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US Nuclear Reactor Effluent Comment Deadline for 11.59 PM Eastern (DC-NY) Time, TONIGHT, October 1st: http://www.regulations.gov/#!docketDetail;D=NRC-2014-0044

Summary of some noteworthy points re tonight’s “Nuclear Effluents” comment deadline (A longer, better documented version, is here: https://miningawareness.wordpress.com/2015/09/30/us-nuclear-reactor-effluent-comment-deadline-11-59-pm-oct-1st-us-eastern-time-dc-ny-and-related-comment-deadlines-in-november/)

This comment period should be extended. The timing undermines its stated objective of bringing it into line with the ICRP: “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)

The stated objective of the comment period is: “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)

It is unfair to have the public comment prior to the publication of the above information. Furthermore, ICRP documents are most often unavailable to the general public, although an old version of dose coefficients may be found online for free. Even if available, the documents have a huge price-tag (e.g. $272.95 for ICRP 103 at Amazon). The US NRC must make them available for free. The documents are often available for free in non-English translations. Drafts are available for free, but this results in the draft often being followed, rather than the final document! Where possible, the US NRC should be following the US government funded, National Academy of Sciences, BEIR report, rather than the ICRP.

Acceptable risk-taking must include choice. The NRC-nuclear industry gives people no choice. For women, 1 mSv per year of radioactive effluents, over a lifetime, translates into a 1% cancer risk, if the radiation does not accumulate in the environment, which it does. Where is the choice? An NRC comment deadline which almost no one hears about doesn’t constitute choice. At the beginning of the AIDs epidemic, the US government sent an informational brochure, about the disease, to each and every mailbox in America. When did they ever send a notice about changes in US radiation-risk policies? The answer is never. The FDA, for instance, upped the “acceptable radiation” in food rate on the sneak to be 15 x the Japanese level.

Additionally, the NRC is about to update the value of human life, which also determines how much radiation must be filtered from effluents. Low value of human life means little filtration. High value means more filtration . “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

The $1,000 given per man (person) rem ($100 per mSv), found in the current comment docket, 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.

A $9.4 million value for human lives-detriment, used by the US Dept. of Transportation (https://en.wikipedia.org/wiki/Value_of_life), 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, life-shortening effects (14-15 years), etc. http://costprojections.cancer.gov/annual.costs.html

How this cost of averted exposure is actually applied remains unclear. If surrounding population numbers are taken into account, then nuclear reactors in rural areas would not be required to filter as much radiation as those in more heavily populated areas. There appears no value put on nature or on agricultural land, needed to grow food for an increasing global population.

These cancers, and other illnesses, induced by radioactive effluents from the nuclear industry, are part of the true cost of nuclear energy, which is externalized upon insurance companies (resulting in higher premiums); the taxpayer, when insurance no longer pays (and for the elderly and uninsured); and volunteer caregivers.

The nuclear utilities-industry keep the profits (benefits) for themselves, while they externalize the costs (risks) upon the rest of society, and upon the environment.

Previously discussed: Concentration “limits” are not an acceptable measure of radiation in air and water “effluents”. There needs to be a legally binding fixed amount of radioactive emissions to the environment by nuclear reactors (and other parts of the nuclear fuel chain) – preferably zero. If that is too costly then the reactors must be shut-down. 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 here: https://miningawareness.wordpress.com/2015/03/18/us-nrc-radioactive-dilute-and-deceive-scam-comment-deadline-march-24th/ (at bottom)

The US NRC term “design objectives” appears largely meaningless and not legally binding. There are “design objectives” for the emissions of actual quantities of radiation (as opposed to concentrations) under RM-50-2 from 1974. However, they appear non-binding and are limited in scope. For liquid effluents the annual “design objective” of 185 billion radioactive shots per second (becquerels), for each reactor unit, is notable for its exclusions (tritium and dissolved gases). The “design objectives” for air emissions is limited to the short-lived Iodine 131, which should be held in containment on site for several months until it is non-radioactive and not emitted at all. Instead, the “design objective” for I–131 in gaseous effluents is 37 billion radioactive shots (becquerels) per reactor unit per year. More can be dissolved in liquid effluents. Note that there may be multiple units at one site. They also only apply to reactor construction permit applications on or after January 2, 1971, and prior to June 4, 1976. (See p. 25240 Federal Register / Vol. 80, No. 85 / Monday, May 4, 2015 / Proposed Rules )

No distinction is made between types of radiation (alpha, beta, gamma) or longevity of radionuclides in the environment.

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. For 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. So, the apparently still unavailable, new ICRP dose coefficients are a very, very important for defining risk.

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, shots are generally counted in rounds per minute and not per second. The M134 machine gun has one of the highest rates of fire at up to 100 rounds per second. 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. For guns, 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 generations. Maybe there is a reprieve and maybe not.

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.

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 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.PDFClimate 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

Additionally there can be short-term fatalities as far as 60 miles away from a nuclear accident! See: “Chernobyl on the Hudson“: http://www.ucsusa.org/sites/default/files/legacy/assets/documents/nuclear_power/indianpointhealthstudy.pdf Impact considerations which only include the 50 mile radius are clearly inadequate, as Chernobyl itself showed, as it has contaminated so much of Europe. Animals in far away Norway and the UK remain highly contaminated due to the Chernobyl nuclear accident.

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? Clearly to side-step public imput.