Nukewatch Quarterly Fall 2013

By John LaForge 

On April 15, the EPA issued new so-called Protective Action Guides (PA guides) for dealing with large-scale radiation releases. The rules are meant to provide federal, state and local officials with protocols for responding to and cleaning up after reactor disasters or other industrial explosions, fires or spills — like the catastrophic triple meltdowns at Fukushima, Japan. 

As published in the Federal Register, they would allow drinking water contamination 20,000 times less stringent than the EPA’s current rules. They also suggest that officials cleaning up after a radiological accident do not have to follow EPA Superfund guidelines for environmental remediation. 

As such, the new PA guides are a government bailout of the utilities, that will, if unchanged, save reactor owners the staggering costs of adequate disaster decontamination. Industry has for years pushed for weaker regulation. In 2002, Roger Clarke, then President of the International Commission on Radiological Protection (ICRP), warned in the Bulletin of the Atomic Scientists, “Some people think that too much money is being spent to achieve low levels of residual contamination.” Since Fukushima, government and industry officials have said that using rigorous EPA/Superfund standards would be too expensive at several sites, including the Santa Susana Field Laboratory (see story below). 

According to comments by Physicians for Social Responsibility, Public Citizen and the Sierra Club, the PA guides “essentially admit that nuclear power is so dangerous that it could contaminate vast areas with extraordinarily high radiation levels, but rather than protect the people, [EPA] is proposing that government just let people be exposed to massive carcinogenic risks.” 

The PA guides took effect in April but can be amended or rescinded. 

The new PA guides: 

* Weaken drinking water standards for radioactivity and no longer comply with current Safe Drinking Water Act limits.

* Eliminate a 1992 nuclear disaster recovery recommendation from EPA that no one should be exposed to more than 5,000 millirems of radiation over 50 years. This benchmark may have eliminated the possibility of following the far weaker National Council on Radiation Protection (NCRP) recommendation that people could be exposed to 2,000 millirems/year, or 100,000 millirems over 50 years. 

* Weaken or eliminate existing protections and increase permitted dose limits far beyond what the EPA now uses for radiation, which particularly endanger women, infants and children. 

* Weaken current rules established by the EPA regarding relocation due to radiation doses to the thyroid and skin and weaken the limit of 5 rem over 50 years. 

* Recommend outdated 1998 guidelines that allow markedly increased levels of radioactivity in food. 

* Allow radioactive waste to go to regular landfills, incinerators or recyclers or to hazardous waste sites. 

EPA documents show intent to weaken cleanup regs 

Douglass Guarino, writing September 11 in The National Journal for Global Security Newswire reports that he obtained EPA records about the PA guides. In them Paul Kudarauskas, of EPA’s Consequence Management Advisory Team, said last March that US residents are used to “cleanup to perfection,” but that in view of the Fukushima catastrophe, “People are going to have to put on their big-boy pants and suck it up.” 

In one response, Dave Kraft, the Director of the Chicago-based Nuclear Energy Information Service, demanded that EPA rescind the PA guides and fire Mr. Kudarauskas. 

Daniel Hirsch, President of Committee to Bridge the Gap, emphasizes that the NCRP’s plans for implementing the new PA guides would allow the public to be exposed to more radiation. “In essence,” Hirsch reports, the PA guides say “nuclear power accidents could be so widespread and produce such immense radiation levels that the government would abandon cleanup obligations” forcing people to absorb and live with far more cancers. 

One document released to Guarino/GSN is a talk by Mike Boyd, an official in the agency’s radiation office, given about the new Protective Action guide during a May meeting in Paris in which Boyd praised cleanup standards suggested by the private NCRP and the nongovernmental ICRP. Both bodies recommend exposure standards to governments for industry workers and the public. 

However, the recommendations of these two groups have been previously criticized as too lax by the EPA, state cleanup officials and environmental activists because they suggest cleanup standards “thousands of times less rigorous than what has ever been permitted in the United States.” 

No exposure to radiation is safe, since even the smallest dose has cellular-level effects that can lead to immune dysfunction, birth defects, cancer and other diseases. The definitive National Academy of Sciences’ 2006 report Biological Effects of Ionizing Radiation, BEIR-7, declared “It is unlikely that there is a threshold below which cancers are not induced.” 

In accordance with BEIR-7, official EPA policy assumes there is no safe level of radiation exposure. 

But when John Cardarelli — an official in EPA’s emergency management office and a colleague of Kudarauskas on the EPA Consequence Management Advisory Team — spoke in May 2012 to Japanese emergency managers dealing with Fukushima, he presented sham theories explicitly rejected by the National Academy in BEIR-7. In particular, Cardarelli endorsed the “hormesis” hypothesis (that a little radiation is beneficial, acting like a “vaccination”), which the NAS debunked by name in BEIR-7. 

The EPA’s letter to GSN defends Cardarelli’s presentation, arguing that the “scientific community is not unified on radiation health effects. But to the contrary, every US governmental agency that regulates radiation exposures has adopted the NAS finding that no matter how little, any radiation exposure can cause cancer. 

In a Sept. 2012 talk to an interagency group led by Homeland Security, Cardarelli recommended a 100 millirem-per-year radiation dose limit. About 1-in-300 people would be expected to develop cancer if exposed to this level for 30 years, according to NAS and EPA risk models. 

Guarino reports that the authors of the Dept. of Homeland Security paper “have defended their recommendations in part by arguing that the 2011 Fukushima disaster in Japan contaminated an area the size of Connecticut and demonstrated the impossibility of a Superfund-level cleanup of that scope.” But rather than declare that evacuation is the only safe response to severe contamination, DHS wants to raise radiation dose limits to between 100 and 2,000 millirems per year. Over 30 years, this equates to a cancer risk of between one-in-23 and one-in-466 from long-term radiation exposure. 

Normally, the EPA does not permit cancer risks greater than one-in-10,000. 

Daniel Hirsch, with GAP, says the cancer risk would likely be higher. Accounting for the greatly increased susceptibility of women, infants and children to radiation, or the likelihood that chronic doses would last for an entire 70-year lifetime, up to one-in-six people would be expected to develop cancer, Hirsch said.