Re: Brazil Nut Radwaste Standard

[BLHamrick@AOL.COM]

In a message dated 6/6/2003 4:59:32 PM Pacific Standard Time, jjcohen@PRODIGY.NET writes:


> One on the many irrationalities in radiation safety regulations is
>
> allowing the consumption of Brazil nuts that typically have a natural
>
> radioactivity content in excess
>
> of 3.0 nCi/g. Apparently, it's OK to eat them, but not to dispose of them in
>
> landfills.



Similarly, there's been some uproar about K-40 in landfill leachate in California.  The levels were something like 1000 pCi/L, but, whoa!!  That's 20 times one of the drinking water standards for beta activity!!  Nevermind the fact that everytime I go to my grocery store and buy a gallon of milk, it's about 2000 pCi/L.  No, let's waste lots of government time and money having a freak fest over the K-40 in landfill leachate, which by the way, to my knowledge, no one actually drinks.


It is this kind of foolishness that infuriates me.  The entire article from the San Diego Union-Tribune repeated some of the same myths and legends that have been repeated over the last two years in the California press and legislative briefing papers.  The same myths and legends that I have heard one man, repeat over and over and over, causing alarm in the pretty, itty-bitty heads of a variety of politicos.


Here are some examples:


Myth: California recently tried to de-regulate radioactive waste.

Fact:  California previously relied on the public dose limit of 100 millirem per year to guide decommissionings, and in 2001 California tried to adopt the NRC's decommissioning rule to reduce that level to 25 millirem per year for decommissioned sites.


Myth:  The 25 millirem per year standard for landfills is 10 times the amount that would have been allowed at Ward Valley.

Fact:  This is apples and oranges.  The 25 millirem per year standard for decommissionings, which was mutated into a de facto disposal standard by the anti-nuclear groups, was to be used to assess residual radioactivity at a site - i.e., accessible in surface soils, building surfaces, etc.  The 2.5 millirem per year dose assessment related to Ward Valley was a dose goal the contractor agreed could be met in an off-site, post-closure dose assessment, where there was technically no accessiblity to the site.  That is, using a simple example, if Ward Valley took only Type A waste, the Cs-137 concentration would be limited to 1 microcurie per cubic centimeter, whereas, the NRC screening level for Cs-137 at a decommissioned site is 1.1E-5 microcuries per gram or about 1.87E-5 microcuries per cc (of average soil), yet they're comparing dose from these concentrations, and stating that the projected decommissioned site dose is 10 times HIGHER than the Ward Valley "limit."  Oh, and they're getting away with it too.


Myth: The EPA's "limit" for chemical contamination is an increased risk of one in a million, and radioactivity should have to meet this too, as it's not a "privileged pollutant."

Fact:  The EPA's regulations say that a risk range from 1E-6 to 1E-4 SHOULD be used where there are no Applicable or Relevant and Appropriate Requirements (ARARs).  Their guidance clearly states this risk range does not create a bright line limit.  Furthermore, the recent MOU with NRC, and guidance going back to 1983 states they fully expect NRC cleanups will be protective of public health and safety, and it is not their intent to go back and reexamine these sites unless there are some extenuating circumstances.


There are more examples.


There should be a way to sue some of these "intervenors" for waste, fraud and abuse of taxpayer funds.  They do not let facts get in their way, they squeak loudly, and cost the taxpayers millions in hours spent by their civil servants trying to respond to their outrageous claims and histrionics.  Recollect Robert Preston in The Music Man - There's Trouble, right here in California...With a capital "T," which rhymes with "P" and that stands for...Plutonium!!  Or, whatever, the alleged pollutant du jour.  Really, it oughta be a crime.


Barbara