Fairewinds Comments on the EPA’s Proposed Changes to the Protective Action Guidelines (PAG)
/
RE: Environmental Protection Agency (EPA)
Radioactive Protective Action Guides (PAGs) and Water PAGs
Docket Number (EPA-HQ-OAR-2007-0268; FRL-9947-55-OW)
Dear Janet McCabe – EPA Acting Assistant Administrator for the Office of Air and Radiation and the EPA Docket:
Fairewinds Energy Education has prepared this brief report in response to the EPA’s suggested changes to its Radiation Protective Action Guidelines (PAGs). Specifically, the EPA is suddenly recommending a huge increase to “allowable” public exposure levels from radiation releases caused by a mishap or disaster at an atomic reactor, waste storage site, fuel production site, etc. What does this mean? It means that the EPA is arbitrarily choosing to increase human exposure levels to atomic radiation releases without conducting an adequate scientific review and without quantifying the significant health consequences to people.
Fairewinds Energy Education’s scientific review of the data has found no evidence or basis in science to allow such a health compromising transfer of risk to everyone living in the United States. Therefore, Fairewinds Energy Education strongly objects to the implementation of these proposed rule changes that will compromise public health and safety and benefit atomic corporations by allowing a significant reduction in each corporation’s mandated cleanup of costly radiation catastrophes.
The EPA is proposing that levels of 500 millirem per year are acceptable in radioactively contaminated water for general public consumption and an increase to 100 millirem per year of exposure levels to pregnant women and young children. These levels far exceed EPA’s acceptable risk range for cancer causing radiation exposure levels.
Let me simplify this for you and for readers of Fairewinds’ comments. If implemented, this proposed change in radiation guidelines greatly increase radiation exposure to people to a totally unacceptable radiation risk level. At the same time, the changes will reduce radiation disaster cleanup costs to corporations and transfer that horrific risk and cost of cleanup to states, cities, towns, and villages that will already be suffering astronomical losses.
Since the triple meltdown at Fukushima Daiichi and its decimation of much of the Fukushima Prefecture (state) due to extensive ongoing radiation releases, Fairewinds’ Chief Engineer Arnie Gundersen has traveled to Japan three times on public speaking and scientific fact finding research and analysis. Most recently, Mr. Gundersen spent one month in Japan in February of 2016 measuring the ongoing radioactive releases from the atomic disaster, and interviewing numerous “survivors”, who have been exposed to radioactive releases from the meltdowns and are continuing to be exposed to the ongoing buildup and movement of significant amounts of radioactivity. Mr. Gundersen has two degrees in Nuclear Engineering and more than 44-years of atomic energy operations and risk analysis experience.
A thorough review by Fairewinds of the evidence collected and the available published literature proves that the proposed changes to the PAGs are a convoluted attempt to shift excessive radiation risks to a population of innocent bystanders at the same time the EPA is transferring excessive profits to the corporate owners of atomic power reactors, waste storage facilities, atomic fuel producers, etc.
Beginning in February of 2012, when Mr. Gundersen spoke at the Foreign Correspondents Press Club in Tokyo, he went on record stating that the economic cost of the Fukushima Daiichi cleanup would exceed a quarter of a trillion dollars ($250 Billion), and this figure does not include the mammoth health costs the government of Japan will have to cover for victims of this ongoing radioactive debacle.
Instead of meeting the humanitarian needs of its people, the response by the pro-nuke Japanese government, Tokyo Electric and the IAEA (International Atomic Energy Agency – chartered by the United Nations (UN) to promote atomic power worldwide) to this ongoing radioactive tragedy has been to significantly increase allowable radiation exposures to Japanese citizens by 20 times more radiation exposure than previously allowed.
The PAGs are designed to protect real people from health damaging radiation exposure, and the PAGs were serving this function as well as the regulations allowed. This change proposed by the EPA is a complete financial boondoggle that will benefit corporate profiteers while damaging the health, water, and food supplies of all Americans.
The atomic power industry in Japan, the IAEA, and the Japanese government created these changes to radiation exposure guidelines in Japan in order to minimize the astronomical radiation cleanup costs from the ongoing radiation debacle caused by the three Fukushima Daiichi meltdowns. Instead of having Tokyo Electric and the Japanese government pay the costs as the regulations were originally designed, the Japanese government has transferred enormous additional radioactive risk to its own people, who are still being unwittingly exposed. Toxic illness causing radioactivity will be in Japan for centuries, and the alleged cleanup methods currently being applied are simply spreading toxic radioactivity to Japan’s once pristine agricultural community and its crucial rivers, streams, and aquifers as well as the Pacific Ocean from which it derives much of its food sources of fish and seaweed.
While Fairewinds has numerous technical concerns that we have detailed below, the fundamental question that the EPA must address is:
· Why is the EPA considering placing civilians at such a dramatically increased magnitude of risk?
· When these corporations first built their atomic reactors and other facilities, the licenses to do so were granted under the obligation that these corporations are ultimately responsible for all maintenance and cleanup. Why are corporations gaining profits while the financial risk will be borne by people in and near those reactors for hundreds and thousands of years (in the case of plutonium releases, like what happened in Japan)?
The radiation measurements taken in Fukushima by Mr. Gundersen and other scientific colleagues coupled with their field interviews, shows that the proposed PAGs place American civilians at greater risk while saving American corporations hundreds of billions of dollars in cleanup costs.
Conclusions:
It is Fairewinds Energy Education’s expert opinion and conclusion that the proposed Protective Action Guidelines are not PROTECTIVE as required by federal statute and therefore should be rejected entirely.
Conclusion 1. It clear then that if the new PAGs are implemented, the atomic production industries will benefit financially at the expense of human health. This change in radiation standards is in direct contradiction to the public health role set in legal statute that created the EPA. May we remind you that your statutory authority is for: “establishing generally applicable environmental standards for protection of the general environment from radioactive material”.
According the National Academy of Science Biological Effects of Ionizing Radiation (BEIR VII) report, the EPA is bound by the linear non-threshold (LNT) radiation theory. BEIR VII is clear that there is no safe limit for radiation exposure and that radiation damage to civilians increases in a direct proportion to the amount of radiation they receive.
“A comprehensive review of available bio-logical and biophysical data supports a “linear-no-threshold” (LNT) risk model—that the risk of cancer proceeds in a linear fashion at lower doses without a threshold and that the smallest dose has the potential to cause a small increase in risk to humans.” [1]
The EPA proposal to increase the PAG limits 100-fold is a direct violation of BEIR VII and the governing federal statute authorizing the EPA. According to BEIR VII, Americans will receive the corresponding 100-fold increase in radiation damage if the EPA is allowed to violate federal law and implement the guideline changes it is promoting.
Conclusion 2. If the EPA violates federal statute and implements the new PAG limits, radiation risk to the exposed civilian population will increase 100-fold. Circumventing the Safe Drinking Water Act, Superfund cleanup levels, and EPA’s history of limiting the allowable risk of cancer to 1 in a million people exposed, is a clear breach of the National Environmental Policy Act (NEPA) of 1969 (Public Law 91-190, approved Jan. 1, 1970, 83 Stat. 855), that pertains to ecological systems.
It appears that the EPA proposed changes to the PAGs are based on the erroneous assumption, also held by the Nuclear Regulatory Commission (NRC), that the meltdown at Three Mile Island (TMI) did not increase cancers in the surrounding area or in those who were victims of the disaster. The peer reviewed analysis by epidemiologist Dr. Steve Wing showed that people exposed to radiation from TMI meltdown suffered meaningful increases in cancers.
“Exposure to high doses of radiation shortly after the nuclear accident at Three Mile Island may have increased cancer among Pennsylvanians downwind of the plant, scientists at the University of North Carolina at Chapel Hill say. Dr. Steven Wing, associate professor of epidemiology at the UNC-CH School of Public Health, led a study of cancer cases within 10 miles of the facility from 1975 to 1985. He and colleagues conclude that following the March 28, 1979 accident, lung cancer and leukemia rates were two to 10 times higher downwind of the Three Mile Island reactor than upwind.”[2]
Conclusion 3. Peer reviewed scientific evidence indicates that nuclear disasters and toxic radioactive releases, such as the Three Mile Island meltdown, cause cancer. It is a complete mischaracterization of federal radiation dose standards for the EPA to suggest that increasing the PAGs 100-fold will have no deleterious impact on public health when toxic radioactive releases happen.
The proposed changes to the PAGs appear to be based upon the erroneous assumption, also misstated by the Nuclear Regulatory Commission (NRC), that there was no increase in cancer as a result of the tragic Chernobyl meltdown. According to the peer reviewed analysis of Dr. Alexey Yablokov and others, the people exposed to radiation discharges by the Chernobyl catastrophe experienced a statistical increase in cancer.[3]
“It concludes that based on records now available, some 985,000 people died, mainly of cancer, as a result of the Chernobyl accident [catastrophe]. That is between when the accident [meltdown] occurred in 1986 and 2004. More deaths, it projects, will follow.
The book explodes the claim of the International Atomic Energy Agency [IAEA]– still on its website that the expected death toll from the Chernobyl accident will be 4,000. The IAEA, the new book shows, is under-estimating, to the extreme, the casualties of Chernobyl.”[4]
Conclusion 4. Peer reviewed scientific evidence clearly indicates that nuclear disasters like Chernobyl cause cancer. The EPA suggestion that increasing the PAGs 100-fold will have no deleterious effects on public health is a complete mischaracterization of federal radiation dose standards.
Fairewinds own evidence-based scientific research in Fukushima Prefecture indicates that there will be between 100,000 and 1,000,000 additional cancers in Japan as a result of the world’s most recent atomic reactor meltdowns. As delineated earlier in this submission, the Japanese government has unilaterally increased its allegedly allowable radiation exposures to humans by 20 times, putting its entire population, and especially women and children at significant risk for developing additional cancers from these intense radiation exposures.
The analysis conducted by Fairewinds Energy Education and its scientific colleagues indicates the contribution from small but highly radioactive particles (hot particles) absorbed by the internal organs of exposed individuals is being totally ignored by regulatory bodies worldwide, such as the IAEA and WHO (World Health Organization). Human exposure to these small particles within internal organs exposes people to high-energy radiation for decades. The proven impact of hot particle exposure is being completely ignored by federal regulators and all international health agencies. By not considering non-uniformly distributed radioactive particles in its dose calculations, the EPA is introducing a systematic bias to its dose calculations that will create radiation-induced casualties and a humanitarian calamity.
Conclusion 5. Peer reviewed scientific evidence indicates that small but highly radioactive particles are released in large quantities post-accident. The radioactive concentration in releases is not uniformly distributed. Therefore, a thorough analysis of the dose consequences from these hot particles must be ascertained before making any changes to PAG regulations.
The EPA proposed changes to the PAGs absolutely underestimate the radiation induced cancers that those changes will cause to people throughout the United States while offering an enormous financial bonus to the corporation creating the risk and producing these highly radioactive liquid and gaseous discharges. Changing the PAGs decimates public health by putting the public at greater risk of radiation induced cancers while benefiting corporate profits.
[1] http://dels.nas.edu/resources/static-assets/materials-based-on-reports/reports-in-brief/beir_vii_final.pdf
[2] Study suggests Three Mile Island radiation may have injured people living near reactor, University of North Carolina, February 1997: http://www.unc.edu/news/archives/feb97/wing.html
[3] Annals of the New York Academy of Sciences , Chernobyl: Consequences of the Catastrophe for People and the Environment
[4] Review by Karl Grossman, http://www.globalresearch.ca/chernobyl-the-consequences-of-the-catastrophe-for-people-and-the-environment/23745
