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Monday, August 5, 2013

Call Off The Chihuahuas

The chihuahuas watchdogs are restless in CA after learning that the state allowed Boeing to dispose of some waste (with traces of radioactivity) at a municipal landfill.

I highly doubt Boeing and the regulators are violating a bunch of laws.

Notice this gem?

"The US EPA has estimated that a person exposed to the levels of radiation that regulators and Boeing are using as radioactive release criteria could deliver a dose up to 45 millirem per year. That is equivalent to 22 additional chest X-rays a year and almost twice EPA's limits for public exposure from an operating nuclear plant, but it is what DTSC, DPH, and Boeing have used to approve sending radioactive materials offsite, Tucker said."

That comes from the Committee To Bridge The Gap report (link at end of original article, go to bottom of page 28, using the page numbering within the document) which says:

"Indeed, assessments of the dose or risk from contamination at the levels in the Table vary
widely, depending in part on the radionuclide. EPA, for example, estimates doses of up to 45
millirem per year effective dose equivalent for a typical reuse scenario of a building
contaminated at these levels. That is the equivalent of approximately 22 chest X-rays each
year, or one a week, allowed to continue over many years."

In other words, if one were to inhabit a building (I don't know if EPA modeled the building as a residential or occupational building), at the contamination levels given in U.S. NRC Reg. Guide 1.86 (the "Table" above) one could get a dose of 45 mrem/yr.  The dose would also depend on the actual nuclides chosen by EPA, they are unlikely to exactly match Boeing's.

But wait?  I thought federal law was being broken here?  It's not.  That Reg. Guide has been used for decades as the prior paragraph in the report states.

But the larger point is that this waste is hauled off in containers to a landfill where it is diluted with other waste and buried.  That's a totally different exposure scenario (how many people live at a landfill or work at one at the location this waste has been buried?) than spending 8 or 12 hours per day within a building surrounded by 6 surfaces which are contaminated.

It's dishonest fearmongering to mention the 45mrem/yr.

And the 22 chest x-rays?  That's a big number.  That would assume each is about 2 mrem (2 mrem x 22 = about 45 mrem).

But each is actually about 10 mrem.

So even if the 45 mrem/yr was accurate (it's not AT ALL), it would only be equivalent to 4-5 chest x-rays which isn't as scary as 22!

What appears to be happening is that Boeing and the state are implementing the Reg. Guide to declare the waste non-radiological (free from radiological regulatory controls).  This has gone on routinely across the country for decades.

We all have more important things to be concerned with.

Fear mongering ---->Press attention---->Donations

Rinse, lather, repeat.


  1. But what about the recycled materials?

  2. What about them? There are no regulatory controls for material below the Reg. Guide limit. One is free to do with them as one pleases.

  3. The could end up in products people use, as mentioned in the article.

  4. BTW Wikipedia tells some more about the Santa Susana site's history... wow. If only a fraction of that is true, no wonder folks are on their toes.

    1. Yeah, looks all to be true. It was a free-for-all in the past, but today the site is highly scrutinized. The PR blitz is a manufacturversy.

    2. It's only a decade ago... can attitudes really change that quickly? More importantly, have they, and why? From the Wikipedia article it looks like an uphill battle all the way.

  5. Yeah, that's the point of recycling, but the doses any people actually get will be around 1 mrem/year or less. This standard documents the doses:

    Funny, how that fact is absent from the PR.

    1. But of course! This is not a scientific paper and they have no duty to present both sides of the issue. This is a legal move in a highly adversarial situation. Puts the other side on their toes too -- serves them right, I say. Let the courts sort it out.

    2. Yeah, the court will look to the law which gives the U.S. NRC authority to regulate radioactive materials. It will see the U.S. NRC is doing so in accordance with the law. It will see that the state (called an Agreement State, because it has agreed to implement regulations no less stringent than the NRC's, all according to law). It will see that Boeing is licensed by the state and is following the requirements of its license according to law.

      Where's the legal case? It's just whining.

      To the extent Boeing has violated any laws go after them for those. Apparently, these chihuahuas don't know of any instances so they had to manufacture a controversy.