August 11, 1999

David Allard
DEP, Bureau of Radiation Protection
Rachel Carson State Office Building
P.O. Box 8469
Harrisburg, Pa. 17105-8469


Dear Mr. Allard

ACE is thankful that DEP is aware that radioactive loads of waste are coming to landfills all over Pennsylvania, including the Pottstown Landfill. It is encouraging to know that DEP has started a process to try to deal with this critical issue.

However, the Document you have prepared, DRAFT GUIDANCE A DOCUMENT ON RADIOACTIVITY MONITORING AT MUNICIPAL AND RESIDUAL WASTE PROCESSING AND DISPOSAL FACILITIES, is very complicated and difficult to interpret. There seem to be some fundamental issues which need to be publicized and clearly understood by the public. Therefore, ACE is requesting DEP have a series of public meetings at which DEP would explain this document in detail, and allow time following your presentation for all questions and comments from the public. We also ask that this be followed by another 30 days for comment.

You obviously recognize how serious this radioactive threat has become in Pennsylvania. But we would like to share with DEP some of our reasons for concern, and for this request.

1. The Nuclear Regulatory Commission is starting a process of releasing VAST amounts of radioactive material and waste into the environment.

2. The Nuclear Regulatory Commission has proposed massive deregulation of radioactive materials and waste, such as scrap metal, furniture, equipment, glass, paper, plastic, and concrete, etc. from nuclear facilities as well as soil. This could include military and Department of Energy waste.

3. Monitoring is done by the operator of the facility, whose interests are profits. Since there could be big money in dumping all this radioactive waste, there is little incentive for the operator to be on the side of public health and safety where monitoring is concerned.

4. There is enough recent research, on people who have been exposed to low-level radiation, which leads us to believe there is NO SAFE THRESHOLD DOSE of radiation. With such a threat to our society, we must exercise The Precautionary Principle.

5. Standards are to be set by the Nuclear Regulatory Commission, the same agency trying to deregulate and release vast amounts of radioactive waste into our environment. Since they are the agency trying to get rid of this radioactive waste, we do not feel they will set standards that will be protective of public health and safety.

6. There are at least 56 landfills in Pennsylvania. The radioactive waste stream into these landfills will get worse and worse, exposing more and more people to this critical danger, through the gases into our air, and the leachate into our water supplies.

Sincerely,
Dr. Lewis Cuthbert
President, ACE

Copies:
DEP Secretary James Seif
Senator James Gerlach
Representative Dailey
Montgomery County Commissioners