[ RadSafe ] " EPA Tritium Risk Plan May Force Tighter Nuclear Plant Controls "

[Steven Dapra]

June 20, 2007

	I read this article (approximately 1200 words) and the first thing I 
noticed that it named no one.  It's all based on sources, informed sources, 
officials, etc., etc.  It described tritium as "controversial."  Although 
this description is true, it means nothing.  (Look up "controversial" and 
you'll see why.)

	The article says, "The tritium MCL is currently set at 20,000 picocuries 
per liter of water, roughly 4 millirems of exposure per year."  Is four 
millirems a year something we --- or anyone --- should be worrying 
about?  Plus, one would have to drink the tritiated water to get that much 
exposure.  How many people are drinking tritiated water at any level, let 
alone at 20,000 pC/l?

	Are there any human cases of tritium-induced cancer?  I mean cases that 
have been reported in the medical literature, not hearsay claims from 
Caldicott-like fear-mongers.  Are there any reported cases of *any* adverse 
and long-lasting (for over a year) effects in humans?

	It seems to me that the only noticeable or significant effect of this 
attempt to increase the risk estimate for tritium would be to increase the 
power of a Federal government and an EPA that are both already far too 
powerful.  In the long run, the increased risk estimates would lead to more 
expensive electricity, as the reactor owners would (possibly? probably?) be 
forced to spend vast sums of money to control a radionuclide that seems to 
pose little or no threat to human health.  (Four millirems a year?  That's 
not much of a threat, is it?)

Steven Dapra
sjd at swcp.com


(The article:)

EPA is considering a substantial increase in its estimates of the risks 
posed by human exposure to tritium, a controversial byproduct of nuclear 
power generation, in a move that could prompt nuclear regulatory agencies 
to tighten their risk-based approaches for regulating radiological releases 
from nuclear power plants.
However, sources say any effort by EPA to tighten the risk estimates for 
tritium would likely prompt opposition from the industry and nuclear 
regulators, who fear it would complicate industry efforts to present 
nuclear power as an alternative to coal-fired generation under any future 
climate change regime.
Informed sources say EPA is weighing whether to double the effectiveness 
factor it assigns for tritium, a risk estimate figure used in setting 
contamination and cleanup standards that represents a given radionuclide's 
potential to damage the human body. EPA and other federal regulators 
generally set this factor at 1.7 for tritium and similar radionuclides.
However, recent scientific findings from the International Commission on 
Radiological Protection and evidence accumulated by the National Institute 
for Occupational Safety and Health (NIOSH) have led some EPA regulators to 
consider increasing that factor to 2 or higher, the sources say.
Tritium is an isotope of hydrogen that produces relatively low levels of 
radiation. Nuclear power plants release tritium in water and steam 
discharges. Regulators in several instances have also dealt with tritium 
leaks from nuclear facilities in the form of contaminated water. 
Consequently the task of estimating the health risks associated with 
tritium is a highly contentious issue among nuclear experts, industry and
environmentalists.
Observers say increasing the effectiveness factor for tritium could result 
in risk assessments that suggest human exposure to tritium is more harmful, 
thereby giving federal regulators grounds to tighten tritium containment 
and release standards at nuclear power plants, research laboratories and 
places where nuclear fuel is stored. Additionally, a key activist source 
says the increased risk figures could encourage more severe federal 
enforcement actions should regulators discover tritium leaking at a nuclear 
facility.
Increasing the effectiveness factor for tritium would have little to no 
impact on EPA's radiation standards because the risk associated with 
tritium would still be within already regulated levels, which are based on 
calculated doses, the sources add. Nevertheless, the move could spur 
regulators in other agencies -- such as the NRC and the DOE-- to adopt a 
similar risk assessment approach, the sources say.
Sources say EPA efforts to tighten its risk estimates would likely prompt 
opposition from NRC and the industry, in part because it could stifle 
efforts to build as many as 27 new nuclear reactors in the United States 
over the next few years.
Nuclear industry officials are hoping for a so-called "renaissance" for 
nuclear power nationwide, arguing in part that the plants provide increased 
energy supplies without increasing harmful greenhouse gas emissions that 
contribute to climate change.
However, environmentalists and Democrats are calling for stricter safety 
and environmental controls on the industry before new plants can be 
built.  News that EPA is eyeing an increase in the tritium effectiveness 
factor could bolster anti-nuclear activists and prompt opposition from NRC 
and industry.
The expected growth in the nuclear energy sector, an informed federal 
source says, is one reason NRC would likely resist any effort to increase 
the risk factors connected to tritium. "The other agencies would try to 
stop it," the source says. "Not under this administration, it'll never make 
it through." A radiological protection expert agrees, saying such an 
increase in tritium effectiveness factor could "make the NRC mad."
An NRC source downplays the significance of increasing the effectiveness 
factor for tritium, saying the agency would have to formulate its own 
technical opinion on the factor before adopting it. The source also takes 
issue with the suggestion that the factor could impact power plant 
standards, noting that new plants tend to use the most current methods to 
ensure radiation exposures remain well below regulated levels. A nuclear
industry source agrees, noting that the deliberative nature of setting 
radiation standards could mean that any regulatory change may be years in 
the making.
One informed source cautions that it is "not a foregone conclusion" that 
increasing the factor will lead to stricter tritium regulations because 
those rules are most often based on specific dose calculations. However, an 
expert with a nuclear watchdog group suggests the increased factor would 
translate into tougher standards and regulators "would have to do something 
to undercut that" in their risk calculations for it to not have a
significant impact.
But despite potential efforts to block tighter risk factors for tritium, 
the federal source notes that EPA is slated to begin a review of its water 
contaminant limits for radionuclides in 2009. Increasing the effectiveness 
factor, the source adds, could encourage agency regulators to impose 
stricter maximum contaminant level (MCL) limits, which the agency also uses 
to set cleanup standards, during this review. The tritium MCL is currently 
set at 20,000 picocuries per liter of water, roughly 4 millirems of 
exposure per year.
EPA has already seen pressure from nuclear watchdog groups to impose 
significantly stricter water standards for plutonium in the pending review. 
EPA is also in the midst of a Science Advisory Board panel review examining 
the agency's risk approach to radiation that will likely prompt the agency 
to adjust its risk calculations for many radionuclides. A nuclear watchdog 
group has repeatedly urged the panel to increase the effectiveness factor 
for tritium to 3 or higher, citing several studies arguing it should be 
raised. A source with one group says the panel will soon receive formal 
written comments advocating such an increase.
The panel's most recent draft report, released Feb. 23, says tritium is 
among several issues the National Academy of Sciences most recent report 
evaluating radiation risks, which is the basis on the panel's work, did not 
address. EPA has a "need to derive a basis for risk estimates" for it, the 
report says.
The report also suggests EPA's effectiveness factor for tritium could be 
increased as the agency adopts its proposed radiation risk methods based on 
the NAS report. In its discussion of the risks associated with low-energy 
photons and electrons, the report says "an effectiveness factor for these 
low energy radiations in the range of 2 to 2.5 seems reasonable." The 
report includes the chemical symbol for tritium, 3H, among the particles 
that would fall within that category.
Additionally, tritium will likely be at issue in a June 21 meeting between 
officials with the NRC and the nuclear industry focused on a voluntary 
industry initiative begun last year to boost groundwater protection 
standards at power plants. The initiative was prompted by concerns over 
tritium leaks at several nuclear facilities.
However, the nuclear industry contends such leaks are not dangerous to 
public health and are generally contained within the facility in question. 
The radiological protection expert adds that concerns over tritium leaks 
would be better addressed by ensuring it is contained at a site, rather 
than increasing the risk factors associated with it. The source points out 
that NRC and the nuclear industry itself closely monitor tritium to ensure 
leaks
and other unintentional releases are prevented.