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US NRC Comment Deadline on “Radiation Protection” next Monday 22 June 2015, 11.59 pm (one minute to midnight) NY-DC (ET). Comment here: http://www.regulations.gov/#!documentDetail;D=NRC-2009-0279-0098 (ID: NRC-2009-0279-0098) The original list of questions to be answered is found here: https://www.federalregister.gov/articles/2014/07/25/2014-17252/radiation-protection

The costs of additional cancers, leukemia, kidney damage, and the clean-up of contaminated water are among the costs which the US NRC-Nuclear Industry is externalizing upon society. The US NRC allows nuclear reactors-facilities to emit radioactive materials into the environment with no apparent limit. The “limit” is strictly based on dilution into air and water. Even the US EPA has suggested that dilution might be used to bring the water up to standard. https://miningawareness.wordpress.com/2015/03/18/us-nrc-radioactive-dilute-and-deceive-scam-comment-deadline-march-24th/

How Radiation Affects People’s Health” from “US EPA: Radionuclides in Drinking Water: A Small Entity Compliance Guide“, p. 3
US EPA: Radionuclides in Drinking Water: A Small Entity Compliance Guide, p. 3
bubbles in water

Two of the questions which the NRC asks are found below. Note that they are speaking of concentration and not amount of radionuclides emitted. Until they speak of actual amount then it is meaningless.

As for age and gender – children, the unborn and women appear the most at risk overall. According to “Health Risks from Exposure to Low Levels of Ionizing Radiation: BEIR VII – Phase 2” p. 312 “TABLE 12D-3 Lifetime Attributable Risk of Solid Cancer Incidence and Mortality“, 1 mSv per year throughout “life” (defined as 70 years even though US life expectancy is 81 for women), excess risk from this exposure for men is 621 (deaths 332); for women is 1019 (deaths 497). For 81 years it would be 1.2% for women. The death rate for those with these cancers is around 51%. See more here: https://miningawareness.wordpress.com/2015/06/17/lockheed-martin-opposes-usnrc-radiation-protection-rule-wants-to-keep-rule-from-1956-comment-deadline-22-june-11-59-pm-dc-ny-et/ For certain radiation induced diseases males are actually more at risk than females. The BEIR report is US government funded: “This study was supported by Environmental Protection Agency Grant #X-826842-01, Nuclear Regulatory Commission Grant #NRC-04-98-061, and U.S. Department of Commerce, National Institute of Standards and Technology Grant #60NANB5D1003.

Two US NRC Questions:
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.”

“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?

Once again, this is meaningless until they assign radionuclide actual limits and model its distribution through the environment. This dilute and deceive cannot work forever. Furthermore, the NRC web site says the limit is 1 mSv (100 mrem).

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 where there is a long-lived component of the radionuclides 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 for emissions. The EPA water standards, discussed below, seem protective if applied correctly, but create problems of what to do with the sludge, filters, etc.

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 They appear to have just said that radiation sent directly into the sewer system and people who are contaminated because of medical treatment or experiments (it must leave their bodies in some way) do not count under this 1 mSv.

Drinking water is supposed to have radiation protection standards. However, the NRC-EPA-Nuclear Industry are leaving it to the water provider, whether public or private to pay for clean-up: “Radionuclides in Drinking Water: A Small Entity Compliance Guide

One key change in the new Radionuclides Rule is that, rather than monitor at a ‘representative’ point in your distribution system, you must now monitor at EACH entry point to the distribution system (EPTDS). This change prevents situations in which the ‘average; water meets the standard, even though some people are drinking poor-quality water from a contaminated source. It also makes the Radionuclides Rule consistent with other regulations covering chemical contaminants in drinking water.

Unless told otherwise by the State, a system which uses an intermittent source of supply (i.e., a source that is used seasonally) or that uses more than one source and that blends water from more than one source before distribution, must sample at an EPTDS during periods of normal operating conditions. Normal operating conditions include when water is representative of all the sources being used…” (p. 7)

If your State says you are vulnerable to contamination from man-made radionuclides, you must take quarterly samples for gross beta emitters and annual samples for tritium and strontium-90 at each entry point to the distribution system. If the running annual average (minus potassium-40) is less than or equal to 50 pCi/L, the State may reduce your monitoring to once every 3 years. Systems in the vicinity of a nuclear facility may be allowed to use the facility’s own surveillance data.

Systems determined to be using waters that are contaminated by effluents from nuclear facilities must analyze monthly samples or composite three monthly samples each quarter for gross beta activity, analyze a composite of five consecutive daily samples each quarter for iodine-131, and analyze four quarterly samples or composite four consecutive quarterly samples for strontium-90 and tritium.

If your State determines that you are vulnerable to contamination, or already contaminated, the initial monitoring period takes place between 2004 and 2007. Your monitoring requirements after this time will vary depending on your results.

How Can I Tell If My System Is in Violation?

Determining if your system is in violation requires two steps. First, if your system is vulnerable to contamination and the results of testing for all beta and photon emitters is less than or equal to 50 pCi/L, you are in compliance. If your results are greater than 50 pCi/L, you must have the samples further analyzed for the individual nuclides. The results of the more specialized analysis are compared to the concentration limits as explained above.

If you are using waters that are contaminated, the State calculates compliance as described above. If the sum of the fractions is less than 1, your system is in compliance“. (p. 12) http://www.epa.gov/ogwdw/radionuclides/pdfs/guide_radionuclides_smallsystems_compliance.pdf (50 pCi is 1.85 Bq.)
Radionuclides in Drinking Water: A Small Entity Compliance Guide p. 4 Rad Max Contam
Radionuclides in Drinking Water: A Small Entity Compliance Guide” p. 4
Radionuclides in Drinking Water: A Small Entity Compliance Guide Requirements for Beta-Photon
Note use of the more protective “critical organ does”. Concentration is appropriate for ingestion. It is not appropriate for emissions into the environment.
Radionuclides in Drinking Water: A Small Entity Compliance Guide  Beta and Photon Derived concentrations drinking water, p. 11
Radionuclides in Drinking Water: A Small Entity Compliance Guidehttp://www.epa.gov/ogwdw/radionuclides/pdfs/guide_radionuclides_smallsystems_compliance.pdf

Tritium [H3]: 20 000 picocuries = 740 becquerels
Strontium 90: 8 picocuries = .296 becquerels

Notice how the following is misleading. This is the dose for Strontium if and only if it were alone! “EPA set standards for the concentration of 90Sr in community water supplies. The average annual concentration of 90Sr in water supplies should not exceed 8 pCi/L (0.3 Bq/L). EPA also established maximum contaminant levels (MCLs) in drinking water for radionuclide activities to protect against harmful effects of 90Sr. For beta particles like strontium, the MCL is 4 mrem per year (4×10-5 Sv per year).http://www.atsdr.cdc.gov/phs/phs.asp?id=654&tid=120

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. As we have seen some water providers are dependent upon the local nuclear reactors- facilities to test the water for them.

Who, if anyone, pays to clean up the difference between radionuclides emitted by nuclear facilities, and that allowed in drinking water? This has actually become a problem in some places and requests have been made to spray it on agricultural land, moving the problem to food and ground water.
Radionuclides in Drinking Water: A Small Entity Compliance Guidep. How to Meet the MCL p. 19
Radionuclides in Drinking Water: A Small Entity Compliance Guide“.
Radionuclides in Drinking Water: A Small Entity Compliance Guide., p. 21 Water Treatment Waste

The NRC-EPA need real standards and strict standards, which account for all radionuclides emitted in air and water and per nuclear reactor-facility. The actual quantities of the radionuclides must be measured and not the concentration!

Apparently the current EPA air “standard” for emissions of radionuclides is national, rather than per reactor-facility, and covers only a couple of radionuclides. 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 upon emission. 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.
NRC rules 10 CFR Pt. 20 App. B list of Radionuclides

The EPA “clean water” drinking water standard appears improperly described and probably improperly applied. There’s supposed to be less tritium if there is strontium or other Beta emitters thrown in, but testing appears sparse.

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 violation of drinking water standards.

And, communities do drink from the river waters that the Nuclear Power Stations emit to, and in some cases they drink recycled sewer waters. Plants and animals do not have their water cleaned.

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.

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.

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.

Tritium readily forms water when exposed to oxygen. As it undergoes radioactive decay, tritium emits a very low energy beta particle and transforms to stable, nonradioactive helium. Tritium has a half-life of 12.3 years…. Current treatment of landfill leachates do not remove tritium.http://www.epa.gov/radiation/radionuclides/tritium.html

Uranium and radium are known to be hard on the kidneys. Apparently this is true for Strontium too. “Kidney Int. 2003 Mar;63(3):927-35. Dose-dependent effects of strontium on bone of chronic renal failure rats. Schrooten I1, Behets GJ, Cabrera WE, Vercauteren SR, Lamberts LV, Verberckmoes SC, Bervoets AJ, Dams G, Goodman WG, De Broe ME, D’Haese PC. http://www.ncbi.nlm.nih.gov/pubmed/12631073