The U.S. Environmental Protection Agency’s draft EPA “Protective Action Guide” (PAG), posted on its website April 15, allows hundreds to thousands of times more radiation in disasters than the agency had previously allowed. Americans have until Monday, July 15 to comment* even though the EPA made the new PAG effective immediately.
According to EPA’s own data, the new PAGs will result in exponentially higher radiation-induced fatal cancers than the current goal of one in ten thousand to one in a million Americans.
In various exposure scenarios listed in the report, depending on which radionuclide, the resultant cancer rates would claim several out of ten, one in eight, one in six – even as low as one in 1.7.
The EPA PAG’s justification for these astronomically higher numbers is that during a disaster like a nuclear meltdown, a terrorist ‘dirty bomb,’ or a nuclear detonation, all limits currently for radiation exposure in air, water, food and soil are targets for revision.
“These PAGs are basically admitting that contamination levels could be so high from such an event that they may not be able to be cleaned up to existing standards such as the drinking water contamination levels,” says Maryland-based Nuclear Information and Resource Service. “Thus, EPA would permit unacceptably high radiation risks at each of the stages after nuclear disaster without even suggesting any steps to prevent or minimize the potential disasters.”
Depending on the radionuclide, the increased limit eclipse’s EPA’s long-established levels. Those limits were created in the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA).
Various draft PAG exposure scenarios utilizing the EPA’s own numbers show fatal cancers at levels hundreds to thousands of times higher than with CERCLA at Superfund cleanup sites across the country.
EPA says that their PAG does not affect Superfund sites across the country. But what the PAG does do, albeit in a non-binding advisory fashion, is create vastly loosened limits for domestic nuclear meltdowns and radiation waste accidents including during transportation. “Mobile Chernobyls” as anti-nuclear activists call them, would be exempt from strict radiation limits.
So would any number of private industry nuclear emergencies including pharmaceutical fires. First responders from firefighters to police and National Guard will use the EPA’s PAG extreme radiation limits to gauge the risk to its own personnel. They in turn will use these life-threatening levels to advise the public.
Radiation levels would rise thousands of times for some of the most dangerous radionuclides. Cesium-137, Strontium-90 and Plutonium-239 would all be considered safe at levels thousands of times what the EPA currently allows. The draft EPA PAG lists the new drinking water limit for Iodine-131 at 81,000 picocuries per liter [pCi/l, 27,000 times its current EPA limit of 3 pCi/l. Adding more misery to the mix, these numbers are for the so-called “intermediate phase” when the emergency has passed and would be in place for one to several years thereafter.
Iodine-131, with its 8.5 day half-life, targets the thyroid and is especially dangerous to infants, children and pregnant women. The isotope is so lethal that radiation-aware people around the world keep potassium iodide (KI) pills stocked in case of its release. KI pills fill the thyroid with a harmless form of iodine and suppress I-131 from damaging the thyroid. The thyroid is responsible for the growth of organs, including the brain, making the radionuclide particularly harmful to young people.
“[The EPA PAGs] incorporate the DHS PAGs for dealing with long-term cleanup from a nuclear weapons explosion and apply it to any kind of release,” said Daniel Hirsch in an EnviroReporter.com interview. Hirsch is president of the Committee to Bridge the Gap, a nuclear watchdog group, and lectures at the University of California Santa Cruz on nuclear policy matters. “In essence, the PAGs and the documents associated with them are saying nuclear power accidents could be so widespread and produce such immense radiation levels that the government would simply abandon most cleanup obligations and force people to live with exposures so high that extremely large fractions of the exposed population would get cancer from the exposure.”
Hot zones would no longer be considered hot, not by a long shot. Adopting these ’emergency’ levels eviscerates decades worth of EPA radiation regulations and limits created and supported by costly scientific studies funded by the American taxpayer for the last 43 years.
Referencing guidelines from the International Atomic Energy Agency, Nuclear Regulatory Commission, Department of Energy and the National Council on Radiation Protection & Measurements (NCRP), the EPA has created a “new normal.” That new normal, as defined by the IAEA, NRC, DOE and NCRP, is radically more radioactive than any other plan the EPA has ever issued.
The EPA PAG’s rationale has never been clearly stated other than the supposed benefits of bringing EPA’s 1991 PAG up in line with the Department of Homeland Security’s (DHS). The draft EPA PAG refers repeatedly to the 2008 DHS PAG as the basis for its radiation limits. It also cites associated guidance from the NCRP.
The PAG draft was signed April 5 by Bob Perciasepe, acting EPA Administrator though it was developed during the Bush Administration. “[T]he 2013 PAG Manual recommends projected radiation doses at which specific actions may be warranted in order to reduce or avoid that dose,” Perciasepe said. “The 2013 PAG Manual is designed to provide flexibility to be more or less restrictive as deemed appropriate by decision makers based on the unique characteristics of the incident and the local situation.”
A convoluted bureaucratic process has been set in motion that when fully implemented will destroy decades of sound radiological science. Since EPA’s PAG uses most of DHS’ PAG standards, it will update its standards when DHS does. DHS is already doing that with the nuclear industry-funded NCRP, which just published a 587-page (5.21 MB) report February 25 for DHS called “Decision Making for Late-Phase Recovery from Nuclear or Radiological Incidents.” Once DHS accepts this report so will the EPA. The agency already cites NCRP in its draft PAG as a standards and operations resource so all it would do is update the EPA PAG’s footnotes and it will be a fait accompli.
“This is a public health policy only Dr. Strangelove could embrace,” stated Jeff Ruch, director of Public Employees for Environmental Responsibility, noting that the EPA PAG lacks an understandable rationale.
SUCK IT UP
Staying on message to spin the new normal as a good and necessary cutting of radiation protection levels during emergencies takes some finesse. EPA’s spin flew out of control in March when a mid-level EPA scientist told it like it really is, without realizing there was a reporter in the audience of nuclear industry heavyweights.
“People are going to have to put their big boy pants on,” said Paul Kudarauskas of the EPA Consequence Management Advisory Team, “and suck it up.”
NIMBY’s, according to Kudarauskas, would have to give up their “not in my backyard” mentality because “cleanup to perfection” was a thing of the past now that EPA had a “fundamental shift” in cleanup philosophy after the Fukushima meltdowns.
Kudarauskas confirmed the accuracy of the quotes to EnviroReporter.com while fudging on what he meant because, Kudarauskas says, the article took what he said out of context in a roomful of government and nuclear industry people who didn’t expect to be quoted by the press.
“I don’t want to stir any more feathers because someone properly quoted me,” Kudarauskas said in an April 25 interview with EnviroReporter.com. “I’m not going to do it. I want my management present so they hear what I’m telling you because it was taken so far out of context that it is ridiculous.”