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US Nuclear Reactor Effluent Comment Deadline for 11.59 pm October 1st http://www.regulations.gov/#!docketDetail;D=NRC-2014-0044

There are, at least, a few noteworthy points about the upcoming US NRC “Nuclear Effluents” comment deadline, besides the already discussed problem of dilution NOT being a solution, and the need for a legally binding fixed amount of radioactive emissions to the environment by the nuclear industry- preferably zero (If the cost is too high a price for doing business, then they have no business in business). https://miningawareness.wordpress.com/2015/06/18/radiation-in-water-dilute-deceive-externalize-costs-us-nrc-comment-deadline-mon-22-june-2015-11-59-pm-one-minute-to-midnight-ny-dc-et/ See screenshots of effluent concentration “limits” rule at bottom of this March post: https://miningawareness.wordpress.com/2015/03/18/us-nrc-radioactive-dilute-and-deceive-scam-comment-deadline-march-24th/ Concentration limits are obviously not limits at all. At least it’s obvious if you sit and think a little bit.

The US NRC does (according to the comment docket) have “design objectives” for the emissions of actual quantities of radiation (GigaBecquerels-Curies) in effluents (as opposed to concentrations) in Docket RM–50–2, “Concluding Statement of Position of the Regulatory Staff, Guides on Design Objectives for Light-Water-Cooled Nuclear Power Reactors” (February 20, 1974, pp. 25– 30), but they appear to be non-binding and limited in scope: “The design objective for radioactivity in liquid effluents, excluding tritium and dissolved gases, is a calculated annual quantity not to exceed 5 Curies (Ci) (185 gigaBequerel (GBq)) per reactor unit. Additionally, the design objective for I–131 in gaseous effluents is a calculated annual quantity not to exceed 1 Ci (37 GBq) per reactor unit.” A gigabequerel is one billion radioactive emissions per second (1,000,000,000). Notice the omissions. It excludes dissolved gases and tritium for liquid effluents, and only includes the short-lived Iodine 131 for gaseous effluents. Iodine 131, half-life 8 days, can be held for several months to become non-radioactive, so it should not be released at all. They also appear to be applicable for only a certain historic timeframe of construction licensing: “The Docket RM–50–2 objectives and dose limits are applicable to reactor construction permit applications that were docketed on or after January 2, 1971, and prior to June 4, 1976“. (p. 25240 Federal Register / Vol. 80, No. 85 / Monday, May 4, 2015 / Proposed Rules ) Furthermore, there seems to be no distinction between types of radiation or longevity of radionuclides.

Different radionuclides have different biological impacts, requiring dose conversions from Becquerels (or Curies) to a measurement of biological impact, such as millisievert or millirem. The impacts also vary according to age and gender. In this comment period, they are using man (person) rem, which is 10 millisieverts (mSv). Small changes in dose conversion factors can make big changes in determining biological impacts (e.g. mSv; person rem, etc), which, in turn, gives indication of cancer risks. It is a very big deal.

It appears that the ICRP is about to produce new dose conversion coefficients, and yet, the US NRC is requesting public comment BEFORE the new coefficients are available. The new dose coefficients must be even more damning or they would postpone this comment period, as some NRC staff seem to have suggested. The timing of this comment period undermines its stated goal: “input from stakeholders on the development of a regulatory basis for the NRC’s regulations governing radioactive effluents from nuclear power plants. The regulatory basis would support potential changes to better align the NRC regulations governing dose assessments for radioactive effluents from nuclear power plant operations with the most recent terminology and dose-related methodology published by the International Commission on Radiological Protection (ICRP) contained in the ICRP Publication 103 (2007)” (Federal Register p. 25237 Vol. 80, No. 85 Monday, May 4, 2015) A few pages later, “The NRC staff cautioned, however, that the NRC should not initiate a rulemaking to better align with these ICRP Publication 103 recommendations until the ICRP publishes its updated dose coefficients and other supporting information“, (Federal Register / Vol. 80, No. 85 / Monday, May 4, 2015 / Proposed Rules p. 25239)

Would people be allowed to run around shooting randomly like the nuclear industry does? Clearly no. They would be considered terrorists; insane; evil. Even a Los Alamos researcher has compared radiation to gunshots at the cellular level. For guns, the rate of shooting doesn’t get this high though. Gunshots are counted in rounds per minute and not per second. One of the highest rates for guns would be 100 rounds per second. “The M134 Minigun is a 7.62×51 mm NATO, six-barrel machine gun with a high rate of fire (2,000 to 6,000 rounds per minute)“. https://en.wikipedia.org/wiki/Minigun This is the same rate of radioactive “shots” (100 Bq) allowed for food in Japan. The US allows 15 x that amount of radiation in food, i.e. 1,500 Becquerels (radioactive shots per second). And, unless the ammunition has depleted uranium, when the shooting is done it’s over and the results quickly known. Radioactive “effluents” means sitting on death row for you and your children and future generations. Maybe you will get a reprieve and maybe not. Almost no one cares about the impacts on animals and plants.

Suitably vague wording from Appendix A to Part 50 – General Design Criteria for Nuclear Power Plants: “The nuclear power unit design shall include means to control suitably the release of radioactive materials in gaseous and liquid effluents and to handle radioactive solid wastes produced during normal reactor operation, including anticipated operational occurrences. Sufficient holdup capacity shall be provided for retention of gaseous and liquid effluents containing radioactive materials, particularly where unfavorable site environmental conditions can be expected to impose unusual operational limitations upon the release of such effluents to the environment“. Just what is “control suitably”? Suitably for who? Public health? Utility bottom line? That looks like a potential field day for lawyers.

The US NRC values human life detriment (e.g. cancer, death) at about $1 million, compared to the US Dept. of Transportation at $9.4 million. https://en.wikipedia.org/wiki/Value_of_life Since women get radiation induced cancers at a rate 20% higher than average, women’s lives are valued less, by the NRC. This isn’t surprising for such a misogynistic world. As others have noted, with no women there are eventually no men, but this statement itself inherently assumes that women have no value as people, thinkers, or workers – always shocking to those of us who were lucky enough to raised to see everyone as equal humans, regardless of gender or race. It is also strange for an industry where women have played important founding roles, as high level scientists, and low level workers, before and during the Manhattan Project.

There is no value, of course, for plants, animals or agricultural land included. And, even though more women will get cancer, a higher percentage of men do die of these radiation induced cancers, slightly closing the gap.

The $1,000 given per man (person) rem ($100 per mSv), for this comment period, (Federal Register / Vol. 80, No. 85 / Monday, May 4, 2015 / Proposed Rules, p. 25239) calculates to $1 million per extra cancer prevented (following BEIR where there are an estimated excess 1% cancers per 100 mSv and 100% per 10,000 mSv, in conjunction with the model which the NRC apparently uses to calculate), This also excludes non-cancer health-related impacts and cancers induced in future offspring. This also excludes accumulation in the environment. The BEIR-ICRP models seem most appropriate for external, low-LET, radiation, especially x-rays. X-rays do not accumulate in the environment. It is also unclear how this $1,000 per person rem or $100 per mSv works. Is it multiplied by the numbers of people living in the 50 mile radius, such that in rural areas there are fewer requirements to filter radiation? A $9.4 million value for human lives gives a $9,400 per person rem ($940 per mSv) value.

$1 million sounds like a lot until you consider both the high cost of US medical care, and that for the half who die of these cancers, their lives are shorted by 14 to 15 years, meaning loss of earnings potential, health and happiness, no retirement (because you’re dead), loss of care-givers for the elderly and for children, etc. How many years will they have cancer? 5 years? If you divide $1 million by 20 it is $50,000. The first year of brain cancer – and other cancers frequently metastasize to the brain – costs over $100,000 for treatment. http://costprojections.cancer.gov/annual.costs.html It remains shocking that insurance companies haven’t gone after the nuclear industry. Is it because they are pacified with simply raising premiums and dumping off patients when they have exceeded their maximum lifetime coverage?

Little mentioned is the $1,000 for thyroid man rem. Thyroid cancers are a small percentage of radiation induced cancers with few deaths. However, medical care is required, the cancer may return or spread elsewhere, and the individual has life and death dependency upon access to replacement thyroid hormones and testing to make sure it is the right dose, for the rest of their lives. http://www.nhs.uk/Conditions/Cancer-of-the-thyroid/Pages/Introduction.aspx http://www.nhs.uk/Conditions/Cancer-of-the-thyroid/Pages/Treatment.aspx It can be difficult to get the dosage right and too much leads to nervousness and weight loss; too little to sluggishness and weight gain.

Will the utilities pay the medical expenses for these cancers? No. For all cancers, and other illnesses, induced by the nuclear industry, the medical cost is externalized upon insurance companies, and comes back as inflated insurance premiums, and ultimately the taxpayer pays in the form of medicaid-medicare. It is also externalized upon volunteer, often family, caregivers. The nuclear utilities-industry keep the profits (benefits) for themselves. They externalize the costs (risks) upon others. Under Price-Anderson the nuclear industry pays virtually nothing, even in the event of a catastrophic nuclear accident. The NRC proposal to raise radiation exposure limits to 100 mSv per year, which over a lifetime will lead to an average 80% or more cancer rate, almost completely nullifies everything else. “Atomic insights”, run by a former US Nuclear Navy man, who is pushing the 100 mSv per year agenda, had a catchy blog post title: “NRC calls off expensive search for witches.” We won’t give the blog the boost of clicking on it to see the content. Under the 100 mSv per year protocol, according to BEIR estimates, there will be an estimated 101,900 cancers for women per 100,000 women, over the course of an average lifetime. About half of these cancers will be fatal, and shorten life by about 15 years. Hence, many witches will be dead, along with non-witches. No need to witch hunt the dead and dying. Historic witch-hunts targeted women more than men, as does cancer inducing ionizing radiation from the nuclear industry. Contrary to pro-nuclear propaganda, which even contradicts itself, intermediate doses start at 100 mSv and the impacts accumulate over a life-time. Thus, they are not really speaking of 100 mSv, but 6,000 to 8,000 mSv, or more, over the course of a life-time. But, that is another story for another day. Deadline for 100 mSv is November 19th. http://www.regulations.gov/#!docketDetail;D=NRC-2015-0057 Note in your readings that there is dose fractionated over time and single dose. The pro-nuclear lobby muddles this. They are NOT proposing 100 mSv over a lifetime, which is close to the 1 mSv currently allowed, but rather 100 mSv per year! The 1 mSv per year already gives unchosen, unnecessary, and high risk of cancer. Acceptable risk-taking must include choice. For women, 1 mSv per year, over a lifetime, translates into a 1% cancer risk. 100 mSv into over 100%. Where is the choice? An NRC comment deadline which almost no one hears about doesn’t constitute choice.

An upcoming comment period (November 3rd) on this topic of value of life claims that the NRC value was updated to $2,000 per man rem ($200 per mSv), which they turn into value of life of $3 million, although it would be $2 million. However, a recent NRC presentation puts it still at $1,000 per man rem ($100 per mSv): http://hps.ne.uiuc.edu/rets-remp/PastWorkshops/2014/Wed_05-1_Conatser_2014_10CFR50_Appendix-I_Revision.pdf The NRC bureaucracy doesn’t seem to know which end is which even though both are rear ends. The $1,000 may be death (mortality) and the $2,000 detriment (morbidity-illness).

Originally the $1,000 included the 15 years of life shortening effects, and medical care, and dates from the 1970s. It should go without saying that wages, and especially medical costs have increased over the course of almost half a century.

To be comparable to the US Dept. of Transportation number, the figure should be $9,400 per person rem and $940 per mSv.

This matters because the higher amount can force them to reduce radiation emissions, and increase safety. If life has little value they will spew more radiation (and cut more corners with safety).

The NRC is reporting in mGy rather than mSv which should never be the case with internal exposure: “The annual design objective for radioactive material above background in gaseous effluents is a calculated quantity not to exceed 0.1 mGy (10 mrad) gamma-air dose and 0.2 mGy (20 mrad) beta-air dose, with provisions for increasing or decreasing the design objectives based on total body dose and skin dose.” Biological impact must be given in mSv (or mrem). They allow for more beta irradiation than gamma for Noble Gases, even though they may be inhaled and beta emitters are dangerous internally. (See p. 25240 Federal Register / Vol. 80, No. 85 / Monday, May 4, 2015 / Proposed Rules).

Krypton 85, a noble gas, not only may be implicated in climate change but it gets stored in body fat. Thus, it has more than transient external impacts and the biological impacts should NOT be expressed in mGy, but rather mSv or mrem. (See EPA, Krypton, Review of the Literature): http://nepis.epa.gov/Exe/ZyPDF.cgi/9100O6VD.PDF?Dockey=9100O6VD.PDF

The value of life may be updated and ICRP is updating its dose coefficients and other things, so why are they asking for comment now?

Section II.D of 10 CFR part 50, appendix I, concerns the use of cost- benefit ratios, to ensure facilities use radwaste treatment technology that can reduce the dose to the population within 50 miles of the reactor. The cost-benefit criteria are $1,000 per total body man-rem and $1,000 per man-thyroid-rem. The design objectives and cost benefit criteria may need to be revised to better align 10 CFR part 50, appendix I, with the recommendations of ICRP Publication 103. For example, the dose calculation methodologies in 10 CFR part 50, appendix I (based on ICRP Publication 2), result in a total body dose, while the dose calculation methodologies in ICRP Publication 103 result in an effective dose. Although both calculation methodologies result in an estimate of the dose to an individual, different assumptions are used in each calculation. As a result, the estimated doses to the individual will be different, but the differences are not expected to be significant with respect to radiological protection for members of the public. A more exact estimate of the differences in dose estimates between the two calculation methodologies will be available once all of the dose coefficients for ICRP Publication 103 are published, which is currently scheduled for 2015. A summary of the differences in the dose estimates between ICRP Publication 2 and ICRP Publication 103 methodologies is expected to be included in the regulatory basis document.”

Compare to future comment period in one month:
the revision to NUREG-1530 would revise the dollar per person-rem conversion factor to $5,100 per person-rem. The value is based on an updated VSL of $9.0 millionhttps://www.federalregister.gov/articles/2015/09/04/2015-22050/reassessment-of-nrcs-dollar-per-person-rem-conversion-factor-policy (Notice they reduced the conversion factor so they can pretend to value life-detriment at $9 million, when it is, in fact, at $ 5.1 million.)

Section II of 10 CFR part 50, appendix I, assigns design objectives for doses due to liquid and gaseous effluents. Under Section II.A of appendix I, the annual design objectives for liquid effluents from all pathways of exposure are 0.03 milliSievert (mSv) (3 millirem (mrem)) to the total body and 0.1 mSv (10 mrem) to any organ. Under Section II.B, the annual design objectives for noble gases in gaseous effluents are 0.1 milliGray (mGy) (10 millirad (mrad)) gamma-air dose and 0.2 mGy (20 mrad) beta-air dose, with provisions for increasing or decreasing the design objectives based on total body dose and skin dose. Under Section II.C of appendix I, the annual design objective for radioactive iodines and particulates in gaseous effluents is 0.15 mSv (15 mrem) to any organ. These design objectives are referenced to the total body and various organs of the human body in accordance with the 1959 recommendations of ICRP Publication 2
A more exact estimate of the differences in dose estimates between the two calculation methodologies will be available once all of the dose coefficients for ICRP Publication 103 are published, which is currently scheduled for 2015. A summary of the differences in the dose estimates between ICRP Publication 2 and ICRP Publication 103 methodologies is expected to be included in the regulatory basis document.

Additionally there can be short-term fatalities as far as 60 miles away from a nuclear accident! Who knew that!?
See: “Chernobyl on the Hudson“: http://www.ucsusa.org/sites/default/files/legacy/assets/documents/nuclear_power/indianpointhealthstudy.pdf

Climate risks by radioactive krypton-85 from nuclear fission Atmospheric-electrical and air-chemical effects of ionizing radiation in the atmospherehttp://www.opengrey.eu/item/display/10068/255704

Reassessment of NRC’s Dollar Per Person-Rem Conversion Factor Policy A Notice by the Nuclear Regulatory Commission on 09/04/2015 This document has a comment period that ends in 38 days (11/03/2015) SUBMIT A FORMAL COMMENThttps://www.federalregister.gov/articles/2015/09/04/2015-22050/reassessment-of-nrcs-dollar-per-person-rem-conversion-factor-policy