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THE
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PERMISSIBLE RELEASES DO NOT MEAN SAFE Authority: Responsibility is shared between the US Nuclear Regulatory Commission (NRC) and Environmental Protection Agency (EPA). Under the Clean Air Act, states are allowed to issue air emission regulations that are more conservative, lower, than federal standards. Acquiescing to industry’s wishes, Massachusetts Department of Public Health has failed to act. Standards: Emission standards are based on calculations, not fact. The standard depends upon assumptions concerning what is released; how it is dispersed; and projected effects that they will have on the population. The outcome of any calculation is dependent on the quality of data that is entered into the calculation. Nuclear reactors fall under Environmental Protection Agency (EPA) and the Nuclear Regulatory Agency (NRC). Pertinent EPA standards apply to allowable doses from all processes that release radiation into the air for said area, not simply the nuclear reactor, and apply to drinking water. EPA’s allowable radioactive release dose into the air from all processes that release radiation is 25 mrem/yr; and into drinking water it is 4 mrem/yr. (regulation reference: 40 CFR 190). NRC dose limit: NRC’s 1OCFR 20.1301 limits the levels of radiation to unrestricted areas resulting from the possession or use of radioactive materials such that they limit any individual to a dose of less than or equal to 100 mrem per year to the total body. NRC dose objective/goal: In addition to this dose limit, the NRC, in 1OCFR 50 Appendix I, has established design objectives for nuclear plant licensees. The NRC design objective for the dose to a member of the general public from radioactive material in liquid effluents released to unrestricted areas to be limited to: less than or equal to 3 mrem per year to the total body; and, less than or equal to 10 mrem per year to any organ. The NRC’s design objective air dose due to release of noble gases in gaseous effluents is restricted to: less than or equal to 10 mrad per year for gamma radiation; and, less than or equal to 20 mrad per year for beta radiation. The dose to a member of the general public from iodine-131, tritium, and all particulate radionuclides with half-lives greater than 8 days in gaseous effluents is limited to: less than or equal to 15 mrem per year to any organ. Not easy to understand. A dose limit is just that – a limit. It is the maximum allowable release that can be enforced –like a speed limit on the highway. The dose objective or goal is like a wish. To continue with the automobile analogy, it would be like having speed goals on our highways instead of limits. To add to the confusion, some limits are given in millirads (mrad/yr) and some in millirems (mrem/yr). A RAD is the amount of radiation absorbed by exposed material and a REM measures the damage to a human from radiation. 1 RAD= 1 REM in measures of gamma and beta radiation; and1 RAD = 10-20 REM in measures of alpha radiation. Also different types of emissions are treated separately so that "allowable standards" of each seem low. Particles have one standard, gases another, liquids another, gamma radiation another, beta radiation another. In real life, you get a mixture; however, NRC assumes in making their standards that people living near a nuclear reactor will not be exposed to both the air and the water. They do not say how this can be possible; we don’t buy it. What does the limit 100 mrem/yr mean? What are the cancer risks?
The
Federal Government’s “permissible” maximum radiation dose for members of
the public exposed to Pilgrim is 100 mrem/yr for a 70-year lifetime.
According to the National Academy of Sciences 2005 Biological Effects of
Ionizing Radiation Report (BEIR VII) this translates to a risk of (1) in
(100) members of the public getting cancer and (1) in (175) getting a
fatal cancer dose, if so exposed.
2005 CANCER RISK ESTIMATES AT
PERMISSIBLE RELEASE DOSE (100 mSv)
On
average, assuming a sex and age distribution similar to that of the
entire U.S. population, the BEIR VII lifetime risk model predicts
approximately one individual in 100 persons would be expected to
develop cancer (solid cancer or leukemia) from a dose of 100 mSv.
Lower doses would produce proportionately lower risks. For example
one in 1000 would develop cancer from an exposure to 10 mSv.
TABLE 1: Baseline lifetime risk estimates of cancer incidence and mortality.
Table 1. The table shows the number of cancer cases and deaths expected to result in 100,000 persons (with an age distribution similar to that of the entire U.S. population) exposed to 100mSv. The estimates are accompanied by 95% subjective confidence intervals shown in the parentheses that reflect the most important uncertainty sources including statistical variation, uncertainty in adjusting risk for exposure at low doses and dose rates, and uncertainty in the method of transporting data from Japanese to a U.S. population. For comparison, the number of expected cases and deaths in the absence of exposure is listed. Source: BEIR VII: Health Risks from Exposure to Low Levels of Ionizing Radiation, Report in Brief, June 2005, page 2-3
Source: BEIR VII: Health Risks from Exposure to Low Levels of Ionizing Radiation, Report
in Brief, June 2005, page 490.
Comparison National Academy's BEIR VII Risk Estimates June 2005 to EPA's 1989 Standards; We now know exposure to radiation is many times more dangerous. Using the Risk Assessment for Boiling Water Reactors Based on the National Emission Standards for Hazardous Air Pollutants (NESHAPS) for September 1989, the lifetime fatal cancer risk for 10 mrem/yr lifetime exposure was (3) in (10,000) and the cancer incidence risk is 1.5 -2.0 times the mortality risk. We now know that exposure is many times more dangerous. Risk assessments performed by the EPA - 1989
Risk Assessment Methodology Environmental Impact Statement NESHAPS for Radionuclides Background Information Document-Volume 3 EPA/520/1-89-007
Note: Source: Paper prepared by Dr. Elizabeth Bourque, Massachusetts Department Public Health, August 16, 1991 – ____________________________________________________________________________________________European Committee on Radiation Risk proposes 1.0 mrem/yr. (Busby, Bertell, et al, European Committee on Radiation Risk, “Recommendations of the ECRR: The Health Effects of Ionizing Radiation Exposure at Low Doses for Radiation Protection Purposes,” 2003.) ALARA: The NRC attempts to soften the high health risks from its allowable release rate by stating that reactors are encouraged to release far less - “ALARA,” as low as reasonably achievable. However a standard or rule is one thing, it is enforceable; a goal is quite another thing – not enforceable. We have speed limits on our roadways, not speed goals. Therefore, the allowable limit is what counts. Compliance: Regulations also must embody compliance standards. However, Pilgrim is essentially responsible for gathering its own data and issuing its own reports. Emission reports by the industry to the NRC have been unreliable and, in many instances, ludicrous – nevertheless they have gone unchallenged by the NRC. For example in June 1982, Cesium 137 samples in cows milk in a nearby farm was attributed by the Health Physicist employed at Pilgrim today to the cow’s pregnancy. We know that cows ordinarily do not lactate during pregnancy and when pregnant they produce calves not Cesium 137.
For More Information, see Monitoring
Penalties Licensees are not penalized for releasing higher than allowable emissions for any given year by a requirement to shutdown for the remainder of that year and institute corrective actions prior to re-start.
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