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.”
Kudarauskas’ confirmation of his quotes and refusal to clarify what he meant do not inspire confidence that he meant anything other than he said. Despite assurances of an approved interview, EPA instead sent EnviroReporter.com an email with no subject line and a hastily composed blow-off. EPA has no time for prying questions, especially ones that pertain to the actual arithmetic of discombobulating complex radiation regulations.
The EPA’s draft PAG is a hot tale told in cold radionuclide names and numbers. No amount of Byzantine sleights of hand in the draft EPA PAG’s footnotes can obscure the stark reality of the literal heights of the new radiation limits. Or the misery they would cause.
The worst radioactive isotopes prevalent in a radiological disaster, including Cesium-137, Strontium-90 and Plutonium-239, would be allowed at levels so high that in one EPA radiation scenario, exposure would lead to a 100 percent chance of getting a fatal cancer, eight times over. Food radiation limits would be loosened so much that one in fifty people could contract the terminal disease.
Cesium-137 and Strontium-90, two virulent radionuclides that cause blood and bone cancers including leukemia, reaches new limits literally. Cs-137 is now considered safe at 270 times its previous cutoff level. Sr-90 comes in at 676 times what is the maximum level considered safe to drink.
The report creates different “alternatives” or environmental situations such as early, mid and late nuclear disaster scenarios. This results in different new rad limits on isotopes. In EPA PAG Alternative II for Strontium-90 in drinking water, the 246 Becquerels per liter (Bq/l) new limit is 7,022 times EPA’s PRG. At 50 Bq/l Plutonium-239 is now over 3,447 times its own PRG as determined by the agency that made both.
According to environmental and public health advocates, the NRCP, which created the guidelines that EPA will adopt, is “an organization dominated by industry and government interests” and so doesn’t seem to mind sending folks back to their farms, homes and offices to work and live in a radiologically contaminated environment with concentrations of deadly isotopes skyrocketing as high as tens of millions of times the PRGs.
This would happen without cleanup undertaken. Who needs to clean up when it’s still within the new PAG benchmarks that dictate no cleanup necessary if the public is dosed with less than 1 rem per year? That small sounding number could seem reasonable until one realizes that it is the equivalent of each individual exposed getting 15,000 chest X-rays over a thirty year period.
In fact, the DHS PAG which the EPA version incorporates doesn’t require cleanup until 10 rem a year is reached which is 150,000 chest X-rays in the same period of time. The EPA’s own calculation of how many cancers would be caused by this radiation is one in every 1.7 people. Females, however, run an even higher risk than males from the same high level of exposure.
Instead of blowing radiation limits sky high in all instances, the PAGs just get rid of some of the most important ones. The 1992 EPA PAGs required relocation of people if skin and thyroid doses reached a certain limit. No more. In order to “avoid confusion,” says EPA draft guidelines, the limits have simply been removed.
The skin and the thyroid are most sensitive to radiation exposure. Now there will be no guidance at all on this which seems blatantly dangerous to both people exposed and to the maintenance of some semblance of order should a nuclear accident, terrorism or detonation occur. This is an especially dangerous rewrite of the safety rules for first responders and others charged with maintaining order in the case of a nuclear emergency.
If there has to be a cleanup, however, the PAG provides astonishing new guidance: take radioactive debris and waste and dump it in unregulated municipal garbage dumps. In Guidance for the Late Phase in Chapter 4 of the PAGs, it is suggested that nuclear waste be allowed into these facilities without any attention paid to the fact that these dumps could leak the radioactive material, which could also migrate through surface and groundwater.
The EPA’s reliance on DHS PAGs will gut radiation protections by using these emergency levels to not only apply to nuclear detonations or “dirty bombs” but even minor nuclear events like a radiopharmaceutical spill or fire. This makes the guide practically useless for emergency responders and puts them in the front line of the hot zone without the adequate protection they deserve based on sound science that will keep them safe.
Compounding the effect of the draconian new radiation limits is the EPA PAGs’ adherence to outdated Food and Drug Administration guidelines on what’s allowed in American food and drink. FDA guidance for just food alone allows 500 millirem exposure per year which is the equivalent of a chest X-ray daily in radiation dose equivalent.
These old FDA rules are astonishing on the face of them. FDA allows up to 4,700 picocuries (pCi/l) of Iodine-131 in a liter of milk while the EPA allows 3 pCi/l in drinking water. For Cesium-137, which also has the 3 pCi/l EPA threshold, the FDA allows up to 33,000 pCi/l. Yet even with these huge discrepancies, EPA has chosen to abandon their own limits in favor of the FDA ones that were created decades ago.
Slashing radiation safety measures are an across the board enterprise that EPA has embraced wholly. It is the kind of historic policy shift that radically rewrites radiation policy. The losers are first responders, police, military and the public.
THE THREAT FROM WITHIN
The EPA PAG is ingenious as it is dangerous. Should any of America’s aging 103 nuclear reactors have an accident or meltdown, the EPA can declare contaminated air, water, food and soil safe. Should terrorists attack and destroy a lightly defended nuclear reactor spent fuel pool, which would release far more radiation than a meltdown, the new PAG ought to handle it even if first responders get nuked in the process. If a cargo of radioactive material is released into the environment from a simple accident, the agency can simply point to the “protective” levels to say it’s safe.
There is no better way to hurt an enemy than to have the enemy hurt itself. It’s a plan that Osama bin Laden would have loved. Get American officials to give Americans assurance that the EPA says that radioactive contamination unleashed in a terrorist attack isn’t so bad after all.
It’s the ‘Fukushima Fakeout’ where the lesson learned from the Japanese meltdowns is to blow the numbers out so high that even lethal levels of radiation are rated tolerable. It makes as much sense as having police officers remove their bulletproof vests in a gunfight or unlocking seatbelts in a vehicular crash.
The Japanese government is perfecting the art of justifying high radiation exposure to the unwitting population still close to Fukushima Dai-ichi. An investigation by Japan’s leading daily newspaper Asahi Shimbun May 25 revealed that the “government avoided setting stringent radiation reference levels for the return of Fukushima evacuees for fear of triggering a population drain and being hit by ballooning costs for compensation.”
The government initially sought a 5-millisievert per year (mSv/y) cutoff line where above it would be deemed too hot to return for earthquake and multi-meltdowns refugees of the March 11, 2011 multiple disasters. Previously, the target had been 1 mSv/y. All of this was rejected in favor of 20 mSv/y because the “prefectural government could not function with population drain under the 5-millisievert scenario,” said a state minister quoted by Asahi Shimbun. “In addition, there were concerns that more compensation money will be needed, with an increase in the number of evacuees.”
Instead of the numbers of evacuees increasing, the 20 mSv/y will increase excess cancers in one in every six Japanese exposed, based on the most current radiation risk estimates from the National Academy of Sciences and EPA. This mind-bogglingly lax standard is exactly the one proposed by the NCRP which will make its way into the draft EPA PAG long after commenting is over and the dangerous levels become law.
“In the place of longstanding health-based cleanup standards, NCRP now proposes setting cleanup levels for many radiological releases in the 1 to 20 mSv/y range, with such doses to be permitted to extend for one’s entire life,” says Hirsch in his comments on the PAG. “These are extraordinary doses. 20 mSv/y is the equivalent of approximately one thousand chest X-rays annually, or three chest X-rays every day of your life, from the moment of birth to the moment of death. Of course, there would be no informed consent or medical benefit from such exposure, only medical detriment.”
Giving false safety information about radiation to Americans in times of crisis is ludicrous. High radiation limits may help keep people calmer in crisis, theoretically, but that only helps in the short term and is harmful in the mid and long term. Inflated radiation limits will induce our most needed civil servants in a radiation crisis to needlessly expose themselves and others.
The final steps before formal acceptance of the PAG comes as its creator, Obama’s nominee for Administrator of the Environmental Protection Agency, Gina McCarthy, is closer to assuming office than when the PAG controversy first erupted in earnest in March.
McCarthy supervised the draft EPA PAG radiation limits as she has been in charge of the EPA’s Office of Air and Radiation since 2009. She oversaw a revised version of the EPA PAG which would allow Americans to consume water at thousands of times in excess of EPA “Maximum Contaminant Levels” (MCLs) for radiation.
Her nomination had been stalled by Republicans in the Senate but Sen. David Vitter (R-Louisiana), the ranking Republican on the Senate Environment and Public Works Committee, said July 9 that he no longer opposed bringing McCarthy’s nomination to the floor of the Senate without filibuster. That leaves one holdout Republican, Sen. Roy Blunt (R-Missouri) who wants answers from the EPA, Army Corps of Engineers and US Fish and Wildlife Service for a floodway project in southeast Missouri along the Mississippi River levee system.
It seems that McCarthy is the right person for the nuclear industry. It is indeed a critical time considering the shape of many of America’s nuclear reactors: aging and prone to accidents and leaks. Loosening the limits allows more radiation to be let loose in the environment without being considered dangerous.
This sets the stage for astronomical radiation limits to be used not only in emergencies in case of nuclear war or terrorism, but in all radiological “incidents” across America. All that is needed to make that change is a future updated footnote in the EPA PAG.
“If this typifies the environmental leadership we can expect from Ms. McCarthy, then EPA is in for a long, dirty slog,” said Ruch.
NUCLEAR NATIONAL PARK
The new EPA PAG also opens the door open for the huge radiation level hikes to be implemented at contaminated sites across the country. That could include such infamously polluted places as the Santa Susana Field Laboratory (SSFL), 35 miles northwest of downtown Los Angeles, where America’s worst partial nuclear reactor meltdown occurred. The site is now the subject of an intense greenwashing and astroturfing campaign by polluter and community collaborators. Despite astronomical levels of radiation, the former Rocketdyne site could be declared clean tomorrow using these new EPA PAG numbers.
Judging from the EPA’s egregious behavior at the SSFL since our reporting on the facility began in 1998, we have little doubt that the agency will continue to use and abuse any rule or regulation to enable the polluters to escape fully remediation the site.
But federal chicanery and bait and switches can’t escape the all too real result: huge hikes in radiation limits would result in needless casualties should any number of nuclear-related scenarios unfold.
Places like SSFL could be released as parkland without further cleanup, a scenario that would please the responsible polluting parties – DOE, NASA and lab owner Boeing – already emboldened by EPA blatant waste of $41.5 million evaluating SSFL for radiation then subverting its own findings to greatly lessen the amount of hot land to be remediated. The polluters and government agencies charged with regulating their toxic contamination are working closely together to insure that no full and proper cleanup of the site will take place as we exposed in Boeing’s Meltdown Makeover.
“EPA is statutorily mandated to produce the PAGs and other radiation guidance for the rest of the federal family and historically has viewed DOE and NRC [Nuclear Regulatory Commission] as not sufficiently protective in radiation matters,” Hirsch said. “The PAG now abdicates EPA’s responsibility to come up with guidance and instead references almost exclusively documents from DOE [Department of Energy] that EPA has historically opposed. For example, it now directs the use of DOE’s Operational Guidance document which uses cleanup concentrations hundreds of thousands of times higher than EPA’s official concentrations.”
The radical changes are a far cry from the 1991 EPA PAG’s admonitions to put public safety first over economic profits. “PAGs should not be higher than justified on the basis of optimization of cost and the collective risk of effects on health,” the 274 page document reads. “That is, any reduction of risk to public health achievable at acceptable cost should be carried out.”
The 2013 draft EPA PAG trims down to 86 pages largely because it foists off specific limit levels on radionuclides on other nuclear industry-influenced figures. The hugely inflated acceptable limits are all part of what the Nuclear Regulatory Commission chairman calls “the new normal.”
“For example, I’m sure that as the U.S. industry considers the question of filtered containment venting and other filtration strategies, you will benefit from the collective years of experience other countries have with this technology,” said NRC Chairman Allison M. Macfarlane at the Nuclear Energy Institute’s Nuclear Energy Assembly in Washington, D.C. May 14. “One critical aspect of the ‘new normal’ is that public interest in nuclear power, whether positive or negative, remains heightened. Where certain technology is in place in some countries and not others, both the public and our elected leaders are naturally predisposed to make comparisons.”
Those comparisons include the fact that the NRC doesn’t require American reactors to have filters on their containment domes to remove radionuclides released into the environment in emergency situations like the one in Japan when hydrogen gas buildup blew one reactor to smithereens. Instead, it’s voluntary, as Macfarlane said.
The point of having PAGs is supposedly to deal with all manner of nuclear emergency including attack and accident. EPA PAG instructions include recommendations on when to evacuate an area, shelter in place and when and if to take potassium iodide (KI) pills in case of extreme Iodine-131 exposure.
The emergency rad levels are supposed to give first responders some sort of reference with what level of threat they are dealing. But even that role is muddled in the document referring to other agencies and their standards which aren’t included in the PAG.
“PAGs do not establish an acceptable level of risk for normal, nonemergency conditions, nor do they represent the boundary between safe and unsafe conditions,” the EPA report reads. “The PAGs are not legally binding regulations or standards and do not supersede any environmental laws.”
Then what would be the point of such guidelines other than to render any recommendations mute even if they could be found in the draft EPA PAG? They are nowhere to be found. It is a first responder’s nightmare when it comes to determining safe levels of radiation in an emergency situation.
NEW BOSS, SAME AS THE OLD BOSS
The new EPA PAG is solidly an Obama Administration endeavor, eclipsing the efforts of the previous Republican executive branch. Federal authorities now envision an environment where the needs of the companies and government entities responsible for radiologically contaminated sites across the country supersede those of the population in general. Anybody who objects will be painted as a NIMBY who just can’t handle radiation like a real man.
EPA Administrator nominee Sullivan may have made a safe bet that Americans won’t see the dangers of sky high radiation standards or even care. Public unawareness and apathy over the ongoing Fukushima triple meltdowns are strong arguments for that bet.
No one wants to think that the government, on any level, would choose to lie to the American public in a nuclear emergency or about a radioactively contaminated site. But it has happened repeatedly. Now, no one has to lie. The new limits are so high that signaling the all-clear will be much easier.
The Obama Administration has introduced a policy shift that fundamentally removes established radiation protections for the American people. That the President is taking this extraordinary step shouldn’t be a surprise to environmental policy watchdogs.
Obama’s EPA has failed to monitor for Fukushima radiation in the Pacific even when there has been incontrovertible evidence of the irreparable harm the triple meltdowns are doing to the ocean. EPA pulled RadNet mobile radiation detection systems offline across America just months after the ongoing calamity began saying they weren’t needed. Today more than half of the Fukushima fallout-detecting beta detectors aren’t functioning in the 123 cities that RadNet monitors.
The Administration has little to worry about though because it knows that the country is filled with willing victims, people determined to dismiss the nuclear threat from foreign and domestic sources. It witnessed the laissez-faire reaction of Americans to the disaster in Fukushima. It knows that it can count on the media to treat the triple meltdowns as only a Japanese problem despite the reality that American water are just 5,000 miles away at the receiving end of the Kuroshio Current.
THE PERFECT CRIME
The dearth of media coverage of one of the greatest ongoing environmental disasters in history belies how thin mainstream media’s investigative ranks have become. Few newspapers have the resources or scientific expertise to even tackle such a complicated subject especially when it can be fobbed off as just politically motivated anti-nuclear hysteria.
What better way to control the literal fallout of a nuclear disaster in America than to have one of the few highly respected government agencies, EPA, give the all-clear when it isn’t all clear at all? What better way to keep people calm and willing to productively exist in an environment so hot that it increases the odds of deadly cancers thousands of times? What better way to sneak it into the EPA’s go-to radiological disaster guide than in obscure and complex footnotes? Who better to implement it than the person who oversaw its creation, now Obama’s EPA chief choice?
It is the perfect crime because it hasn’t even happened yet, but the future victims have already signaled their consent when the terrible crisis comes. America’s aging 103 nuclear reactors haven’t melted down or been destroyed in a tornado, hurricane, flood or earthquake. No terrorist has set off a dirty bomb or destroyed a lightly-defended and protected spent fuel pool, some as close as mere yards from where anyone with a rocket launcher could attack.
These quiet and hard to comprehend sleights of hand are akin to taking a police officer’s bulletproof vest away during a gun battle, stripping a fireman of his protective suit in case of conflagration or cutting the cords to the parachute of a pilot jumping from a nose-diving plane. And when it happens, and happens repeatedly under countless scenarios in a country awash in nuclear materials and radioactive waste, the Environmental Protection Agency’s Gina McCarthy will be assuring Americans that it’s all okay because the EPA says so.
The passage of the EPA’s draft Protective Action Guide will only serve to endanger Americans needlessly. To protect family, friends and community in the face of this bureaucratic betrayal, folks are going to have to depend on trusted sources and themselves to know what the real situation is and what to do about it. Our lives will depend on it.
* The EPA has extended the comment period to September 16, 2013. See http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2007-0268-0071