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VOLUME 16, NUMBER 1
August 2009
AN IEER PUBLICATION
Radioactive Rivers and Rain: Routine Releases
of Tritiated Water From nuclear Power Plants
By annIe MakhIjanI and arjun MakhIjanI, ph.d.
nuclear power plants generate tritium in the
course of their operation and release it both to the atmosphere and to water bodies. tritium releases have also occurred as a result of malfunctions such as leaks (referred to by the nuclear regulatory Commission (nrC) as "unintended releases") from several nuclear power plants.1 one such example of leaks was at exelon's Braidwood plant in Il inois. (see Figure 1.) Many reactors have experienced leaks that have not been monitored.2 Further, releases of tritiated water vapor from the stacks of nuclear power plants can result in radioactive rainfal , which can contaminate surface water bodies as well as groundwater.3 the nrC does not require monitoring of rainfall or water bodies that may be contaminated by radioactive rainfall (unless the water is figure 1. Water contaminated with tritium (up to 1,000 picocuries per liter) was
otherwise required to be monitored).
found in ditches running along the west side of Center street, a public road northeast of the Braidwood nuclear power station, in March 2006. exelon workers are seen here vacuuming the tritiated water out of the ditches. (source: Illinois environmental As radioactive water, tritium can protection agency, Exelon Braidwood Nuclear Facility: Update on Tritium Releases and Groundwater Impacts, Fact sheet 2 (april 2006) at http://www.epa.state.il.us/ cross the placenta, posing some risk of birth defects and early Retiring Reference Man
pregnancy failures.
The Use of Reference Man
tritium, a radioactive form of hydrogen, is a gas in in Radiation Protection with
its elemental form. But, like ordinary hydrogen, tritium Recommendations for Change1
combines with oxygen to make water, cal ed tritiated water, with the crucial difference that tritiated water is By arjun MakhIjanI, ph.d., and LIsa LedWIdge radioactive. as radioactive water, tritium can cross the reference Man — a hypothetical adult White male placenta, posing some risk of birth defects and early — is currently the basis of many federal regulations and pregnancy failures. Ingestion of tritiated water also compliance guidelines, including workplace radiation increases cancer risk. In this article we will only discuss exposures, cleanup of radioactively contaminated sites, and tritium in the form of radioactive water.
some radionuclide limits in drinking water, notably alpha- this article describes the problem of routine tritium radiation-emitting transuranic radionuclides. the use of emissions, which in our opinion is underappreciated, reference Man is scientifical y inappropriate because the especial y because non-cancer fetal risks are not yet part of vast majority of people, including women and children, fall the regulatory framework for radionuclide contamination outside the definition: and because tritium releases constitute the largest routine Reference man is defined as being between 20-30 releases from nuclear power plants. years of age, weighing 70 kg [154 pounds], is 170 cm [5 feet, 7 inches] in height, and lives in a climate with an average temperature of from 10o to 20oC. He is a Caucasian and is a Western European or Atomic Puzzler—CO Series Wrap-Up .18 North American in habitat and custom. (International Commission on Radiological Protection, 1975)2 Answers to last Atomic Puzzler .18 plant operators and the nrC initial y dismissed public concerns about Science for Democratic Action leaks, saying that tritium levels measured offsite by the plant operators Science for Democratic Action is published by the were well below the epa drinking water standard of 20,000 picocuries Institute for energy and environmental research: per liter4 and were "safe"5 even though all radiation protection regulations 6935 Laurel avenue, suite 201 and the most recent report of the national academies (commonly takoma park, Md 20912, usa known as the BeIr vII report)6 concluded that the hypothesis that best phone: (301) 270-5500 fits the facts is that every exposure to radiation produces a corresponding FaX: (301) 270-3029 cancer risk – low exposures produce low risk, and that risk increases with e-mail: info[at]ieer.org exposure. there is no threshold below which there is zero risk. the epa's Web address: www.ieer.org method of expressing this reality is to set a Maximum Contaminant Level the Institute for energy and environmental research goal (MCLg) which corresponds to zero health risk. the epa value for (Ieer) provides the public and policy-makers with MCLg for all radionuclides, including tritium, is zero.7 thoughtful, clear, and sound scientific and technical studies on a wide range of issues. Ieer's aim is to The problem of routine tritium emissions is, in our bring scientific excellence to public policy issues to promote the democratization of science and a opinion, underappreciated, especial y because non- cancer fetal risks are not yet part of the regulatory president: arjun Makhijani, ph.d.
framework for radionuclide contamination and Librarian: Lois Chalmers senior science Fellow: hugh haskell, ph.d.
because tritium releases constitute the largest Bookkeeper: diana kohn outreach director, united states: routine releases from nuclear power plants.
project scientist: annie Makhijani outreach Coordinator: jennifer nordstrom Further, tritium releases general y constitute the largest routine administrative assistant: releases from nuclear power plants and as such have caused widespread Betsy thurlow-shields contamination of water bodies at low-levels. It is this widespread nature senior scientist: Brice smith, ph.d. (summer only) of tritium pol ution combined with the fact that it affects water bodies and is, in fact, radioactive water that had led the ontario drinking Water Thank You to Our Supporters advisory Council, in a report commissioned by the ontario Minister We gratefully acknowledge our funders whose of the environment, to recommend a very substantial tightening of the generous support makes possible our project to ontario drinking Water Quality standard for tritium to 20 becquerels per provide technical assistance to grassroots groups working on nuclear weapons-related environmental liter (540 picocuries per liter) from the current 7,000 becquerels per liter.8 and security issues, our global outreach work, and We covered the issue of the various risks of tritium earlier, in our our efforts to promote sound energy policy.
Science for the Vulnerable report and in a Science for Democratic Action Colombe Foundation article.9 In this article we document the routine releases of tritiated water educational Foundation of america to the environment from nuclear power plants. a sampling of the data is published in this issue and a more extensive dataset will be published separately on our Website (at http://www.ieer.org/sdafiles/16-1/tritium_ Lintilhac Foundation releases.html). We chose recent years to present the data for effluent Livingry Foundation releases (gaseous and liquid) and environmental measurements in water. stewart r. Mott Charitable trust releases vary from year to year. Interested parties are encouraged to new-Land Foundation ploughshares Fund examine annual environmental reports to ascertain trends.
town Creek Foundation Wallace global Fund Tritium production and releases from
thanks also to the sda readers who have become pressurized and boiling water reactors
donors to Ieer. your support is deeply appreciated. the quantity of tritium released to the air and to water depends Credits for this Issue on the type of reactor; however, it also varies a great deal even among printing: ecoprint reactors of the same general design.
editor: Lois Chalmers In pressurized water reactors (pWrs) most of the tritium that is Science for Democratic Action released to the environment is produced by the interaction of neutrons is free to all readers.
with boron and lithium. the boron is added to the primary cooling water We invite the reprinting, with proper credit, of to control the rate of the nuclear reactions in the fuel and the lithium materials from this newsletter. We also appreciate is added to control corrosion.10 this is not an issue with boiling water receiving copies of publications in which articles reactors (BWrs), in which neither boron nor lithium is added to the have been reproduced.
primary water.11 primary cooling water is the water that removes the heat generated by fission reactions in the fuel present in the reactor vessel. Corrections, revisions, and clarifications to Ieer's BWrs have a secondary cooling loop, where the steam generated from printed materials, including Science for Democratic Action, can be found at http://www.ieer.org/errata.html the primary water is condensed. In pWrs, the water in the whole year, are released to the environment, of which the primary does not boil. the high pressure primary 85 percent are waterborne effluents (663 curies) and water is used to boil water in a secondary loop in a device the rest are airborne effluents (107 curies).16 the liquid cal ed a steam generator. the primary water transfers its effluents are discharged in batches in lakes, rivers, and heat to water that is converted to steam, which drives the oceans, often through underground pipes. Leaks can occur turbine, which in turn drives the electricity generator. the in such pipes and when they do, they contaminate the soil condensing loop, where the steam is condensed back to and groundwater.
water, is the tertiary cooling loop. (see Figure 2.) routine In boiling water reactors (BWrs) boron is not added to tritium discharges and emissions are mainly associated with the water and therefore tritium is not produced in boron- the primary water of the reactor.
neutron reactions in the primary water. the tritium in BWrs is mainly produced as a result of ternary fission in reactors. the peterson and Baker study estimated that 120 curies per 1,000 MWe are released per year to the environment, of which 75 percent is in gaseous form and the rest in liquid form.17 Leaks can also occur from BWrs that have pipes carrying primary water that are buried underground. at some plants tritium has leaked out of the cooling pool in which spent fuel is put after being unloaded from the reactor.18 Monitoring of tritium
figure 2. pressurized water reactor diagram. For the animated version, go to
http://www.nrc.gov/reading-rm/basic-ref/students/animated-pwr.html.
the nrC requires power plant operators Source: u.s. nuclear regulatory Commission to monitor releases of radionuclides on site tritium is also produced, in greater quantities, in the and off site. the onsite and offsite releases from a plant fuel rods of both pWrs and BWrs from ternary fission12 are reported every year in the effluent report and the (fission in which there are three fission fragments). only environmental report respectively. a tiny fraction of this leaks into the primary cooling water In the effluent report the plant operator is required along with some other fission products through very small to give quarterly data on the amount of tritium curies cracks and holes that form in a small number of the fuel released from each reactor,19 including the concentration rods.13 the pWr's cooling water is constantly taken out of tritium before the water is sent to the underground for chemical treatment, volume control, and to reduce the pipe,20 the frequency at which the releases occur, and how radioactivity. then most of it is sent back into the reactor long the releases last.21 table 1 gives the annual releases vessel. the chemical treatment is mainly to reduce the from a selected number of plants for the year 2005. amount of boron as the reactivity in the fuel decreases (the exhaustive list can be found on Ieer's website at with time.14 some of the fission products that leak into the primary water of the reactor are removed by passing the however, the reporting is not consistent for plants that water through ion exchange resins; however, this does not have more than one reactor. For example, for plants with affect tritiated water which, being chemical y identical to two reactors, three ways of reporting are found: water, just passes right through.15 the part of the cooling – each reactor has a different amount of curies (e.g., water which is not returned to the reactor vessel is put in Mil stone 2 and 3) holding tanks. It is periodical y released to the environment – each reactor has the same amount of curies (e.g., after further treatment and dilution to bring the tritium Braidwood 1 and 2) concentration to a level deemed "safe" by the nuclear industry and the nrC. Fresh water is mixed in with the – there is only a total amount of curies (e.g., Calvert balance of the primary water to make up for the water that is withdrawn into the holding tanks.
the second and third methods of reporting indicate that discharges from each reactor may not be measured; EPA's Maximum Contaminant Level rather only the total discharges from both reactors may be measured. this may make it difficult to detect problems Goal for all radionuclides, including or to infer their existence from the reported data. Further, the amount of tritium discharged from pWrs tritium, is zero.
is highly variable. hence the peterson and Baker study should be regarded only as a rough guideline rather than a 1985 study by peterson and Baker estimated that an indication of actual releases from particular reactors. about 780 curies of tritium per 1,000 megawatt electric (MWe) from a pWr, operating at 82 percent capacity for Table 1: 2005 annual liquid releases of tritium from selected pressurized
water nuclear reactors
Braidwood 1 & 2
electrical output (MWe) releases 1 & 2 (curies)
curies per 1,000 mWe
fort calhoun
electrical output (MWe) omaha public power district curies per 1,000 mWe
millstone 2 & 3
electrical output (MWe) dominion nuclear Connecticut, Inc.
dominion nuclear Connecticut, Inc.
releases 2 & 3 (curies)
curies per 1,000 mWe
calvert cliffs 1 & 2
electrical output (MWe) CCnppI - subsidiary of CCnppI - subsidiary of Constel ation energy group Constel ation energy group releases 1 & 2 combined
curies per 1,000 mWe
sources: Individual reactor fact sheets and the 2005 effluent reports for each plant. see links at http://www.nrc.gov/info-finder/reactor/ and at
http://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-info.html.
For example, the number of curies per 1,000 megawatt (20,000 picocuries per liter) is used as a reference, but it is electric (MWe) reported in the 2005 liquid effluents quite unsatisfactory if the California public health goal (400 reports range from a low of 297 curies at the Fort picocuries per liter) is the reference value. evidently, for a Calhoun reactor to a high of 1,518 curies at the Mil stone 3 reliable conclusion that the level is below 400 picocuries reactor. hence, the range is from more than about a factor per liter, the LLd required should be consistently lower or two lower than the peterson and Baker liquid release than that. the California public health goal is a recent estimate to more than a factor of two higher.22 development and the nrC LLd has not caught up with it. actual measurement practices at nuclear power plants vary quite a lot. the Offsite Dose Calculation Manual Guidance reports (nureg-1301 for pWrs and nureg-1302 for BWrs) direct the plant operator to the environmental reports give the concentrations have a lower limit of detection (LLd) of 2,000 picocuries of tritium in picocuries per liter for drinking, surface, per liter that can be increased to 3,000 picocuries per and groundwater/wel -water at different locations in liter if no drinking water pathway exists.27 Most plant the proximity of the plant. unfortunately, the points of operators have lower LLds (in the few hundreds of measurement are not comparable and so the inferences picocuries); however these lower limits are not required. regarding the relationship of the measurements to as a result, some power plant operators simply report potential public exposure are rather difficult to make.
that tritium levels are below the lower limit of detection. some natural background tritium in surface and In some cases, even the LLd values are not specified. We groundwater arises from the interaction of cosmic recommend that the nrC tighten its tritium LLd to 200 radiation with the atmosphere. however, these levels picocuries per liter or less and require the specification of are very low – typical y 5 to 25 picocuries per liter in surface water and less than 6.4 to 12.8 picocuries per table 2 gives the concentrations of tritium, for the year liter in groundwater.23 Large amounts were added in the 2006, from selected plants that have levels higher than 400 atmosphere and global waters due to atmospheric testing picocuries per liter. of nuclear weapons. the vast majority of atmospheric Further, we note that tritium measurements are done testing had stopped by 1963, though some scattered quarterly, with composite samples that are col ected at tests by France and China continued after that. the last various intervals, commonly monthly.28 this means that atmospheric test was by China in 1980. since the half-life samples from the times tritium is discharged (many times of tritium is 12.3 years, most of the additions due to testing each quarter) and the times that it is not, are put together have decayed away. however, just radioactive decay would and averaged to give a quarterly result. there are two still leave testing tritium at a level higher than natural main problems with this approach. there is general y background. In practice, the concentration of tritium in no independent verification by the nrC of when the fresh water due to testing fal out is much lower than that samples are actual y taken. the nrC (and hence the implied by radioactive decay alone due to the very large public) depends on the reactor operators' word that they dilution by ocean water.24 tritium levels in water bodies are taken at the time of contaminated water discharge near nuclear power plants are often much higher than the and not just before or well after, for instance. as a result, background level, which is defined as the combination of there is no verification of the representativeness of the natural and testing related tritium.25 samples and hence of the accuracy of the data in providing the concentrations of tritium in drinking water near estimates of total tritium releases. While there may be all the power plants are well under 20,000 picocuries nrC inspections on occasion, there is no coherent body per liter, the epa standard for tritium in drinking water. of verification data that would enable the public to have however, there are examples where the levels in some confidence that nuclear power plant operators are drinking water are above 400 picocuries per liter, which col ecting and reporting accurate and representative data. is the California recommended public health goal26 and since tritium discharges are sometimes made into water also above 540 picocuries per liter, which ontario is bodies that are used for drinking downstream of the considering as its drinking water standard. Most of the reactor (as is the case with the Braidwood plant),29 this measurements reported in the environmental reports lack of independent verification of discharges is troubling, are not for drinking water. the levels reported in table 2 especial y in the context of batch sampling. are used for reference and comparison purposes in this If the samples are not coordinated with plant article. however, we note that there are several examples discharges occurring over a period of time and are not of drinking water that are above the recommended public ful y representative of the discharges, the estimates of health goal set by California, which Ieer recommends be total tritium discharges made using the results could be adopted throughout the country as a goal as wel . It is inaccurate. there is at present no independent way for based on risk estimates that guide superfund cleanup.
communities and the public to verify what is occurring in the first point to make regarding the reported terms of discharges measurements and reporting of the measurements is that the nrC requirement for a same. this has become more important in light of the minimum detection limit, also cal ed the Lower Limit of controversies surrounding the failure to report known detection (LLd), is 2,000 to 3,000 picocuries per liter. tritium leaks at the Braidwood plant for an extended this is satisfactory if the epa drinking water standard Table 2: Tritium concentrations in drinking and surface/lake/river water
near selected pressurized water reactor plants in 2006
data shown for the sample locations with the highest annual mean.*
distance from plant, in miles, and
(picocuries
(picocuries
per liter)
per liter)
7.30 (indicator)** rock hill Water supply Catawba 1 & 2 (sC)1 13.5 (control) Belmont Water supply Comanche peak 1 & 2 9.9 Lake granbury Mcguire 1 & 2 (nC) north Mecklenburg Water treatment Facility oconee 1, 2, & 3 (sC)3 18.9 anderson water plant 518-935Water near intake of 76 purrysburg (sC) Water treatment plant vogtle 1 & 2 (ga) (downstream from both vogtle and savannah river site (part of weapons complex)) Finished water at treatment plant 24 public water sampling location 0.45 (indicator)** discharge Canal Catawba 1 & 2 (sC) 4.21 (control) Lake Wylie 1.4 ese (indicator)** Comanche peak 1 & 2 (tX) 1.5 n (indicator) squaw Creek reservoir shearon harris 1 (nC) 0.45 (indicator) discharge Canal Bridge Mcguire 1 & 2 (nC) 11.9 (control) plant Marshall Intake Canal 3.37 Waste heat treatment Facility Lagoon north anna 1 & 2 (va) 5.80 north anna river oconee 1, 2, & 3 (sC) 0.79 Lake hartwel point Beach 1 & 2 (WI) 4.0 Lake Michigan h.B. robinson 2 (sC) three Mile Island 1 (pa) 0.5 susquehanna river vogtle 1 & 2 (ga) 0.80 savannah river6 9.9 tennessee river Wolf Creek 1 (ks) 3.2 Coffey County Lake sources by plant: Annual Radiological Environmental Operating Reports (er) for 2006 (except for point Beach, where the source is the 2006
Annual Monitoring Report.). Links at http://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-info.html. Page citations can be
obtained from ieer.
table 2 notes
period of time. Further, it should also be noted Braidwood routine tritium discharges are diluted and discharged * the lower limit of detection in many of these into the kankakee river,30 which is an important water measurements is stated to be larger than the measurement, resource in the region.31 making the figures that are less than 2,000 or 3,000 picocuries per liter difficult to interpret in such cases. We have quoted the figures here since, in almost all cases, they are published without a "less than" or "<" note and are as noted above, tritiated water vapor is also discharged presented to more than one significant figure from nuclear power plant stacks. this occurs in both BWrs and pWrs. these discharges are also highly ** "Indicator" sampling locations are chosen because any contamination is expected to be highest at that point. the reported 2004 gaseous discharges of tritium from "Control" locations are expected to not be contaminated pWrs ranged from 0 to 972 curies. the latter number is by the plant (upstream if on a river), so are expected to reflect background levels of contamination, unless there is a for palo verde 3 and is nine times higher than the value different source of contamination upstream of the control of 107 curies estimated by peterson and Baker (cited location, for example, another nuclear power plant. above) as a typical reference value. the discharges from BWrs range from 0 to 281 curies.32 again, the highest the Catawba 2006 environmental operating report, value is about nine times higher than the reference section 3.2, says that some of the contamination comes value of 30 curies estimated by peterson and Baker. a from the Mcguire plant situated 40 miles upstream. this could explain the high tritium level at the indicator location table summarizing the 2004 gaseous releases from all although this is not borne out by the tritium levels found u.s. reactors will be available at http://www.ieer.org/ at the Mcguire plant. the report also says "Indicator and control locations were established for comparison purposes to distinguish radioactivity of station origin from natural or Tritiated water vapor is also discharged other ‘manmade' environmental radioactivity." 2 the Comanche peak 2006 environmental operating from nuclear power plant stacks. This report, section e, says that this location "was used as a occurs in both BWRs and PWRs. These surface drinking water location based on the proximity of the City of granbury intake to the granbury potable water discharges are also highly variable.
3 the oconee 2006 environmental operating report lists rainfall episodes that occur during gaseous discharge other drinking water sampling sites, both closer to the plant, events result in the rainfall becoming contaminated with but no measurements seem to have been taken at the tritium. such contamination could reach high levels under closer locations. certain weather and tritium release conditions. 4 range for the fourth quarter 2006.
data for rainfall near reactors are not part of the environmental reports filed by nuclear power plant For the month of september 2006. high number operators. Ieer has corresponded with the nrC about attributed to discharge from kewaunee power station, approximately another 4 miles north of the sampling site.
monitoring rainwater. our best understanding is that the nrC does not require rainwater monitoring nor 6 station 83 is located on the right bank (west side) of the monitoring of groundwater and surface water that savannah river, directly across from doe's savannah river may be affected by contaminated rainfall events. Ieer's correspondence with the nrC about this is reproduced 7 only one value reported.
at the end of this article. We infer that the nrC does not believe that separate pathway monitoring is necessary since the dose limits are below those required. however, this is flawed logic. If private groundwater sources and rainfall are not monitored, how can the nrC know that dose limits are not being exceeded, especial y since high contamination events can occur and, under present dispensation, escape detection.
the possibility of contamination by rainfall was raised in a presentation made by ken sejkora, of entergy nuclear northeast – pilgrim station, who has stated that "Localized washout can result in very high concentrations, possibly even exceeding drinking water standards."33 the potential that rainwater could be contaminated significantly is an important issue for several reasons. For one thing, the epa only limits contamination of public drinking water systems. private wel s and small public water systems (general y meaning less than 15 connections and fewer than 25 people served) are not least some cases, and the fact that tritiated water crosses protected. private wel s and small public water systems the placenta and behaves just like ordinary water in the are not protected by epa drinking water regulations. this living world but for its radioactivity leads us to call for an is because it could be economical y onerous to require overhaul of the system for monitoring and reporting of individuals and small water systems to conform with epa both routine and non-routine tritium releases. another standards in cases where remediation was required. reason for such an overhaul is that tritium contamination however, this does not make the people involved less from nuclear power plants affects many water bodies vulnerable. Indeed, it leaves them more vulnerable if there and, hence, large numbers of people at low doses. this is no means for them to find out if their water supplies are is the reason that a far tighter tritium standard is being at risk of contamination. Information about contamination proposed in ontario, Canada. Final y, in the united states, in cases where there is a risk of it, as for instance, near there is also tritium contamination from nuclear weapons nuclear power and nuclear weapons plants, is even more plants. some places, such as those downstream of both important in such cases.
the vogtle nuclear power reactors and the savannah river site, a nuclear weapons plant, are affected by both.
In its "lessons learned" document relating to tritium the first principle that needs to be enforced is the leaks, the nrC acknowledges that gaseous tritium releases nrC's rule that exposures of the public should be kept "as from nuclear power plants can contaminate groundwater: low as reasonably achievable." We are not convinced that gaseous migration of tritium can be linked to tritium discharges to public water bodies are necessary atmospheric deposition of condensated tritiated at all or, if so, that they are necessary to the extent that water or condensation of subsurface water vapor actual y occurs. Indeed, it appears possible with existing containing tritium, as noted in Iaea and u.s. technology and moderate cost to eliminate or reduce geological survey research studies.34 routine liquid discharges significantly. primary water can be reused more and the part that is not reused can be stored Private wel s and small public water systems are in tanks, as was done for a period at Braidwood after the revelations of leaks in 2005. the waste water can be not protected by EPA drinking water regulations.
grouted and the grout can be stored as low-level waste.36 We understand that the nrC itself is in the process of reviewing its procedures regarding early detection of leaks In fact, the nrC has itself documented tritiated and reporting them to the public as a result of the scandals rainwater fal ing onto the site of the palo verde nuclear surrounding tritium leak disclosures.
plant.35 yet, it contented itself with the observation that Ieer's recommendations around tritium cover a "no elevated levels have been found in wel s located outside the protected area" of the palo verde reactors. • The NRC should conduct a thorough review of routine however, it does not note that the nrC does not require tritium discharges to the water from pWrs over the monitoring of rainwater or of private wel s, though it may last two decades and analyze the reasons for the sometimes be carried out.
differences in discharges. the same should be done for atmospheric releases from all nuclear power reactors. the aim should be to pinpoint operational practices these recommendations relate to routine releases of and design changes (in new reactors) that would greatly tritium and the contamination of air and water that they reduce them.
cause. the nrC's "lessons learned" document about • NRC should itself monitor each discharge of primary tritium leaks contains a number of recommendations, coolant water and ensure that water authorities which relate mainly to developing new guidance and downstream are informed. the monitoring and record conducting dialogs and looking into modernizing rules and keeping should include inspection of the discharges guidelines. there is no actual hard fol owup in terms of at the time they are made. the nrC should ensure actual leak prevention, tightening monitoring requirements, that samples are taken so as to be representative of or other tightening of standards that fol ow this 2006 the discharges. split samples should be preserved "lessons learned" report. Ieer will make a separate and appropriate detailed entries should be made in assessment of the problem of leaks and issues associated logbooks independently maintained by the nrC onsite with it in the future.
inspectors. randomly selected examples of these the main problems of routine discharges of split samples should be subjected to independent radioactivity to the water occur as a result of periodic discharges of the reactor's primary cooling water to water bodies and of tritiated water vapor to the atmosphere, • The NRC should develop a policy of keeping creating radioactive rainfall when the release and rainfall tritium releases as low as reasonably achievable as a occur at the same time.
supplement to its dose guidelines. the upper limit for the high variability in tritium discharges from pWrs, environmental concentrations should be tightened to the many leaks, the failure of some nuclear plant operators no more than 400 picocuries per liter on an annual to disclose the leaks to the public in a timely manner, in at average basis.
• The NRC should put into place requirements for plant reports on our web page. http://www.nrc.gov/reactors/ monitoring and hardware that would greatly reduce the risk of leaks and facilitate early detection. public document room will be able to assist you in • Nuclear plant licensees should be required to monitor locating older reports not included in the reIrs database.
onsite groundwater and disclose those results.
• Nuclear plant licensees should be required to monitor We would also like to know if there is an explanation rainwater and offsite groundwater in a manner designed for the large range of releases and what the nrC has done to detect rainwater and groundwater contamination. to encourage nuclear power plant operators to minimize the results should be reported to the nrC by licensees atmospheric tritium releases.
as part of their annual environmental reporting.
• There should be significant penalties for failure to NRC Answer:
disclose offsite migration of radionuclides due to leaks each plant must minimize its radioactive effluents in and accidents or contamination of offsite rainwater, accordance with its license, with 10 CFr 50, appendix groundwater, or drinking water above 400 picocuries I and with the "as Low as reasonably achievable" (aLara) philosophy. nrC inspectors periodical y • The lower limit of detection should be lowered to 200 monitor the radioactive effluent release programs and picocuries per liter.
the environmental programs. this includes the licensee's procedures to limit their effluent releases to aLara, the • The NRC should require licensees to make public al calibrations of monitoring equipment, observing actual health and environmental documents, including all raw releases to verify compliance with regulations, and a measurement data and times of discharges.
review of the results reported in the annual effluent and Measuring Tritium in
the annual differences in release quantities of Precipitation: NRC's staff
radioactive materials from nuclear plants occur as a result response to IEER Questions
of different waste processing equipment and methods as well as in the timing of plant operations. For example, An e-mail regarding gaseous tritium releases, from Scott during a reactor shutdown for maintenance and refueling, Burnel , NRC public affairs officer, sent on September 18, larger quantities may be released than during plant 2008, to Annie Makhijani, included an attached response, which is reproduced below: Is the nrC monitoring rainfal , surface water, and 1. Plant Sites with Groundwater Contamination at http://www.nrc.gov/reac- groundwater onsite and offsite? If there is monitoring in place at or near any commercial nuclear power plant, we 2. For instance, there were leaks at exelon's Braidwood plant in Illinois. nrC 2006 (u.s. nuclear regulatory Commission, Liquid Radiation would like to obtain the data that has been col ected over Release Lessons Learned Task Force Final Report, ML062650312, the past decade. Washington, dC: nrC, september 1, 2006, link at http://www.nrc.gov/ reactors/operating/ops-experience/tritium/nrc-actions.html) pp. 12-13. NRC Answer:
these leaks triggered widespread concerns among people who live near the plant about their safety and health. nuclear power plants are licensed to release radioactive 3. sejkora 2006 (ken sejkora, Atmospheric Sources of Tritium and Potential effluents in strict accordance with their license's safety Implications to Surface and Groundwater Monitoring Efforts, presented at provisions and restrictions. essential y, the restrictions are the 16th annual rets-reMp Workshop, Mashantucket, Ct, 26-28 june based on both dose limitations and on radioactive release 2006, link at http://hps.ne.uiuc.edu/rets-remp/presentations2006.htm) 4. Code of Federal Regulations, 40 CFr 141.66 2007 nrC requires that licensees perform radioactivity 5. Online NewsHour, "radioactive Leaks in Illinois," april 17, 2006, at http:// monitoring both in the radioactive effluent prior to its and exelon Corporation, "Moustis Call for plant shutdown ‘uninformed,' release and in the environment, including samples of water exelon nuclear says," news releases, april 10, 2006, at http://www.ex- sources, vegetation, fish and milk, after releases have been performed. Licensees must then report their monitoring results in both the annual radioactive effluent report and 6. national research Council, Board on radiation effects research, Health Risks from Exposure to Low Levels of Ionizing Radiation: BEIR VII Phase 2. in the annual radiological monitoring report. these reports the national academies press, Washington, dC, 2006 are publical y available in the agency Wide documents 7. Code of Federal Regulations, 40 CFr 141.55 2007 access and Management system (adaMs). http://www.
8. ontario drinking Water advisory Council, Report and Advice on the Ontario Drinking Water Quality Standard for Tritium, odWaC, toronto, prior to 2005, several years of data was also made May 21, 2009, at http://www.odwac.gov.on.ca/reports/052109_ available to the public at the reIrs hyperlink you listed in odWaC_tritium_report.pdf. Candu heavy water reactors generate more tritium than u.s. light water reactors.
your letter. however, since 2005, in order to make recent 9. arjun Makhijani, Brice smith, and Michael C. thorne, Science for the data even more accessible to the public, nrC is now Vulnerable: Setting Radiation and Multiple Exposure Environmental providing a direct link to the effluent and environmental Health Standards to Protect Those Most at Risk, Institute for energy and environmental research, takoma park, Maryland, october 19, 30. exelon nuclear, Braidwood Generating Station Groundwater Fact Sheet, 2006, at http://www.ieer.org/campaign/report.pdf and arjun Makhijani, exelon, Braidwood, IL, november 28, 2006, at http://www.exeloncorp.
Brice smith, and Michael C. thorne, "health risks of tritium: the Case for strengthened standards," Science for Democratic Action v.4, no.4 (February 2007) pp. 1, 10-12, at http://www.ieer.org/sdafiles/14-4.pdf 31. Will County, Illinois, resolution #09-71, in public health & safety 10. glasstone and sesonske 1981 (samuel glasstone and alexander Committee resolutions, at http://www.willcountyboard.com/Board%20 sesonske, Nuclear Reactor Engineering, 3rd ed., van nostrand reinhold, new york, 1981), para 9.97 32. nrC database (u.s. nuclear regulatory Commission, effluent 11. glasstone and sesonske 1981, para 9.119 database for nuclear power plants, nrC, Washington, dC, at http:// 12. national Council on radiation protection and Measurements, Tritium in the Environment, recommendations of the national Council on radiation protection and Measurements, nCrp report no.62, nCrp, 33. sejkora 2006, slide 22. sejkora claims that testing fallout should result Bethesda, Md, March 9, 1979 (reprinted january 15, 1995), p. 1 in a residual tritium concentration in rainwater of 100 to 300 pCi/liter (slides 6 and 21). however, he did not take the dilution effect of the 13. glasstone and sesonske 1981, para 9.96 oceans into account. actual data are presented in tuttle 1992. they 14. glasstone and sesonske 1981, paras 9.104 and 5.202 show that testing-related tritium had declined to less than low-end of natural background level of 5 pCi/liter by about 1990. see tuttle 1992, 15. glasstone and sesonske 1981, paras 9.99, 9.102, and 9.104 16. harold t. peterson and david a. Baker, "tritium production, releases 34. nrC 2006, p. 43 and population doses at nuclear power reactors," Fusion Technology v.8, no.2 (september 1985), pp. 2544-2550. abstract at http://www.osti.gov/ 35. nrC 2006, pp. 6 and 11 36. glasstone and sesonske 1981, pp. 599-602 17. peterson and Baker 1985 18. see, for example, nrC 2006, pp. 5-8.
More IEER Materials on Tritium
19. Currently there are 68 plant sites. thirty-two plants have only one operating reactor, thirty-three have two reactors, and three have (in reverse chronological order)
three reactors. there are links to the reports at Radioactive Effluent • tritium releases to air and Water from
nuclear Power Plants: tables of release data
20. according to sections 3/4.11.1 of Offsite Dose Calculation Manual from 2004 or 2005 (aug. 2009), at http://www.ieer.
Guidance for both the pressurized Water reactors and for the Boiling Water reactors, nureg-1301 and nureg-1302, the maximum concentration of tritium that can be released to unrestricted areas is 1 • Health risks of tritium: the case for
million picocuries per liter, as "specified in 10 CFr part 20, appendix B, strengthened standards (newsletter article, Feb.
table II, Column 2." however some plant operators use less restrictive values ("applicable limit") that are 3 to 10 times more lax and some- 2007), at http://www.ieer.org/sdafiles/14-4.pdf times do not even give one. • memo on tritium, review of Braidwood
21. the frequency of releases ranges from more than once a day to every Generating station Groundwater issue:
two months. For most plants the releases are every two to ten days.
Frequently asked Questions (March 20, 2006), at 22. gaseous and liquid release total estimate was 780 curies, 85 percent of that is 663 is for liquid releases only.
23. Merril eisenbud and thomas gesell, Environmental Radioactivity from • statement on tritium, prepared for a February 7,
Natural, Industrial, and Military Sources, 4th ed., academic, san diego, 2006, public forum in godley, Il inois. (February 2006), 1997, p. 182, for surface water and r. allan Freeze and john a. Cherry, Groundwater, prentice hall, englewood Cliffs, nj, 1979, p. 136, for • statement on tritium before the House
24. tuttle 1992 (r.j. tuttle, Tritium Production and Release to Groundwater at committee on intergovernmental
SSFL: Safety Review Report, rockwell International, Canoga park, Ca, 1 coordination, state of Georgia (october 1999),
december 1992 (rI/rd92-186) at http://www.etec.energy.gov/library/ groundwater/rI-rd-92-186_tritium_production_at_ssFL.pdf), p. 9, says "extrapolation of the decreasing concentration from the end of • tritium Production: doe moves ahead Where
1975, with an effective half-life of 3.2 years (faster than the radioactive decay of tritium because of dilution by ocean water), to the end of nonproliferationists fear to tread (newsletter
1991 shows a remaining activity of only about 6 pCi/L from the weap- article, winter 1996), at http://www.ieer.org/sdafiles/ ons tests." a further extrapolation to 2008 shows a remaining activity of 0.15 pCi/L.
25. In some cases, notably that of the savannah river, which has both com- • tritium: the environmental, health,
mercial nuclear reactors and a nuclear weapons plant along its shores, budgetary, and strategic effects of the
most of the tritium appears to be due to the latter.
department of energy's decision to produce
26. anna M. Fan and george v. alexeeff, Public Health Goal for Tritium in tritium (Ieer report, january 1996), at http://www.
Drinking Water, prepared by Office of Environmental Health Hazard Assessment, California environmental protection agency, California epa, sacramento, March 2006, at http://oehha.ca.gov/water/phg/pdf/phgtri- 27. nureg-1301, table 4.12-1 and nureg-1302, table 4.12-128. the epa gives this definition "Composite sampling is a technique whereby multiple temporally or spatially discrete, media or tissue samples are combined, thoroughly homogenized, and treated as a 29. exelon nuclear, Braidwood Station Units 1 and 2 Annual Radiological Environmental Operating Report, 1 January through 31 December 2006, exelon, Braceville, IL, May 2007. pp. 9-10

r e f e r e n c e m a n FroM page 1
this article provides some examples where reference Man is currently used in u.s. radiation protection standards or official guidance documents, and makes some recommendations for change. It examines some key policies of three u.s. federal agencies: the environmental protection agency (epa), the nuclear regulatory Commission (nrC) and the department of energy (doe). We also comment on the recent correspondence between then senator obama, Congressman henry Waxman, and the epa about reference Man. (a link to this correspondence is at http://www.ieer.org/sdafiles/16-1/referenceman-letters.html) Environmental Protection Agency
External dose
epa calculates a person's external dose using guidelines provided in Federal guidance report 12 (Fgr 12). the calculations are based almost entirely on reference Man, with the exception of the inclusion of sex-specific organs of women such as the uterus. Children are not at all considered in this guidance.
specifical y, Fgr 12 calculates "[a]ll organ doses" using figure 3: the bottle manikin absorption (BoMaB) phantom simulates
a hermaphroditic phantom5 (see Figure 3) that is based reference Man in size and internal body density. It is used to "calibrate on the reference Man model. the weight, location of the systems used to detect and quantify the amount of radioactive materials organs, density of organs, and other features of this model in workers." BoMaB is loaned to doe sites by the pacific northwest are, with the exception of the female specific sex organs, national Laboratory. phantoms for a reference Female and four-year old child are also available. (sources: http://picturethis.pnl.gov/picturet.
those of a male that is slightly heavier than the reference nsf/by+id/aMer-5XBn9n, http://www.pnl.gov/phantom, and http:// Man as defined above (73 kilograms versus 70 kilograms) and also somewhat tal er (179 cm versus 170 cm). thus, while Fgr 12 does include doses to the ovaries and the continued use of reference Man does not take breasts, the basic geometry of the body and the weight of into account the greater radiation doses received by the model is that of an adult male.
some parts of the population that result from the same even so, the model does not accurately represent environmental conditions and the higher cancer risks female adult doses to many organs, since women are on per unit of dose that they face. this especial y applies to average lighter than men. general y, the lighter a person, women (including pregnant women) and children. the greater the dose from a given amount of external specifical y, the overall fatal cancer risk experienced by radiation to internal organs, all other things being equal, females is 37.5 percent greater than that experienced by since there is less shielding of these organs by the rest of males for the same radiation exposure. the differential the body. therefore, the same external radiation field cancer incidence risk is even higher (52 percent higher for would produce a greater dose in the internal organs of women than men).3 For children, the fatal cancer risk per unit of dose is Moreover, the chemical composition of female bodies higher than for adults. the risk of developing cancer from is different from that of men. For example, on average, exposure is about 3.7 times greater for an infant boy than females have a greater proportion of their body weight the risk for a 30 year old adult male receiving the same as fat than men. hence it is critical to have a model that radiation dose and 4.5 times greater for an infant girl than is specific to females of various ages, if external doses to the risk for an adult female. a female infant has about a many organs are to be accurately estimated.
seven times greater risk of getting cancer than a 30-year the problem is even greater in the case of children. the old male for the same radiation exposure.4 approach used in Fgr 12 would general y underestimate It also should be noted that, even though reference doses experienced by children's organs, for instance, Man is taken to be an adult male in his twenties, the because their bodies are thinner and more radiation gets definition makes no mention of the possibility that a through the outer layers to reach the various organs. this man may become a father and what that might mean is even acknowledged in Fgr 12. Further, the chemical in terms of the impacts on the framework of radiation composition of children's bodies is substantial y different, protection regulations. Further, while radiation dose to including that of radiosensitive organs. the gonads is calculated in the reference Man framework one reference6 cited in Fgr 12 contains data on infants to take account of possible hereditary effects, non-cancer and children of various ages that could have been used to reproductive effects are not part of the u.s. regulatory framework for radiation protection. r e f e r e n c e m a n FroM page 11
estimate external exposure doses to people of varying after taking into account the fact that infants breathe only ages. But the epa did not do so.
about one third the amount of air per day on average as the problems of using a reference Man approach an adult male. But the ingestion dose from drinking water (with a couple of female organs added into the model) are contaminated with iodine-129, another radioisotope of compounded by the facts that iodine, will be greater for an adult. this is because the higher dose conversion factors for infants for iodine-129 Children are at higher risk than adults are outweighed by the higher water consumption of adults.
however, the risk to infants of developing cancer from of getting cancer from the same dose of the ingestion of iodine-129 will still be greater despite the lower radiation dose received, with the difference being radiation. Females are at higher risk than greatest between female infants and adult males. this is males of getting cancer from the same because radiation doses received in childhood are more likely to lead to cancer than the same dose received as an dose of radiation.
adult. In the case of the risk of thyroid cancer, for example, the risk to female infants drinking the same contaminated water as adult males is about 26 times greater, even after using a hermaphrodite model that is basical y a grown taking into account the fact that infants drink much less man with female organs added on is not a suitable water on average than adults.7 substitute for scientifical y sound models for women and children (of various ages) in their own right.
dose: a measure of the energy deposited due to
the current guidance general y used for internal radiation exposure in a person, organ, or other medium. dose calculations is Federal guidance report 11 (Fgr units are rad or gray (gy), with 1 gray = 100 rad. When 11). Fgr 11 uses reference Man. the newer Fgr 13 the relative biological effectiveness of a particular radiation contains dose and risk factors for children, but the dose type (relative to gamma radiation) is taken into account, conversion factors in Fgr 11 are still the basis of most u.s. the value of rad or gray is multiplied by a quality factor to radiation protection regulations. dose conversion factors yield the units rem or sievert (sv); 1 sievert = 100 rem. are the numbers used to convert intakes of amounts risk: the probability of injury, disease, or death, usual y
of radionuclides to radiation dose (which, according to expressed as a value ranging from zero to one. In radiation regulations and the national academy of sciences, is protection, "risk" is shorthand for the chance that a given proportional to cancer risk for solid cancers).
radiation dose will lead to death from cancer.
the 2002 update to Fgr 13 specifies dose conversion factors at various ages, although it continues to average external dose: dose received by a radiation source
the values for males and females. hence it is possible outside the body, e.g., from an x-ray machine or gamma- to calculate the doses to infants and to children at emitting radionuclides in soil.
various ages in order to determine whether the same internal dose: dose received by a radiation source
environmental conditions, such as water or food inside the body, e.g., an inhaled dust particle containing contamination, produce a higher dose for adults or for plutonium or ingested tritiated water.
children. however, it is not possible to use Fgr 13 to determine if boys would receive a higher dose than girls or Clean air standards
the u.s. regulation that governs air emissions of radionuclides (excluding radon) from department of In the case of the Clean Air Act energy facilities is specified in 40 CFr 61 subpart h and is regulations (40 CFR 61 Subpart H), administered by the epa. (CFr stands for Code of Federal regulations.) It specifies that the dose to the maximal y children are specifical y excluded from exposed member of the public due to radionuclides released to the air shall not exceed 10 mil irem per year. the compliance calculations in order an air dispersion model developed by epa, cal ed Cap- to maintain "consistency" with earlier 88, is general y used to estimate the doses for compliance calculations. the most recent version still uses adult dose compliance models. conversion factors. according to the user guide, "although Fgr 13 contains age-dependent dose factors, Cap88-pC only uses the adult factors in order to retain consistency When Fgr 13 is used to estimate the dose from with previous versions."8 internal y deposited radionuclides for a specified set of environmental conditions, the segment of the population hence, in the case of the Clean air act regulations that gets the highest dose may or may not be children. For (40 CFr 61 subpart h), children are specifical y excluded instance, the dose to the thyroid experienced by infants from the compliance calculations in order to maintain to due breathing air contaminated with iodine-131 will be about 11 times greater than that for an adult male, r e f e r e n c e m a n FroM page 12
"consistency" with earlier compliance models. this is early in life. For instance, for a given level of intake, the unjustifiable from the point of view of public health. thyroid dose due to inhalation of iodine-131 in the first five years of life is over five times greater than the dose Nuclear Regulatory Commission
received during the entire adult lifetime, defined as ages 18 nuclear regulatory Commission (nrC) radiation to 70 years.10 Further, for external dose where the person protection regulations in the workplace and for the is submerged in an external radiation field, the nrC general public general y use reference Man, with a minor regulations drop the factor of two for lifetime exposure.
and unsatisfactory adjustment for age in the case of The curious case of Connecticut Yankee
some external exposure calculations. these regulations the perverse effect of relying on reference Man are specified in 10 CFr 20, which cover nrC licensees has long been evident. For instance, in the Connecticut including all nuclear power plants and commercial fuel yankee decommissioning proceedings, the utility argued fabrication plants. it was only required to consider reference Man in its Workers, including pregnant ones
decommissioning plan. In summarizing the arguments of the regulations for workers are based on reference Connecticut yankee, the Commission, referring to its Man, with one exception: pregnant workers. When a regulations that establish radiation protection standards woman declares her pregnancy to her employer, the dose (10 CFr 20), noted: to the fetus must be restricted to 500 mil irem for the although the plain language of the regulation does duration of the pregnancy. not restrict the terms "critical group," "individual," this limit was set in the 1970s to provide the fetus with or "human being" to mean any specific age, race, the same protection as was then given to the general or gender, Cy [Connecticut yankee atomic power public, once a woman declares her pregnancy, which is, in Company] argues that the regulation incorporated effect, a declaration of her intent to carry the pregnancy the environmental protection agency's "reference to term. however, the maximum al owable exposure for Man" concept, which assumes a person is a white the general public was reduced from 500 mil irem to 100 male, age 20-30. Cy contends that the critical mil irem per year in the late 1980s, while the limit for fetal group at haddam neck should be composed of exposure in the workplace has been left unchanged. resident farmers, as Cy described them in its License the fetal exposure limit is obsolete by a factor of five or termination plan, and that the "average" member is more. It should be reduced to, at most, that of the general therefore an average farmer. doses to children are public. "at most" because therefore irrelevant, it argues.11 • In the latter stages of pregnancy, fetal exposure results the Commission eventual y ruled that the Connecticut in risks that are comparable to those of infants; yankee should consider doses to children, but that: • In the early stages of pregnancy, there are risks of If the evidence shows, as Cy claims it wil , that doses non-cancer effects that have not yet been adequately to children are lower than doses to adults, Cy will studied or quantified and are not yet considered in prevail without the need for an appeal. But even if radiation protection regulations; and, the evidence shows that doses to children are higher, • The limit does not address the radionuclide burden Cy will still have the opportunity after the [nrC's a woman may accumulate before she realizes she is atomic safety and Licensing] Board's final decision pregnant, which will irradiate the fetus and may even be to argue before the Commission that our regulations preferential y remobilized and relocated to fetal tissues.
prohibit considering doses to children.
the nrC's decommissioning guidance sets metabolic parameters either for reference Man or "at the the use of reference Man carries over to the mean of the distribution for an average human."12 the regulations governing exposures of the general public, decommissioning guidance also states that notably without regard to gender. a reduction in the air concentration limits derived from adult values by a factor the metabolic parameters were set at "Standard
of two is made for many radionuclides "to adjust the Man" or at the mean of the distribution for an occupational values (derived for adults) so that they are applicable to other age groups."9 evidently, the nrC uses the term "average human" as with occupational exposure, the regulations for and "average man" interchangeably, which is a lamentable the general public ignore females in the population, confusion, with significant consequences for a majority of despite the fact that they are the majority. the factor of the u.s. population.
two adjustment to account for the fact that the general While the nrC uses reference Man in its overall population is exposed from childhood to adulthood does regulations specified in 10 CFr 20, it uses a different not include gender differences. framework in evaluating the effect of the emissions from Moreover, although the factor of two is sufficient power plants. these emissions are supposed to be kept adjustment for some radionuclides and routes of exposure, "as low as reasonably achievable" (aLara). the design such as the ingestion of cesium-137, it is inadequate for criteria for this are specified in federal regulations 10 others, especial y for the heightened risks of exposure r e f e r e n c e m a n FroM page 13
CFr 50, appendix I. the 1977 guidance for use by the nrC staff in evaluating nuclear power plant applications includes dose conversion factors for infants, four-year-olds, teenagers, and adults. In its guidance, the nrC specifies on May 30, 2008, then-senator Barack obama and the evaluation of internal doses to the public in each of Congressman henry Waxman, then Chairman of the these age groups to ensure that the dose to the most house oversight and government reform Committee, exposed does not exceed aLara guidelines. In evaluating sent a letter to then-administrator stephen L. johnson of the design of reactors to meet the aLara criteria, the the epa, inquiring about the use of reference Man in epa nrC's guidance, in effect since the mid-1970s, specifies guidelines and standards and plans to phase out the use of parameters that enable the calculation of internal radiation the reference Man model. doses for exposed individuals of various ages, including In epa's july 24, 2008, response, robert j. Meyers, then infants.14 however, external radiation doses were not principal deputy assistant administrator of the epa's estimated according to age in this guidance. office of air and radiation, described the current situation Department of Energy
as regards reference Man as fol ows: epa regulations, guidance documents, and reference Man is also used in the doe guidance, procedures issued prior to 1990 (prior to ICrp "radiation protection of the public and the environment,"15 publication 60) were based on reference [standard] because it uses the dose conversion factors from Fgr Man….For some regulatory applications, numerical 11. the doe guidance al ows for exceptions to the use values to radionuclide-specific doses – as distinct of reference Man, but the use of other models requires from risks – are still taken from the adult worker special permission and must be approved by doe. Further, dose conversion factors provided in Federal the guidance al ows parametric variation, such as location guidance reports 11 and 12. however, for many of the individual in relation to the radiation source, but not years, our calculations of risk and our regulatory variation for gender or age. actions and guidance for environmental exposures For external doses, the doe guidance specifies using have factored in the varying age-sensitivity of the dose conversion factors for submersion from epa's Fgr 12, but also refers to a 1988 doe document that the epa also made the fol owing statement in the same considers a hermaphrodite model that is an improvement over the reference Man model. the use of a lower weight (58 kilograms) and the locations of the ovaries and breasts epa does not believe in continued use of reference are more appropriate than that in Fgr 12, but there is still Man, and general y stopped using it in 1990. epa no routine consideration of children in the doe guidance. continues to update and improve its age- and gender- specific models in light of continuing research. epa's radionuclide-specific cancer risk reference Man is also built into the main computer coefficients are used for calculating the excess cancer program used by government and industry to assess risk to the general population from chronic low risks from radioactivity remaining after remediation of level exposure to radionuclides in the environment. radioactively contaminated sites and for projections of our risk coefficients and regulatory actions are radiation doses from low-level waste disposal facilities. this "conservative" in that they sum the risks from an model, cal ed resrad, was developed and is maintained entire lifetime exposure, taking into account age- by doe's argonne national Laboratory.16 dependent differences in intake, biokinetics, and In the 2007 version of resrad, dose conversion sensitivity to radiation. thus, our regulations are ful y factors for children are included, but these new libraries protective of the entire population, including infants are not required to be used for compliance calculations. and children.
In fact, its default dose conversion factor library remains that from Fgr 11, which is based on reference Man. We applaud EPA's declaration that it this version of resrad is an improvement over prior ones, since one can now calculate doses to children using "does not believe in continued use resrad which was not possible with previous versions of the program without modification by the user. however, of Reference Man." insofar as the decommissioning regulations of the nrC are based on reference Man – and they general y are, We applaud epa's declaration that it "does not believe as discussed above – the nuclear industry is still free to in continued use of reference Man." an explicit statement argue that children are not relevant to the regulations and along these lines is long overdue and it is a sign of great progress that it has been made. however, the latter part of the same sentence – that the epa "general y stopped using it [reference Man] in 1990" is not ful y consistent with the first quote from the letter in which epa admits r e f e r e n c e m a n FroM page 14
that it continues to rely on Fgr 11 and Fgr 12 for "some "that the BeIr vII risk estimates do not differ dramatical y regulatory applications." not only are these guidance from those currently in use by the epa" and that "current documents based on reference Man, they are applied standards and guidance are protective." this is misleading. widely, in the epa as well as in the nrC and doe. epa's Current standards are in terms of dose limits, which Clean air act compliance is also based on reference Man.
were largely set in the era of reference Man. the fatal Further, while the epa letter states that "the varying cancer risk implied by current standards18 is all over the age-sensitivity of the population" is factored in to its map, ranging from about 1 in 240 for the overall nrC guidance, there is in fact no specific guidance that even dose limit of 100 mil irem per year to the pathway specific enables a calculation of external doses to children. limit of about 1 in 6,000 (rounded) for the 4 mil irem Children's external organ doses are estimated as if per year drinking water limit for most beta and gamma their bodies were as developed as those of reference emitting radionuclides that give a whole body dose. Man, which underestimates doses in many situations. however, the fatal cancer risk to females is about 1 in 200 the epa also has not published guidance for calculating and that to males is considerably lower – about 1 in 300.
radionuclide-specific internal doses to women of any age the situation is even more problematic when cancer for a given intake. incidence risk is taken into account. the best estimate for epa does use updated lifetime risks in its calculations, cancer incidence risk for women in BeIr vII is more than but such calculations are not at issue. epa, nrC, and 60 percent higher than the epa's estimate in Fgr 13 which doe regulations are not based on risk but on radiation averages the risks for males and females. the lifetime dose. If the guidance for calculating doses is based on cancer incidence risk for females, using the BeIr vII risk reference Man, then doses to women and children will be coefficients, is about 1 in 100, if the annual dose limit of systematical y underestimated in many situations.
100 mil irem is maintained. this is very high; a significant tightening of radiation protection standards for the public The lifetime cancer incidence risk for females, is in order.
using the BEIR VII risk coefficients, is about 1 in 100, if the annual dose limit of 100 mil irem While there has been a modest amount of progress is maintained. This is very high; a significant in incorporating some recent guidance that concerns women into radiation protection, the use of reference tightening of radiation protection standards Man in radiation protection regulations remains pervasive. for the public is in order.
Children have often been ignored, even though the science to determine when they may get higher doses has long been available. Women are either partial y included or not hence, it is clear that the epa did not "general y stop" included at al .
using reference Man in 1990. rather, the use of reference Current radiation protection standards were mostly set Man continues to be pervasive. and even in the cases before publication, in the last decade, of conclusions that where Fgr 13 is properly applied to estimating dose that women and children are general y at much greater risk includes age-dependence, the dose conversion factors for of developing cancer than men from the same exposure. males and females continue to be averaged, as are the risk hence, radiation protection standards are outdated in two ways that reinforce a lower level of protection for women The use of Reference Man continues • Radiation dose calculations done for proving compliance to be pervasive.
with regulations use dose conversion factors for reference Man, with relatively minor adjustments in We appreciate that the epa has committed to review some cases. this underestimates radiation doses to the gender-specific dose and risk situation in light of the children in most cases and to women in some cases for publication of the BeIr vII report, as noted in its letter: the same environmental conditions. Female children are the most adversely affected in many situations.
at issue now is whether separate male and female risk coefficients should be published for the general • Cancer risks from the same radiation dose are general y population, given the approximate two-fold higher for children and women, though, for some difference in risk per unit dose estimated in BeIr vI . specific cancers, men have a higher risk.
epa is now examining how best to account for this the failure to estimate doses to children and cancer difference in future guidance and regulations. any risks to children when they are in excess of doses and proposed changes in epa's radiation risk assessment risks received by adults would appear to be in violation approach will be subjected to interagency review of president Clinton's 1997 executive order on children, and public comment through the usual rulemaking which was reaffirmed by president Bush, with some and guidance development procedures.
changes, in 2003: despite this acknowledged "two-fold" difference in risk between males and females, the epa's letter also claims r e f e r e n c e m a n FroM page 15
a growing body of scientific knowledge demonstrates to protect themselves. therefore, to the extent that children may suffer disproportionately from permitted by law and appropriate, and consistent with environmental health risks and safety risks. these risks the agency's mission, each Federal agency: arise because: children's neurological, immunological, (a) shal make it a high priority to identify and assess digestive, and other bodily systems are still developing; environmental health risks and safety risks that may children eat more food, drink more fluids, and disproportionately affect children; and breathe more air in proportion to their body weight than adults; children's size and weight may diminish (b) shal ensure that its policies, programs, activities, and their protection from standard safety features; and standards address disproportionate risks to children that children's behavior patterns may make them more result from environmental health risks or safety risks.19 susceptible to accidents because they are less able a summary of Ieer's recommendations fol ows.
1. end the use of reference man for estimating both
9. reduce maximum allowable fetal exposure in the
dose conversion factors and cancer risk in radiation workplace. the maximum al owable fetal exposure in
protection regulations and guidance. radiation-related workplaces (including doe facilities and 2. calculate compliance to the part of the
those regulated by the nrC) in cases where a radiation population receiving the highest dose. Compliance
worker declares her pregnancy should be reduced from with annual maximum exposure limits should be calculated 500 mil irem to 100 mil irem using dose conversion factors using dose conversion factors for the portion of the for fetal exposure. this limit should be reduced when dose population that would receive the highest radiation dose limits to members of the public are reduced. for a given set of environmental conditions.
10. Publish reference characteristics for populations
3. develop and publish dose conversion factors for
not adequately covered. the epa should examine
females. epa's Fgr 11 should be retired and replaced
and publish reference biological characteristics for sections with an updated version of Fgr 13 with dose conversion of the u.s. population not adequately covered, including factors and cancer risks for males and females separately african americans and hispanics.
(not averaged) at various ages.
11. tighten nrc and doe rules for maximum
4. develop and publish age and gender specific
allowable exposure from nuclear fuel cycle and
external dose conversion factors. epa's Fgr 12
nuclear weapons facilities. the nrC's present
should be revised to include dose conversion factors at radiation protection standard for the general public20 of various ages for males and females.
100 mil irem per year is inadequate and obsolete, especial y in light of the BeIr vII report's conclusions. the nrC 5. develop and publish fetal dose conversion factors
should revise 10 CFr 20 for nuclear fuel cycle facilities and for use in compliance calculations for cases of declared limit the dose from nuclear fuel cycle facilities combined to conform with 40 CFr 190, which specifies the epa 6. fill critical gaps in early fetal dose estimation
standard for dose from a single nuclear fuel cycle facility. methods and put protective standards into place
the doe should similarly modify doe order 5400.5 until then. the assumption that the dose to the embryo/
to reduce the maximum dose to the general public from fetus in the first eight weeks of pregnancy is the same as 100 mil irem per year from nuclear weapons facilities to that to the uterine wal is not valid for al radionuclides. conform with 40 CFr 190. a considerable tightening of Consideration should be given to tightening the maximum drinking water standards for transuranic radionuclides is contaminant limits for tritium and alpha-emitters until a satisfactory scientific framework can be put into place. 12. Publish a White Paper on risk-based radiation
7. calculate risks for those most at risk. Lifetime risk
protection. Current radiation protection standards are
calculations should be based on those most at risk. In based on dose limits (or maximum concentrations derived general, this means that lifetime risks would be calculated from dose limits) rather than on risk. their risk implications for females, unless risks for specific cancers to which men are quite varied, with lifetime risk being greater for females are more vulnerable are being evaluated.
and annual risk being general y greater for children, 8. revise the default parameters in resrad. doe
especial y female children. even under the tightened argonne should modify the resrad program so that the standard proposed here, the lifetime risk to females if the default calculations always refer to those who would get maximum dose were received each year would be about the highest dose and are at highest risk from a given set of 1 in 400. We recommend that the epa publish a White paper on risk-based or risk-informed radiation standards where both doses and risks are calculated on a gender- and age-specific basis and where the lifetime risk to a maximal y exposed individual is kept much lower than that implied by the current single fuel cycle facility limit specified in 40 CFr 190.
r e f e r e n c e m a n FroM page 16
12. shepherd, et al. 2006 (j.C. shepherd, et al., Consolidated Decommissioning 1. this article summarizes the december 2008 Ieer report, The Use Guidance - Decommissioning Process for Materials Licensees - Final Report, of Reference Man in Radiation Protection Standards and Guidance with nureg-1757, vol. 1, rev. 2, u.s. nuclear regulatory Commission, Recommendations for Change, by arjun Makhijani. (revised april 2009). september 2006, at http://www.nrc.gov/reading-rm/doc-collections/ Full citations can be found in the report, at www.ieer.org/reports/refer- nuregs/staff/sr1757/v1/sr1757v1r2.pdf), p. h-5. [emphasis added] enceman.pdf. also see the table, "Where is reference Man?" summariz- 13. shepherd, et al. 2006, table B-2, footnote a (p. B-3). [emphasis added] ing regulatory standards in Science for Democratic Action vol. 15, no. 4, at 14. u.s. nuclear regulatory Commission, Regulatory Guide 1.109: Evaluation of Annual Doses to Man from Routine Releases of Reactor Effluents for the 2. International Commission on radiological protection, Report of the Task Purpose of Evaluating Compliance with 10 CFR 50, Appendix I. revision 1. Group on Reference Man, [ICrp publication] no. 23. pergamon press, Washington, dC: nrC, october 1977, at http://www.nrc.gov/reading- oxford, 1975, p. 4 3. nas-nrC 2006 (Health Risks from Exposure to Low Levels of 15. u.s. department of energy, Radiation Protection of the Public and the Ionizing Radiation: BEIR VII – Phase 2, national research Council of Environment, (order, doe 5400.5, Change 2: 1-7-93), February 8, 1990; the national academies, 2006, at http://www.nap.edu/openbook.
january 7, 1993, at http://www.directives.doe.gov/pdfs/doe/doetext/ php?isbn=030909156X.), p. 15 4. nas-nrC 2006, p. 311 16. argonne national Laboratory, RESRAD 6.4, argonne, IL, anL, 5. a "phantom" is a mannequin constructed to compute radiation doses u.s.department of energy, 2007, at http://web.ead.anl.gov/resra/ to various parts of the body under specified radiological conditions. For instance, dose to internal organs due to an external source of radiation 17. the obama-Waxman-epa correspondence is reproduced as can be computed in this way.
attachments in the Ieer report at www.ieer.org/reports/referenceman.
6. M. Cristy and k.F. eckerman, Specific Absorbed Fractions of Energy at pdf and also at http://www.ieer.org/sdafiles/16-1/referenceman-letters.
Various Ages from Internal Photon Sources – [Vol.] I Methods, ornL/ tM-8381/v1, oak ridge national Laboratory, october 1987, at http:// 18. average of male and female risks, using a fatal cancer risk coefficients in BeIr vII report, p. 312. 7. risk calculations as based on BeIr vII report, summarized in Ieer's 19. William j. Clinton, "executive order 13045 – protection of Children report, Science for the Vulnerable: Setting Radiation and Multiple Exposure From environmental health risks and safety risks," Federal register v. Environmental Health Standards to Protect Those Most at Risk, by arjun 62, no. 78 (april 23, 1997) pp. 19885- 19888, at http://www.epa.gov/ Makhijani, Brice smith, and Mike thorne (october 19, 2006, at www.
fedrgstr/eo/eo13045.pdf ieer.org/campaign/report.pdf), pp. 27 and 38. Intake and inhalation rates 20. our analysis and recommendations are focused on members of the are from the epa's 1997 Exposure Factors Handbook: Volume I – General general public (with the exception of pregnant women who are radia- Factors, epa/600/p-95/002Fa, (august 1997, at http://rais.ornl.gov/ tion workers) and on nuclear fuel cycle and nuclear weapons facilities. homepage/eFh_Final_1997_epa600p95002Fa.pdf), p. 5-24 for air and specifically, we are not addressing medical, academic and other similar p. 3-26 for water.
facilities, or the circumstances under which workers in such facilities are 8. u.s. environmental protection agency, CAP88-PC Version 3.0 User Guide, radiation workers or members of the general public.
december 9, 2007, at http://www.epa.gov/radiation/docs/cap88/user- 21. see arjun Makhijani, Bad to the Bone: Analysis of the Federal Maximum Contaminant Levels for Plutonium-239 and Other Alpha-Emitting 9. r.e. Zelac, et al., Consolidated Guidance: 10 CFR 20 – Standards for Transuranic Radionuclides in Drinking Water, Ieer, august 2005, at http:// Protection Against Radiation. Final Report, nureg-1736, u.s. nuclear regulatory Commission, october 2001, at http://www.nrc.gov/readin- 10. Calculated from Fgr 13 dose conversion factors in the 2002 Cd supplement, with linear interpolation between the ages of 1 and 5, 6 and 10, 11 and 15, and 15 and 18 years.
11. this excerpt and the following from u.s. nuclear regulatory Commission, "In the Matter of Connecticut yankee atomic power Company (haddam neck plant), docket no. 50-213-oLa, (License termination plan), december 5, 2001," CLI-01-25. In Nuclear Regulatory Commission Issuances: Opinions and Decisions of the Nuclear Regulatory Commission, With Selected Orders, July 1, 2001-December 31, 2001, nureg-0750 volume 54, nrC, 2001, pp.368-375, at http://www.nrc.
gov/reading-rm/doccollections/nuregs/staff/sr0750/nrci54.pdf, p. 372 and 374 (footnotes omitted).
atomic PUz zler : co 2 series Wr aP- UP
CO emissions: Coal, Gas, nuclear
the past four atomic puzzlers – in sda vol. 14, nos. 3 and 4, and sda vol. 15, nos. 3 and 4 – chal enged readers to determine carbon dioxide emissions from four different types of electricity generating sources given reasonable assumptions: a coal-fired power plant, a natural gas fired plant, a nuclear power plant with fuel enriched via gaseous diffusion, and a nuclear power plant with fuel enriched via gas centrifuge. here we wrap up this special puzzler series with a side-by-side comparison of the answers. the table below shows that nuclear power emits far less Co per unit electricity than coal or natural gas. Comparison of CO Emissions: Coal, Natural Gas, Nuclear
co emitted per
co emissions
co emissions
kilowatt-hour of
of nuclear
of nuclear
electricity generated
power relative
power relative
(in grams)
to coal fired
to natural gas
power plant
fired plant
coal fired plant
natural gas fired plant
nuclear reactor – uranium
enrichment via gaseous diffusion
nuclear reactor– uranium
enrichment via gas centrifuge
despite this, it is not low-Co energy sources that we lack. What we lack is time and money. Based on this simple rubric, nuclear fails.1 Factor in proliferation, waste, and safety headaches2 and it becomes clear that nuclear has no place in a sensible, economical, and safe energy future.
1. see arjun Makhijani, Carbon-Free and Nuclear-Free: A Roadmap for U.S. Energy Policy (Ieer press and rdr Books, 2nd 2. see Brice smith, Insurmountable Risks: The Dangers of Using Nuclear Power to Combat Global Climate Change (Ieer press and rdr Books, 2006), at http://www.ieer.org/reports/insurmountablerisks. an sWers to atomic PUz zler in s da vol . 15, no. 4
Calculating CO emissions from nuclear power (uranium enrichment via gas centrifuge)
1. 110 metric ton sWu/year x 1,000 kg/metric ton = 110,000 kg sWu/year.
110,000 kg sWu/year x 55 kilowatt-hours/kg sWu = 6.05 x 106 kilowatt-hours/year.
2. 6.05 x 106 kilowatt-hours/year x 0.46 = 2.783 x 106 kilowatt-hours/year from coal.
2.783 x 106 kilowatt-hours/year from coal x 982 grams Co2/kilowatt-hours from coal = 2.733 x 109 grams Co /year = 2.733 x 106 kg Co /year from coal. 6.05 x 106 kilowatt-hours/year x 0.41 = 2.480 x 106 kilowatt-hours/year from natural gas. 2.480 x 106 kilowatt-hours/year from natural gas x 404 grams Co /kilowatt-hours from natural gas = 1.002 x 109 grams Co /year = 1.002 x 106 kg Co /year from natural gas. total = 2.733 x 106 kg Co /year from coal + 1.002 x 106 kg Co /year from natural gas = 3.735 x 106 kg Co /year.
3. 1,000,000 kilowatts x 365 days/year x 24 hours/day x 0.85 = 7.446 x 109 kilowatt-hours/year.
4. 3.735 x 106 kg Co /year from Les / 7.446 x 109 kilowatt-hours/year from reactor = 0.000502 kg Co /kilowatt-hour.
5. 0.000502 kg Co /kilowatt-hour for nuclear / 0.982 kg Co /kilowatt-hour for coal = 0.00051 = 0.051%.
0.000502 kg Co /kilowatt-hour for nuclear / 0.404 kg Co /kilowatt-hour for natural gas = 0.0012 = 0.12%.
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