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Our nation's clean water policy should provide all communities with access to healthy, safe water by protecting the streams and wetlands that contribute to our drinking water supply.

Letter to EPA Protective Action Guides for Radionuclides

Honorable Gina McCarthy,
Administrator
US Environmental Protection Agency
1200 Pennsylvania Ave, NW
Washington, DC 20460

US EPA Air and Radiation Docket and Information Center
Mail Code: 6102T, 1200 Pennsylvania Ave NW, Washington DC 20460

Re: Protective Action Guides for Radionuclides
Docket ID No. EPA-HQ-OAR-2007-0268

Dear Administrator McCarthy:

On behalf of Physicians for Social Responsibility, with over 30,000 members, I am writing to express grave concern and opposition to important elements of the revised radiation Protective Action Guides (PAGs).  We find the new PAGs to be much broader in application than originally intended, and to have insufficient reduction in allowed radiation exposure over time after an event to adequately protect the public’s health.  Given that these new guidelines have already been put into place without any public input, we recommend they be withdrawn. 

The issues of concern are outlined here:

Use of blanket guidelines for all types of radiation release

It would make sense to offer identical and generic guidelines for radiation releases if such generic guidelines were truly protective of public health.  Given that the current version of the PAGs were originally created to apply only to a terrorist use of a dirty bomb (over which the government had no direct control) it may make sense to allow slightly higher radiation exposure for the general population for a limited period of time.  However, since the PAGs proposed now apply to any radiologic event, it is essential that controllable risks, such as nuclear power plant accident scenarios, should be held to tighter clean-up standards. The Federal Government does have responsibility for setting the standards for safety and to have them implemented faithfully and fully by industry.   

Allowing more radiation in drinking water - much more than the Safe Drinking Water Act regulations

Immediately following a radiologic emergency, one could assume that water would be provided from alternative sources (similar to that used after a hurricane when safe clean drinking water is not available locally).  However, there should be no alteration of the existing standard allowed under other emergency situations and there should be for a radiologic emergency. 

To continue to allow elevated levels of cancer-producing radionuclides in water after the initial emergency has subsided (defined as one to several years after the emergency) is unacceptable. Particularly when some of the proposed limits include levels over 1,000 times the levels allowable under the Safe Drinking Water Act.   

Ingestion of radiation by radionuclides such as Strontium-90 (deposited in bones/teeth) or Cesium-137 (heart, muscle, and kidney) get taken up and concentrated in human tissue and continue to release radiation for decades to a lifetime, depending on the turnover and tissue location.   Not only does this introduce a long-term carcinogen into the body, we know that other negative outcomes include cardiac disease, decreases in immune function and kidney function.  Likewise, we know that children and pregnant women are much more at risk because fetal and childhood exposures cause far more damage as the cells are dividing at a much great rate.

Poorly protective long-term clean-up standards with no time limit for toleration of elevated levels

It is true that the National Academy of Science’s BEIR VII estimates demonstrate no threshold for radiation exposure, therefore, PAGs, which allow ongoing radiation exposure rates from 1 to 10 REM per year without a deadline for cleanup, are unacceptable.   Plans for allowing the population to return to a site need to be based on clear standards and not one in which the levels are much higher than EPA’s remediation goals for our currently contaminated sites.  

New allowances to permit disposal of radioactive waste in unlicensed sites including municipal garbage dumps

Radioactive waste streams need to be dealt with differently than typical waste. Issues that will arise for radioactive waste management in facilities that are not specifically licensed for radioactive materials include worker exposure without proper monitoring, mixing of waste streams with potential increase of contamination of ground water, or risk airborne emissions of radiation from fires in landfills.

Lastly, the Relocation Protective Action Guidelines should continue to include levels of radioactive iodine exposure, skin exposures and high cumulative whole body doses.

Evacuation of the population is always a difficult decision to make.  Current programs to dispense or to have potassium iodide on hand for the population living within 10-50 km of a nuclear power plant are inadequate and have not been fully implemented.  Because potassium iodide only addresses one form of radiation exposure, evacuation zones are strongly recommended based on simulations and most-probable risk scenarios extending for the full limit of radiation exposure. Exposure limits and evacuation zones should be identified for skin doses and for cumulative whole body doses.

Conclusion

PSR strongly encourages the EPA to withdraw the current PAG recommendations, strengthen them as described above, and especially to clarify cumulative acceptable dose limits over the long term.  We feel that any effort to set water limits that are weaker than the Safe Drinking Water Act is not acceptable. 

Providing adequate safety and protection for the public health should be the EPA’s top priority.  Relaxation of guidelines can lead to inadequate safety management of nuclear facilities (some of which do not meet basic fire standards, and nearly one quarter of which have structures similar to the Fukushima Daiichi Reactors).  The role of the EPA is to protect the public health. The new PAGs are not in the best interests of the American public.

Sincerely,

Catherine Thomasson, MD
Executive Director

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