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Jonathan Campbell

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ENVIRONMENTAL ACTION ALERT

PEOPLE AND COMPUTERS AT RISK

PLEASE READ AND SEND LETTER - SAMPLES BELOW –

TO THE EPA AND CALL DOE NOW

DEADLINE FOR EPA COMMENT EXTENDED TO JAN 31, 1998!

Greetings,

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 U.S population and 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 that underrate the effect of human exposure, the agencies set guidelines for radioactivity levels for recycled metals or products manufactured from them that would not "significantly" affect human health. The guidelines were based on a "cost-benefit" analysis - one which literally measured the "benefit" of money saved by recycling the metals against the "risk" of killing a few people at random. (Radiation exposure causes cancer statistically - exposure of an entire population to radiation causes cancer in the people whose DNA happens to receive multiple damage). This "cost-benefit" analysis, sometimes called "Risk Assessment" therefore has a more appropriate designation: Premeditated Random Institutional Murder (PRIM).

In addition, 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 significantly affect overall biological function, though the threat to health is quite significant - as mentioned above, multiple ionization damage to a single DNA chain can cause cancer.

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 information.

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.

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 people and 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 are two sample letters 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. The first addresses the risk to computers, and the second addresses the health risks. Please sign and send a copy of one of these letters, 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 January 31, 1998.

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 hazards.

John Karhnak, Director
Center for Cleanup and Recycle (Mail Code 6602J)
Office of Radiation and Indoor Air
U.S.EPA
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 not.

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 far.

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.

Sincerely,

John Karhnak, Director
Center for Cleanup and Recycle (Mail Code 6602J)
Office of Radiation and Indoor Air
U.S.EPA
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. I am alarmed that you are considering this program because of its potential hazard to the U.S. population. 

To justify this introduction of radioactive material into the U.S. metal supply, you have used a "cost-benefit analysis" which weighs the "benefits" of cost-savings and "reuse" of the metals against the harm done to people, namely, the death of some "small" number of people exposed. This "risk analysis" is more accurately called Premeditated Random Institutional Murder, and the EPA does not have the right to make this judgement.

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 metals that surround us everyday in our homes and where we travel and work.

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 far.

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 us.

This program is a serious danger to the U.S. population, and must not be allowed to proceed.

Sincerely,