The Maine Yankee Atomic Power Company is RADNET's model nuclear power generating facility; its radiological emergency response plan is useful for evaluating how protective action guidelines would be implemented in the event of a nuclear accident in Maine. In the case of the state of Maine, a near total lack of radiation monitoring equipment outside of the one mile radius where MYAPC and the state of Maine have installed seventeen pole mounted real-time monitors (these units measure ambient radiation levels only, as expressed in µR/hr) suggests that after any type of "incident" at the Maine Yankee reactor, it will be extremely difficult to track an air-borne plume of radioactive contamination, let alone obtain accurate data about the uneven levels of ground deposition. (See RADNET's review of the Maine Radiological Emergency Response Plan in RADNET, Section 12.)

The extremely liberal FDA/FEMA protection action guidelines for a domestic nuclear accident and the ability of the licensee to control both data collection and the dissemination of information originating at the corporate EOC in Brunswick raise the probability that what little information about radiological effluents and plume pathways is available can be easily manipulated. This situation, in which the licensee (or its representatives, the State Nuclear Safety Advisor and the State Nuclear Safety Inspector) has a near total control of radiological information, allows a rhetorical response from official sources ("well below protective action guidelines", etc. etc.) in lieu of real-time air concentrations or nuclide-specific / media-specific data (e.g. cesium ground deposition, forage concentrations, or for example, ¹⁴⁰Ba milk concentrations). There remains a very large radiological monitoring gap to be filled between normal, nearly non-detectable levels of reactor effluents and the emergency conditions which would characterize a situation where the FDA / FEMA protective action guidelines would be invoked. Given the current lack of laboratory facilities, the limitations of manual terrestrial sampling methods, and the questionable availability of accurate aerial monitoring data, it is very likely that, in the event of a nuclear accident in Maine, there will be a grossly insufficient database upon which to judge which protection action guidelines or "levels of concern" would be appropriate to implement. The best illustration of this problem of a lack of data upon which to base implementation of protection action guidelines is the passage of the Chernobyl plume through Finland where a number of stations had nuclide specific real-time monitoring equipment far superior to any now available in Maine. In just a few hours on April 28, 1986, the Chernobyl plume passed Nurmijarvi, Finland. Air concentrations of over thirty Chernobyl derived radionuclides reached some of the highest levels ever observed other than (classified) close-in monitoring of nuclear weapons testing fallout. RADNET has reprinted the peak concentrations of the twenty one most important constituents of the Chernobyl plume as it passed over and impacted Nurmijarvi through rainfall associated deposition (See RADNET Section 10, Chernobyl: Finland, Sinkko). After passage of the plume, air concentrations of most nuclides returned to near normal within twenty four hours, illustrating the futility and folly of relying primarily on ambient radioactivity levels for evaluation of the seriousness of a nuclear "incident." The state of Maine is entirely without nuclide specific real-time monitoring equipment and also lacking in real-time ambient radiation monitoring capabilities outside of the one mile radius of the pole mounted monitors at MYAPC. The lack of radiological monitoring capabilities of the licensee, the NRC, the state of Maine, the Department of Energy and the Environmental Protection Agency allow the potential for a situation where there will be no way to evaluate the radiological impact of a MYAPC release as it passes the arbitrary 50 mile ingestion pathway perimeter and affects citizens in more distant parts of Maine and other states and countries. This shortcoming in emergency preparedness plans, monitoring equipment and laboratory capacity is consistent with the evasions and lack of truthfulness that has characterized licensee, state of Maine, and NRC statements about Maine Yankee Atomic Power Company policies and practices in the past.
 

F. Post-Chernobyl National Safety Guidelines for 131I in Milk (WHO, 1986)

The following WHO summary provides a selection of radiation protection guidelines in effect in Europe for ¹³¹I at the time of the Chernobyl accident:
 

Country	National Safety Guideline	Expressed in picocuries/liter
	(Becquerels/liter)
Soviet Union	2,000	54,000
Poland	1,000	27,000
Sweden	2,000	54,000
Romania	185	4,975
Austria	370	10,000
Czechoslovakia	1,000	27,000
West Germany	500	13,500
Switzerland	3,700	99,900
Yugoslavia	-	-
Turkey	-	-
United Kingdom*	2,000	54,000
United States	555	15,000
Italy	500	13,500

• These diverse guidelines compare with the FDA/FEMA emergency PAG for domestic nuclear accidents which are 150,000 pCi/liter ¹³¹I in milk for infants and 2,000,000 pCi/l ¹³¹I in milk for adults.
• Following the Chernobyl accident, much controversy surrounded the temporary radiation standards of 600 Bq/kg set for radiocesium in the general food supply in the European community, which were finally set at 1,000 Bq/kg (= 60,000 cpm) for dairy products and 1,250 Bq/kg for other commodities, by the European Commission in May of 1987. The radiocesium limits for Britain were set at 1,000 Bq/kg for all imported foods. The 1987 guidelines are the ones currently in effect.
• For more information on ¹³¹I and milk see NCI's 1997, Estimated exposures and thyroid doses received by the American people from Iodine-131 in fallout following Nevada atmospheric nuclear bomb tests and our special appendix: Contaminated milk: A paradigm.

There is no one comprehensive radiological monitoring program that is maintained by any agency of the United States government that is even worth labeling "radiological monitoring" program. The EPA's environmental radiation data reports represent the closest approximation to anything that could be called monitoring. Many of the NRC citations listed below imply or mandate licensee radiological monitoring as in the REMP cited below. Most of the citations listed below are either remediation guides, survey manuals or fragments of that elusive comprehensive radiological monitoring program for all nuclides and all pathways which in the late 20th century has yet to be devised. See RADNET Section 9: Dietary Intake for excerpts from reports issued by the RISO National Laboratory. These annual reports on environmental radioactivity are more inclusive than anything published by the United States government and set an example which must be considered in any future update of our radiological surveillance programs.
 

1. Nuclear Regulatory Commission (NRC)

All NRC regulatory guides have their basis as outgrowths of rule makings issued and printed in the Code of Federal Regulations. One of the first rule makings pertaining to residual radiation is the U.S. Atomic Energy Commission's Regulatory Guide 1.86, June, 1974 which sets decontamination guidelines for remediation of facilities for release for unrestricted use. Table 1 in this guide is the one and only contamination guideline (other than the occupational and public exposure guidelines established in 10 CFR Part 20) and sets acceptable average, maximum and removable surface contamination levels. This short guideline sets the standard for grossly inadequate one-dimensional radiological surveillance paradigms.

The traditional preoccupation with surface contamination rather than volumetric contamination is illustrated by Table 1, which is still the primary guideline being used in decommissioning facilities such as the Yankee Atomic facility in Rowe, MA.
 

Radioactive contamination at less than maximum acceptable surface levels noted above allow a return to unrestricted use of decommissioned nuclear facilities in the United States. The significance of the maximum surface contamination levels in Regulatory Guide 1.86 is illustrated by the fact that these contamination guidelines for isotopes such as ²³⁹Pu, ⁹⁰Sr and ¹³⁷Cs average five to ten times the cumulative fallout from all weapons testing (e.g. ²³⁹Pu: 60 Bq/m², ⁹⁰Sr: 1,500 Bq/m², ¹³⁷Cs: 3,500 Bq/m²). There are currently no volumetric contamination guidelines for recycled reactor metals (e.g. stainless steel, carbon steel, etc.)

These one-dimensional contamination guidelines are perpetuated in the new MARSSIM, which fails to meet the needs of what is in effect a revolutionary new approach to site release criteria: a 25 mrem/yr TEDE for all nuclides in all pathways. Surface contamination is not even the main pathway of concern at decommissioned NRC reactors and DOE weapons production facilities where the ingestion pathway is the critical route of exposure for the long-lived isotopes which characterize spent fuel wastes.

Most of the NRC rules and regulations pertaining to radiation protection including the new radiological criteria for license termination are included in 10 CFR Part 20, et. al., which focus primarily on occupational exposure. Radiation protection guidelines for the general public are currently 100 mrem/yr including an air emissions limit of 10 mrem/yr and an external dose limit of 50 mrem/yr. The NRC has no volumetric concentration guidelines for any media including human foodstuffs. The current draft of the new FDA proposed guidelines for contaminated foodstuffs (reviewed in this section of RADNET) provides an important point of comparison with DCGLs which will evolve out of the application of MARSSIM to decommissioned facilities in the future.

Annual REMPs are filed by every nuclear utility under the jurisdiction of the NRC. Up until recently, the only source for these monitoring reports would be either NRC public document rooms or the NRC public document distribution office, which charges 9 cents a page. In view of the rapid growth of electronic availability of information of every kind, REMP's for most licensees should be available on the Internet soon. For RADNET's review of an MYAPC REMP, visit RAD 11: Part 3 Plume Source Points or RAD 12: Maine Yankee Atomic Power Company Section 5: Decommissioning Debacle: Site Characterization Management Plan. In general, nuclear utility REMP's, if MYAPC is a typical example, provide a grossly inadequate characterization of the environmental impact of plant operations, particularly for those facilities sited on bodies of water such as estuaries, lakes or rivers.

Berven, B.A., Cottrell, W.D., Leggett, R.W., Little, C.A., Myrick, T.E., Goldsmith, W.A. and Haywood, F.F. (1986). Generic radiological characterization protocol for surveys conducted for DOE remedial action programs. ORNL/TM-7850. Martin Marietta Energy Systems, Inc., Oak Ridge National Laboratory.

Boyns, P.K. and Sevart, M.D. (December, 1973). Aerial radiological survey of the area surrounding the Dresden Nuclear Power Station, Morris, Illinois, September, 1968. EGG-1183-1528. [NRC] EG and G, Inc., Las Vegas, Nevada. pp. 82.

• "Aerial radiation survey data consisting of exposure rates normalized to 3 feet above the ground plus gamma ray spectral charts, effluent characterization for operational sites (intensity rates and isotope constituents), and pertinent descriptive information of the installation." (abstract).
• "The report contains the data for the survey of the Dresden Nuclear Power Station and surrounding area, including an effluent plume tract." (abstract).

• This draft is a key component of the NRC regulatory puzzle pertaining to determining the release criteria for decommissioned facilities such as NRC ... "cleanup criteria is determined on a site specific basis, taking into account the radiological characteristics of both a residual radioactivity and background at the facility. ... The process for establishing site specific data needs is currently performed by the licensee, but, in the future, data needs might have to be negotiated with local, state, or federal regulatory entities." (pg. 3).
• "Wherever possible the licensee should use actual measurements, rather than modeling, when determining the source term (i.e., residual radioactivity remaining at the site) upon which the calculated TEDE will be based." (pg. 6).
• "In each scenario, the critical group is an individual or relatively homogeneous group of individuals expected to receive the highest exposure within the assumptions of the particular scenario. The average member of the critical group is that individual who is assumed to represent the most likely exposure situation, based on prudently conservative exposure assumptions and parameter values within the model calculations." (pg. 6).
• "The NRC has developed models to provide generic dose conversion factors for residual radioactivity ... The low concentration levels, extended time periods for analysis, and multiple pathways of concern make model calculations the most defensible and cost effective approach." (pg. 9).
• "The first level of screening uses the default pathways and parameter values in the generic models of NUREG/CR-5512, and requires the site source term as the only site-specific input. The second level of screening allows some default parameters and pathways to be changed based on site-specific requirements, and therefore requires more site-specific data based on increased site information requirements." (pg. 9-10).
• This report represents an ongoing process for loosening regulatory requirements so as to "provide flexibility to allow licensee's to account for their own unique, site-specific factors." (pg. 10). The end result of this deregulation is not only greater flexibility for the licensee, but also the opportunity to systematically evade comprehensive radiological monitoring prior to and during decommissioning, especially of nuclear power plants under the supervision of the NRC.
• The most recent and best example that manifests this tendency is the MARSSIM, which is reviewed at the beginning of this Section of RADNET. The only existing compilation of what might be considered DCGLs (as described in the MARSSIM but not mentioned in this earlier report) can be found in Appendix A-1, Annual Total Effective Dose Equivalent Factors. This appendix provides an estimate of mrem/yr effective dose for all the isotopes of concern in pathway analyses for the following pathways: external, inhalation, ingestion, soil ingestion, irrigation and drinking water, aquatic food and total dose.
• Recent conversations with staff at the Maine Yankee Atomic Power Company (Citizen's Advisory Panel meeting, January 15, 1998) as well as with numerous NRC officials indicate a widespread lack of knowledge of exactly what DCGLs are, how they are determined and how they are implemented. One major problem appears to be that the DCGL is determined for each radionuclide on the basis of a TEDE of 25 mrem/yr. If the TEDE for a number of isotopes approaches the 25 mrem/yr limit, the result is a combination of confusion and manipulation of data, hopefully resulting in the successful achievement of a site release criteria. Unfortunately, this criteria may be achieved based on pathway analyses for all isotopes in all pathways which never actually occurs.
• The numerous tables in the appendices of this volume contain the closest approximations to what is supposed to be a site-specific DCGL at MYAPC as is currently available. No mention is made of the marine pathway in the various scenarios noted above, however, Table A-1 does include an aquatic food dose estimate.

Gogolak, C.V., Huffert, A.M. and Powers, G.E. (August 1995). A nonparametric statistical methodology for the design and analysis of final status decommissioning surveys: Draft report for comment. NUREG-1505. Division of Regulatory Applications, Office of Nuclear Regulatory Research, U.S. NRC, Washington, D.C.

Huffert, A.M., Meck, R.A. and Miller K.M. (August 1994). Background as a residual radioactivity criterion for decommissioning: Appendix A to the generic environmental impact statement in support of rulemaking on radiological criteria for decommissioning of NRC-licensed nuclear facilities. Draft report. NUREG-1501. Division of Regulatory Applications, Office of Nuclear Regulatory Research, U.S. NRC, Washington, D.C.

• Another important document in the deregulation and liberalization of the requirements necessary for NRC licensees to achieve release criteria for final termination of a nuclear power plant license.
• "Existing clean-up criteria for nuclear facilities are a patchwork of applicable regulation, guidance, and practices ... these regulations do not explicitly state which radiological criteria to apply to demonstrate that a site has been adequately remediated." (pg. 59).
• "Typically nuclear power licensees subtract the background component from the gross radioactivity monitored in effluents so that only reactor effluents, without background, are reported to the NRC." (pg. 65). This and other NRC documents are not particularly explicit about the large amount of flexibility these recent rulemakings and radiological criteria provide for the licensee in determining a theoretical background level of radioactivity. This flexibility allow licensees such as MYAPC huge leeway in characterizing the environmental impact of plant operations, as there is now no longer any need for an exact and scientific calculation of defacto background radiation levels, which now include radiation from all anthropogenic sources except the licensee.
• This loophole combines with a number of other deficiencies in the site characterization process, particularly those relating to omissions and defects in historical site assessment, and results in the failure to accurately characterize the environmental impact of past and ongoing licensee activities.
• This publication contains an extensive bibliography listing all of the major NRC publications pertaining to decommissioning NRC facilities published up until August 1994. For further comments on this ritual of institutionalized evasion refer to the previous citation as well as to the MARSSIM.

Huffert, A.M. and Miller, K.M. (August 1995). Measurement methods for radiological surveys in support of new decommissioning criteria: Draft report for comment. NUREG-1506. Division of Regulatory Applications, Office of Nuclear Regulatory Research, U.S. NRC, Washington, D.C.

Kennedy, W.E., Jr. and Strenge, D.L. (October 1992). Residual radioactive contamination from decommissioning. NUREG/CR-5512, Final report. Pacific Northwest Laboratory, U.S. NRC.

• Another component in the labyrinth of NRC rules and regulations which allow licensees to decommission facilities without an accurate account of the actual environmental impact of facility operations.
• This publication focuses on four exposure scenarios for unrestricted release: volume contamination re: building renovation, surface contamination re: building occupancy, volume contamination re: residential use, and drinking water contamination from total site inventory. Other specific exposure pathways are not emphasized in this publication.
• This publication is a prelude to site characterizations such as are now occurring at MYAPC which focus on building and equipment contamination (for decommissioning contractors) at the expense of analysis of the broader impact of plant operations in pathways such as the marine environment. The next publication in this series is NUREG-1500; see the review in this section.

• This is the final in a series of annual publications which have been discontinued, along with much of the remaining useful components of federal government, by budget cutbacks.
• Tabulated data includes site-specific airborne and liquid effluents as well as information on solid wastes, energy generation and individual plant summaries.
• Liquid and gaseous emissions vary widely from plant to plant with a slight declining trend over time due to improvements in equipment and training.

United States Nuclear Regulatory Commission. (August, 1979). Decommissioning of nuclear facilities - a review and analysis of current regulations. NUREG/CR-0671. Pacific Northwest Laboratory for U.S. NRC, Washington, D.C.

United States Nuclear Regulatory Commission. (August, 1979). Technology, safety and costs of decommissioning a reference pressurized water reactor power station. NUREG/CR-0130 Addendum. Pacific Northwest Laboratory for U.S. NRC, Washington, D.C.

United States Nuclear Regulatory Commission. (December, 1979). Facilitation of decommissioning of light water reactors. NUREG/CR-0569. Pacific Northwest Laboratory for U.S. NRC, Washington, D.C.

United States Nuclear Regulatory Commission. (1988). Final generic environmental impact statement on decommissioning of nuclear facilities. NUREG-0586. U.S. NRC, Washington, D.C.

• This NRC publication analyses the decommissioning process without addressing the environmental impact of the decommissioning process or levels of residual radioactivity which would result.
• Issues discussed include worker radiation exposure, amounts of waste generated, radiation exposure received by the public and other details pertaining to planning and executing the decommissioning process.
• This NRC publication raises a question which is not resolved in this or any following NRC publication: how can the TEDE of the general population be determined without knowledge of the environmental impact of plant operations based on (nonexistent) pathway analyses of all radionuclides in all ecosystems which are components of the source term lease by a specific installation such as MYAPC?

• A general overview of the context of what were at this point ongoing rulemaking changes for decommissioning including a discussion of regulatory alternatives and the various kinds of nuclear facilities affected by this proposed rulemaking. This volume includes lengthy cost analyses.
• It is this NRC publication which first introduces the concept of setting residual radioactivity levels resulting from plant operations and decommissioning (e.g. total TEDE at 25 mrem/yr).
• For a reference power reactor, "it is assumed that there are areas of contaminated soil resulting from onsite spills." (pg. 4.2). Soil surface contamination is assumed to be limited to an area not exceeding 2,000 sq. ft. No mention is made of any power reactors with liquid effluent diffusers in lakes, rivers or maritime environments.
• This publication makes the following concession in regards to the biological environment: "Issues related to biota may be very site-specific and will need to be addressed in a EIS prepared for a specific facility." (pg. 5-3).
• An obvious flaw in this GEIS is impact analyses scenarios which have no relevance for a site-specific TEDE for a maximally exposed tourist stuffing he and his family with mussels, sea vegetables and other biota from within the marine pathway at MYAPC.

• Volume 2 contains the relevant appendices on natural background radiation as a residual radioactivity criteria as well as cost analyses, comments and a discussion of restricted use and disposal capacities.
• This volume includes the observation that "various sources of ionizing radiation that collectively produce an average total effective dose equivalent of about 3 mSv (300 millirem) per year to the United States resident." (pg. A-82). It also discusses the wide variations in background radiation which can range up to 1000 mrem. Needless to say, no mention is made of the wide variations which can result from exposure to a variety of anthropogenic source points.

United States Nuclear Regulatory Commission. (1995). Measurement methods for radiological surveys in support of new decommissioning criteria. NUREG-1506. U.S. NRC, Washington, D.C.

• This regulation focuses in on "data quality objectives (DQOs)" which are essentially the planning approaches for site cleanup, including scoping surveys and reviews of previously collected data and the history of site operations which then lead to a conceptual model of the site being remediated. A key question in this guide is how "data will serve specific needs in support of the decommissioning process." Based upon these needs "the data collection program can be designed ... for the different environmental media to be sampled." (pg. 2.1).
• This is a rather explicit reference to a theme which reappears in many NUREG guides: taking the data and designing its presentation to suit the economic as well as public relations needs of licensees such as power reactor operators undergoing decommissioning or license termination.
• "For conducting radiological surveys for decommissioning, the DQO approach would, in general, entail the following:
1. Identify the critical radionuclides, their critical pathways, the contaminated media, and the types of measurements or samples that are needed.
2. Check default values of the concentrations for each identified radionuclide...
3. Determine whether the radionuclide is already present in the background and establish the needs of the statistical tests that will be used to demonstrate compliance with the dose limits and ALARA requirements.
4. Choose instrumentation/measurement methods based on detection limits as compared to the default concentrations for each radionuclide, as well as for estimating the site inventory, that is, the total amount of residual radioactivity present in the environmental media.
5. Establish numbers of personnel, types of expertise, and necessary training levels required to conduct measurements. Formulate a plan and then perform measurements. Assess measurements as the plan is executed." (pg. 2-2).
• "It is recommended that water bodies on site be included in a survey to support decommissioning, as both the water itself and, to a greater extent, the underlying sediment represent sinks for runoff of radionuclides from facility operations." (pg. 5-3).
• See Table 7.1 for some common temporal variations for consideration during site surveys.

United States Environmental Protection Agency. (January, 1996). Environmental Radiation Data Report 76: October - December 1993. EPA-402-R-96-004. National Air and Radiation Environmental Laboratory, U.S. EPA, Montgomery, AL.

• This is a randomly selected volume of these reports which are still published on a quarterly basis. These reports are the closest the United States comes to systematic radiological monitoring. This program contains data from the Environmental Radiation Ambient Monitoring System (ERAMS), which is a nationwide series of radiation monitoring stations. The key word is ambient; the ERAMS data includes an air program for airborne particulates in precipitation, plutonium and uranium in airborne particulates and precipitation, krypton-85 from 12 sampling locations with only occasional reporting, surface water program for tritium and a drinking water program for gross beta, gross alpha, ⁹⁰Sr, ²²⁶Ra, and specific gamma activity if available. The program also includes external gamma ambient monitoring and an analysis of pasteurized milk for ⁴⁰K, ¹³⁷Cs, ¹⁴⁰Ba and ¹³¹I.
• The milk program is probably the most useful in that it will quickly show the impact of nuclear accidents over a wide area. The other data are generally composed of quarterly composites which provide very little data about environmental radiation and are useful only on the occasion of a major nuclear accident. The most important information is what is not contained in these radiation data reports: site-specific, media-specific data of radioactive contamination such as long-lived spent fuel wastes (LLSFW) in pathways which are neither mentioned nor analyzed in these "environmental" radiation data reports.
• Also see the EPA's Radiation and Data Reports in Section 10: Chernobyl: USA. For a history of the EPA's monitoring reports, which were originally sponsored by the old Atomic Energy Commission (AEC) see RADNET Section 9: Part 1: Dietary Intake.

United States Environmental Protection Agency. (1988). Guidance for conducting remedial investigations and feasibility studies under CERCLA, interim final. EPA/540/G-89/004. OSWER Directive 9355.3-01. U.S. EPA, Washington, D.C.

United States Environmental Protection Agency. (1988). Superfund removal procedures. OSWER Directive 9360.0-03B. Office of Emergency and Remedial Response. U.S. EPA, Washington, D.C.

United States Environmental Protection Agency. (1991). Site assessment information directory. Office of Emergency and Remedial Response. U.S. EPA, Washington, D.C.

United States Environmental Protection Agency. (May, 1992). Manual of protective action guides and protective actions for nuclear incidents. EPA 400-R-92-001. ANR-460. Office of Radiation Programs, U.S. EPA, Washington, D.C.

• This volume includes the famous Federal Register Notice of October 22, 1982 which includes the emergency protective action guidelines (PAG) which were later incorporated into the FEMA guides. The FEMA guide for Maine is reviewed in this section of RADNET. RADNET readers are reminded that while the emergency protection action guide for a teenager or adult is 50 mCi/m² (110 million counts per minute), the emergency PAG for authorized persons within an Emergency Operations Center (EOC) is 300 counts per minute above background total body contamination (shower, shave quickly, use a separate exit, keep out of the dining room, etc. etc.)
• Nonetheless, this publication is an excellent guide to what the EPA thinks should be the basic approach to any emergency radiological situation.
• "...the estimation of radiation risks is not a fully mature science and the evaluation of radiation hazards will continue to change as additional information becomes available." (pg. B-19).

United States Environmental Protection Agency. (January 1996). Documenting ground water modeling at sites contaminated with radioactive substances. EPA/540-R-96-003. Radiation Protection Division, Office of Radiation & Indoor Air, U.S. EPA, Washington, D.C.

United States Environmental Protection Agency. (January 1996). Three multimedia models used at hazardous and radioactive waste sites. EPA/540-R-96-004. Radiation Protection Division, Office of Radiation & Indoor Air, U.S. EPA, Washington, D.C.

United States Environmental Protection Agency. (June 1996). Radiation exposure and risks assessment manual (RERAM). EPA/402-R-96-016. Radiation Protection Division, Office of Radiation & Indoor Air, U.S. EPA, Washington, D.C.

United States Environmental Protection Agency. (November 1996). Technology screening guide for radioactively contaminated sites. EPA/402-R-96-017. Radiation Protection Division, Office of Radiation & Indoor Air, U.S. EPA, Washington, D.C.
 

3. Department of Energy (DOE)

Almost all these citations are either site specific environmental monitoring reports, which are often done annually for the larger weapons production facilities now under remediation or are survey guides. The DOE is one of four participants sponsoring the MARSSIM, a multi-agency radiation survey manual which is cited in the first part of this section of RADNET. This flawed document provides an interesting model on current thinking within the federal government on how radiological monitoring should be done.

Berven, B.A., Cottrell, W.D., Leggett, R.W., Little, C.A., Myrick, T.E., Goldsmith, W.A. and Haywood, F.F. (1987). Procedures manual for the ORNL radiological survey activities (RASA) program. ORNL/TM-8600. Martin Marietta Energy Systems, Inc., Oak Ridge National Laboratory.

Mork, H.M., Larson, K.H., Kowalewsky, B.W., Wood, R.A. and Paglia, D.E. (July, 1966). Project SEDAN. Part I. Characteristics of fallout from a deeply buried nuclear detonation from 7 to 70 miles from ground zero. Part II. Aerial radiometric survey (final rept.). AEC-PNE-225F. Atomic Energy Commission, Washington, D.C. pp. 117.

• "Adequate samples of fallout from the detonation of a nuclear device buried in desert alluvium at 635 feet below ground surface were obtained to delineate the eastern part of the fallout pattern from 7 to 70 miles from ground zero." (abstract).
• "The Aerial Radiometric Surveys, CETO Project 62.80, determined the distribution of Sedan fallout to a distance of more than 200 miles from ground zero. The dose rate contours show the pattern to be asymmetric with a steep gradient west of the midline with a very gradual gradient on the east." (abstract).

United States Department of Energy. (1991). Environmental regulatory guide of radiological effluent monitoring and environmental surveillance. DOE/EH-0173T. U.S. DOE, Washington, D.C.

United States Department of Energy. (1992). Environmental implementation guide for radiological survey procedures manual, DOE report for comment. Martin Marietta Energy Systems, Oak Ridge National Laboratory.

United States Department of Energy. (1994). Decommissioning handbook. DOE/EM-0142P. U.S. DOE, Washington, D.C.
 

4. Food and Drug Administration (FDA)

The Food and Drug Administration has a modest program of monitoring contamination in both imported and domestic foods. For a summary of these publications see RADNET Section 9: Dietary Intake. In this section, Chernobyl peak pulse in U.S.A. Imported Foods gives an example of data pertaining to the Chernobyl nuclear accident that was withheld from the public at the time it was collected. The complete survey is available upon request from the Center for Biological Monitoring.

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.

• See annotations in Part 1 of this section.

The Environmental Measurements Laboratory was extremely active during the time of fallout derived from weapons testing in the late 1950's and 1960's. After weapons testing fallout declined so did the funding for EML and aside from a number of reports associated with the Chernobyl accident (see citations in RADNET Section 10: Chernobyl Fallout Data), the EML reports have become sparse. The EML home page (RADLINKS: Part II D-5) provides a link to citations of most of the monitoring reports that this small agency produced. Other important citations are annotated in RADNET Section 8: Anthropogenic Radioactivity: Baseline Data. These citations include: Bennet, 1978, two by Toonkel, 1980 and Klusek, 1984. A publication by Hardy, 1981 is annotated in RADNET Section 11: Major Plume Source Points: General Bibliography.

United States Department of Energy. (1990). EML procedures manual, HASL-300, 27th ed. HASL-300-ED.27-Vol 1. Environmental Measurements Laboratory, U.S. DOE, New York.

4/12/17: Reports from 1995 to 2007 can be found here: http://www.wipp.energy.gov/namp/emllegacy/publications.htm

6. U.S. Geological Survey (USGS)

Some of the most interesting information collected by the USGS is in the vicinity of BEMR - listed remediation sites such as the Idaho National Engineering Laboratory or the Hanford Reservation. These studies are often cited in the environmental monitoring reports of the national laboratories referenced above. RADNET has not yet accessed any of these reports but would be interested in listing a representative selection of them in the future.
 

7. U.S. Intelligence Community

Most national intelligence agency radiological surveillance utilizes remote sensing data of one type or another. All of this data is classified information at this time. Visit RADNET Section 13: RADLINKS Part II-D: U.S. Intelligence Community. Visitors to these links will see many references to the remote sensing technologies which are utilized by the U.S. government to observe foreign nuclear weapons production source points which inevitably create their tell-tale plumes of gamma emitting contaminants. Also surf the IAEA links, as the IAEA cooperates with the U.S. and other government agencies in a joint anti-proliferation surveillance program.
 

Aarkrog, A., Botter-Jensen, L., Chen Qing Jang, Dahlgaard, H., Hansen, H., Holm E., Lauridsen, B., Nielsen, S.P. and Sogaard-Hansen, J. (1991). Environmental radioactivity in Denmark in 1988 and 1989. Riso National Laboratory, Roskilde, Denmark.

Aarkrog, A. (1992). Source terms and inventories of anthropogenic radionuclides. Report No. DK-4000. Riso National Laboratory, Roskilde, Denmark.

Commission of the European Communities. (1989). Council regulation (Euratom) No 3954/87 laying down the maximum permitted levels of radioactive contamination of foodstuffs and feedingstuffs following a nuclear accident or any other case of radiological emergency.  Off. J. Eur. Commun., 11(L371), amended by Council Regulation 2218/89 Off. J. Eur. Commun., 1(L211).

International Atomic Energy Agency. (1996). International basic safety standards for protection against ionizing radiation and for the safety of radiation sources. Saf. Ser. No. 115. IAEA, Vienna.

International Commission on Radiological Protection. (1977). Recommendations of the International Commission on Radiological Protection. Annal. ICRP. 1(3). Pergamon Press, Oxford, ICRP Publ. 26.

International Commission on Radiological Protection. (1991). 1990 recommendations of the International Commission on Radiological Protection. Annal. ICRP. 21(1-3). Pergamon Press, Oxford, ICRP Publ. 60.

International Commission on Radiological Protection. (1993). Principles for intervention for protection of the public in a radiological emergency. Annal. ICRP. 22(4). Pergamon Press, Oxford, ICRP Publ. 63.

International Commission on Radiological Protection. (1994). Age-dependent doses to members of the public from intake of radionuclides:  Part 2 ingestion dose coefficients. Annal. ICRP. 23(3/4). Pergamon Press, Oxford, ICRP Publ. 67.

International Commission on Radiological Protection. (1996). Age-dependent doses to members of the public from intake of radionuclides:  Part 5 compilation of ingestion and inhalation dose coefficients. Annal. ICRP. 26(1). Elsevier Science, Oxford, ICRP Publ. 72.

International Commission on Radiological Protection. (1996). Conversion coefficients for use in radiological protection against external radiation. Annal. ICRP. 26(3/4). Elsevier Science, Oxford, ICRP Publ. 74.

Ministry of Agriculture, Fisheries and Food. (1996). Radioactivity in food and the environment, 1995. RIFE-1. MAFF, London.

Ministry of Agriculture, Fisheries and Food and Scottish Environment Protection Agency. (1997). Radioactivity in food and the environment, 1996. RIFE-2. MAFF and SEPA, London.

Ministry of Agriculture, Fisheries and Food and Scottish Environment Protection Agency. (September 1998). Radioactivity in food and the environment, 1997. RIFE-3. Centre for Environment, Fisheries and Aquaculture Science, MAFF and SEPA, London.

• This series of reports is among the most important and comprehensive examples of a surveillance program for anthropogenic radioactivity in the environment carried out by any governmental entity in the world.  RIFE stands in startling contrast (despite the tradition of government 'secrecy' in the United Kingdom) to the witless and evasive monitoring efforts of the United States federal government including the NRC and its licensees and the EPA and DOE.
• Routinely included in the RIFE surveillance program are many radionuclides absent from U.S. monitoring activities:  ¹⁴C, ⁶⁵Zn, ⁹⁵Zr, ⁹⁵Nb, ⁹⁹Tc, ¹⁰³Ru, ¹⁰⁶Ru, ^110mAg, ¹²⁵Sb, ¹³⁴Cs, ¹⁴⁴Ce, ¹⁵⁴Eu, ¹⁵⁵Eu, ²³⁷Np, ²³⁸Pu, ^239,240Pu, ²⁴¹Pu, ²⁴¹Am, ²⁴²Cm, and ²⁴⁴Cm.  Small plumes of many of these radioisotopes are associated with discharges from not only Sellafield but many other nuclear facilities in the United Kingdom.
• Also, desultory NRC monitoring efforts are in contrast to the wide variety of biological media surveyed in the RIFE report as well as the detailed nature of the overall surveillance program in the United Kingdom.  No United States publication even comes close to the comprehensive presentation and assessment of sampling and measurements contained in these reports.
• The RIFE surveillance program constitutes, in essence, what is completely missing from United States monitoring efforts:  the proverbial "10-61 analyses," so-called because the United States Code of Federal Regulations Section 10 Part 61 requires NRC licensees to document comprehensively the radiological content of all solid low-level waste destined for near surface landfills.  At the same time, the NRC is completely negligent in requiring comprehensive documentation of the environmental impact of gaseous and liquid releases from US facilities, both routine and nonroutine.  For further discussion of these radiological surveillance deficiencies at a United States nuclear power plant (Maine Yankee Atomic Power Company) see RAD12: Maine Yankee Atomic Power Company: Paradigm of the Twilight of the Nuclear Era: Part 6: Patterns of Noncompliance.
• This report is particularly important in documenting the huge impact of fuel reprocessing activities at the Sellafield facility.  Of particular importance is the documentation of the ⁹⁹Tc (technetium) pulse in lobsters and other biota (see pg. 53, 55, 76, 93, 99) derived from the new Thorp installation in Sellafield, and ²⁴¹Am (americium) pulse and contamination from other isotopes derived from the Sellafield facility.  For more information about the ⁹⁹Tc pulse, link also to Greenpeace.
• "The report demonstrates that foodstuffs and seafood produced in and around the United Kingdom in 1997 are radiologically safe to eat and that the exposure of consumers to artificially produced radioactivity via the foodchain remains well below UK and EU limits." (executive summary).
• "Natural radionuclides are the most important source of exposure in the average diet of consumers.  Man-made radionuclides contributed less than 5% of the dose." (executive summary).
• "Estimated doses to high-rate fish and shellfish consumers, in the vicinity of Sellafield, from artificial radionuclides in the diet have decreased from 14% (in 1996) to 10% (in 1997) of the EU dose limit of 1 millisievert.  The decrease was largely due to changes in the consumption of shellfish by these people." (executive summary).
• "The highest dose to members of the public in the UK from both artificial and natural radioactivity was estimated to be 0.49 millisieverts to high-rate fish and shellfish consumers in the Whitehaven area." (executive summary).
• "The highest doses in Scotland were also attributable to liquid wastes from Sellafield and were received by a group of high-rate fish and shellfish consumers in Dumfries and Galloway.  Their dose was 0.047 millisievert.  Technetium-99 contributed the single largest dose to this group, 0.010 millisievert in 1997, a reduction from 0.019 millisievert in 1996 due to a decrease in the detected levels in Nephrops."  (executive summary).
• "Levels of technetium-99 in lobsters from the vicinity of Sellafield were again above those specified in the EU post-accident intervention levels and were comparable to 1996 levels.  The assessed dose to the most exposed group of seafood consumers from technetium-99 discharges was less than 5% of the EU dose limit."  (executive summary).