TABLE OF CONTENTS, SECTION 6:

1. RADNET Nuclear Accident Radiation Protection Guidelines (draft)

Introduction:  Types of Nuclear Accidents
A. Exposure Pathways

1. Deposition Mechanisms
2. Exposure Pathway Types

B. Accident Exposure Timetable
C. Protection Actions
D. Ingestion Pathway Bioaccumulation Alert
E. General Notes
F. Other types of Nuclear Accidents

1. Nuclear weapons tests or accidental detonations
2. Chronic weapons production facility and fuel reprocessing facility discharges
3.  Lost licensed devices and medical sources
4.  Uranium-tipped weapons
5.  Nuclear power plants as small nuclear accidents-in-progress

G. Verities of Nuclear Accidents

Introduction: General Radiation Protection Guidelines
A. 1997 Revised FDA Radioactive Contamination Guideline
B. ATSDR Toxicological Profile for Ionizing Radiation
C. MARSSIM draft Multi-Agency Radiation Survey and Site Investigation Manual

A. Early Guidelines (Antediluvian): 1961
B. Revised PAG Guidelines: 1982 and 1992
C. Post-Chernobyl Levels of Concern: 1986
D. Official Protection Action Guidelines for Authorized Persons: A Radiological Paradigm
E. A Radiological Paradigm, Continued
F. Post-Chernobyl National Safety Guidelines for ¹³¹I in Milk (WHO, 1986)

A. USA Programs

• 1. Nuclear Regulatory Commission (NRC)
• 2. Environmental Protection Agency (EPA)
• 3. Department of Energy (DOE)
• 4. Food and Drug Administration (FDA)
• 5. Environmental Measurements Laboratory (EML)
• 6. U.S. Geological Survey (USGS)
• 7. U.S. Intelligence Community


B. Programs Outside the USA

• A. Derived Concentration Guides for Radiation Protection
• B. Post-Chernobyl Radiation Protection Guidelines

This is a draft.. in progress, and we solicit any corrections, comments, criticisms or additions.  We will be adding the marked links next week and finishing proofreading the newest sections.
 

Introduction:  Types of Nuclear Accidents

Accidental Radioactive Contamination of Human Food And Animal Feeds:  Recommendations for State and Local Agencies by the United States Food and Drug Administration lists five different types of nuclear accidents and the types of radionuclides which are dispersed by these accidents.

"The types of accidents and the principal radionuclides for which the DILs were developed are:

• nuclear reactors (I-131; Cs-134 + Cs-137; Ru-103 + Ru-106),
• nuclear fuel reprocessing plants (Sr-90; Cs-137; Pu-239 + Am-241),
• nuclear waste storage facilities (Sr-90; Cs-137; Pu-239 + Am-241),
• nuclear weapons (i.e., dispersal of nuclear material without nuclear detonation) (Pu-239), and
• radioisotope thermoelectric generators (RTGs) and radioisotope heater units (RHUs) used in space vehicles (Pu-238)." (pg. 13).

• Nuclear weapons tests or accidental detonations

 

Warning:  The most serious type of nuclear accident has not yet occurred:  Detonation of multiple nuclear warheads at a Russian or U.S. nuclear storage complex such as that at Pantex, TX, in which case you won't need this or any other accident protection guideline.

• Chronic weapons production facility and fuel reprocessing facility discharges (e.g. Hanford, Savannah River, Rocky Flats, Sellafield (UK) , Marcoule (FR), Russian weapons production and fuel reprocessing installations, etc.)

 

Note:  The largest and most significant accident to-date may not be the Chernobyl accident in 1986, but rather, the huge liquid discharges of nuclear waste effluents to the North Sea from the various facilities within the Sellafield, UK fuel reprocessing complex.

• Lost licensed devices and medical sources
• Uranium-tipped weapons
• Nuclear power plants (chronic operational, decommissioning and accidental releases.)  See Section F for an analysis of the Maine Yankee Atomic Power Company as a (small) nuclear accident-in-progress.

1. Deposition Mechanisms:

In any nuclear accident, the radioactive plume results in two types of ground deposition:  dry deposition and wet deposition. Some types of nuclear accidents can result in only the slow, chronic release of liquid effluent contamination, e.g. fuel reprocessing activities at the Sellafield (UK) and Marcoule (FR) where liquid effluent dispersal is more important than the airborne plume.  In this situation, the primary exposure pathway will be the ingestion pathway.
 

2. Exposure Pathway Types:

There are four basic pathways of human exposure to contamination resulting from nuclear accidents of any kind.

a.  External Exposure

(1.)  Facility (accident location) radiation shine
(2.)  Plume cloud shine
(3.)  Ground shine

b.  Absorption (Dermal Deposition)
c.  Inhalation

(1.)  Plume inhalation
(2.)  Resuspended ground deposition inhalation

d.  Ingestion

(1.)  Primary:  Ingestion from foliar and surface contamination
(2.)  Secondary:  Ingestion of contamination via pathways to human consumption such as the forage - cow - milk pathway
(3.)  Tertiary:  Ingestion of contamination via indirect pathways to human consumption, e.g. the incorporation of contaminated whey into processed foods and their redistribution to markets in areas unaffected by ground deposition

In any nuclear accident, there are two fundamental protective action options:  evacuation or sheltering.  Persons living in the vicinity of any nuclear facility during a major nuclear accident have only one viable option:  evacuation to an unimpacted area.  This is easier said than done because, in most accident situations, including Chernobyl, the authorities, whether the NRC or any other governmental authority, had or will have minimal information about the amount of contamination (source term) in and direction of the plume passage.  The Chernobyl accident illustrates the possibility that population groups could be evacuated from the immediate area of the accident (+/- 10 km) and moved to distant areas (+/- 200 km) and actually be entering areas with greater amounts of ground contamination than occurred in the immediate vicinity of the accident.  Governmental agencies responsible for nuclear accidents can almost always be relied upon to provide inaccurate or insufficient information with respect to plume pathways and deposition activity.  Unless you are sure you are close to and downwind from a major nuclear accident, immediate sheltering to avoid the most intense short-lived activity in the passing plume is usually your safest option.

Evacuation:

All situations requiring evacuation are characterized by the following safety precautions:

• Access control to the contaminated area.
• Control and sheltering of livestock.
• Control and sheltering of animals if not already evacuated.
• Food and water controls.
• Decontamination efforts.
• Relocation.

• Seek immediate shelter.
• In the likely event that no stocked fallout shelter is available, the safest option is usually sheltering within one's own residence.
• If you are still outside and you haven't been able to seek shelter yet, or for some urgent reason you must go outside during plume passage, remember that a simple particulate respirator (dust mask) is an essential first line of protection against inhaling plume pulse particulates (see note in Section F-5 below.)
• As soon as you reach shelter, close all windows and doors to minimize inhalation of passing plume.
• Avoid using surface water supplies and rainwater.
• Avoid exposure of children to contaminated surface water (puddles and rain) and ground contamination.
• Avoid tracking in ground deposition:  remove contaminated clothing and footwear.
• Avoid consumption of foods contaminated with surface deposition, especially leafy vegetables with foliar contamination.  Also avoid fruits such as raspberries, which are difficult to wash and food which rapidly bioaccumulates contamination, such as mushrooms and sea vegetables.  Otherwise wash and peel vegetables (such as root crops, e.g. carrots, potatoes) which would not otherwise be contaminated.
• Avoid consuming foods subject to rapid secondary ingestion pathway contamination, e.g. forage - cow (sheep, goat) - milk (cheese) pathway.  Use food products produced and/or packaged prior to plume passage whenever possible.
• Shelter livestock and pets; use uncontaminated feeds.
• Avoid exposure to surface ground contamination by staying indoors as much as possible.
• Cover garden sites with tarps prior to plume passage if time permits.
• Utilize greens grown in a greenhouse situation whenever possible.
• Package, box or bag contaminated clothing and footwear and remove from immediate vicinity of the living quarters if possible.
• Vacuum rugs, sweep floors and package or box resulting detritus as a contaminated substance and remove from immediate vicinity of living quarters if possible.
• Due to filtering and/or diluting all subsurface water sources and most public drinking water, sources will remain relatively safe after most types of nuclear accidents.
• In the days after a nuclear accident, if you have avoided inhalation of the passing plume and if you can avoid extensive exposure to ground deposition, your principal pathway of exposure will be the ingestion pathway.

Know your bioaccumulators.  If you can avoid the primary ingestion pathway, including foods such as leafy green vegetables, berries, broccoli and cauliflower contaminated with surface deposition (foliar contamination,) the principle ingestion exposure pathway would likely result from secondary contamination of the following foods which are quickly contaminated after a nuclear accident:

• milk and milk products
• cheese, including goat cheese
• tea, if not packaged and produced prior to plume passage
• sea vegetables
• mushrooms
• sheep and cattle grazing on contaminated forage
• reindeer and any other animals grazing on contaminated moss and lichens
• shellfish

• It is safe to eat any food produced and packaged prior to the plume passage.
• Saltwater fish, due to the diluting effects of the ocean, accumulate much less fallout than fresh water species.
• Most underground and artesian water supplies will be relatively unaffected by fallout deposition.
• Most root vegetables, even if grown in contaminated soils, will not contain huge quantities of the most important short-lived radionuclide, ¹³¹I, which contaminates leafy green vegetables and the forage pathways immediately after a nuclear accident.
• Root vegetables may take up biologically available long-lived radionuclides such as ¹³⁷Cs, but not in sufficient quantities to constitute an immediate health hazard.

Know your biologically significant radionuclides.

(1/2 T = the radiological half-life, that is the time it takes for one half of the radioactivity to decay in any radioactive substance)

• Some ubiquitous radionuclides dispersed in nuclear accidents are unreactive and inert and, as such, are not biologically significant, e.g. ⁸⁵Kr (Krypton-85, a gas).  ⁸⁵Kr is is an inert unreactive gas and, therefore, does not bioaccumulate in pathways to human consumption.  The only exposure pathways are external exposure and absorption.
• ¹³¹I (Iodine-131) is a short-lived (1/2 T = 8 days) but very biologically significant radionuclide which is very volatile.  After contaminating forage, ¹³¹I moves quickly through pathways to human consumption.  Its target organ is the thyroid.
• ¹³⁴Cs (1/2 T = 2.062 years) and ¹³⁷Cs (1/2 T = 30.174 years) are among the most biologically significant radionuclides due to their mobility and radiological toxicity.  Cesium follows the potassium cycle in nature and its target organ is the entire body.
• Strontium, ⁸⁹Sr (1/2 T = 50.55 days) and ⁹⁰Sr (1/2 T =28.82 years) follow the calcium cycle in nature and are bone-seeking radionuclides.
• Ruthenium, ¹⁰³Ru (1/2 T = 39.8 days) and ¹⁰⁶Ru (1/2 T = 1 year) are particularly ubiquitous components of nuclear reactor accidents but also have low radiotoxicity.  Their target is the lower large intestine.
• Tritium, ³H (1/2 T = 12.346 years) is a ubiquitous component of nuclear industries and is a volatile form of radioactive water.  Though tritium quickly achieves equilibrium in the environment, it also becomes tissue bound, and, as a form of radioactive water, its target is the whole body.
• Plutonium, ²³⁹Pu (1/2 T = 24,131 years) is among the most biologically significant  and highly radioactive of all radionuclides.  As an alpha emitter and, thus, without any penetrating power compared to beta and gamma emitters, plutonium is particularly hazardous if inhaled either directly from the plume passage or, most especially, from resuspended ground deposition activity.  Due to its long half-life, ²³⁹Pu is the most important radioisotope in the very late stages of a nuclear accident (100 years to 10,000 years).  Plutonium is a bone-seeking radionuclide; in its oxide form, it is not readily absorbed through the gut, but, upon aging, it can change its chemical form and become more biologically available in the years after ground deposition.
• Technetium, ⁹⁹Tc (1/2 T = 212,000 years) is particularly associated with nuclear fuel reprocessing and fuel reprocessing accidents.  It is a very volatile radionuclide and as with tritium, impossible to filter or control.  Little information is available about technetium and its behavior in the biosphere, but recent radiological surveillance activities in the United Kingdom and in Denmark have shown that it accumulates to alarming levels in lobsters.
• Americium, ²⁴¹Am (1/2 T = 432 years) is a decay product (daughter product) of ²⁴¹Pu (1/2 T = 14.355 years) and "grows in"  as ²⁴¹Pu decays.  ²⁴¹Am is a highly mobile and radiotoxic isotope with high concentration ratios in both fresh water and marine environments.  When ²⁴¹Am decays, it "grows into" ²³⁷Pu.
• Plutonium, ²³⁸Pu (1/2 T = 87.71 years) is the third most common constituent in spent fuel and, thus, one of the most biologically significant radionuclides associated with an accident at a fuel reprocessing facility such as Sellafield in the UK.  ²³⁸Pu is used as an energy source in satellites with RTGs (radioisotope thermoelectric generators) and is therefore the principal component of nuclear powered satellite accidents.

(1 Bq = one becquerel = 1 disintegration per second = 27 pCi = 27 picocuries.  One picocurie = 2.2 disintegrations per minute)

• Cesium-137:  10,000 pCi/kg.  After the Chernobyl accident, the FDA implemented a "level of concern" such that imported foods contaminated with more than 10,000 pCi/kg of either cesium-137 or a combination of cesium-137 and cesium-134 were seized.  The FDA also issued guidelines for ¹³¹I:  8,000 pCi/kg for general use foods 1,500 pCi/kg for infant foods.
• Iodine-131:
• The federal standard for Iodine-131 in drinking water is 300 pCi/l(11 Bq/l).
• The federal standard for Iodine-131 in air is 100 pCi/m³.
• WHO intervention levels for contaminated milk
• Becquerels per liter = Bq/l; multiplied by 27 = pCi/l = picocuries per liter

Generic action levels for contaminated foodstuffs (implemented after the Chernobyl accident):

FDA derived intervention levels (DILs) August 13, 1998, for all components of the diet:

 

Radionuclide Group	Bq/kg			pCi/kg
Sr-90	160			4320
I-131	170			4590
Cs-134 + Cs-137	1200			32,400
Pu-238 + Pu-239 + Am-241	2			54

• The Federal Emergency Management Agency (FEMA) has a surface contamination guideline of "300 counts per minute above background" for authorized persons entering an emergency operations center (EOC) during an accident at an NRC licensed nuclear facility.  (Three hundred counts per minute (300 cpi) equals 660 pCi per person; it can be assumed that each authorized person has an absolute minimum of 1 square meter of surface area.)
• The surface contamination guideline for authorized persons contrasts sharply with a 1982 U.S. Department of Health and Human Services emergency protection action guideline (PAG) which is nuclide-specific and includes the following initial ground deposition action guidelines for members of the general public.  The following chart was initially issued with the reporting units of microcuries/square meter, kilogram, etc.  We have changed it to picocuries (1 microcurie = 1,000,000 picocuries) to provide a more accurate contrast with the FEMA guidelines which are in counts per minute. (1 count/minute = 2.2 picocuries/minute.)

RADNET has included this older protection action guideline in our current radiation protection guidelines because, in the event of a serious nuclear accident at an NRC licensed facility, the above 1982 guideline is the one likely to be used by the NRC and its licensees in informing the public about the relative risks of the resulting contamination.  The NRC and its licensees have not acknowledged the publication of the 1998 FDA guidelines for contaminated food, nor is it likely that the FDA guidelines for contaminated food will be of any interest to the NRC and its licensees in an accident situation.

1. Nuclear weapons tests or accidental detonations

Each and every nuclear weapons test explosion, whether by Russia, France, England, China, India, Pakistan or the United States constitute a defacto nuclear accident.  In the case of an accidental or deliberate detonation of one or more nuclear warheads, all of the isotopes, except Pu-238, that are listed by the FDA for all types of nuclear accidents, would be the principle radionuclides of concern.  Other important radionuclides associated with the detonation of nuclear weapons include barium-140, lanthanum-140, niobium-95, tellurium-132, and zirconium-95.

The early phase of this type of accident would only last as long as detonation and plume passage, often as little as 24 hours.  The intermediate phase of a nuclear weapons detonation as a nuclear accident would begin as ¹³¹I is quickly taken up in forage pathways.  The late phase would begin soon after the intermediate phase with secondary ingestion of contaminated food as well as continued external exposure from ground deposition.  The very late phase of nuclear weapons detonations-as-accidents, which reach their peak during the early 1960's with intensive Russian and American nuclear weapons tests, continue today with the inhalation of re-suspended ground deposition (e.g. ²³⁹Pu).

2. Chronic weapons production facility and fuel reprocessing facility discharges

The following principal weapons production and fuel reprocessing chronic accidents-in-progress can best be evaluated by linking to the many bibliographic citations which provide descriptions of the effluent discharges from these facilities.

• U.S.A.:  Hanford, Savannah River, Oakridge National Laboratory, Rocky Flats Environmental Technology Site, Los Alamos National Laboratory (2 Ohio - Fernald, ??)
• Russia:  We have minimal information on numerous Russian weapons production and fuel reprocessing sources of chronic contamination, but a review of the citations we have in RAD 11:  Part 6 is sufficient to suggest that the net effect of all chronic discharges from Russian point sources may be greater than any other single nuclear accident which has happened to-date and will most likely surpass the more well documented emissions from the Sellafield complex in northern England.
• Sellafield:  The most well documented of all chronic nuclear accidents-in-progress
• Marcoule (FR):  Another important chronic nuclear accident-in-progress about which little or no information is available.

This section is under research and construction

4.  Uranium-tipped weapons

This section is under research and construction

5.  Nuclear power plants as small nuclear accidents-in-progress

RADNET has used the Maine Yankee Atomic Power Company (MYAPC) in Wiscasset, Maine as a case study for analysis of safety, legal, economic and decommissioning issues pertaining to nuclear power plant operation.  This facility may also be used as an example of a nuclear power plant as a small nuclear accident-in-progress.  MYAPC began operation in 1972 and was closed in 1997.  Operational and decommissioning discharges of anthropogenic radioactivity may be divided into the following categories:

• Chronic gaseous emissions during plant operation (1972 - 1997).
• Gaseous plume pulse discharges during reactor containment purges (1972 - 1997).  Reactor containment purges occur whenever the reactor is shut down and the spent fuel is removed and replaced.
• Chronic liquid discharges during plant operation (1972 - 1997).  These liquid discharges are a result of routine plant operations; Montsweag Bay was and continues to be the repository of all such deliberate discharges.
• Elevated fission product emissions associated with fuel cladding failure (1972 - 1975?).  Most contamination associated with fuel cladding failure would be in the form of liquid emissions to Montsweag Bay.
• Incidental and inadvertent loss of radiological controls (1972 - 1997).  These unplanned releases of radioactive material can include gaseous, liquid and particulate emissions from a variety of scenarios.  Sometimes these incidents are detailed in NRC public documents in the form of licensee event reports (LER); more frequently these losses of radiological controls are the subject of secret radiological incident reports (RIR) which are generally not made public.
• Specific nuclear accidents:  Sometimes, routine losses of radiological controls rise to the level of a nuclear accident.  Such was the case with a March, 1984, 7,000 gallon leak at the MYAPC reactor water storage tank (RWST) which spread contamination over an area in excess of 10,000 square feet.  Another specific nuclear accident of an unknown type resulted in the contamination of Bailey Point with a large fragment of nuclear material.
• Chronic hot particle contamination (1972 - 1999).  It has recently been disclosed that hot particle contamination is a routine component of plant operations.  Hot particle contamination can involve the discharge of spent fuel fragments as well as CRUD discharges which result from the flaking and mobilization of activation product scaling from plant equipment such as the reactor vessel internals.  Charles Hess documented an incident of hot particle contamination in Montsweag Bay in 1974.
• Decommissioning activities liquid emissions (1997 - ?).  As a normal component of decommissioning activities at all nuclear power plants, contaminated stored water is routinely discharged into local waters, in the case of MYAPC, Montsweag Bay.  During 1998, at least 5 tanks were drained during decommissioning activities, the largest discharge being a 300,000 gallon release of radioactive water during May, 1998 from the reactor water storage tank, the same one that leaked in 1984.  approximately 10,000 gallons of the most radioactive water and silts at the bottom of this tank were withheld from this discharge and remain at the bottom of the tank.  Other tank discharges occurring during decommissioning activities include the neutron shield tank and .... (information not available.)
• Decommissioning activities hot particle contamination (1999 - 2000?).  Among many routine decommissioning activities that have the potential to result in uncontrolled discharge of radioactive materials include the underwater segmentation of the reactor vessel internals, many of which are highly radioactive class C or greater than class C (GTCC) stainless steel components.  During the segmentation process, which must occur underwater due to the high radiation fields emanating from the reactor vessel internals, large quantities of contaminated radioactive water are produced.  All of this radioactive water has the potential to be contaminated with activation and fission products including spent fuel fragments and especially CRUD activation products.  While much of this contamination may be successfully filtered out prior to discharge of these effluents to Montsweag Bay, the likelihood exists that the maximum peak of hot particle contamination resulting from the Maine Yankee Atomic Power Company as a small nuclear accident-in-progress will occur in the future, during and after reactor vessel segmentation.
• Reactor vessel dross (1999 - ?).  During the decommissioning process and following reactor vessel internal component segmentation, the likely destination of the intact reactor vessel is a near surface landfill disposal area (e.g. Barnwell, SC).  The Yankee Rowe (MA) reactor vessel was buried at Barnwell containing thousands of curies of uncharacterized "dross" which likely contained long-lived spent fuel hot particles as well as CRUD activation products.  The same scenario will apply to the deconstruction of MYAPC or any other nuclear reactor in any location.
•  Airborne particulates (1972 - 2002?).  Airborne particulates, a component of routine gaseous emissions, also have the potential to occur during (uncontrolled) decommissioning demolition activities as a result of the unavoidable spread of radioactive dusts and fibers.  This is particularly true of the rapid decommissioning techniques used in the DECOM method of decommissioning rather than the SAFESTOR method, which postpones deconstruction of contaminated building components.

Note:  The greatest hazard of a normally operating nuclear power plant occurs during reactor containment purging, just prior to removal of spent fuel.  For persons living immediately down wind of the reactor containment (< 5 miles), use of a particulate respirator, which can provide some protection against inhalation of particulates during the plume passage in any kind of nuclear accident may also be a prudent protective action.  Obviously, sheltering during reactor containment purging is the most preferable protection action, but for persons who must be outside, use of the particle respirator is an excellent protective action to avoid accidental inhalation of particulates released during containment purging.

Particulate respirators can be purchased from Northern Safety Co., Inc., (800) 631-1246.  They offer several styles of design in price ranges from $10 to $50.
 

G. Verities of Nuclear Accidents

• Contamination resulting from almost every conceivable type of nuclear accident will almost always be well within authorized release limits.
• Information about accident ground deposition and ingestion pathway concentration levels involving complex radiochemical or gamma ray spectroanalyses will generally not be available after a nuclear accident.

These types of analyses are time-consuming and must be done in a laboratory setting; the results of these analyses are unlikely to be available in the few months following any kind of major nuclear accident.
• In regard to plutonium:  "the fate of the sediment is the fate of the plutonium" (Graf, W.L., 1994, Plutonium and the Rio Grande:  Environmental Change and Contamination in the Nuclear Age, Oxford U. Press, pg. 3)
• The following quote from Hardy, et.al., 1986, report no. EML-460, pertaining to Chernobyl fallout in Skutskar, Sweden, will be the likely response of authorized information sources in any future nuclear accident.  "The dose and subsequent health risks to the population of Western Europe are minimal." (pg. 259).
• In the event of a nuclear accident, the most intense levels of contamination are associated with rain and snowfall events.  In case of a nuclear accident, watch the weather channel carefully.

United States Food and Drug Administration. (March 5, 1997). Draft: Accidental radioactive contamination of human food and animal feeds: Recommendations for state and local agencies. Center for Devices and Radiological Health, U.S. FDA, Washington, D.C.

• This draft was issued on 3/5/97, but not received as requested for review by RADNET until August 9, 1997. This proposed draft represents a radical revision of the 1982 FDA recommendations, which are rescinded by these proposed standards.
• Derived intervention levels are far stricter (more conservative) than the 1982 regulations. Derived intervention levels for the radiocesium group (1,160 Bq/kg for 15 year old = 31,320 picocuries/kg) are far closer to the "levels of concern" which resulted in seizure of food containing 10,000 picocuries/kg of radiocesium following the Chernobyl accident.
• The most radical change in these guidelines is the inclusion of numerous additional radionuclides for consideration following a nuclear reactor or other type of nuclear accident. (See Appendix E). The derived intervention level for transuranic nuclides such as ²³⁸Pu, ²³⁹Pu and ²⁴¹Am range from 2.0 to 2.5 Bq/kg for a 3 month old infant. These more inclusive guidelines are an acknowledgment of the lessons of the Chernobyl accident, i.e. a major nuclear accident includes many different radionuclides whose health physics impact can not be delineated by a single protection action guideline standard such as 10,000 picocuries (370 Bq).
• The one significant unfortunate lapse in this draft is the use of the "number of samples contaminated above regulatory limits" to summarize contamination levels derived from the Chernobyl accident without reference to the specific levels of contamination in the samples analyzed. (See tables C-1, C-2, and C-3). This continues the FDA inclination to withhold nuclide-specific data after incidents of widespread contamination of foodstuffs. The substitution of an arbitrary action limit to replace nuclide-specific data illustrates that the FDA is still inclided to withhold information about rising levels of radioactive contamination in the food chain. In the event of another accident the use of this arbitrary limit raises the question: will the FDA withhold data if contamination trends up towards the derived intervention level? All levels of contamination below the DIL, are after all, "below regulatory limits."
• "Recommendations on accidental radioactive contamination of human food and animal feeds were issued in 1982 by the Food and Drug Administration (FDA) (FDA 1982, Shleien et al 1982). Since then, there have been enough significant advancements related to emergency planning to warrant updating the recommendations." (pg. 1).
• "DILs [Derived Intervention Levels] are limits on the concentrations permitted in human food distributed in commerce. ... Comparable limits were not provided in the 1982 FDA recommendations. DILs apply during the first year after an accident." (pg. 3).

 

Table D-5 (pg. D-13)
DERIVED INTERVENTION LEVELS (Bq/kg)
(individual radionuclides, by age group, most limiting of either PAG)
Radionuclide	3 months	1 year	5 years	10 years	15 years	Adult
Sr-90	308	362	616	389	160	465
I-131	196	167	722	1200	1690	2420
Cs-134	1600	2190	1940	1530	958	930
Cs-137	2000	2990	2810	2180	1370	1360
Cs group(a)	1800	2590	2380	1880	1160	1150
Ru-103	6770	8410	12200	16400	25000	28400
Ru-106	449	621	935	1340	2080	2360
Pu-238	2.5	21	17	14	12	10
Pu-239	2.2	18	14	13	10	9.8
Am-241	2.0	17	13	11	9.1	8.8
Pu+Am group (b)	2.2	19	15	13	9.6	9.3
(a) Computed as: (DIL for C2-134 + DIL for Cs-137) /2
(b) Computed as: (DIL for Pu-238 + DIL for Pu-239 + DIL for AM-241) /3

• "The 1982 FDA recommendations were developed from the prevailing scientific understanding of the relative risks associated with radiation as described in the 1960 and 1961 reports of the Federal Radiation Council (FRC 1960, 1961). Since 1982, FDA and the other federal agencies in the United States have adopted the methodology and terminology for expressing radiation doses provided by the International Commission on Radiological Protection (ICRP) in 1977 (ICRP 1977, ICRP 1984a, EPA 1987)." (pg. 5).
• "The equation given below is the basic formula for computing DILs.
 

	intervention level of dose (Sv)
DIL (Bq/kg) =
	f x Food Intake (kg) x DC (Sv/Bq)

Where:
DC = Dose coefficient; the radiation dose received per unit of activity ingested (Sv/Bq).
f = Fraction of the food intake assumed to be contaminated.
Food Intake = Quantity of food consumed in an appropriate period of time (kg)." (pg. 8).
• "The food monitoring results from FDA and others following the Chernobyl accident support the conclusion that I-131, Cs-134 and Cs-137 are the principal radionuclides that contribute to radiation dose by ingestion following a nuclear reactor accident, but that Ru-103 and Ru-106 also should be included (see Appendix C)." (pg. 10). ... "DIL is equivalent to, and replaces the previous FDA term Level of Concern (LOC)." (pg. 12).
• "The types of accidents and the principal radionuclides for which the DILs were developed are:
• nuclear reactors (I-131; Cs-134 + Cs-137; Ru-103 + Ru-106),
• nuclear fuel reprocessing plants (Sr-90; Cs-137; Pu-239 + Am-241),
• nuclear waste storage facilities (Sr-90; Cs-137; Pu-239 + Am-241),
• nuclear weapons (i.e., dispersal of nuclear material without nuclear detonation) (Pu-239), and
• radioisotope thermoelectric generators (RTGs) and radioisotope heater units (RHUs) used in space vehicles (Pu-238)." (pg. 13).
• "For each radionuclide, DILs were calculated for six age groups using Protective Action Guides, dose coefficients, and dietary intakes relevant to each radionuclide and age group. The age groups included 3 months, 1 year, 5 years, 10 years, 15 years and adult (>17 years). The dose coefficients used were from ICRP Publication 56 (ICRP 1989)." (pg. 14).
 

 
Table 2 (pg. 16)
Recommended Derived Intervention Levels (DILs)
or Criterion for Each Radionuclide Group

All Components of the Diet

Radionuclide Group	(Bq/kg)			(pCi/kg)
Sr-90	160			4300
I-131	170			4600
Cs-134 + Cs-137	1200			32,000
Pu-238 + Pu-239 + Am-241	2			54
Ru-103 + Ru-106	C3 -------- +  6800	C6 -------- 450	< 1	C3 ---------- + 180,000	C6 --------- 12,000	< 1

• "Typical precautionary actions include covering exposed products, moving animals to shelter, corralling livestock and providing protected feed and water." (pg. 20). "The blending of contaminated food with uncontaminated food is not permitted because this is a violation of the Federal Food, Drug and Cosmetic Act (FDA 1991)." (pg. 22).
• "In 1986, FDA received a variety of foods collected locally by United States Embassy staff in Central and Eastern European countries. A total of 48 samples from Bulgaria, Czechoslovakia, Finland, Hungary, Poland, Romania, Russia, and Yugoslavia, were analyzed. Results for Ru-103, Ru-106, and Ba-140 are summarized in Table C-3." (pg. C-4). "In September 1986, 28 samples of spices from Turkey and Greece (not offered for import) were provided by the American Spice Trade Association (ASTA) for testing by FDA. ... a dilution factor of ten was applied to the concentrations for this category of foods [see table C-3, pg. C-10]." (pg. C-5).
• "The results support the expectation that concentrations of I-131 and Cs-134 + Cs-137 would serve as the main indicators of the need for protective actions for imported and local food. However, concentrations of Ru-106 were consistently in excess or at a significant fraction of the DIL, which suggests that Ru-106 should also serve as an indicator, i.e. be included as a principal radionuclide for nuclear reactor incidents. ... for local samples of fresh vegetables harvested during the first week of the incident, half of the samples had Ru-103 concentrations a significant fraction of the DIL and another quarter of the samples had Ru-103 concentrations in excess of the DIL. Consequently, it would be prudent to consider Ru-103 as a principal radionuclide for local deposition, particularly in the early phase of a nuclear reactor incident." (pg. C-6).
• "Also, the analytical method for determination of Sr-90 in food is lengthy compared to analysis for the gamma-ray emitting radionuclides, such that protective actions based on the concentration of Sr-90 could not be taken in a timely manner. Therefore, Sr-90 would not be an effective indicator of the need for protective actions in the early phase of a nuclear reactor incident." (pg. C-7).
• "During the first year after an accident, concentrations in local or imported food other than for I-131, Cs-134, Cs-137, Ru-103, and Ru-106 are expected to be significant only when one or more of these principal radionuclides has exceeded its DIL. Therefore, the food would already have been subject to protective action." (pg. C-7).
• "For food consumed by most members of the general public, ten percent of the dietary intakes was assumed to be contaminated. This assumption recognizes the ready availability of uncontaminated food from unaffected areas of the United States or through importation from other countries, and also that many factors could reduce or eliminate contamination of local food by the time it reaches the market. ... "FDA applied an additional factor of three to account for the fact that subpopulations might be more dependent on local food supplies. Therefore, during the immediate period after a nuclear accident, a value of 0.3 (i.e., thirty percent) is the fraction of food intake that FDA recommends should be presumed to be contaminated. ... For infants, (i.e., the 3-months and 1-year age groups) the diet consists of a high percentage of milk and the entire milk intake of some infants over a short period of time might come from supplies directly impacted by an accident. Therefore, f was set equal to 1.0 (100%) for the infant diet. ... DILs are presented in Table D-4 for Sr-90, I-131, Cs-134, Cs-137, Ru-103, Ru-106, Pu-238, Pu-239, and Am-241 for six population age groups and applicable PAGs." (pg. D-4, 5).
• "After a reactor accident, radionuclides other than the principal radionuclides may also be detected in the food supply, ... The DILs for fifteen other radionuclides were determined by the same procedure used in Appendix D." (pg. E-1).
• "Fractions of food intake assumed to be contaminated (f) are: 0.3 for all radionuclides except Te-132, I-133, and Np-239 in infant diets (i.e., the 3-month and 1-year age groups); 1.0 for Te-132, I-133 and Np-239 in infant diets." (pg. E-2).
• "During the immediate period after a nuclear reactor accident, ... Once food monitoring data is available, the recommended DILs or criterion for the principal radionuclides I-131, Cs-134 + Cs-137, and Ru-103 + Ru-106 ... should be used. The more complex radiochemical or gamma-ray spectrometric analyses for the fifteen other radionuclides listed in this Appendix would not be generally available." (pg. E-3,4).
 

 
Table E-6 (pg. E-9)
DERIVED INTERVENTION LEVELS (Bq/kg)
Most limiting of Derived Intervention Levels for the 5 mSv H_E or 50 mSv H_T
(individual radionuclides, by age group)

Radionuclide	3 months	1 year	5 years	10 years	15 years	Adult
Sr-89	1400	2400	3600	4500	5800	87
Y-91	1200	1600	2300	3000	5300	59
Zr-95	4000	5000	7000	9700	14000	16000
Nb-95	12000	14000	19000	26000	35000	40000
Te-132	4400	7300	35000	59000	89000	150000
I-129	110	76	72	56	68	84
I-133	7600	7000	30000	56000	79000	130000
Ba-140	6900	7900	11000	15000	27000	29000
Ce-141	7200	92	12000	18000	29000	34000
Ce-144	500	670	1100	1400	2300	2700
Np-227	4	37	27	22	16	15
Np-239	28000	36000	180000	260000	400000	460000
Pu-241	120	970	720	550	490	480
Cm-242	19	130	180	240	340	390
Cm-244	2	13	16	18	19	18

• Neither the FDA nor any other U. S. Government agency has the capacity for the rapid and timely monitoring, analysis and reporting of radioactive contamination in any significant quantity of foodstuffs during a nuclear accident of any type. 1950's era laboratory capacity remains unimproved in an era of funding shortages. In the event of a nuclear accident, neither the FDA or any other agency would be able to determine whether intervention to prevent consumption of contaminated foodstuffs is justified or necessary. These revised DIL's are a step in the right direction but have no real world credibility in the event that extensive foodstuffs monitoring becomes necessary.
• The peak pulse of Chernobyl derived radiocesium in imported foods was observed by the FDA in 1987, ten to sixteen months after the accident began. At no time since the Chernobyl accident has the full body of raw data been available to the general public; the Center for Biological Monitoring obtained this information via a Freedom of Information Request. The FDA report on Chernobyl contamination took nine years to prepare and the result was only a few pages of clever disinformation.
• A full copy of the raw data collected by the FDA is available from the Center for Biological Monitoring for a charge of $12.00 for copying and mailing. For a summary of the FDA survey of Chernobyl derived contamination in imported foods see RADNET Section 9, Part 4: Chernobyl Peak Pulse in U.S.A. Imported Foods.

United States Department of Health & Human Services. (September 1997). Draft for public comment: Toxicological Profile for Ionizing Radiation. Prepared by: Research Triangle Institute for the US Dept. of Health & Human Services, Public Health Service, Agency for Toxic Substances and Disease Registry, Atlanta, Georgia.IS.

The Agency for Toxic Substances and Diseases Registry developed this toxicological profile as a component of the CERCLA, also known as the Superfund Act. This toxicological profile is probably the most important publication issued by the federal government pertaining to ionizing radiation. The editor of RADNET will make a number of critical comments about this draft in the following review. These criticisms should in no way detract from the importance of the publication of this toxicological profile since it is the first attempt at a comprehensive analysis of the health physics significance of ionizing radiation in the United States. Despite the deficiencies discussed below, this draft ushers in a new era in government publications due to its innovative inclusion of Internet URL addresses for links to important information sources pertaining to ionizing radiation. These addresses are included in the references in Section 10 of this report both as a component of some citations which can be accessed electronically as well as separately under the heading http: in the bibliography.

In our opinion this toxicological profile for ionizing radiation raises the following central issue: how can dosimetric models documenting the health physics impact of ionizing radiation be used to estimate doses from radioactive substances taken into the body without a much more complete knowledge of actual media specific, nuclide specific levels of contamination? The credibility of the dosimetric models used in this and other reports is undercut by a lack of pathway analyses for all radionuclides in all pathways in all ecosystems - a Herculean task not discussed in this profile. Current NRC criteria for decommissioning nuclear facilities such as the Maine Yankee Atomic Power Company are based on the effective use of radiological dose as the appropriate measure for the decommissioning of radiologically contaminated areas. In the case of the NRC, the primary decommissioning guideline is 25 mrem/yr TEDE (total effective dose equivalent) from all radionuclides in all pathways. Both the NRC and the ATSDR profile fail to emphasize the significance of comprehensive a priori pathway analyses as a basis for credible dosimetric evaluation. Concurrent unresolved issues which further undercut the credibility of current dosimetric models include the problem of exposure to ionizing radiation not high enough to evaluate statistically and the lingering controversies pertaining to the delayed effects of exposure to low levels of ionizing radiation. The general problem of insufficient data with respect to nuclide-specific, media-specific analyses within particular pathways and ecosystems is not discussed in detail in this publication but is occasionally referenced as in the following quotation under the heading "Identification of data needs": (4.10, pg. 189) "Some human data do exist on the health effects associated with acute exposure to ionizing radiation (see Chapters 3 and 5); however, most of the potential effects have been derived from laboratory animal data. It would be helpful to estimate the dose of radiation each of these individuals was exposed to and monitor these people over the long term to determine what health effects (if any) these doses of ionizing radiation had on lifespan, cancer rates, and reproductive effects. There is ongoing research in these areas."

The publication of this profile is a giant step in the direction of federal sponsorship of a comprehensive protection action guideline for ionizing radiation, the criticisms made in the following annotation notwithstanding.

• "The ATSDR toxicological profile succinctly characterizes the toxicologic and adverse health effects information for the hazardous substance described therein." [ionizing radiation] (pg. v).
• "The focus of the profiles is on health and toxicologic information; therefore, each toxicological profile begins with a public health statement that describes, in nontechnical language, a substance's relevant toxicological properties." (pg. v).
• The toxicological profile on ionizing radiation includes the following topics 1-8 plus the Glossary:
1. Public health statement
2. Principles of ionizing radiation
3. Summary of health effects of ionizing radiation
4. Radiation accidents
5. Mechanisms of biological effects
6. Sources of population exposure to ionizing radiation
7. Regulations
8. Observed health effects from radiation and radioactive material
• "No Minimal Risk Levels (MRLs) have been derived for any route of exposure in this profile at this time. However, ATSDR is currently in the process of examining and critically evaluating the large database of health effects caused by exposure to ionizing radiation. During this evaluation process, ATSDR is also examining many other factors, including (1) which specific studies would lend themselves to be most suitable for deriving an MRL, and (2) what health effect(s) an MRL should be based upon (cataract formation, reduction in IQ, etc.). Any MRLs that are derived will be integrated into the final version of this profile." (pg. 19).
• Table 2.2, Effective Half-Lives of Selected Radionuclides in Major Adult Body Organs, is significant in that it omits many of the biologically significant radionuclides associated with the nuclear fuel cycle. This is symptomatic of the continuing aversion to a comprehensive documentation of all biologically significant radionuclides in all pathways to human consumption, not only in this profile, but in all federally sponsored publications on this subject.
• Chapter 2 includes a detailed description of equipment used to measure internally deposited as well as external ionizing radiation (pg. 53-69) and includes a listing of relevant Internet sites.
• Table 3.1 on page 72 is the ATSDR priority listing of radionuclides present at Department of Energy NPL sites. This listing is particularly important because it includes naturally occurring radionuclides (NOR) which have been remobilized by anthropogenic activities, especially in the nuclear fuel cycle. This priority listing also excludes some of the principle radionuclides of concern listed in the FDA's new proposed derived intervention level (DIL) guidelines. (See Part 1: 1997 REVISED FDA RADIOACTIVE CONTAMINATION GUIDELINE.) The failure to cite these guidelines in the references or to discuss or include these guidelines in the text is one of the principle shortcomings of this publication and should be remedied in the draft review process by their inclusion in the final report. Chapter 3 is otherwise an excellent general survey of the health effects of ionizing radiation.
• Chapter 4 is a grossly insufficient historical overview of nuclear accidents to date. The discussion of the first accident is symptomatic of the problem of accurate documentation of anthropogenic radioactivity in the environment: the loss of four nuclear weapons over Palomares, Spain in 1966. Maximum levels of surface contamination resulting from the spread of ²³⁹Pu following the chemical explosion of two warheads is listed at just above 60,000 counts per minute per square meter (1,000 Bq/m²). The same authors as those cited here have more recently reported soil contamination over a larger area with 2.2 ha exceeding 1,200,000 Bq/m² (72,000,000 cpm/m²). See RAD 11: Section 12: Palomares: Garcia-Olivares and Iranzo, 1997.
• "Soil contaminated with 700-60,000 cpm (counts per minute: 60,000 cpm corresponds to a contamination level of 462 µg/m²) was mixed with petroleum oil and plowed under to a depth of 8 inches, then covered over with another layer of top soil." (pg. 178). The contaminated soil is in what reporting unit? A kg? A pail full? A fifth of contaminated soil? What wit was so innovative as to institute reporting units of µg/m² for plutonium contamination?
• The excellent summary of the September 11, 1957, plutonium fire at Rocky Flats is a timely reminder that the contamination at RFETS is not limited to the leakage from drums stored at pad 903 as so often implied by much of the current literature on this important source point (see RAD 11: Part 5: Litaor, 1994, 1995, etc.)
• Chapter 6 continues to perpetuate the obsolete model of average lifetime exposure to ionizing radiation. "Less than 1% of the total ionizing radiation to the U.S. population comes from occupational sources, nuclear fallout, the nuclear fuel cycle, or other miscellaneous exposures. The total average annual effective dose equivalent for the population of the United States, natural and anthropogenic, is approximately 360 mrem (3.6 mSv) and is described further in Chapter 1 of this profile (BEIR V 1990)." (pg. 211). The obsolescence of this antiquated model of sources of exposure to ionizing radiation has been dramatically illustrated by the National Cancer Institute Study: Estimating Thyroid Doses of I-131 Received by Americans from Nevada Atmospheric Nuclear Bomb Test. The following quotation from the Executive Summary of the NCI report graphically illustrates this point. "The overall average thyroid dose to the approximately 160 million people in the country during the 1950s was 2 rads. The uncertainty in this per capita dose is estimated to be a factor of 2, that is, the per capita dose may have been as small as 1 rad or as large as 4 rads, but 2 rads is the best estimate. The study also demonstrated that there were large variations in the thyroid dose received by subcategories of individuals. The primary factors contributing to this variation are county of residence, age at the time of exposure, and milk consumption pattens." (pg. 2).
• The exposure levels documented in the NCI report during the 1950's and 1960's as well as those experienced by many communities following the Chernobyl accident in 1986 demonstrate the obsolescence of the ancient paradigms which are perpetuated in the NCRP 1987 report number 93 cited as the basis of the pie chart on page 211 of the ATSDR profile. Prior to publishing a final copy of this report, the ATSDR needs to consider the irrelevance of ivory tower estimations of total average annual effective dose equivalents for large populations when in fact the real issue is the radically variable exposures of specific population groups and individuals to specific sources of ionizing radiation. A truthful 1960's era pie chart incorporating two rads of exposure to ¹³¹I, not to mention the accompanying exposure to all the other longer-lived test explosion fission products and nuclear fuel cycle contaminants, would in no way have any resemblance to Figure 6-1 in this publication. This editor urges the authors of this profile to reconsider the wide range of exposures to the many sources of anthropogenic radioactivity which are generally not less than 1% of total exposure and which can only be documented by the tedious analysis of the TEDE resulting from all radionuclides in all pathways in the site-specific situation, rather than in a theoretical model.
• The discussion of exposure from the nuclear fuel cycle in Section 6.4.3, pages 231-235, constitutes only the briefest of introductions to this Pandora's box of sources of exposure to ionized radiation. In contrast, the discussion of exposure to radiopharmaceuticals used in medicine in the same chapter is excellent.
• Chapter 7 is a discussion of regulations and guidelines applicable to ionizing radiation, but as noted is grossly deficient for its failure to incorporate the FDA's 1997 revised radiation contamination guidelines.
• Chapter 8 discusses the health effects from radiation in four pathways: inhalation, "oral," dermal, and external exposure. The use of the term "oral" in place of the more traditional ingestion pathway references the reluctance of the ATSDR as well as other government agencies including the NRC to execute comprehensive pathway analyses, of which the ingestion pathway is the most important.
• The glossary continues this ritual of evasion: no definitions are provided nor references made to terms such as bioaccumulation, bioindicators, forage pathways, long-lived radionuclides, concentration ratios, etc. In fact nowhere in this publication is there any adequate illustration of pathways of nuclear effluents to man, as illustrated in Platt, et. al. 1973. Empiracal Benefits Derived from an Ecosystem Approach to Environmental Monitoring of a Nuclear Fuel Reprocessing Plant. IAEA-SM-172/31, B-268, pg. 678.

United States Department of Energy, Environmental Protection Agency, Nuclear Regulatory Commission and Department of Defense. (December 6, 1996). Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM): Draft for public comment. NUREG-1575. EPA 402-R-96-018. NTIS-PB97-117659. Washington, D.C. http://www.epa.gov/radiation/cleanup.

• "MARSSIM provides information on planning, conducting, evaluating, and documenting environmental radiological surveys for demonstrating compliance with dose-based regulations. The MARSSIM, when finalized, will be a multi-agency consensus document." (Federal Register, January 6, 1997, 62(3), pg. 736).
• The MARSSIM is a notable landmark in the publication of US government radiological surveillance literature, summarizing as it does the policies, paradigms and paradoxes of federal radiological surveillance programs in the twilight of the nuclear era.
• This manual summarizes the techniques and surveillance models to be used by the EPA, NRC, DOD and DOE in decommissioning or remediating a wide variety of contaminated weapons or nuclear electricity production sites or facilities. At the same time it expresses many of the conflicts and institutionalized rituals of evasion which allow these four federal agencies to avoid comprehensive radiological characterization of the environmental impact of many controversial facilities such as the Maine Yankee Atomic Power Station (see RADNET's review of the MYAPC Duratek Site Characterization Plan which derives from this document as well as other citations in RAD 12: Twilight of the Nuclear Era: Maine Yankee Atomic Power Company).
• While it would seem at first glance that the MARSSIM would result in accurate radiological characterization of the environmental impact of facilities such as MYAPC, the weasel wording of key definitions such as Derived Concentration Guideline Level (DCGL) allow site characterization without a full accounting of the environmental impact of plant operations. Specifically, NRC site release criterion are based upon the estimation of the Total Effective Dose Equivalent (TEDE) of all nuclides in all pathways.
• A detailed perusal of the slippery and very questionable definition of the DCGL as the basis of the release criteria in fact gives the NRC and the licensee wide leeway in evading the responsibility of a comprehensive characterization of the actual radiological environmental impact of plant operations. At no point in the MARSSIM is reference made to the Derived Intervention Levels (DIL) contained in the FDA's Accidental Radioactive contamination of human food and animal feeds: Recommendations for state and local agencies.
• A thumbnail sketch of this huge 600 page manual would include these notations:
1. Implicit within the MARSSIM is the recognition of the impossibility of a return to unimpacted status for most sites.
2. The controversial definition of the DCGL reveals the preposterous assumption, despite the stated intentions of MARSSIM, that the NRC (EPA, DOE) can proceed with decommissioning or facility remediation without an accurate site characterization of the actual environmental impact of operations at these locations. By the time a final site survey might fulfill this function - in the case of Maine Yankee at the end of decommissioning - it will be too late to have any significance.
3. The arbitrary, artificial, and in fact theoretical nature of the DCGL (see Section 5 for quotations directly from MARSSIM) as the basis of release criteria not only puts the cart before the horse, it raises the metaphorical spectra of trying to get the cart over a snowy mountain pass to a distant market where a theoretical horse may or may not be available to pull the cart. The DCGL is in fact an example of governmental muckety-muck at its most obfuscating.
4. A whole series of questionable presumptions, deficient historical site assessments, self-serving definitions and statistical sleight of hand lead to site-specific DCGL's (MARSSIM does not list any specific derived concentration guideline levels which would apply to all contaminated facilities) in some hazy future which in fact have no credibility for evaluating the TEDE of site activities.
5. The artificial statistical essence of the DCGL in fact allows the systemic evasion of accurate pathway analysis of contaminated media impacted by facility operations. Particularly egregious is the failure to characterize background radiation, both from Naturally Occurring Radionuclides (NOR) and from the accumulation of fission products prior to the over generalized and questionable determination of the DCGL. In fact no mention is made in this or any U.S. government publication of the existence of a cumulative fallout record (see RISO National Laboratory Cummulative Fallout Record).
6. The best summary of the unreliable and arbitrary nature of the DCGL is found in the controversial definition of "contamination" in the glossary: "the presence of residual radioactivity in excess of levels which are acceptable for release of a site or facility for unrestricted use." (pg. GL-4). Just one example of contamination which is not contamination in the context of the DCGL: the cumulative fallout of Plutonium-239 from weapons testing in the latitude of MYAPC is approximately 65 Bq/m² (3900 cpm/m²); the DCGL would allow MYAPC derived plutonium contamination to equal the "background" level of plutonium-239 (a very unlikely possibility) before it would even begin to meet the definition of contamination. In fact, to provide a TEDE approaching 25 mrem/yr (site release criteria) plant contamination would have to be many times the background level before it would have significance as a DCGL.
7. With respect to the Maine Yankee Atomic Power Company and most other DOE facilities undergoing remediation, large quantities of plant derived contamination can be present within the environments being characterized without having any significance with respect to the release criteria. Another way of summarizing the MARSSIM: the actual environmental impact of plant operations as a component of the release criteria is irrelevant.
• Due to the length of RADNET citations from the draft MARSSIM ("DO NOT USE, CITE, OR QUOTE") please go to Part 5 of this section of RADNET for a selection of some of the more interesting weasel word definitions as well as for an excellent up-to-date summary of radiological surveillance techniques. See especially, chapters 5 and 6 of the MARSSIM which can be downloaded in its entirety from the EPA site at: http://www.epa.gov/radiation/cleanup.
• The EPA has issued a review report of MARSSIM (EPA-SAB-RAC-97-008, September, 1997) prepared by the Radiation Advisory Committee (RAC) of the Science Advisory Board.
• This 77 page report is available for downloading from the EPA's Science Advisory Board website. This review report explicitly addresses one of the central weaknesses of the MARSSIM: "The Subcommittee concluded that MARSSIM needed to more clearly emphasize that its scope is limited to guidance for surficial media and not to radioactive contamination of any other media." (abstract, pg. ii). "MARSSIM should discuss its rationale for limiting its scope to guidance for contaminated surface soils and building surfaces. Furthermore, it should more clearly state that radioactive contamination of subsurface soil, surface water, and ground water are explicitly excluded from its coverage. The document should include some discussion of why these particular media were not included." (pg. 2).
• A number of other minor criticisms and suggestions are made in this report. Nonetheless, this review evades the fundamental weakness underlying MARSSIM: a site release criterion of 25 mrem/yr TEDE for all radionuclides in all pathways at any given facility must be based on meticulous routine environmental radiological surveillance for the long-lived isotopes which characterize spent fuel wastes as well as weapons testing fallout. In the case of the Maine Yankee Atomic Power Company as well as other NRC and DOE facilities, no such database exists. The near total lack of site-specific data for both "background" anthropogenic radioactivity and the radiological impact of plant operations undermines the possibility of establishing credible release criteria.
• The Draft regulatory guide DG-4006: Demonstrating compliance with the radiological criteria for license termination summarizes the NRC regulatory position as developed in MARSSIM on dose modeling, use of derived concentration guidelines, use of generic screening and use of site-specific information.