean is clean." This will be a big opportunity for linguistic detoxification (you simply define something that's dirty as "clean" and declare that "clean" sites needn't be cleaned up). We are betting Mr. Reilly will jump at this chance. It would be nice if we were wrong.

However, evidence seems to indicate otherwise: EPA is currently working aggressively to define away the nation's radioactive waste problem.

EPA, in concert with the Nuclear Regulatory Commission (NRC) and the nuclear power industry, are about to declare one-third of the nation's low-level nuclear wastes as "below regulatory concern," (BRC) which will allow them to be dumped into ordinary municipal landfills and incinerators. It may happen as soon as this month. With a swipe of the pen, Mr. Reilly and his overlords at the Nuclear Regulatory Commission are going to convert vast quantities of "radioactive" wastes into "nonradioactive" wastes without changing the physical or chemical characteristics of those wastes at all.

As a result, the two largest producers of radioactive wastes--nuclear power plant operators, and the military-will be able to stop worrying where to put huge inventories of radioactive pipes, instruments, tools, sludges, filters, resins, soils, clothing, and other objects contaminated with radioactivity. They will be able to set them out at the curb in garbage cans where they will be picked up by unsuspecting garbage haulers, taken to dumpsters, and eventually buried in the ground, incinerated in municipal incinerators or recycled into new consumer products. If there's a garbage spill in your neighborhood, too bad for you. You won't even know you're being exposed to radiation unless you happen to own a geiger counter or other sophisticated measuring instrument. If you are a conscientious operator of a dump or incinerator, too bad for you: there will be no way for you to know when radioactive materials are being brought through the gate because there's no way you could monitor each truckload with a geiger counter, and radioactive wastes will bear no special markings or labels. (Conveniently, the federal Department of Transportation [DOT] is cooperating in the EPA-NRC BRC proposal; DOT has agreed to remove its current requirements for placards and labels during transportation.) If you are a citizen who purchases a kitchen sink, child's toy, cooking utensil or other consumer item made with radioactive recycled metal, NRC and EPA want you to be happy and don't worry: the risks are small, the benefits large, they say. What benefits, you ask?

The expensive requirements of handling radioactive wastes--labeling them, monitoring them, transporting them in special containers, making maps of where they're buried, maintaining careful records for future generations--all these requirements will be unnecessary for BRC wastes if Mr. Reilly and the NRC have their way. The nuclear industry and the military will thus gain from EPA-NRC largesse in two ways: The nuclear industry's 100-or-so reactors are getting old, and the federal weapons program has some 280 installations that have nearly outlived their usefulness. All of these facilities will soon have to be dismantled pipe by pipe, tank by tank, and thrown away. Under the new BRC rules, much of this stuff will go to the city dump instead of being shipped to a radioactive waste burial tomb under constant guard; the nuclear power industry will save dollars and the atomic warriors will save face and dollars. For example, the military has recently admitted that cleanup of its past slovenly practices (see RHWN #124) will cost $45 to $70 billion, and some estimates exceed $100 billion. The EPA-NRC alchemy to define away much of this problem is a fabulous boon for the sloppiest industry the world has ever known.

Consider the impact at just one facility, the Idaho National Engineering Laboratory. There the EPA's and NRC's BRC rules would allow the government to change the definition of 50% of its 2.3 million cubic foot inventory of radioactive garbage. Clearly, it's a way of passing today's costly problems onto tomorrow's children: the radioactive wastes won't have become less dangerous--we simply won't have to pay for their management today. And the harm done to our children? That's our children's problem don't you know. It's a very Reagan-Bush solution to a very expensive problem.

The name of the EPA-NRC proposal to linguistically detoxify radioactive wastes is BRC (below regulatory concern). The BRC proposal is rushing forward, and the only hope of stopping it is for local communities, counties, even utility authorities who own dumps or incinerators, to adopt resolutions in opposition, and for citizens to write strong letters to William Reilly, to the NRC, and to their Senators and Representatives. But you've got to act quickly.

Write: William Reilly, EPA, 401 M St., SW, Washington, DC 20460; and write U.S. Nuclear Regulatory Commission; Attention: Docketing & Service Branch; Re: Below Regulatory Concern Petition, Washington, DC 20555; for questions or NRC documents, phone William Lahs at NRC: (301) 492-3774.

The best article on this problem, and what it means for local communities, including specific steps you can take to derail these epa-nrc efforts, appeared in the April-June issue of The Workbook.

Get: Diane D'Arrigo, Judith Johnsrud, and Lynda Taylor, "NIMBY: Nukewaste in My Backyard?" The Workbook Vol. 14 (April/June, 1989), pgs. 46-55. Reprints of this excellent expos are available for $2.00 from: Southwest Research and Information Center, P.O. Box 4524, Albuquerque, NM 87106; phone (505) 262-1862. The Workbook is a quarterly journal of environmental-social change that costs $12.00 per year; a true bargain. You should also stay in touch with the Nuclear Information Resource Service (NIRS), Suite 601, 1424 16th St., NW, Washington, DC 20036; (202) 328-0002.

--Peter Montague, Ph.D.

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