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Bad to the Bone:
Analysis of the Federal Maximum Contaminant Levels for Plutonium-239 and
Other Alpha-Emitting Transuranic Radionuclides in Drinking Water

By: Arjun Makhijani, Ph.D.
June 2005

PDF of entire report
[300 KB, 33 pp.]

Press Release

Table of Contents

Acknowledgements

Main findings

Recommendations

I. Introduction

II. National Primary Drinking Water Regulations – Radionuclides
A. Bone dose estimation in ICRP 2
B. Bone dose estimation, present-day dose conversion factors
1. Bone doses according to FGR 11
2. Bone doses according to FGR 13

III. Conclusions

IV. Costs

V. Estimating the impact of residual radioactivity

VI. Other risks and radionuclides

References

Recommendations

The EPA is going to review the radionuclide standards for drinking water as part of a scheduled process in 2006. We urge the EPA to revise the drinking water regulations in regard to alpha-emitting, long-lived transuranic radionuclides. The Department of Energy should evaluate its cleanup and decommissioning efforts with a view to meeting the tighter standard.

1. The EPA should reduce its maximum contaminant levels for all alpha-emitting, long-lived transuranic radionuclides, combined, by one hundred times to an MCL of 0.15 picocuries per liter during its 2006 review of radionuclide standards for drinking water.

EPA should set a combined maximum contaminant level for alpha-emitting, long-lived transuranic radionuclides of 0.15 picocuries per liter. If only one of the radionuclides in question were present, then the limit for that radionuclide would be 0.15 picocuries per liter. The radionuclides included are: neptunium-237, plutonium-238, plutonium-239, plutonium-240, plutonium-242, americium-241, and americium-243. These changes should be made as part of the EPA's review of radionuclide standards in drinking water that is scheduled for 2006.

2. The DOE should fund a one-time baseline sampling and analysis for public water systems that are hydrologically or hydrogeologically connected to DOE sites with major plutonium wastes or dumps.

DOE sites with wastes buried underground or in tanks containing more than 100 curies of alpha-emitting, long-lived transuranic radionuclides should be considered to have potential risks to drinking water. These sites include the Savannah River Site, Hanford, Idaho National Laboratory, Los Alamos National Laboratory, Oak Ridge, and the Nevada Test Site. Testing of downstream water for the purpose of providing a baseline level of contamination is desirable and should be funded by the DOE since the tiny amounts of alpha-emitting, long-lived transuranic radionuclides in current water supplies are due to military-related atomic energy activities (fallout from testing).

3. The DOE should evaluate its on-site water monitoring from the point of view of the proposed standard and intensify it, if necessary. Resources for independent verification should be provided by the federal government.

The DOE currently carries out extensive surface and ground water monitoring. This may be sufficient for the purposes of providing assurance that downstream water resources continue to be protected from contamination with alpha-emitting, long-lived transuranic radionuclides. If not, the existing programs should be intensified.

The federal government should also provide states and public water system authorities that are hydrologically or hydrogeologically contiguous to DOE sites with the funds to conduct independent checks on DOE's on-site and off-site water monitoring. Such funds would better be provided through the EPA, rather than through the DOE, in order to assure the independence of the monitoring and the continuity of the funding.

4. A separate limit of detection of each alpha-emitting, long-lived transuranic radionuclide of 0.01 picocuries per liter should be set.

5. The DOE should make public the source code for the model that is used to assess the impact of residual radioactivity on food, water, and the environment.

Argonne National Laboratory developed a "family" of programs to assess the radiological impact of environmental contamination by radionuclides. The main one, called simply RESRAD, is used to assess the impact of residual radioactivity in the soil on human beings, by estimating radiation doses by a variety of pathways, such as food and water and re-suspended soil. Its source code is not public. It does not incorporate dose conversion factors for children, infants, or fetuses at various times in their development. Its internal structure and its effects on the resulting estimates of doses and risks are not available for independent scrutiny. We strongly recommend that the RESRAD source code be made public, so that it can be examined and improved in the manner of the operating system Linux. The government, of course, need not adopt any changes that are made by the public unless it finds them useful for implementing environmental regulations. But there is no reason for holding a source code paid for by taxpayer dollars secret, particularly as billions of dollars are being spent on cleanup decisions based on the results generated by the RESRAD program.


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Institute for Energy and Environmental Research

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June 2005