There is no safe level of radiation — Lowering the dose reduces the number of people who will be damaged, but not the severity of medical consequences to those individuals. The US National Academy of Sciences’ Committee on the Biological Effects of Ionizing Radiation, after more than three decades of study, wrote in the BEIR VII report: “The committee has concluded that there is no compelling evidence to indicate a dose threshold below which the risk of tumor induction is zero.” Nevertheless, the federal government has established permissible releases and dose limits from nuclear reactors, and NRC spokespersons regularly refer to releases as posing “no harm to the public”.
Permissible Releases Do Not Mean Safe — NRC’s allowable radioactive release dose to members of the public is 100 mrem per year to the total body. The lifetime fatal cancer risk for 100 mrem/yr is (3) in (1,000) and the cancer incidence risk is 1.5 -2.0 times the mortality risk. See the EPA’s Risk Assessment for boiling water reactors.
Radioactive Releases Occur Routinely — As a matter of routine operation, radiation is released from Pilgrim in the form of liquid, gaseous, and solid radioactive wastes.
Accidents Can Happen… Releases Have Been High — Radiation Reports for 1982 showed for example, Cesium -137, 1,000,000 times higher than expected in milk tested 12 miles west of the reactor… See the Land Study which showed how microclimate concentrated Pilgrim’s fallout: a Meteorological Analysis of Radiation Releases For the Coastal Areas of The State of Massachusetts For June 3rd to June 20th 1982
Pilgrim’s Environmental Radiation Reports — The NRC relies upon self-reporting from reactor operators to track radioactive releases and their projected dispersion.
High Releases – Unreliable Reporting — Pilgrim’s environmental impact report for 1980 noted strontium 1,000,000 times in excess of the concentrations expected to be present…” and went on to say that this is unquestionably due to atmospheric fallout resulting from atmosphere testing.” This ignores the fact that no similar increase was experienced at the control station in Whitman.
Accessing Pilgrim’s effluent reports on the web.
There is no safe level of radiation.
Radiation exposure can cause cell death, genetic mutations, cancers, birth defects, and reproductive, immune and endocrine system disorders. Radiation splits atoms and can break apart the bonds between atoms. When this happens in living cells, it can lead to cell death, interfere with the cell to function properly, or the uncontrolled proliferation of the cell – leading to cancer and disease. When it occurs inside a reproductive organ, male or female, it can lead to hereditary or genetic damage in offspring.
Permissible Releases Do Not Mean Safe.
Government regulations allow “permissible” levels of contamination. However, since there is no safe threshold to exposure to radiation, permissible does not mean safe.
NRC’s allowable radioactive release dose to members of the public is 100 mrem per year to the total body. The lifetime fatal cancer risk for 100 mrem/yr is (3) in (1,000) and the cancer incidence risk is 1.5 -2.0 times the mortality risk.
Authority: Responsibility is shared between the US Nuclear Regulatory Commission (NRC) and Environmental Protection Agency (EPA). Under the Clean Air Act, states are allowed to issue air emission regulations that are more conservative, lower, than federal standards. Acquiescing to industry’s wishes, Massachusetts Department of Public Health has failed to act.
Standards: Emission standards are based on calculations, not fact. The standard depends upon assumptions concerning what is released; how it is dispersed; and projected effects that they will have on the population. The outcome of any calculation is dependent on the quality of data that is entered into the calculation.
Nuclear reactors fall under Environmental Protection Agency (EPA) and the Nuclear Regulatory Agency (NRC). Pertinent EPA standards apply to allowable doses from all processes that release radiation into the air for said area, not simply the nuclear reactor, and apply to drinking water.
EPA’s allowable radioactive release dose into the air from all processes that release radiation is 25 mrem/yr; and into drinking water it is 4 mrem/yr. (regulation reference: 40 CFR 190).
NRC dose limit: NRC’s 1OCFR 20.1301 limits the levels of radiation to unrestricted areas resulting from the possession or use of radioactive materials such that they limit any individual to a dose of less than or equal to 100 mrem per year to the total body.
NRC dose objective/goal: In addition to this dose limit, the NRC, in 1OCFR 50 Appendix I, has established design objectives for nuclear plant licensees. The NRC design objective for the dose to a member of the general public from radioactive material in liquid effluents released to unrestricted areas to be limited to: less than or equal to 3 mrem per year to the total body; and, less than or equal to 10 mrem per year to any organ.
The NRC’s design objective air dose due to release of noble gases in gaseous effluents is restricted to: less than or equal to 10 mrad per year for gamma radiation; and, less than or equal to 20 mrad per year for beta radiation. The dose to a member of the general public from iodine-131, tritium, and all particulate radionuclides with half-lives greater than 8 days in gaseous effluents is limited to: less than or equal to 15 mrem per year to any organ.
Not easy to understand. A dose limit is just that – a limit. It is the maximum allowable release that can be enforced –like a speed limit on the highway. The dose objective or goal is like a wish. To continue with the automobile analogy, it would be like having spped goals on our highways instead of limits.
To add to the confusion, some limits are given in millirads (mrad/yr) and some in millirems (mrem/yr). A RAD is the amount of radiation absorbed by exposed material and a REM measures the damage to a human from radiation. 1 RAD= 1 REM in measures of gamma and beta radiation; and1 RAD = 10-20 REM in measures of alpha radiation.
Also different types of emissions are treated separately so that “allowable standards” of each seem low. Particles have one standard, gases another, liquids another, gamma radiation another, beta radiation another. In real life, you get a mixture; however, NRC assumes in making their standards that people living near a nuclear reactor will not be exposed to both the air and the water. They do not say how this can be possible; we don’t buy it.
In short, NRC’sallowable radioactive release dose for nuclear reactors into the air is 10 mrem/yr; and liquid release dose rate is 3 mrem/yr (regulation reference: 10 CFR 50 Appendix I).
What does the limit 100 mrem/yr mean? What are the cancer risks?
Using the Risk Assessment for Boiling Water Reactors Based on the National Emission Standards for Hazardous Air Pollutants (NESHAPS) for September 1989, the lifetime fatal cancer risk for 100 mrem/yr lifetime exposure is (3) in (1,000) and the cancer incidence risk is 1.5 -2.0 times the mortality risk.
What does the goal 10 mrem/yr mean? What are the cancer risks?
Using the Risk Assessment for Boiling Water Reactors Based on the National Emission Standards for Hazardous Air Pollutants (NESHAPS) for September 1989, the lifetime fatal cancer risk for 10 mrem/yr lifetime exposure is (3) in (10,000) and the cancer incidence risk is 1.5 -2.0 times the mortality risk.
This can be compared to the allowable kill rate from a chemical factory that releases a mixture of chemicals into the air of (1) cancer death in (100,000) or a factory that releases only one chemical into the air of (1) cancer death in (1,000,000). Why are nuclear reactors permitted to kill more people? Cancer is not the only health risk, either.
Radioactive Releases Occur Routinely.
It doesn’t take an accident at Pilgrim to release radioactivity into our air, water, and soil. As a matter of routine operation, radiation is released from Pilgrim in the form of liquid, gaseous, and solid radioactive wastes. Solid radioactive wastes include anything from laundry (considered low-level waste) to spent fuel rods (considered high-level waste.)
Radioactivity released includes over 100 different isotopes only produced in reactors and atomic bombs, including Strontium-89, Strontium-90, Cesium-137, and Iodine-131. Humans ingest them either by inhalation or ingestion, through food.
Each radionuclide seeks different parts of the human body; iodine seeks out the thyroid gland, strontium clumps to the bone and teeth (like calcium), and cesium is distributed throughout the soft tissues. All are carcinogenic. Each decays at varying rates; for example, iodine-131 has a half-life of eight days, and remains in the body only a few weeks. Strontium-90 has a half-life of 28.7 years, and thus remains in bone and teeth for many years.
These radionuclides are different from “background” radiation found in nature in cosmic rays and the earth’s surface. Background radiation, while still harmful, does not specifically attack the thyroid gland, bones, or other organs.
(The following material is taken with permission from a Fact Sheet prepared by Nuclear Information Resource Service)
It doesn’t take an accident for a nuclear power plant to release radioactivity into our air, water and soil. All it takes is the plant’s everyday routine operation, and federal regulations permit these radioactive releases.
Radioactivity is measured in “curies.” A large medical center, with as many as 1000 laboratories in which radioactive materials are used, may have a combined inventory of only about two curies. In contrast, an average operating nuclear power reactor will have approximately 16 billion curies in its reactor core. This is the equivalent long-lived radioactivity of at least 1,000 Hiroshima bombs.
A reactor’s fuel rods, pipes, tanks and valves can leak. Mechanical failure and human error can also cause leaks. As a nuclear plant ages, so does its equipment – and leaks generally increase.
Some contaminated water is intentionally removed from the reactor vessel to reduce the amount of the radioactive and corrosive chemicals that damage valves and pipes. The water is filtered and then either recycled back into the cooling system or released into the environment
A typical 1000-megawatt pressurized-water reactor (with a cooling tower) takes in 20,000 gallons of river, lake or ocean water per minute for cooling, circulates it through a 50-mile maze of pipes, returns 5,000 gallons per minute to the same body of water, and releases the remainder to the atmosphere as vapor. A 1000-megawatt reactor without a cooling tower takes in even more water–as much as one-half million gallons per minute. The discharge water is contaminated with radioactive elements in amounts that are not precisely known or knowable, but are biologically active.
Some radioactive fission gases, stripped from the reactor cooling water, are contained in decay tanks for days before being released into the atmosphere through filtered rooftop vents. Some gases leak into the power plant buildings’ interiors and are released during periodic “purges” and “ventings.” These airborne gases contaminate not only the air, but also soil and water.
Radioactive releases from a nuclear power reactor’s routine operation often are not fully detected or reported. Accidental releases may not be completely verified or documented.
Accurate, economically-feasible filtering and monitoring technologies do not exist for some of the major reactor by-products, such as radioactive hydrogen (tritium) and noble gases, such as krypton and xenon. Some liquids and gases are retained in tanks so that the shorter-lived radioactive materials can break down before the batch is released to the environment.
Government regulations allow radioactive water to be released to the environment containing “permissible” levels of contamination. Detectors at reactors are set to allow contaminated water to be released, unfiltered, if below “permissible” legal levels.
The Nuclear Regulatory Commission relies upon self-reporting and computer modeling from reactor operators to track radioactive releases and their projected dispersion. A significant portion of the environmental monitoring data is extrapolated – virtual, not real.
Accurate accounting of all radioactive wastes released to the air, water and soil from the entire reactor fuel production system is simply not available. The system includes uranium mines and mills, chemical conversion, enrichment and fuel fabrication plants, nuclear power reactors, and radioactive waste storage pools, casks, and trenches.
Increasing economic pressures to reduce costs, due to the deregulation of the electric power industry, could further reduce the already unreliable monitoring and reporting of radioactive releases. Deferred maintenance can increase the radioactivity released – and the risks.
Many of the reactor’s radioactive by-products continue giving off radioactive particles and rays for enormously long periods – described in terms of “half-lives.” A radioactive material gives off hazardous radiation for at least ten half-lives. One of the radioactive isotopes of iodine (iodine- 129) has a half-life of 16 million years; technetium-99 = 211,000 years; and plutonium-239 = 24,000 years. Xenon-135, a noble gas, decays into cesium-135, an isotope with a 2.3 million-year half-life.
It is scientifically established that low-level radiation damages tissues, cells, DNA and other vital molecules – causing programmed cell death (apoptosis), genetic mutations, cancers, leukemia, birth defects, and reproductive, immune and endocrine system disorders.
Accidents Can Happen… Releases Have Been High.
For example, we know that Pilgrim had extremely high emissions due to defective fuel, mechanical problems and lack of filtration. These problems culminated in June 1982 when Pilgrim blew its filters and released contaminated resin material into our neighborhoods. The licensee’s own Environmental Radiation Reports for 1982 showed for example, Cesium -137, 1,000,000 times higher than expected in milk tested at the indicator sampling farm 12 miles west of the reactor and no elevation at the control station, 22 miles away; Cesium-137 again (1,000,000) higher in vegetation samples from indicator farms .7 miles and 1.5 miles from the reactor. Elevated releases have been reported in subsequent years. Typically the licensee has blamed the increase on “atmosphere fallout” that ignores a critical fact – no similar increases were experienced at the control stations. How fallout, like a smart bomb, was able to find Pilgrim’s indicator locations while simultaneously missing the control stations is beyond comprehension. As you will read below, higher off site radiation detected is now “explained away” or hidden from the public by re-locating many “control stations” very close to the reactor – really, we know that they are indicator stations. Pilgrim began operations in 1972 with defective fuel and without proper filtration equipment in place. Poor management culminated in large off site releases in 1982 – Pilgrim blew its resin filters, saturated with radioactivity, into neighboring communities. Neighbors recall suited workers coming onto their private property to collect samples. A meterology report was commissioned and it was, “…the concluding opinion of this paper that the meterology which affected the Massachusetts lowland microclimate greatly intensified the radiation problem within the area.” Read the report.
Pilgrim’s Environmental Radiation Reports
Licensee Charged With Tracking Their Own Releases. The Nuclear Regulatory Commission relies upon self-reporting and computer modeling from reactor operators to track radioactive releases and their projected dispersion. A significant portion of the environmental monitoring data is extrapolated – virtual, not real. What is put into the computer model, assumptions, will effect the answer that comes out
Radioactive Releases Are NOT Fully Accounted For by the Licensee. Radioactive releases from Pilgrim’s routine operation often are not fully detected or reported. Accidental releases may not be completely verified or documented.
High Releases – Unreliable Reporting
Pilgrim has a long history of claims that the amount of radiation released is so small that it is inconceivable that any cancer or negative health impact would be caused. Do not buy it.
There is at the heart of Pilgrim’s argument, a fundamental flaw – no one knows how much radiation Pilgrim has actually released. What we know is that it is more, and again who knows how much more, than is shown in their reports. There are a number of reasons that this is so.
1. The first is that Pilgrim’s reports are ludicrous on their face. For example:
A. Milk is tested for radionuclides, both in farms around Pilgrim and at a control station in Whitman, 22 miles away. Pilgrim’s environmental impact report for 1980 noted that , at the farms around Pilgrim, “the measured average concentrations of both CS-137 and SR-90 were respectively 10,000 and 1,000,000 times in excess of the concentrations expected to be present…” and went on to say that this is unquestionably due to atmospheric fallout resulting from atmosphere testing.”
The effort to blame the increase on “atmosphere fallout” ignores a critical fact – no similar increase was experienced at the control station in Whitman. How fallout like a smart bomb, was able to find Pilgrim’s farms while simultaneously missing those in Whitman, is beyond comprehension.
Milk, late June 1982: the cesium-137 concentrations in the cow’s milk, Kings Residence were 1,000,000 times in excess of the concentrations expected. Pilgrim’s report attributes the increase, in a new and novel way, to the cow’s pregnancy, “It is not uncommon to find marked increases of CS-137 associated with a cow’s pregnancy, and this was most likely the cause.” Page 3-69. Animals do not produce cesium on their own. It must be introduced into the cow’s system from an environmental source. The likely source was the nuclear reactor up the street.
Vegetation, June 1982: the cesium-137 measurements detected in vegetable samples from the Evans Residence (0.7 miles W) and the Whipple Residence (1.5 miles SSW) were 1,000,000 times what would be expected and once again according to Pilgrim, “strongly indicates fallout.”
Shellfish, June 1982: Positive measurements of BE_7, Cs-137 and CO_60 found at Plymouth Harbor. The Cs-137 again according to Pilgrim is, “…due to fallout.”
B. The same “he did it” attitude is found in yearly reports in previous and subsequent years right up to now, not only in milk but in such things as cranberries, vegetation and shellfish. For example, report for 1988 stated that “no iodine-131 was detected in milk during 1988 (but, once again, the cesium-137 and strontium-90 is considered to be attributable to fallout from previous atmospheric testing…”) Iodine-131 was found in 1980. Again the reason for both years’ reports seems obvious. Pilgrim was closed from 1986 through 1988. Relatively short-lived iodine-131 was thus unlikely to be detected after two years, but quite expectedly reappeared when the plant opened in 1990. Cesium-137 and strontium-90, on the other hand, are long-lived, and can far more plausibly be attributed to emissions in 1986 and before that to some far off “atmosphere testing.”
2. The second reason for the likely difference between real emissions and what Pilgrim reported is that reports ignore the potential airborne radionuclide emission points. One such point is the turbine room; it was not monitored at all until the early 1990’s. How many other points were, and remain, unmonitored?
3. Finally there is the instrumentation used to make measurements. It is simply not accurate – for an analysis, please see monitoring section
Meteorological Analysis of Radiation Releases For the Coastal Areas of The State of Massachusetts For June 3rd to June 20th 1982
By Professor William T. Land
June 3rd, 1982 and again on June 11th, releases of radiation were reported to have occurred from Pilgrim Nuclear Power Plant located in Plymouth, Massachusetts. During the next seventeen days meteorological events kept the releases that were vented on shore and concentrated especially in the lowland areas within the 200 miles of the coast of Massachusetts.
A listing of probable causes resulting in radiation concentration within the microclimate would include (in order of importance):
1. ONSHORE WINDS: Winds from the east and north moving radiation back toward the land away from the coast.
2. WIDESPREAD RAINFALL; Rain which could keep radiation in the lower stratosphere and washout radiation into the ecosystems, food chair and water supplies.
3. COOL DESCENDING AIR; Air which would prohibit radiation from lifting into high altitude winds which would in turn carry the contaminants at the 18,000 foot level safely out to sea.
4. AIR POLLUTION: Pollution which would give added nuclei for radiation to adhere to thereby increasing its ability to stay at lower stratospheric levels.
5. FOG: Fog which would give additional hydroscopic nuclei for both pollution and radiation to coalesce upon.
6. AIR STAGNATION: Stagnation with little or no wind, haze and temperature inversions which in turn have the ability to trap radiation close to the surface.
In the best situation radiation releases would be quickly removed over land and away from centers of population. Meteorological mechanisms which would enhance air cleaning would include (in order of importance):
1. STRONG SURFACE LAND BREEZES: Breezes which would act as cleaning winds headed out to the open ocean.
2. STRONG COLD FRONTS: Cold fronts or squall lines moving from the west or northwest causing radiation to be carried out to sea on powerful surface cleaning winds.
Unfortunately for the State of Massachusetts, the releases from the Pilgrim Nuclear Power Plant at Plymouth coincided with unfavorable meteorological conditions which created within the microclimate a worst-case situation. Because the 3rd and 20th of June there were very few hours of atmospheric cleaning, very little radiation could have entered the high altitude wind flow and most radiation releases were concentrated inland near population centers.
The reporting stations in Nantucket some sixty miles ESE of the Pilgrim Nuclear Power Plant and Boston some thirty-five miles NNW of the power plant centered between the two reporting stations. Each wind flow that crossed this line headed inland would move radiation toward population centers. During the seventeen day period thirty-four wind directions were measured and 76.5% were from the ocean inland. The remaining 23.5% only averaged from five to seven knots of wind speed. Also these winds were concentrated in the period of June 16th to June 18th. Taking only the wind directions from June 4th through June 15th the eleven day period produced 95.5% of the winds from the ocean inland.
The second variable looked at during period June 3rd to the 20th was rainfall. Massachusetts during this time had rain in very significant widespread and heavy amounts six of the seventeen days. These rains produced during the month historically recorded amounts, some 4.6 times the normal mean for the recording station at Boston. These records contributed to the entire monthly report of 200% above normal (see map). The rains were the result of subtropical depressions moving slowly from the south up the Atlantic seaboard. During the first week alone on June 5th and 6th Boston received a record 8.88 inches of rain. With rainfall of this significance the radiation releases of June 3rd quickly entered all areas of the Massachusetts ecosystem. The storm of June 5th and 6th was not of the convective thunderstorm type with cumulus clouds reaching up to 50,000 feet which has been suspect in contributing to the descent of old fallout. It is impossible for the EPA* (*should be PNPS Pilgrim Nuclear Power Station) to claim that extra radiation left over from Chinese nuclear weapons testing in the 1970’s. Had the EPA* (*should be PNPS Pilgrim Nuclear Power Station) been correct, the state of Connecticut would have been the most severely impacted since it received up to eleven inches of rain from the same storm with well documented severe damage.
The third variable studied was temperature. The period June 3rd through the 20th can only be described as a cool period contributing significantly to a record for the whole month which averaged minus four degrees F. With this cool temperature in mind any chance that a heat wave could have contributed to either atmospheric buoyancy or general health problems has been discussed (see map).
To conclude this report all six factors mentioned in the start of the paper play a role in concentrating the radiation releases were operative. However, special attention should be placed on the significant rainstorm of June 5th through the 6th which followed the releases reported on June 3rd and also the rainstorm of June 11th, 13th and 14th which followed the reported releases of June 11th. It is the concluding opinion of this paper that the meterology which affected the Massachusetts lowland microclimate greatly intensified the radiation problem within the area.
OBTAINED FROM THE FREEDOM OF INFORMATION ACT