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#Stop Holtec dumping of radioactive water, Boston, bureaucracy, cancer, Cape Cod, Cape Cod National Seashore, clean water, Clean Water Act, clean water standards, dangers of nuclear, draft authorization to discharge under the national pollutant discharge elimination discharge elimination system, dumping radioactive water into Cape Cod Bay, environment, filtration, fish, Holtec, Kris Singh, Massachusetts, National Park Service, National Pollutant Discharge Elimination System, NPDES, NRC, nuclear, nuclear accident, nuclear disaster, nuclear energy, nuclear industry, nuclear power, nuclear reactors, nuclear safety, PAG, Pilgrim Nuclear Power Station, public endangerment, public health, radioactive materials in water, radioactive waste, radiological emergency, risk management, Stop Holtec, tritium, underestimating risk, US EPA, US NRC, USA, water, water need
NPS photo of Highland Lighthouse at the Cape Cod National Seashore
This case provides a useful exercise in nuclear (radioactive) water rules and rule-making. It provides some tools which may help the reader challenge/out-wit Kris Singh-Holtec’s attempts to dump radioactive water into Cape Cod Bay, as well as elsewhere. It is a re-write of a related 2016 post on Pilgrim addressing Pilgrim’s NPDES-surface water discharge permit.
Currently, Holtec “is in the process of modifying its NPDES (National Pollutant Discharge Elimination System) and surface water discharge permit.” Holtec International “is still pursuing changing a discharge permit that would allow it to dump one million gallons of radioactive wastewater into Cape Cod Bay,” as recently reported: “Holtec Still Pursuing New Permit, Won’t Discharge Until Approved” January 25, 2023 https://www.capecod.com/newscenter/holtec-still-pursuing-new-permit-wont-discharge-until-approved/ See too: https://miningawareness.wordpress.com/2023/02/11/kris-singhs-holtec-apparently-still-hell-bent-on-dumping-radioactive-wastewater-into-cape-cod-bay-trying-to-modify-its-epa-discharge-permits/
The US EPA or Massachusetts DEP author(s) of the 2016 water discharge permit for Pilgrim nuclear power station, either didn’t know what the clean water rule says, or pretended not to. They pretended that the US EPA standard is 20,000 pCi (740 Bq) per liter for tritium. However, this is only true if it is the only [Beta-photon emitter] radionuclide present.
168 other Beta-photon emitters are supposed to be checked, as well as gross alpha, radium, and uranium, once pre-screening shows at least 50 pCi/L. Even tritium can be filtered. It’s just cheaper and easier to dump into waterways. Dilution prior to discharge has been actively encouraged by the US NRC. Dilution obviously doesn’t change the amount of radioactive material discharged into the environment. Dilution and limits on radioactive water tonnage discharged merely delays release of dangerous radionuclides into waterways. The only exception would be delaying release of short-lived radionuclides until they are no longer radioactive. One dirty trick, which has been used by workers in chemical facilities, and surely some in the nuclear industry, as well, is to allow the discharge to go downstream or disperse before testing.
Post based on excerpts from “Pilgrim Nuclear Power Station on Cape Cod: Water Permit-Water Rule Observations; Public Hearing” https://miningawareness.wordpress.com/2016/07/21/pilgrim-nuclear-power-station-on-cape-cod-water-permit-water-rule-observations-public-hearing-today/ Important related documents: https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=20001ZIN.txt https://www.epa.gov/dwreginfo/radionuclide-rule-compliance-help-public-water-systems
The EPA or Mass DEP author(s) of the 2016 water discharge permit either didn’t know what the clean water rule says, or pretended not to. They pretended that the EPA standard is 20,000 pCi (740 Bq) per liter for tritium. However, this is only true if it is the only [Beta-photon emitter] radionuclide present.
And, 168 other Beta-photon emitters are supposed to be checked, as well as gross alpha, radium, and uranium, once pre-screening shows at least 50 pCi/L (less than 2 Bq (1.85 Bq) of Beta emitters. (See chart further below for the list.)
20,000 pCi is certainly much greater than 50 pCi!
And other radionuclides have been found present in the soil, such as Cesium, so tritium isn’t alone – radionuclides occur together.
For those who missed it, nuclear power stations legally discharge lethal radionuclides into the environment, including waterways, on a routine basis. This information only became widespread knowledge post-Fukushima, when TEPCO announced that they had a permit to dump something like 70,000 tonnes per year of radioactive water at Fukushima (if memory serves correctly).
They are only required to dilute the radionuclides adequately before discharge, and there may be limits on tonnage of water discharged.
Dilution is put forth as a false solution. The NRC promotes diluting radioactive materials with water to discharge into waterways. However, the amount of radiation discharged doesn’t change without filtration, only the speed of discharge.
Dilution and limits on radioactive water tonnage discharged merely delays release of radionuclides. The only exception would be delaying release of (very) short-lived radionuclides until they are no longer radioactive.
Even tritium can be filtered out, it’s just cheaper and easier to dilute and dump. Tritium, with a half-life of 12 years, would have to be held back for over 120 years to no longer be radioactive: https://miningawareness.wordpress.com/2019/08/18/radioactive-activation-products-in-nuclear-power-stations-mean-that-delaying-dismantlement-is-safer-for-workers-and-the-public-pacific-nw-lab-report-for-the-us-nrc/ To claim that tritium can’t be filtered, merely gives the companies that want to dump an excuse to do so. It’s also not just tritium that will be dumped. As this blog pointed out in 2015, the price of filtering tritium appears to have come down enormously in the years since Drake (1996) cited $1,250 per liter as a figure. In 2014 the US DOE estimated 50 to 80 cents per liter. The US DOE gave energy costs of 12 to 50 cents per liter, and this is the major cost of filtration (due to pumping). https://miningawareness.wordpress.com/2015/04/13/recovery-of-tritium-from-tritiated-waste-water-cost-effectiveness-analysis/
The US EPA drinking water standard allows 20,000 pCi (740 Bq) per liter if and only if tritium is the only radionuclide. However, other radionuclides have been found onsite. Additionally, the US NRC has recently reported higher levels of tritium (4,530 pCi/L and historically much higher levels (69,000 pCi/L). 69,000 pCi/L is 2,553 Bq/L.
A Bq (becquerel) is one radioactive disintegration (shot) per second.
The State of Washington environmental agency clearly states:
“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 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://web.archive.org/web/20160104224137/http://www.ecy.wa.gov/programs/nwp/gwcontaminants.htm
Part of the National Seashore faces Cape Cod Bay: https://en.wikipedia.org/wiki/Cape_Cod_National_Seashore , as does Pilgrim Nuclear Power Station.
Pilgrim Nuclear Power Station showing outfall
Location exported from: https://en.wikipedia.org/wiki/Pilgrim_Nuclear_Generating_Station
Pilgrim Nuclear Power Station operated without a water permit for around 20 years.
The EPA or Massachusetts DEP author(s) of the 2016 water discharge permit either didn’t know what the clean water rule says, or pretended not to. They claimed that the EPA standard is 20,000 pCi (740 Bq) per liter for tritium. As already discussed, this is only true if it is the only [Beta-photon emitter] radionuclide present. And, 168 other Beta-photon emitters are supposed to be checked, as well as gross alpha, radium, and uranium, once pre-screening shows at least 50 pCi/L (less than 2 Bq (1.85 Bq) of Beta emitters. 20,000 pCi is obviously larger than 50 pCi!
And other radionuclides have been found present in the soil at Pilgrim, such as Cesium, so tritium isn’t alone- radionuclides occur together.
Nuclear reactors legally discharge lethal radionuclides into the environment, including waterways, on a routine basis. They are only required to dilute the radionuclides adequately before discharge. Dilution is even put forth as an obviously false solution by the so-called nuclear regulators.
According to the [2016] draft water discharge permit:
“Recent studies regarding groundwater onsite have indicated low levels of tritium ranging from 1,000-3,100 picocuries/liter (pCi/L). EPA’s drinking water standard for tritium is 20,000 pCi/L – the average annual amount assumed to produce a dose of 4 mrem/year.” (USEPA- Mass DEP, NPDES Permit No. MA0003557 “DRAFT AUTHORIZATION TO DISCHARGE UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM“)
The US EPA drinking water standard allows 20,000 pCi (740 Bq) per liter if and only if tritium is the only radionuclide. However, other radionuclides have been found onsite. Additionally, the US NRC has recently reported higher levels of tritium (4,530 pCi/L and historically much higher levels (69,000 pCi/L). 69,000 pCi/L is 2,553 Bq/L. A Bq is one radioactive disintegration (shot) per second.
According to the US EPA: “Radionuclides Rule: A Quick Reference Guide“:
“Beta/photon emitters* 4 mrem/yr, Gross alpha particle 15 pCi/L, Combined radium-226/228 5 pCi/L, Uranium 30 µg/L
*A total of 168 individual beta particle and photon emitters may be used to calculate compliance with the MCL…. Vulnerable CWSs” [Community Water Systems] “(2) must sample for: • Gross beta: quarterly samples. • Tritium and Strontium-90: annual samples… If gross beta particle activity minus the naturally occurring potassium-40 activity exceeds 50 pCi/L, the system must: • Speciate as required by the State. • Sample at the initial monitoring frequency.” http://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=30006644.txt
What if the State doesn’t require testing? Apparently if it’s not classified as vulnerable the Community Water Service escapes testing .
Note that this is the rule. It is separate from the so-called PAG recommendations to make people drink highly radioactive water subsequent to a nuclear accident.
Multiply by 0.037 to convert pCi to Becquerels (Bq).
Note that uranium is in micrograms per liter.
The maximum amount of Cesium 137 (Cs-137) allowed per liter of drinking water if there were no other radionuclides is 200 pCi/L (7.4 Bq/L – that is seven point four radioactive disintegrations per second.).
According to the “Pilgrim Nuclear Power Station (PNPS): Tritium in Groundwater Monitoring Wells“, Updates as of May 12, 2015, “Cesium-137 was detected in the vicinities of both catch basins (i.e. approximately 10-15 feet bgs) at concentrations ranging from non-detect to 2,400 pCi/kg” (CB-10) It appears that this is soil. If it were water then it would be roughly 2,400 pCi/L. In the same place (CB-10): “Tritium was detected in the soil proximate to CB-10 at concentrations ranging from non-detect to 175 pCi/kg”
See: http://www.mass.gov/eohhs/docs/dph/environmental/radiationcontrol/tritium/2015-updates/pnps-update-05-12-15.pdf
Click to access pnps-update-05-12-15.pdf
From the US NRC’s summary of Leaks and Spills At U.S. Commercial Nuclear Power Plants, December, 2015 “After a radioactive leak or spill, tritium is generally the first radionuclide to be identified in groundwater. This is because tritium travels through the soil faster than other radionuclides. Leaks and spills at some sites (e.g., Indian Point, Braidwood) involved nuclides other than tritium (e.g., Cobalt-60, Cobalt-58, Cesium-134, Cesium-137, Strontium-90, Nickel-63)” Historically Pilgrim has had as much as 69,000 pCi/L of tritium (December, 2013) and as of December 2015, 4,530 pCi/L of tritium, according to the US NRC: http://www.nrc.gov/docs/ML1532/ML15322A312.pdf
In his 2007 testimony regarding relicensing of Pilgrim, nuclear engineer Arnold Gundersen stated:
“17.4.3. The release of Tritium indicates a leak in a system that in the past was radioactive.
17.4.4. I believe such a leak means that testing should immediately be undertaken that searches for Cesium 134 and Cesium 137, Cobalt 60, and other gamma emitters as well as Strontium 90.” (“ENTERGY NUCLEAR GENERATION CO., LLC and ENTERGY NUCLEAR OPERATIONS, INC. (Pilgrim Nuclear Power Station), License Renewal Application, Dec. 2007” http://static1.squarespace.com/static/54aac5e4e4b0b6dc3e1f6866/t/56bb5a6dc2ea51c64311e706/1455118957188/Gundersen+Pilgrim+Declaration+12-07.pdf )
Non-anonymous public comment was allowed, due on July 25 2016, specifically for this Pilgrim Nuclear discharge draft. On the same day (25 July) anonymous comment was allowed on the Environmental Protection Agency (EPA) Notice: [Nonprotective Inaction ] “Guide for Drinking Water after a Radiological Incident” here: https://www.regulations.gov/docket?D=EPA-HQ-OAR-2007-0268
Some excerpts dealing with radioactive materials from the 300 plus page Pilgrim Water Discharge document:
“Due to detected levels of tritium in groundwater samples in the vicinity of Outfall 005, the permittee conducted an investigation to determine its source and concluded that water from the waste neutralizing sump that was being discharged through the storm drain at Outfall 005 was the likely source of this tritium. The permittee believes that the storm drain associated with Outfall 005 is not watertight and leaks water from the Outfall 011 discharges. In order to avoid groundwater contamination from this discharge through this storm drain, the permittee has rerouted the flow from the waste neutralizing sump only, directly to the discharge canal with a hose, thereby bypassing the storm drain associated with Outfall 005 (See Figure 4). Since this is a discrete outfall to the discharge canal, it has been designated in this permit as a new Outfall, #014. The other discharges from Outfall 011, including demineralized water, service water, and station heating water will not need to bypass the storm drain and will continue to be discharged through the storm drain at Outfall 005. (12/17/15 email from J. Egan to G. Papadopoulos)” The low level radioactive effluent associated with Outfalls 011 and 014 shall continue to meet all the Nuclear Regulatory Commission (NRC) requirements as specified in 10 C.F.R. Part 20“. [Apparently they mean that they are diluting it to a certain concentration.] “These limits are detailed in the PNPS Technical Specifications which define facility operational conditions. EPA and the NRC, in the past, have signed a Memorandum of Understanding (MOU) which specifies that EPA will be responsible for the water quality aspects of the discharge in concert with the State, and the NRC will be responsible for the levels of radioactivity in the discharge“. [Radioactivity in water has nothing to do with water quality?] “Thus, the draft permit addresses only the chemical aspects of water quality and does not regulate radioactive materials encompassed within the Atomic Energy Act’s definitions of source, byproduct, or special nuclear materials. See Train v. Colorado Public Interest Research Group, 426 U.S. 1, 25 (1976) (holding that “the ‘pollutants’ subject to regulation under the [CWA] do not include source, byproduct, and special nuclear material.”). All NRC radioactive discharge requirements will continue to be in effect, as required, in 10 C.F.R. Part 20 and plant technical specifications.” (p. 37)
[…]
“6.8.1 Radiological Wastewater (“radwaste”) Effluents
The discharge of radiological waste water (“Radwaste Effluents”) directly into the discharge canal occurs via a diffuser pipe submerged at the upstream (proximal) end of the canal, adjacent to the discharge structure. It consists of demineralized water contaminated with radioactive species [plant makeup water (contact cooling water)] which is normally recycled within the radwaste processing system. In the event of a discharge, it is sampled, analyzed and pumped to the diffuser pipe in the discharge canal. Radioactive materials that fall within the Atomic Energy Act’s definitions of source, byproduct, or special nuclear materials are not subject to regulation under the CWA. Train v. Colorado Public Interest Research Group, 426 U.S. 1, 25 (1976); see also 40 C.F.R. § 122.2 (defining “pollutant”). Thus, the NRC, not EPA, regulates this discharge, which typically occurs 1-2 times per year, usually during refueling outages.
6.8.2 Groundwater
Recent studies regarding groundwater onsite have indicated low levels of tritium ranging from 1,000-3,100 picocuries/liter (pCi/L). EPA’s drinking water standard for tritium is 20,000 pCi/L – the average annual amount assumed to produce a dose of 4 mrem/year. From 2007 to 2013, PNPS worked with the Massachusetts Department of Public Health (DPH) to resolve the issue, citing weekly phone calls and quarterly meetings to determine the source of contamination. The permittee has determined that the storm line draining to Outfall 005 likely is not watertight and is a source of ongoing contamination of the groundwater from the demineralizer waste associated with internal Outfall 011. See discussion for Outfalls 011 and 014 in Section 6.7 above for the remedy that the permittee is proposing to implement.” (pp. 44 -45)
Regarding testing – this is of Outfall 1 but gives an idea:
“All samples shall be representative of the effluent that is discharged through Outfall 001, taken at a location between the point of discharge from the condensers and the outfall channel discharge to Cape Cod Bay. This sampling point shall also include flows from Outfalls 004, 005, 010, 011, and 014 when discharging. A routine sampling program shall be developed in which samples are taken at the same location, same time and same days of the month. Any deviations from the routine sampling program shall be documented in correspondence appended to the applicable discharge monitoring report (DMR) submitted to EPA. In addition, all samples shall be analyzed using the analytical methods found in 40 Code of Federal Regulations (CFR) §136, or alternative methods approved by EPA in accordance with the procedures in 40 CFR §136. Any change in sampling location must be reviewed and approved in writing by EPA and MassDEP. 2. Sampling frequency of 1/week is defined as the sampling of one (1) discharge event during each calendar week, when discharge occurs. Sampling frequency of 1/month is defined as the sampling of one (1) discharge event during each calendar month, when discharge occurs. For those months when there are no discharges, the Permittee must report a No Data Indicator (NODI) Code (e.g., “C” for “No Discharge”) on the DMR. In Attachment E of NPDES Permit Program Instructions for the DMRs, a list of NODI codes are included at http://www.epa.gov/region1/enforcement/water/dmr.html. The results of sampling for any parameter above its required frequency must also be reported. 3. Continuous monitoring shall be defined as monitoring at a minimum of fifteen (15) minute intervals during discharge. The results shall be recorded with the time and date on a chart, and shall be made available upon request by EPA or MassDEP. If continuous monitoring equipment at the outfall is unavailable, a minimum of four (4) manual grab samples taken at least fifteen (15) minutes apart each day is acceptable in lieu of continuous monitoring data. The permittee shall provide an explanation of why continuous monitoring was not available and when continuous monitoring would be expected to be resumed. The flow rate may be estimated from pump capacity curves and operational hours. The daily maximum discharge temperature and delta T shall be the highest level recorded during the month.” (p. 4) https://www.epa.gov/sites/production/files/2016-05/documents/draftma0003557permit.pdf (Emphasis added)
Two Effluent Release Reports for Pilgrim:
Click to access ML12136A555.pdf
Click to access ML16148A702.pdf
About Drinking Water Compliance:
“The MCL for beta particle and photon radioactivity did not change in the revised rule from the current level of 4 millirem per year (mrem/year). A millirem is a dose of energy to the body. EPA regulates 179 man-made nuclides, and each of them has a concentration of radiation (measured in picoCuries per liter [pCi/L]) which produces the 4 millirem (mrem) dose. These concentrations are listed on a conversion table that the State will use to determine if you are in compliance.
Each nuclide has a different concentration that produces a 4 mrem dose because different radionuclides have different energy levels.
Some nuclides need to be in a higher concentration to give the same 4 mrem dose.
The laboratory will measure the nuclide concentration in the water, and the State will compare this result to the concentration allowed for that particular nuclide (see table on page 13). The comparison results in a fraction…
If your water contains several man-made radionuclides, the State will add all the fractions together…” https://web.archive.org/web/20151014190302/http://www2.epa.gov/sites/production/files/2015-06/documents/compliance-radionuclidesindw.pdf
Click to access compliance-radionuclidesindw.pdf
The State of Washington environmental agency makes this even more clear:
“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 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://web.archive.org/web/20160104224137/http://www.ecy.wa.gov/programs/nwp/gwcontaminants.htm
US EPA Normal Drinking Rules, NOT Proposed PAG Rule, which show how many radionuclides are supposed to be considered is found below. As seen above, they often pretend that there is only one, when giving the amount allowed. In the PAG recommendations for an emergency it is mentioned that “In situations where multiple radionuclides are present, DRLs should be combined using a sum of fractions approach to ensure that the projected dose does not exceed the PAG…” (p. 17) and yet they list only three! https://miningawareness.wordpress.com/2017/01/27/us-officially-allows-radiation-in-drinking-water-1000s-of-times-greater-than-clean-water-act-in-event-of-nuclear-accident-private-interim-nuclear-waste-storage-comment-deadline-today-11-59-pm-et-even/
Excerpts from:”Radionuclides in Drinking Water: A Small Entity Compliance Guide” https://web.archive.org/web/20151014190302/http://www2.epa.gov/sites/production/files/2015-06/documents/compliance-radionuclidesindw.pdf
https://www.epa.gov/dwreginfo/radionuclide-rule-compliance-help-public-water-systems https://web.archive.org/web/20151014190302/http://www2.epa.gov/sites/production/files/2015-06/documents/compliance-radionuclidesindw.pdf
“Comments due date 07/18/2016 Extension date 07/25/2016”https://www.epa.gov/aboutepa/public-notice-draft-permit-pilgrim-nuclear-power-station-plymouth-ma-ma0003557#file-285581
Archive of quick reference guide: http://web.archive.org/web/20160422014854/http://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=30006644.txt
Pilgrim Nuclear Power Station on Cape Cod: Water Permit-Water Rule Observations; Public Hearing
Mining Awareness + 
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