California Coastal Commission Submission by Russell D. Hoffman June 13th, 2001

To: dzoll@sfbg.com
From: "Russell D. Hoffman" <rhoffman@animatedsoftware.com>
Subject: Radioactive waste products disposal (comments on your article)
Cc: governor of California, California Senators

Dear Daniel Zoll,

I was very interested in your informative article in the San Francisco Bay Guardian from June 6th, 2001 (shown below).  With regards to the article, please be aware that:

LLRW = HLRW + filler 

Where:
LLRW ="Low Level Radioactive Waste",  HLRW ="High Level Radioactive Waste", and "filler" = just about anything they want -- water, concrete, iron, cloth, the atmosphere -- you-name-it.  If they can possibly think of a way to dilute it to "below regulatory concern", they will.

They will dump it in our backyards, in the oceans, in the atmosphere, and in outer space.  That is what the bill your article talks about begins to address, but I'm sure it does not go nearly far enough.  But it might help to explain the following, namely, that at Hanford, Washington, radioactive sludge pumps went from a disposal cost of about $0 to $1.5 MILLION when EPA set new standards in the early 1990's.  This changed everything there, because those sludge pumps have to be replaced every 400 hours or so.  In contrast, pumps at our local nuclear power plant are apparently still being disposed of at the near-zero dollar rate.  This indicates they are usually considered LLRW, not HLRW like the ones at Hanford.

But remember, there's no difference.  LLRW = HLRW + filler.  In this case, the filler is steel and whatever else the pumps are made of.

Yesterday (Monday, June 11th, 2001) I attended (as a member of the public) an NRC annual safety review meeting at San Onofre Nuclear (Waste) Generating Station.  (Known as "SONGS", since the "W" is utterly ignored by most members of the public, the Nuclear Regulatory Commission (NRC), the California Coastal Commission (CCC), and Southern California Edison (SCE)).  I had the opportunity to ask SCE officers at the meeting about their own pump disposal costs and frequency.

They assured me that costs of disposal for their pumps was negligible.  Also, they said that since they are not pumping sludge, but rather "clean" fluids, their pumps last a lot longer than those used at Hanford ("clean" being their word; virtually all the fluids they pump are radioactive to one degree or another).  The SCE officers stated that the pumps at SONGS are maintained, rather than having to be fully replaced each time they fail (the ones at Hanford have to be completely replaced because they are so radioactive).

Thanks to your article I suspect that I now know the reason the SONGS pump disposal costs are so low.  It is because neither the Feds nor California has had the good sense to put regulations in place which would protect the public from these items.  I hope this public-health loophole will be cleared up quickly!

Sincerely,

Russell Hoffman
Concerned Citizen

Carlsbad, CA
Attachment:  Your article in SFBG, June 6, 2001
        • news
June 6, 2001    news | a+e | sf life | extra | sfbg.com

License to spill
State relaxes restrictions on radioactive waste
By Daniel Zoll
California has quietly deregulated the disposal of low-level radioactive waste, paving the way for the potentially dangerous material to be sent to municipal landfills and recycled into consumer products, according to a state legislator.

In an undated letter received in December by state senator Sheila Kuehl and U.S. senator Barbara Boxer, state health officials admitted that they are permitting dumping of low-level radioactive waste in unlicensed facilities in cases where there is "no significant risk to the public or the environment."

Environmentalists and legislators say this amounts to a drastic change in state policy, which previously required all radioactive waste to be disposed of in licensed facilities. They also question the state's definition of "significant risk" and warn that the new policy could expose the public to much higher doses of radiation.

"If you liked the deregulation of energy, you'll love the deregulation of radioactive waste," Sierra Club lobbyist Bill Magavern said.

But Senate Bill 243, sponsored by Kuehl, would overturn the new policy and tighten restrictions on radioactive waste disposal and cleanup. The legislation is set to come up for a vote on the Senate floor this week.

"The core of the bill really would be to stop the deregulation of radioactive materials, whether it be in waste, consumer products, or at a contaminated site," Magavern said.

The new policy came to light last year after Boxer and Kuehl found out that the Department of Health Services had approved the shipment of materials containing radioactive waste from a Boeing nuclear laboratory in the San Fernando Valley to Buttonwillow, an unlicensed dump near Bakersfield. As recently as 1999, DHS officials asserted that Buttonwillow "is not even licensed to receive or store radioactive material of any sort." The legislators demanded an explanation last summer, which DHS and the Department of Toxic Substance Control finally provided seven months later.

DHS spokesperson Lea Brooks denied that the department's policy has changed. She says that the radioactive waste from the Boeing facility was sent to a licensed dump in Washington state and that the remaining waste was not radioactive and therefore could be moved to the Bakersfield site. The soil was shipped in January.

"Our staff determined in 1998 that the site posed no public health risk from radioactive waste," Brooks said.

Yet DHS staff did find some radioactive materials. Lee Bailey, chief of radiologic health at DHS, told the Associated Press in January that the soil contained strontium 90 and cesium 137, but he maintained that the levels were so low that it was not considered radioactive under federal Nuclear Regulatory Commission guidelines.

According to Daniel Hirsch of the Committee to Bridge the Gap, a nuclear watchdog group, the NRC standards are dangerously weak.

Under DHS policy, each waste shipment to an unlicensed disposal site could expose the public to up to 25 millirem per year – the equivalent of 170 chest X rays over a person's lifetime.

Hirsch maintains that DHS has no legal basis for using the low NRC standards, since those standards have not been formally adopted by the state. What's more, the Environmental Protection Agency has challenged the NRC standards as "not protective of public health," according to a February 2000 EPA memo.

Kuehl's bill is facing heavy opposition from California Radioactive Materials Management Forum, a nuclear-industry trade group whose members include the University of California and Southern California Edison, as well as the California Manufacturers and Technology Association and some biotech companies.

"What they are trying to do is create a larger amount of regulation on radioactive waste and higher costs for companies without providing any benefit for the public," said April Bailey, manager of legislative affairs for Biocom/San Diego, a biotech industry trade group.

Despite the industry lobbying, supporters are optimistic about the bill's chances. "I don't think that legislators want to proclaim that they are in favor of radioactive waste being recycled into household products like zippers or dumped into their local landfills," Magavern said.

E-mail Daniel Zoll at dzoll@sfbg.com.


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First posted June 13th, 2001.

Webwiz: Russell D. Hoffman