US NRC Radioactive Dilute and Deceive Scam – Comment Deadline June 22nd (Extended)

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alpha, BEIR, beta, cesium, clean air, clean air act, clean water, Clean Water Act, contaminated drinking water, dangers of nuclear, dilute and deceive, dilution, dilution as solution, drinking water, drought, environment, EPA, Farley Nuclear Power Plant, Joseph Farley Nuclear Power, March 24 2015, no safe dose, NRC, NRC comment period, nuclear energy, nuclear power, Nuclear Regulatory Authority, nuclear scam, plutonium, polluted water, pollution, radiation in water, Radiation protection, radiation protection comment, radiation sewer systems, radiation sewerage, radiation sewers, radioactive material, Radionuclides, radionuclides sewers, sewers, tritium, US EPA, US NRC

US NRC Comment Deadline extended to 22 June 2015: http://www.regulations.gov/#!documentDetail;D=NRC-2009-0279-0098

The most strange and deadly scam, which the US NRC is running, is the dilute to deceive scam, where they actually tell the nuclear industry (and labs) that if they dilute the radionuclides with a certain amount of water (or air), then it is ok to put it into the rivers, ocean, air and even into regular sewerage drains! This is what they call “effluent concentration”. Even then the amounts allowed exceed amounts allowed under the EPA’s Clean Water Act, though it doesn’t really matter because what matters is how much radionuclide is actually emitted into the environment and how many months, years, decades, centuries, it’s going to stay there.

So, now it is easy to see that the following question by the NRC is meaningless BS. The actual amounts – not concentration – of the various radionuclides must be modelled. And, how long they stay in the environment:
“Q1-3: How should the calculations of effluent concentration, currently in the 10 CFR part 20 radiation protection regulations, be modified to reflect advances in modeling that are now available? In particular, the NRC is interested in preliminary views on the age and gender averaged approach.” What the F(ukushima Daiichi) would age and gender averaged approach mean? Assuming they were speaking of actual amounts, then the amounts should be “appropriate” for the most fragile. If you are considering age and gender then the fragile must be considered – period. There is no average! Fragility varies according to disease. But, until they start modeling for actual emissions and actual half-life of the radionuclides, then it is meaningless. Half-life in the body is also meaningless because at some point the body will enter steady-state with the environment. And, actually the “appropriate” amount of exposure is none.

Here’s another crazy NRC question “Q1-4: Should the public dose limit of 0.5 mSv (50 mrem) continue to be the basis for the effluent concentration limits for the radionuclides in 10 CFR part 20, appendix B, Table 2, Columns 1 and 2? Should it be reduced or otherwise modified?”

As noted above, effluent concentrations are a dilute to deceive scam. What matters is the amounts and not the concentration. 10 CFR part 20, appendix B, Table 2 should be modified to reflect actual amounts allowed and not concentrations. And, really, any short-lived radionuclides should be contained until they are no longer radioactive, and long-lived radionuclides should never be emitted at all.

It’s not clear where they are getting the 0.5 mSv from. On the NRC web site 1 mSv per year is mentioned. Is this right or wrong? The US EPA has a standard of 0.25 mSv for the body and 0.75 mSv for the thyroid. The ICRP 103 (2007) which they pretend to be coming up to speed with has a dose constraint of less than or equal to 0.1 mSv per year where “prolonged component from long-lived nuclides” (p. 116)

How many cancers will there be in a lifetime from the 1 mSv per year proposed by the US NRC? According to National Academy of Sciences BEIR report, it would be 1 (or more) per 100 people. The ICRP has it at about 0.55 which would round up to one. However, this is assuming that the 1 mSv per year is new, whereas the radionuclides will be building up in the environment and even in the body. If half of the 1mSv emitted were short lived, the next year there would still be 1 mSv emitted plus 0.5 mSv (half) already emitted. Some of the radionuclides (cesium and strontium) have half-lives of about 30 years; other radionuclides like plutonium-americium in the 100s or 1000s of years: “The half-life of plutonium-239 is 24,065 years. This half-life is short enough that 1 microgram of material will undergo more than 2000 decay events per second, but it is long enough to allow that microgram to decay at an approximately constant rate for thousands of years. If plutonium had uranium’s half-life of 4 billion years, there would be so few decays over the span of a human’s lifetime that the radiological toxicity of plutonium would be much less severe. [3] However, that is not the case… [3 Uranium is also much more soluble than plutonium and leaves the body rapidly.]” Los Alamos Science Number 26 2000, p. 78 (That’s straight from the heart of the beast – Los Alamos Nuclear Lab – hardly anti-nuclear!)

Plutonium 241 has a half life of 14 years, which is used to trick people since it becomes more dangerous 241 Americium with a half life of around 432 years.

Furthermore, BEIR is based on low-LET external, radiation. ICRP appears more appropriate for low-LET, as well. ICRP inappropriately lumps medical radiology and the nuclear industry together. BEIR is excluding more dangerous high-LET and internal radiation in their calculation. However, they recognize high LET such as alpha and neutrons as more dangerous. Most of the ICRP research would seem to be based on either external or very short-lived internal low LET radiation. While they are supposed to add weighting factors for high LET and amount of time spent in the body, it’s difficult to see if they can or will add enough weighting factors to thoroughly account for plutonium and americium, which even in a totally clean environment would stay in the body for a lifetime. It takes 20 to 50 years to excrete one half of them, in a clean environment. Furthermore, the US gov has at least one so-called expert who has messed up the formula, making more radiation safer and less more dangerous! Then he’s prancing around the world as an “expert”: https://miningawareness.wordpress.com/2014/07/31/nuclear-effective-dose-radiation-icrp-vs-us-epa/ (This topic is important for the March 24th deadline too.) To err is human, but there is no room for blunders with something so dangerous as radiation, especially not gross blunders.

From the NRC web site (which has been known to have mistakes). They still haven’t corrected this: https://miningawareness.wordpress.com/2014/09/04/the-dangerous-us-nrc-typo-making-low-level-radioactive-waste-more-radioactive-than-allowed-at-wipp/
“NRC Regulations (10 CFR) > Part Index > § 20.1301 Dose limits for individual members of the public. “Subpart D–Radiation Dose Limits for Individual Members of the Public
Source: 56 FR 23398, May 21, 1991, unless otherwise noted.
§ 20.1301 Dose limits for individual members of the public.
(a) Each licensee shall conduct operations so that –
(1) The total effective dose equivalent to individual members of the public from the licensed operation does not exceed 0.1 rem (1 mSv) in a year, exclusive of the dose contributions from background radiation, from any administration the individual has received, from exposure to individuals administered radioactive material and released under § 35.75, from voluntary participation in medical research programs, and from the licensee’s disposal of radioactive material into sanitary sewerage in accordance with § 20.2003, and…” http://www.nrc.gov/reading-rm/doc-collections/cfr/part020/part020-1301.html
DID THEY JUST SAY THAT RADIATION INTO THE SEWER SYSTEM AND PEOPLE WHO ARE CONTAMINATED BECAUSE OF MEDICAL TREATMENT OR EXPERIMENTS DO NOT COUNT UNDER THIS 1 mSv?

Here they say, for air: “(d) To implement the ALARA requirements of § 20.1101 (b), and notwithstanding the requirements in § 20.1301 of this part, a constraint on air emissions of radioactive material to the environment, excluding Radon-222 and its daughters, shall be established by licensees other than those subject to § 50.34a, such that the individual member of the public likely to receive the highest dose will not be expected to receive a total effective dose equivalent in excess of 10 mrem (0.1 mSv) per year from these emissions. If a licensee subject to this requirement exceeds this dose constraint, the licensee shall report the exceedance as provided in § 20.2203 and promptly take appropriate corrective action to ensure against recurrence.” http://www.nrc.gov/reading-rm/doc-collections/cfr/part020/full-text.html

The “notwithstanding” reverts back to “Subpart D–Radiation Dose Limits for Individual Members of the Public Source: 56 FR 23398, May 21, 1991, unless otherwise noted.
§ 20.1301 Dose limits for individual members of the public.
(a) Each licensee shall conduct operations so that –
(1) The total effective dose equivalent to individual members of the public from the licensed operation does not exceed 0.1 rem (1 mSv) in a year, exclusive of the dose contributions from background radiation, from any administration the individual has received, from exposure to individuals administered radioactive material and released under § 35.75, from voluntary participation in medical research programs, and from the licensee’s disposal of radioactive material into sanitary sewerage in accordance with § 20.2003, and…” http://www.nrc.gov/reading-rm/doc-collections/cfr/part020/full-text.html#part020-1301

“§ 20.1203 Determination of external dose from airborne radioactive material.
Licensees shall, when determining the dose from airborne radioactive material, include the contribution to the deep-dose equivalent, lens dose equivalent, and shallow-dose equivalent from external exposure to the radioactive cloud (see appendix B to part 20, footnotes 1 and 2).” http://www.nrc.gov/reading-rm/doc-collections/cfr/part020/full-text.html#part020-1301 There is the eye and skin exposure, discussed this past weekend for cataracts.

The EPA has a dilute and deceive scam going: https://miningawareness.wordpress.com/2014/09/06/radiation-in-water-us-epa-advises-legal-cheating-for-compliance/

The ICRP is more prudent in “recommended” exposure than the US NRC. And, yet, within 35 years the ICRP has changed the “recommended” exposure to the eyes for nuclear workers from 300 mSv in 1977 to 20 mSv in 2012. The 20 mSv is based on an assumption which will probably turn out to be false, and which appears politically motivated. It should probably be 2 mSv or less. At the same time, everyone was being told to buy sun glasses to protect from UV rays. Initially these sun glasses were expensive too.

The disgusting truth is that research on ionizing radiation has been ongoing since 1895. At the beginning of the nuclear age, focus was on how dangerous radiation was. Many animal and even human experiments have been done. The human experiments were both official experiments and unofficial making the population at large act as guinea pigs. They have known from the beginning the dangers. Somewhere along the way they seem to have switched from doing experiments to see how dangerous it was to doing endless experiments in an attempt at proving that it is safe. Despite their efforts to prove the contrary, they have only succeeded in proving that ionizing radiation is even more dangerous than their early results showed. As the National Academy of Science has stated endlessly in their BEIR reports, there is no safe dose of ionizing radiation. Increased dose is increased risk. This is even more true for high-LET internal alpha radiation and high LET neutrons.

The US EPA has a “clean water” water “standard” for drinking water, though it has none for water emissions from nuclear facilities – which makes no sense. Who, if anyone, pays to clean up the difference between radionuclides emitted by nuclear facilities and that allowed in drinking water?

Furthermore, the “Clean Water” drinking water standard appears to be inadequately protective, as well. It allows 740 Bq/liter of tritium in drinking water. The Canadian nuclear lobby was reportedly satisfied with a 20 Bq/liter standard for tritium in drinking water, recommended by the Ontario Water Advisory Commission (OWAC), even though Canadian CANDU reactors produce more tritium than other reactors. OWAC started with the idea that “the target derived risk level should be 1 in a million or 10-6 (meaning 1 new excess cancer occurrence over existing background cancer rates in 1,000,000 people); the target derived risk level should be over a lifetime of exposure of 70 years, and based on cancer incidences above background (occurrences) rather than mortality (deaths);” This led to models ranging from 7 Bq/L to 109 Bq/L.http://www.odwac.gov.on.ca/reports/052109_ODWAC_Tritium_Report.pdf http://www.odwac.gov.on.ca/reports/052109_Tritium_Report_Cover_Letter.pdf
Notice the number was chosen based on cancer morbidity (illness), not just mortality (death). (Unfortunately, if there are cooling towers they could send the balance of tritium out into the air.) Contrary to what TEPCO, AREVA, and EnergySolutions want everyone to believe, there are several ways to filter tritium. One is based on its having a different freezing point from plain water.

To think of Becquerels per liter, you can imagine the radioactive emissions per second as the bubbles in a small bottle (half a liter is 16.9 oz) of carbonated water or cola. Each Becquerel also has eV (electron volt) energy which varies according to radionuclide (as do bubbles). So, there are emissions per second (becquerels) and each emission has energy of “eV” usually in meV or keV.

To show just how farcical NRC, EPA and ICRP “standards” are for public radiation exposure, Unit 1 of JM Farley Nuclear Power Plant, which appears an average old plant, built in 1977, located in Alabama, reported to the NRC, for 2012, for gas and water effluents, a public exposure of 0.3594 mrem (0.003594 mSv) for all organs and the balance of the body, with a 0.0162 mrem (0.000162 mSv) thyroid exposure. The ICRP recommendation per facility is 0.1 mSv (10 mrem) maximum and the NRC is apparently 100 mrem (1 mSv) per facility. As can be seen, this older nuclear reactor, probably leaking because of age, is significantly under what is allowed, meaning that people should be asking for 0.0036 mSv or less exposure for the public (with all organs and balance of body combined). The EPA, NRC, and ICRP are limiting nothing and these do not constitute protective “standards” at all!

Yes, they need water standards but they need real standards and strict standards, which account for all radionuclides emitted in air and water and per facility. The actual quantities of the radionuclides must be measured and not the concentration!

While emissions per facility would appear obvious, apparently the current EPA air “standard” for emissions of radionuclides is national. Furthermore, none of the few radionuclides covered by the EPA, are reported as emitted into the AIR by the several nuclear facilities, we have examined, one of which we discuss here. It seems, based on their web site, that the NRC has an air “standard” of 0.10 mSv. Does the balance of 0.9 mSv go into the water?

This is a partial (or full) list of radioactive elements that should be monitored in air and water. However, each has so many isotopes that the NRC list of “standards” stretches 50 pages. Other than giving a list of isotopes, it is totally worthless as emissions are given as dilutions of microcuries per millilter, which gives no indication of what is actually released into the air or water. The US EPA, on the other hand, only names 2 for air, plus general gross Alpha emitters.

And, the EPA “clean water” drinking water standard appears weak – allowing up to 740 becquerels, radioactive disintegrations, of tritium per liter of water (two small bottles of water or cola) [See more further down]. There’s supposed to be less tritium if there is some cesium, strontium or other Beta emitters thrown in, but one is left with the impression that only tritium gets tested, if anything gets tested.

Alpha emitters, such as plutonium, are to be limited to a total of 0.55 becquerels per liter for drinking water. And, yet, the NRC rules allow “licensees” to put 7.4 Becquerels per liter, directly into the sewers – not that dilution fixes the problem, it only masks it.

The NRC rules invite the nuclear facilities to place plutonium 239 into the effluent water, diluted to 0.74 Bq per liter – once again in technical excess of drinking water under the clean water act.

And, communities do drink from the river waters that the Nuclear Power Stations emit to, and in some cases they drink recycled sewer waters.

Another problem with the NRC’s dilute and deceive strategy is that in times of dry weather or drought the becquerels per liter in the water increases, as the State of Mississippi noted to its dismay at the Salmon underground nuclear test site.

Higher concentration of radionuclides in water, due to drought, in the area of the Idaho National Lab test site, could help account for the thousands of dead snow geese, which reportedly dropped from the sky within the last week.

As well, the NRC needs to recall that its name is the Nuclear Regulatory Agency and so its job is to regulate the industry, rather than to work for the nuclear industry. Its job is to help the EPA keep a high safety standard for water, air, soil. They both appear to have forgotten or be oblivious to their purpose, which is to protect the people and environment from radionuclides from the nuclear industry.

Nuclear Facilities also are allowed to emit so many radionuclides, that it takes 50 pages to list them, including plutonium 239 to the air, along with the water. But, like the water, to talk about concentrations in the air – as opposed to amounts – is really meaningless for anything but the shortest-lived radionuclides. And, the shortest-lived radionuclides can easily be kept in holding tanks until they are no longer radioactive.

Do you think that 740 radioactive emissions is clean water? The NRC wants to manipulate the mrem (mSv) now to say that it should be well over 2,000 becquerels for tritium. How that can be when it is now believed that tritium is more dangerous than previously thought, and may require a weighting factor, cannot be fathomed.

The NRC sets air and water emission limits of radionuclides at micro-curies per milliter, which is utterly deceitful. This is an old trick reportedly used by workers in the petrochemical industry in “cancer alley”, USA – to emit pollution and let it go downstream, down the Mississippi River; wait a few minutes and then measure. The several nuclear power facilities, which we have examined, actually give the real emissions and then appear forced to report it as a dilution at the behest of the NRC! The radionuclides are going someplace. Dilution is not a solution for the longer lived radionuclides nor for simultaneous and ongoing emissions.

J.M. Farley Nuclear Power Station and the Chattahoochee River
For the Nuclear Power Station, which we chose as an example – J.M. Farley, the water emissions are going into the Chattahoochee River, into the Apalachicola River, and on into the Gulf of Mexico at Apalachicola Bay.

Apalachicola Bay, Florida, USA

Chattahoochee and Apalachicola Rivers (ACF Basin), by Pfly, CC-By-SA via Wikimedia
This river basin is already subject to a tri-state water war and the rivers account for 35% of the fresh water going into the Gulf of Mexico.
“Surface-water withdrawn from the Chattahoochee River for the Farley Nuclear Power Plant (owned and operated by The Alabama Power Company) totaled nearly 99 Mgal/d during 1990 (Baker and Mooty, 1993)… Total water-use in the Apalachicola and Chattahoochee River basins in Alabama increased nearly 230 percent from 55 Mgal/d in 1970 to 183 Mgal/d in 1990 (table 10). Nearly 78 percent of this increase was related to the opening of the Farley Nuclear Power Plant during the late 1970′ s. Discounting withdrawals by the Farley Nuclear Power Plant, surface-water withdrawals increased 23 percent.” http://fl.water.usgs.gov/PDF_files/wri93_4084_marella.pdf

“Alabama is concerned about the environmental results should drought occur and the water of the ACF and the ATF river basins is not allowed to flow freely due to use of Lake Lanier for Atlanta water consumption. These two river basins are also the habitat for countless numbers of fish and other aquatic life, which need a proper amount of water to thrive. If the water levels fall too low, then this aquatic life may suffer. Endangered species of both sturgeon and mussel live in the basins and reducing the water supply to the basins would put these endangered species in further jeopardy. Further, NEPA requires the submittal of an environmental impact statement (EIS) before any action with potentially major environmental effects. Such a statement has not been published, indicating the full environmental impact has not been assessed. Draft Programmatic EISs for the two basins were published in 1999, but were never formalized and no Record of Decision (ROD) was ever published.

In Florida, there are major environmental implications. The Apalachicola Bay provides 35 percent of the freshwater input to the eastern Gulf of Mexico, which is vital to the richly productive estuaries in this region. The key to the estuary is the fluctuation salinity levels produced by the ACF’s freshwater flow. A reduced flow of fresh water into these estuaries would drive salinity levels higher, altering the whole balance of the marine life.” http://en.wikipedia.org/wiki/Tri-state_water_dispute

Even if heavier elements, like plutonium, may drop down to the bottom of the Gulf of Mexico, sediments have been shown to be stirred and moved by Gulf hurricanes. There are also living beings down there, which the Environmental Protection Agency should be concerned with, by definition. In fact, researchers have found that much of the oil from the BP oil spill has just dropped to the bottom of the Gulf of Mexico.

Chattahoochee River near JM Farley NPS

You can see an oil spill. You can’t see the radiation from nuclear power stations.

Image: http://www.justice.gov/enrd/5812.htm

Storms will move radionuclides (and oil) which have dropped into large bodies of water back onto land. People will see the oil. People cannot see the radionuclides from the nuclear power plants .

Deepwater Horizon Response, Beach Oil PENSACOLA, Fla. – An oil-coated feather washed onto a Pensacola beach. U.S. Air Force photo by Tech. Sgt. Emily F. Alley.

The supposed EPA AIR emission “limits” on nuclear facilities also make no sense on multiple fronts. First they make no sense in that the “standard” is nation-wide, rather than by facility, and, unlike Russia, the nuclear power plants are private and not government owned making it utter non-sense (For all the Putinphiles: Russia allows 7,000 Bq/liter in the water – over 10 times as much tritium in water as the USA and 70 times as much as Europe allows):
“The total quantity of radioactive materials entering the general environment from the entire uranium fuel cycle. per gigawatt-year of electrical energy produced by the fuel cycle, contains less than 50,000 curies of krypton-85, 5 mii- curies of iodine-129, and 0.5 mllicuries combined of plutonium-239 and other alpha-emitting transuranic radionuclides with half-lives greater than one year.” 40 cfr 190 text (The original law is full of typographical errors, too. So, one can only guess that mii-curies is millicuries. They had “correction tape” in 1977.) The law may be suggesting that upon reprocessing that you figure out how much energy had been produced and work backwards – but this way of doing things makes no sense. Limits must be by facility as they are emitted. The US NRC’s supposed “limit” is also useless, as it is given in mSv and not actual emissions, and so apparently based on dilute and deceive.

JM Farley Nuclear Power Station
Furthermore the EPA rule gives AIR “limits” for only 2 radionuclides (Krypton 85; Iodine 129) plus Gross Alpha. These “restrict” Kr-85 to no more than 50,000 Ci/GW electricity produced , I-129 to no more than 5 mCi/GW electricity produced, with Pu-239 and other alpha-emitters as no more than 0.5 mCi/GW electricity produced. One curie is 37 billion becquerels or radioactive disintegrations (emissions) per second. That is 1 curie = 37 000 000 000 becquerels. The US EPA rule for AIR is for Pu-239 and other alpha-emitters is thus 18 500 000 becquerels per Gigawatt. According to wikipedia, our chosen case study, produces 13,098 GWs (2 reactors together). http://en.wikipedia.org/wiki/Joseph_M._Farley_Nuclear_Generating_Station

So, it would be allowed by EPA to emit 242,313,000,000 becquerels of Plutonium 239 and other alpha emitters into the air, annually. A becquerel is a radioactive disintegration (emission) per second.

But, looking at several reports from nuclear facilities there is no reporting of Krypton 85 or of Iodine 129 – only of Gross Alpha. In our example, JP Farley NPP, there is no Gross Alpha listed as emitted by AIR, only by WATER, for which EPA has no nuclear emission standards. And, as we know, for the US NRC dilution is the solution, so they could put whatever they want into the river.

So, for Krypton 85 the EPA “standard” is for 1,850,000 billion radioactive emissions per second or 1,850,000,000,000,000 per second. Joseph Farley Nuclear Power station, in Alabama, up the Chattahoochee, just north of Florida, has an Annual generation of 13,098 GWh. Thus, they are allowed to emit 13,098 x 1,850,000,000,000,000 radioactive disintegrations per second worth of Krypton 85 per year. 5 millicuries = 185 000 000 becquerels. It has a half-life of 10.756 years, which means it will still be around and radioactive for over 100 years (108 to 172 years depending on how zero you want to get).

Weird thing though – there is no reporting of Krypton 85 for the several sites – including Farley – which we have examined in the USA, only of Krypton 85 m, which is a totally different thing and short-lived at half life of 4.48 hours! There is also Krypton 87, half life of 1.27 hours, which becomes 87 Rubidium, half life of 4.9 years which then becomes 87 Strontium.

So, where is it? Where’s the Krypton 85? Not emitted? Not reported? What? If it is more of an issue for reprocessing then why is the limit per gigawatt? Both of these other Kryptons are so short-lived that since Farley only does batch releases it is difficult to estimate how much there was. After a day they have gone through many half lifes. And, yet there is still 0.000190 curies = 7 030 000 becquerels of Kr 85m and Kr 87 in the AIR batch releases. This appears significantly under the EPA standard of 1,850,000,000,000,000 radioactive emissions, but the half-lifes passed before batch releases would have to be accounted for.

Iodine 129, half life 15.7 million years is supposed to be “restricted” to 5 mCi/GW (185,000,000 becquerels per gigawatt). Funny thing though – there is no reporting of Iodine 129 for AIR for any facilities we have examined… Farley is using batch only mode for WATER, but what is the frequency? In 2012, it was almost every day, varying from less than one day to around 1 1/2 days worth of batch emitted at once. Elsewhere we have read that there is 1 Iodine 129 for every 3 of Iodine 131 (See Landis, 2012). Iodine 131 has a half-life of 8 days, so already after a day or day and a half of it is degraded by about 6 to 10%. However, the Iodine 129, half-life of 15.7 million years would have gone no place! “129I is primarily formed from the fission of uranium and plutonium in nuclear reactors.” http://en.wikipedia.org/wiki/Iodine-129 Furthermore, Iodine 129 “now serves as a groundwater tracer as indicator of nuclear waste dispersion into the natural environment. In a similar fashion, 129I was used in rainwater studies to track fission products following the Chernobyl disaster.” http://en.wikipedia.org/wiki/Isotopes_of_iodine

As remarked by Landis et. al. (2012), Iodine 129 (129 I), half-life 15.6 (or 15.7) million years, continues to accumulate in the environment and is an increasing risk: “…has a fission yield approximately one third that of 131I, and which, due to its long half-life and continued release from ongoing nuclear energy production, is perpetually accumulating in the environ-ment and poses a growing radiological risk” (Landis et. al., 2012, “Surficial redistribution of fallout 131 iodine in a small temperate catchment“, PNAS http://www.pnas.org/content/109/11/4064.full )

For AIR I-129 is “restricted” by the EPA “to no more than 5 mCi/GW electricity produced“. 5 millicuries = 0.005 curies, or a total of 65.49 Curies since they make 13,098 GW per year. They are thus “restricted” by the EPA to emit 185,000,000 becquerels per gigawatt or 2,423 billion becquerels (2,423,000,000,000 becquerels) of Iodine 129 per year. Now this is only Iodine 129, it is not Iodine 131! In 2012, the Farley Nuclear Facility Site reported annual AIR emissions of Iodine 131 of 8.62 E – 6, i.e. 0.00000862 curies of Iodine 131, i.e. 318,940 radioactive disintegrations per second (becquerels). So, they are “restricted” to 580 times the amount that they are emitting! That is, if this were Iodine 129, rather than Iodine 131, and if it were by facility as opposed to nationwide. Could they be cheating by putting it into the water? In the water they report sending out 0.000111472 curies of Iodine 131, 132, 133, i.e. 4,124,464 becquerels. Iodine 132 and 133 have half-lifes in hours, and (for 2012, as reported to the NRC) the testing is weekly, and in batch mode, so it takes fairly complex calculations to estimate what was originally there.

As for AIR, “Released quantities of radioiodines are determined using the weekly samples and release flow rates for the applicable release points. Radioiodine concentrations are determined by gamma spectroscopy,” according to the 2012 report to the NRC on Farley.

According to the same report: “However, the percent of the ODCM limits are not applicable because FNP has no curie limit for gaseous releases. Applicable limits are expressed in terms of dose. Noble gases are limited as specified in ODCM 3.1.2. The other three categories (tritium, radioiodines, and particulates) are limited as a group as specified in ODCM 3.1.2.” We assume that this is because it was grandfathered in from having a license before the law? Or, is it simply because, according to the EPA informational seminar, “Limits apply to total released nationally“! How is that supposed to work? Different power plants have different private owners! Where is a control or incentive? This was actually one of the EPA questions for comment, last summer – if there should be limits and if they should be by facility or nationwide! The EPA and NRC are both updating their “standards” and apparently intend to do joint standards in the end. (Some will notice that much of this post is only slightly modified from last summer’s EPA comment period.)

The (EPA) law itself says: “The total quantity of radioactive materials entering the general environment from the entire uranium fuel cycle. per gigawatt-year of electrical energy produced by the fuel cycle…” (40 CFR 190 text) Is that really nationally, as the EPA info online seminar says, or is it by facility?

Plutonium 239 (Pu 239) with a half-life of 24,100 years, radioactive for 241,000 to 385,600 years, along with other alpha emitters (half-lifes of 100s, and 1,000s of years) is “restricted” by the EPA to 0.0005 curies per gigawatt, i.e. 185,000,000 Bq per GW. This is an AIR “restriction” only. Pu 239 is not reported as being emitted into the air by Farley NPP but only into the WATER. They report Gross Alpha, including Pu 239 of 2.13 E -5 (.0000213) curies, i.e. 788,100 Becquerels of Gross Alpha. Recall that due to the high power, densely concentrated, internal dangers, the weighting factor for alpha emitters, like Plutonium, (Gy to Sv), is 20.

Farley Nuclear Station produces 13,098 GW per year, according to Wikipedia, so would be allowed to emit 6.55 curies or 242 billion becquerels of alpha into the AIR. Instead, they emit 788,100 Becquerels into the water (notice billions allowed compared to thousands produced). Where is the EPA “restrictive limit” here? LIQUID: In a one year period (2012) Farley NPP claims to emit “only” 2.13 E – 5 (0.0000213) curies of gross alpha, i.e. 788,100 Bq.

DRINKING WATER STANDARD FOR RADIONUCLIDES

The EPA has drinking water standards for beta emitters of 4 mrems (0.04 mSv); gross alpha standard of 15 pCi/L, i.e. 0.55 Bq/liter. Uranium is 30 µg/L and combined radium 226/228, 5 pCi/L, i.e. 0.185 Bq/liter. http://water.epa.gov/lawsregs/rulesregs/sdwa/radionuclides/index.cfm
Alpha emitters is .5555 Bq…but weighting factors must be added to reflect that Alpha emitters are more dangerous, and most, or all, are bio-accumulative over a lifetime and have half-lifes in the hundreds and even millions of years. More on the EPA rules on their web site/ http://water.epa.gov/drink/contaminants/basicinformation/radionuclides.cfm

Alpha emitters, such as plutonium, are to be limited to a total of 0.55 becquerels per liter for drinking water. And, yet, the NRC rules allow “licensees” to put 7.4 Becquerels per liter of Plutonium 239, directly into the sewers – not that dilution fixes the problem, as they pretend, it only masks it. One sees the same game being played with TEPCO at Fukushima. The NRC rules invite the nuclear facilities to place plutonium 239 into the water, diluted to 0.74 Bq per liter – once again in technical excess of drinking water under the clean water act.

And, communities do drink from the river waters that the Nuclear Power Stations emit to, and in some cases they drink recycled sewer waters.

Nuclear Facilities also emit so many radionuclide isotopes that it takes 50 pages to list them all! These include plutonium 239 to the air, along with the water. But, for the air, like for the water, to talk about concentrations in the air – as opposed to amounts – is really meaningless for such long-lived radionuclides. For the NRC rules to speak of microcuries per milliliter is simply a con.

According to the clarification given by the US State of Washington:
“EPA has established a maximum contaminant level of 4 millirem per year for beta particle and photon radioactivity from man-made radionuclide’s in drinking water. Cesium-137 would be covered under this MCL. The average concentration of cesium-137 which is assumed to yield 4 mrem/year is 200 picocuries per liter. If other radionuclide’s which emit beta particles and photon radioactivity are present, the sum of the annual dose from all the radionuclide’s must not exceed 4 mrem/year.” http://www.ecy.wa.gov/programs/nwp/gwcontaminants.htm
4 mrems is 0.04 mSv. Thus, if only Cesium were present, Cesium 137 would be 7 Becquerels per liter.

According to the Lawrence Livermore National Lab, it takes about 2 years for cesium – which mimics potassium in the body to become steady state in the body: “In the case of a chronic exposure, organ and body burdens continue to build up over time until a steady state is reached where losses due to decay and excretion are balanced by intake and absorption. Cesium-137 has an effective half-life in an adult of about 110 days, and under chronic exposure conditions reaches a maximal dose contribution after about 2 years. By contrast, plutonium absorbed from the gastrointestinal or respiratory tract enters the blood stream and deposits in liver and bone with an effective half-life of 20 to 50 years. Only a small fraction of plutonium entering the blood stream is excreted in urine…” https://marshallislands.llnl.gov/glossary.php (emphasis added)

Cesium 137 has a half life of 30 years and is a routine emission from nuclear power plants. When speaking of the half-life of radionuclides, it is important to consider that the number of years to reach 0.78% of the original quantity is Half Life x 7; half-life x 16 years brings it to 0.0015%. So, it will be present in the environment in the range of 300 to 480 years. Considering this, the US NRC and others “regulating” the nuclear industry by allowing air and water emissions according to radionuclides per volume of water are operating a dangerous con game over time and space.

The NRC rules state that “if the sewage released by the licensee were the only source of water ingested by a reference man during a year, would result in a committed effective dose equivalent of 0.5 rem.“ Nuclear Regulatory Commission Pt. 20, App. B , p. 383. 0.5 rem is 500 mrem and 5 mSv, which would be in violation of ALL other standards – ICRP (0.1 mSv), EPA (0.25 mSv) and the NRC’s stated standard (1 mSv). AND, putting it into a sewer is likely to work itself back into the drinking water. (It’s not just the US that is sleazy enough to allow radionuclides into the sewers, we first read about this in UK standards!) Furthermore, for Cesium 137, 4,440 Bq/liter may be emitted into the sewer.

Compare this 4,440 Bq/liter – which is what is allowed disposed of by each licensee into sewers only – to the 7 Becquerels per liter allowed in drinking water! Is the balance being filtered? If so, who pays? This 7 Becquerels is supposed to be if and only if there is no tritium or other Beta emitters.

Air and water emission seem to be an additional 0.048 Becquerels per liter per licensee (we think it is per reactor for the NRC) and appear to be annual, rather than monthly. This is for Cesium 137 only, whereas there are about 52 pages of radionuclides listed in the rules. This is, of course, diluted as per NRC specifications for dilute and deceive, given in microcuries per milliliter.

To take J M Farley NPP as an example, in 2012, they reported emitting 0.0002036 curies of Cesium 137, i.e. 7,533,200 Becquerels into the Chattahoochee River. How many becquerels per liter is that? In the end, it really doesn’t matter because that Cesium 137 is accumulating in the environment and with half life of 30 years will still be radioactive in 100s of years. The NRC telling the Nuclear Facilities to dilute the Cesium before putting it into the air or rivers is a criminal hoax.

As for Strontium 90, the “EPA has established a maximum contaminant level of 4 millirem per year for beta particle and photon radioactivity from man-made radionuclide’s in drinking water. Strontium-90 would be covered under this MCL. The average concentration of strontium-90 which is assumed to yield 4 mrem/year is 8 picocuries per liter. If other radionuclide’s which emit beta particles and photon radioactivity are present, the sum of the annual dose from all the radionuclide’s must not exceed 4 mrem/year“. http://www.ecy.wa.gov/programs/nwp/gwcontaminants.htm
8 picocuries per liter is 0.29 Bq per liter of Strontium 90. From our understanding, this 0.29 Bq is supposed to be if and only if Strontium 90 is the only Beta emitters, i.e. no tritium, no cesium, etc.

The US NRC allows 185 Bq per liter of Strontium 90 to be put into sewer systems or 638 times the amount allowed for drinking water. The regular liquid effluent, apparently going straight into the rivers, should be diluted to 18.5 Bq/liter or over 63 times the amount allowed.

J.M. Farley reports emitting 2,960,000 Becquerels of Strontium 90, as liquid effluent. Although the becquerels per liter, is unknown, with the entire Chattahoochee river at their disposition, you can be certain that they diluted the strontium properly, as good NRC students. If nothing else they’ve only to let it float a bit downstream, before testing!

Strontium 90 has a half life of 28.8 years so it too will be around for about 460 years, after shooting downstream into the Gulf of Mexico at Apalachicola Bay.

Overall, J.M. Farley reported pre-dilution (radioactive) waste water effluent volume in liters as 8,590,000 which they dumped and diluted in 8,390,000,000 liters of “dilution water” (Total is 8,390,000,000 + 8590000; % of original in total is 8590000 divided by Total = 0.1022%) Therefore it is 99.897 % diluted (99.897% = 100% – 0.1022%)

“Exposure to technetium-99, as to all radionuclide’s, results in increased risk of cancer. EPA has established a maximum contaminant level of 4 millirem per year for beta particle and photon radioactivity from man-made radionuclide’s in drinking water. Technetium-99 would be covered under this MCL. The average concentration of technetium-99 which is assumed to yield 4 mrem/year is 900 picocuries per liter. If other radionuclide’s which emit beta particles and photon radioactivity are present, the sum of the annual dose from all the radionuclide’s must not exceed 4 mrem/year.” They importantly tell us that technetium,[like iodine] concentrates in the thyroid. http://www.ecy.wa.gov/programs/nwp/gwcontaminants.htm
900 picocuries per liter is 33 Bq/liter technetium 99. While they inform us that it is fairly quickly excreted from the body, in a contaminated environment, the body will simply recontaminate itself.

The NRC allows 22,200 Bq/liter of Technetium 99 into the sewer system and 2,220 Bq into the waterways. This clearly exceeds the 22 Bq/liter allowed in US “Clean Water”. Farley reports liquid emissions of only the short-lived Tc 99m.

“Exposure to tritium, as to all radionuclides, results in increased risk of cancer. EPA has established a maximum contaminant level of 4 millirem per year for beta particle and photon radioactivity from man-made radionuclide’s in drinking water. Tritium would be covered under this MCL. The average concentration of tritium which is assumed to yield 4 mrem/year is 20,000 picocuries per liter. If other radionuclides which emit beta particles and photon radioactivity are present, the sum of the annual dose from all the radionuclide’s must not exceed 4 mrem/year.” (Emphasis added) http://www.ecy.wa.gov/programs/nwp/gwcontaminants.htm
This 20,000 picocuries per liter corresponds to 740 Bq/liter of tritium, i.e. 740 radioactive disintegrations-emissions per second in each liter!

NRC rules allow 370,000 Bq per liter per month of tritium to go directly to the sewer, which is 500 times more than the Clean Water Act allows for drinking water. Who pays to clean the water? Or, do people just drink it in violation of the Clean Water Act? 185 billion becquerels are allowed per year, meaning 15 billion becquerels per month, which is 40,540.5 liters per month of 370,000 Bq.

The annual limits to how much can be put in sewers, though who would be watching?
“NRC Sewers (4) The total quantity of licensed and other radioactive material that the licensee releases into the sanitary sewerage system in a year does not exceed 5 curies (185 GBq) of hydrogen-3, 1 curie (37 GBq) of carbon-14, and 1 curie (37 GBq) of all other radioactive materials combined.” http://www.nrc.gov/reading-rm/doc-collections/cfr/part020/part020-2003.html

Oh, each licensee can ONLY emit 185 gigabecquerels, i.e. 185 billion becquerels per year of tritium into the sewer, 37 billion becquerels of Carbon 14 plus 37 billion becquerels of all other radioactive materials!

The NRC allows nuclear facilities to emit diluted tritium into the waterways at 37,000 Bq per liter or 50 times more than allowed in drinking water!

JM Farley emitted 39.8 trillion becquerels of tritium as liquid effluent – presumably into the Chattahoochee River, which, as good students of the NRC, they diluted down to 21,326.8 Bq/liter – significantly under the NRC regs but 29 times more than the 740 Bq/liter allowed for drinking water, under the Clean Water Act.

Additionally, in 2012, JP Farley reported one “whoops”: anomalous emission of 2,623,300 unidentified becquerels into the water.

Who is a licensee?
“Licensee
A company, organization, institution, or other entity to which the NRC or an Agreement State has granted a general license or specific license to construct or operate a nuclear facility, or to receive, possess, use, transfer, or dispose of source material, byproduct material, or special nuclear material.” http://www.nrc.gov/reading-rm/basic-ref/glossary/licensee.html

We apologize for any mathematics errors. The essential points will remain the same, however. Parts of original documents are provided below so that you can do the mathematics yourself. We have chosen to convert from micro-curies per milliliter to becquerels per liter, because it is easier to understand.

References-Documents-Additional Reading

A few pages from the 50 plus of the NRC rules for radioisotopes. Note that it is in microcuries per milliliters so must be converted to liters, and to millicuries, or curies, or becquerels.