Nukewatch Quarterly Fall 2016
In the summer 2016 Quarterly we reported on the US Environmental Protection Agency’s (EPA) proposed weakening of drinking water contamination standards—known as Protective Action Guides—and urged readers to send comments. Diane D’Arrigo, Radioactive Waste Project Director at Nuclear Information & Resource Service, wrote this update on the status of the proposal.
Well over 60,000 comments were submitted to the EPA by the July 2016 deadline, nearly all of them critical and calling on the agency to:
- Reject the water PAGs—the not-so protective Protective Action Guides—which would dramatically increase allowable radioactivity in drinking water for up to years after nuclear incidents. “Incidents” could be as routine as a radioactive release or a spill, or as devastating as a nuclear bomb or reactor meltdown;
- Require drinking water to meet existing Safe Drinking Water Act Maximum Concentration Levels for the weeks, months or years (the intermediate phase) after radioactive contamination “incidents.”
Over 66,000 comments were submitted to EPA in total on both the 2016 proposed EPA Water Protective Action Guides (Water PAGs) and the more inclusive proposed 2013 PAGs, to which they are being added. The 2013 PAGs on all “pathways of exposure” include a 1998 PAG for food. EPA had said there was no PAG for drinking water, but a review of the agency’s Food PAG revealed that in fact, drinking water was included. So the newly proposed Water PAG would actually add even more allowable radiation exposure from water, essentially doubling the exposure from food and water!
EPA is determined to make official both the 2013 “Protective Action Guides” and their proposed 2016 Water PAGs before the next Presidential Administration is installed—possibly before the election. The agency tried back when President Bush was leaving office but missed getting them finalized then, so is trying again.
The EPA is disingenuous in its promotion of this dangerous “guidance” in several ways. Two are described here:
First, EPA strongly implies the PAGs would apply to the immediate aftermath of a huge disaster, when in fact they apply to the “intermediate” phase of any radioactive “incident” …that “warrant[s] consideration of protective action.” (Ch.1 para 1.1 of the EPA 2013 PAG; https://www.epa.gov/sites/production/files/2015-06/documents/pag-manual-interim-public-comment-4-2-2013.pdf).
So the “Guides” would be preferentially used by reactor operators and others to avoid meeting the stricter Safe Drinking Water Act requirements. The new weaker PAGs would allow enormous levels of invisible but deadly radioactive contamination in drinking water for weeks, months or even years after a nuclear “incident.”
This is a deceptive way to get around meeting the Safe Drinking Water Act Maximum Contamination Levels, Superfund cleanup levels, and the EPA’s long-standing allowable risk range—giving cancer to 1-in-a-million or at worst 1-in-10,000 exposed. The PAGs protect the polluters from liability more than the public from radiation.
Second, these unconscionably high radiation doses from the Water PAGS will be added to very high internal doses from contaminated food we would be allowed to eat under the 1998 Food PAGs (www.fda.gov/downloads/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/UCM094513.pdf) which are incorporated into the 2013 PAG.
Individuals would be allowed doses of 500 millirem/year from water plus 500 millirems/year from food and water in the intermediate phase; plus internal and external doses (2000 millirem the first year, and 500 millirem the year after) from the air we breathe and from external direct gamma rays emitted from the radioactive sources, as permitted by the 2013 PAG. (www.epa.gov/sites/production/files/2015-06/documents/pag-manual-interim-public-comment-4-2-2013.pdf; p. 7, Table 1-1)