“. . .there is no safe dose or dose rate below which dangers disappear. No threshold dose. Serious lethal effects from minimal radiation doses are not ‘hypothetical,’ ‘theoretical,’ or ‘imaginary.’” -Dr. John Gofman

The Search for Science, Technology, Logic, Liability, and

The Core Values of America’s Founding Documents

By Ken Ferruccio

PART 1: SAFETY

REGULATORY SHIFT OF EMPHASIS FROM CONTAINMENT TO MONITORING

The waste management frameworks of the Environmental Protection Agency (EPA) and the Nuclear Regulatory Commission (NRC) lack an empirically reliable and interpersonally available verification basis for believing that radioactive waste can be isolated from persons and properties during and after uranium mining and milling operations and contained in perpetuity during and after waste disposal operations.

It is an inescapable reality, an empirical fact, that waste containment structures continue to fail and contribute to the pervasive contamination of the public health and environment. It is therefore not surprising that the rationale informing the Virginia Uranium Mining Working Group’s Final Report is not a rationale emphasizing regulations for containing waste. It is a rationale emphasizing monitoring waste based on the ALARA standard: “Radiological exposures to workers and environment will be as low as reasonably achievable” ([Final Report]The Commonwealth of Virginia 2012 Uranium Working Group Report, November 30, 2012. Print. 26).

REGULATORY SHIFT OF EMPHASIS FROM CONTAINMENT TO MONITORING UNACCEPTABLE

The shift of emphasis in the Final Report from containing to monitoring radioactive waste is not acceptable. It is common knowledge that the nuclear industry’s greatest vulnerability is that it has not been able to solve its waste management problem. Containment structures continue to fail and cannot be plausibly defended. The shift of emphasis from containment to monitoring does not solve the waste management problem. Safety standards must take precedence over all other concerns, but the NRC legally authorizes radiological exposures within allegedly safe maximum contaminant levels that continue to be scientifically controversial, instead of protecting persons and properties from contamination to begin with. READ MORE

(This document was originally sent to the Governor of Virginia, so you will first see the letter addressed to Gov. McAuliffe. Scroll down to read the rest of the document.)