Strengthen radiation protection standards; drop revised EPA Protective Action Guidelines

July 8, 2013
Dear Friends,
The Environmental Protection Agency has recently revised its "Protective Action Guidelines" (PAGs) that would be used during and following a nuclear disaster or other radiation release. These new, and unacceptable, PAGs basically admit 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. 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.
We are seeking organizational sign-ons to the EPA to demand that they withdraw these PAGs and act to instead strengthen their guidelines.
A copy of the full comment letter to EPA, along with supporting documentation, is available here: http://committeetobridgethegap.org/pdf/pagcommentltr.pdf
Note: this is not a public webpage, please do not post or publicize this link at this time. All documents will be posted when sign-ons are complete.
SIGN ON BY NOON EASTERN TIME, MONDAY JULY 15th, 2013 by sending your name, organization name, city and state to: dianed@nirs.org
Thank you! NIRS and Committee to Bridge the Gap.

SUMMARY of RECOMMENDATIONS IN GROUP LETTER

*Withdraw the 2013 EPA PAGS (Protective Action Guides)

*Do not weaken drinking water standards for radioactivity. Comply with existing Safe Drinking Water Act limits especially in the intermediate and late phases of disasters and cleanup. Provide real, concrete guidance to authorities on how to safeguard water supplies to protect the public to those levels or better.

*Eliminate any implication that EPA PAGs incorporate the worst provisions of Dept. of Homeland Security PAGS including “optimization” (a cost benefit analysis done by the polluter), use of “benchmarks” or ranges of radiation risk much higher than EPA historically allows.

*EPA should retain and strengthen, relocation PAGs for thyroid and skin doses and keep and strengthen (not weaken) the limit of 5 rem over 50 years.

*Replace the outdated FDA food contamination guidelines with markedly lower radioactivity in food.

*DO NOT allow nuclear waste to go regular garbage dumps, incinerators or recyclers or to hazardous waste sites. Treat it like nuclear waste.

*Do not expand the PAGs, originally for big nuclear disasters, to apply to every radioactive release.

*We recommend that all parts of the PAGs that weaken or eliminate existing protections be abandoned, and all dose limits be tightened by at least the increased risk EPA now acknowledges for radiation.

Conclusion

Protective Action Guides are supposed to provide guidance for actions to protect the public from radiation. The current PAGs do the opposite—recommend grossly increased risks to the public without protection. We urge that the PAGs be withdrawn.