Deception by America’s Nuclear Regulatory Commission, about nuclear radionuclides

US NRC Radioactive Dilute and Deceive Scam – Comment Deadline June 22nd (Extended) Mining Awareness Plus, 18 Mar 15 US NRC Comment Deadline extended to 22 June 2015:https://www.federalregister.gov/articles/2014/11/20/2014-27519/radiation-protection http://www.regulations.gov/#!documentDetail;D=NRC-2009-0279-0098

The most strange and deadly scam, which the US NRC is running, is the dilute to deceive scam, where they actually tell the nuclear industry (and labs) that if they dilute the radionuclides with a certain amount of water (or air), then it is ok to put it into the rivers, ocean, air and even into regular sewerage drains! This is what they call “effluent concentration”. Even then the amounts allowed exceed amounts allowed under the EPA’s Clean Water Act, though it doesn’t really matter because what matters is how much radionuclide is actually emitted into the environment and how many months, years, decades, centuries, it’s going to stay there.

So, now it is easy to see that the following question by the NRC is meaningless BS. The actual amounts – not concentration – of the various radionuclides must be modelled. And, how long they stay in the environment:
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.

What the F(ukushima Daiichi) would age and gender averaged approach mean? Assuming they were speaking of actual amounts, then the amounts should be “appropriate” for the most fragile. If you are considering age and gender then the fragile must be considered – period. There is no average! Fragility varies according to disease. But, until they start modeling for actual emissions and actual half-life of the radionuclides, then it is meaningless. Half-life in the body is also meaningless because at some point the body will enter steady-state with the environment. And, actually the “appropriate” amount of exposure is none.

Here’s another crazy NRC question “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?

As noted above, effluent concentrations are a dilute to deceive scam. What matters is the amounts and not the concentration. 10 CFR part 20, appendix B, Table 2 should be modified to reflect actual amounts allowed and not concentrations. And, really, any short-lived radionuclides should be contained until they are no longer radioactive, and long-lived radionuclides should never be emitted at all.

It’s not clear where they are getting the 0.5 mSv from. On the NRC web site 1 mSv per year is mentioned. Is this right or wrong? The US EPA has a standard of 0.25 mSv for the body and 0.75 mSv for the thyroid. The ICRP 103 (2007) which they pretend to be coming up to speed with has a dose constraint of less than or equal to 0.1 mSv per year where “prolonged component from long-lived nuclides” (p. 116)

How many cancers will there be in a lifetime from the 1 mSv per year proposed by the US NRC? According to National Academy of Sciences BEIR report, it would be 1 (or more) per 100 people. The ICRP has it at about 0.55 which would round up to one. However, this is assuming that the 1 mSv per year is new, whereas the radionuclides will be building up in the environment and even in the body. If half of the 1mSv emitted were short lived, the next year there would still be 1 mSv emitted plus 0.5 mSv (half) already emitted. Some of the radionuclides (cesium and strontium) have half-lives of about 30 years; other radionuclides like plutonium-americium in the 100s or 1000s of years: “The half-life of plutonium-239 is 24,065 years. This half-life is short enough that 1 microgram of material will undergo more than 2000 decay events per second, but it is long enough to allow that microgram to decay at an approximately constant rate for thousands of years. If plutonium had uranium’s half-life of 4 billion years, there would be so few decays over the span of a human’s lifetime that the radiological toxicity of plutonium would be much less severe. [3] However, that is not the case… [3 Uranium is also much more soluble than plutonium and leaves the body rapidly.]” Los Alamos Science Number 26 2000, p. 78 (That’s straight from the heart of the beast – Los Alamos Nuclear Lab – hardly anti-nuclear!)

Plutonium 241 has a half life of 14 years, which is used to trick people since it becomes more dangerous 241 Americium with a half life of around 432 years.

Furthermore, BEIR is based on low-LET external, radiation. ICRP appears more appropriate for low-LET, as well. ICRP inappropriately lumps medical radiology and the nuclear industry together. BEIR is excluding more dangerous high-LET and internal radiation in their calculation. However, they recognize high LET such as alpha and neutrons as more dangerous. Most of the ICRP research would seem to be based on either external or very short-lived internal low LET radiation. While they are supposed to add weighting factors for high LET and amount of time spent in the body, it’s difficult to see if they can or will add enough weighting factors to thoroughly account for plutonium and americium, which even in a totally clean environment would stay in the body for a lifetime. It takes 20 to 50 years to excrete one half of them, in a clean environment. Furthermore, the US gov has at least one so-called expert who has messed up the formula, making more radiation safer and less more dangerous! Then he’s prancing around the world as an “expert”:https://miningawareness.wordpress.com/2014/07/31/nuclear-effective-dose-radiation-icrp-vs-us-epa/ (This topic is important for the March 24th deadline too.) To err is human, but there is no room for blunders with something so dangerous as radiation, especially not gross blunders………https://miningawareness.wordpress.com/2015/03/18/us-nrc-radioactive-dilute-and-deceive-scam-comment-deadline-march-24th/

 

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