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radioactive metals being recycled

   hello, all,
         Below is a letter I am circulating to attempt to
  influence the EPA. It is a little far afield of dioxin,
  but relevant to us because it relates to human
  health and democracy.
         In essence, the EPA has proposed allowing
  the nuclear industry to recycle all of their radioactive
  and contaminated metal into the ordinary metal waste
  stream. This would be a catastrophe for human health
  as well as for the computer information infrastructure.
  The letter below focuses on the latter, since talk
  about the former seems to fall on deaf ears. (I'm certain
  that it would not hurt if you modified the letter to make
  health concerns.)
  Jon Campbell
  (EPA email address is included below)
   I am writing you to make you aware of a
  Nuclear Regulatory Commission (NRC), Department
  of Energy (DOE), and Environmental Protection
  Agency (EPA) policy that threatens the
  information infrastructure of the U.S. and the
  manufacture of integrated circuits and PCs.
   Several years ago, these agencies, prompted
  by pressure from the nuclear industry, began to
  promulgate regulations that would allow the sale
  of radioactive metals from nuclear power and
  processing plants to metal scrap dealers. The
  agencies and the nuclear industry referred to the
  process by which this would happen is to declare
  that the radioactivity of these metals is "Below
  Regulatory Concern" (BRC).
  Without fanfare, the agencies have allowed a
  limited amount of trade in radioactive scrap
  metals, and about 40 scrap dealers and smelters
  are currently involved in this practice. In
  September, 1997, the EPA proposed putting these
  rules into place for the entire nuclear industry
  and the huge processing plants. If there is no
  significant opposition to these regulations,
  hundreds of millions of pounds of radioactive
  steel and copper will ultimately enter the steel
  and copper supply of the U.S.
  The agencies' concern was almost completely
  focused on health effects. Using statistics for
  human exposure, the agencies set guidelines for
  radioactivity levels for recycled metals or
  products manufactured from them that would not
  "significantly" affect human health.
  Of course, government health risk estimates
  virtually always underestimate harm, because they
  do not take into consideration vulnerable
  people (those whose immune system is weak or
  suppressed), small children and infants, etc.
  The entire "health risk assessment" scenario
  and "cost-benefit analysis" is a rationalization
  for Institutional Random Murder: deciding that
  it is OK to kill a few random people to make (or
  save) some money.
  Furthermore, the vulnerability of modern
  electronic equipment and particularly computer
  chips and dense memory systems (e.g., hard disk
  platters) to destructive ionizing radiation was
  not discussed extensively. Such equipment is
  billions of times more vulnerable to ionizing
  radiation than biological species. Biological
  systems have detection, rejection, and
  replacement mechanisms for cells that are
  damaged, as well as function replication -
  typically thousands or millions of cells are
  involved in identical cellular activity, so that
  the death of a particular cell will not usually
  significantly affect overall biological function.
  (Multiple ionization damage to a single DNA chain
  can cause cancer, but this is not the main subject of
  this letter).
  In contrast, most electronic circuitry is
  not replicated, because there is an expectation
  that if a set of components is designed correctly
  and the chip is formed correctly that it will
  continue to work, almost indefinitely. Component
  dimensions and inter-component dimensions have
  become sub-microscopic. Magnetic disk drive
  densities are similar or greater. The 4-square-
  inch CPU chips in common use today contain at
  least 2 million individual transistors and many
  times that in other components and
  interconnections. A single 3" disk platter of a
  high-density disk contains 100 million bits per
  square inch.
  It is already known that the damage to CPU
  and other chips from cosmic ionizing radiation is
  significant. The defects caused by ionizing
  radiation are random. They could cause sudden,
  dramatic, catastrophic failure, such as the
  destruction of a CPU register. They could cause
  subtle problems, such as incorrect floating-point
  logic. They could cause hidden, invisible
  destruction or modification of stored
  Once radioactive steel and copper are
  introduced into the metal waste stream, both the
  steel and copper and the foundries and smelters
  will become contaminated. Machine screws,
  batteries, internal wiring, chip wiring, plates,
  chassis parts, tables, desks, filing cabinets,
  keyboard drawers, and other metal components too
  numerous to list all become potential sources of
  destructive ionizing radiation.
  Anything from steel fabrication hardware
  used in chip manufacturing to reinforcing rod for
  buildings might contain radioactive metals. Once
  the floodgates allowing radioactive metals into
  the waste stream are open, there is going to be
  no way to clean up the mess.
  The entire information infrastructure of the
  U.S. is at risk, even now as a result of limited
  allowance of this practice, and especially if it
  is allowed on a massive scale. Not only are
  computers themselves at risk, but the thousands
  of intricate mechanisms that rely on the accuracy
  of computers and embedded microprocessors, from
  airplanes to tracking and guidance systems to
  automobiles and pacemakers, are all vulnerable to
  the threat of radioactive materials.
  In late August, 1997, the U.S Department of
  Energy (DOE) contracted with a company called
  BNFL to recycle 126,000 tons of radioactive-
  contaminated metal, including 6000 tons of
  heavily uranium-contaminated nickel, from the
  gaseous diffusion isotope separation buildings at
  Oak Ridge, Tennessee. The Oil, Chemical, and
  Atomic Workers (OCAW) has filed a suit to prevent
  the contract from going forward, but their
  concern regards worker safety and does not bear
  on the extreme threat to computers and the
  computer industry. (OCAW can be reached for
  more information at 202-637-0400)
  There is no way that BNFL can remove all the
  radioactive isotopes from this material. The
  nickel, in particular, was used for the gaseous
  separation of uranium. The nickel is porous and
  uranium-238, lodged in the pores of the metal,
  cannot be removed. (Nickel is used in batteries
  and in stainless and other high-grade steel.)
  For modern electronic assemblies, there is
  no such thing as "de minimus" (negligible)
  radiation or radiation that is "Below Regulatory
  Concern." Radioactive materials must be
  completely isolated from the metal waste streams
  if our information infrastructure is to survive
  and thrive.
  Below is a sample letter to John Karhnak of
  the EPA, opposing this practice and demanding
  that the radioactive metals already allowed into
  the waste stream be tracked down and recovered.
  Please sign and send a copy of this letter, or
  one that you write based on the information
  above, to Mr. Karhnak via email
  (karhnak.john@epamail.epa.gov), or call him at
  202-233-9280, or write him at the address below,
  as soon as possible. The public comment period
  for the draft regulations ends October 31.
  The DOE/BNFL contract is referred to as the
  "Oak Ridge Three-Building Decontamination and
  Decommissioning Project." Please call Secretary
  of Energy Frederico Peña at 202-586-6210 to ask
  him to stop this project.
  The two (huge) EPA documents describing the
  scrap program can be obtained at
  http://www.epa.gov/radiation/scrap. The cost-
  benefit analysis is based on human radiation
  John Karhnak, Director
  Center for Cleanup and Recycle (Mail Code 6602J)
  Office of Radiation and Indoor Air
  Washington, DC 20460
  Dear Mr. Karhnak,
   This letter is in regard to the EPA program
  for recycling and reuse of radioactive scrap
  metal from U.S. nuclear facilities. As a computer
  professional I am alarmed that you are
  considering this program because of its potential
  hazard to the U.S. information infrastructure.
   Computer machinery - integrated circuits,
  memory, and other components - are millions or
  billions of times as sensitive to ionizing
  radiation as biological systems. The latter have
  complex detection, rejection, and replacement
  mechanisms for cells that undergo damage from
  ionizing radiation, as well as massive function
  replication. Computer chips and components do
   I oppose any introduction of radioactive
  metals into the U.S. metal waste stream, because
  once it occurs, the entire metal supply is at
  risk. It will be impossible to segregate non-
  contaminated machine screws, copper wire, steel
  cabinets, desks, and the myriad components that
  make up computers and their environment. Not only
  computers will be at risk, but all of the
  machinery used in the U.S. that contains
  computers and embedded microprocessors will be at
  risk as well, from airplanes to pacemakers.
   Furthermore, I have learned that a limited
  amount of these radioactive materials have
  already been released to certain waste handlers
  and smelters. This practice must stop
  immediately, and you need to locate, identify,
  and recapture all that has been released thus
   In particular, the EPA must intervene to
  cancel the contract between the Department of
  Energy and BNFL to recycle 126,000 tons of
  radioactive metal from the Oak Ridge gaseous
  diffusion plant. The materials from this plant,
  notably the uranium-contaminated nickel, cannot
  be decontaminated sufficiently to protect
  computer components.
   This program is a serious danger to the U.S.
  information infrastructure, and must not be
  allowed to proceed.