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Saturday, 16 Aug. 2014 update: Suddenly, as of Friday, there are 24,067 comments received (not posted) on the radiation rules docket, “Environmental Radiation Protection Standards for Nuclear Power Operations – 40 CFR 190”, even though the docket is closed and the number was 23,959 on Thursday. http://www.regulations.gov/#!docketDetail;D=EPA-HQ-OAR-2013-0689 The US EPA worker(s) in charge of the radiation rule files appears to have come back from 2 1/2 days holiday for Friday afternoon DC time. We haven’t figured out what holiday that was! They managed to upload a whole 11 comments sent in last June. Now these aren’t long posts. These aren’t the comments with many appendices often sent in by nuclear lobbyists. These comments are between 1/2 page and 1 page. One might guess that they had been lost, since they date from June. They seem to have been e-mailed in with names, which makes us wonder how many others might be lost? An excerpt from one of the comments from June, uploaded only today:
June lost comment excerpt
The EPA claims to have gotten a repetitive “mass mailing” and deleted 23,592 comments. This number seems to come from the 23,592 signatures (we count 24,067) from Food Water Watch, which was one upload (550 pages of signatures). If this could account for many missing, it still leaves 575 of which 376 have been uploaded. The EPA, by the way, uploaded two comments from the US NRC, long ago, one of which is 24 pages long. How this is “public comment” is unfathomable. 8 pages of comment with an additional 40 pages of appendices plus about a page of references from a facility supervisor of Kennecott uranium, a uranium mining subsidiary of Rio Tinto, were received and uploaded in June. Multiple comments from or on the behalf of nuclear power plants were uploaded. One anonymous comment is someone alleging to work at the DOE lab. We have already mentioned that Energy Solutions nuclear waste company sent in their lengthy comment late. It too was posted ahead of the short public comments sent in June, posted only today. Going back to the PAGS, radiological emergency comments, from last September, they alleged to have deleted 2,704 and then 2,090 as repetitive. In this case there is no real evidence given regarding the deleted posts, which appear to have been signed by name. Only one sample remains. They posted only 202 comments. If they really deleted 4,794 of 4,996 comments then there are only two missing still from last September.

The big thing which came out of our last months of research is that for all practical purposes there are no US EPA standards for radiation. While this decision was made in 1977, the decision has also been made by the EPA not to update standards. If they had real standards they might have work to do called enforcement. While on the topic, it is worth noting that, in general, there are only one or two so-called EPA “Rad-net” monitors per state and they are not always near nuclear facilities and they are checked by unpaid volunteers. One state has no monitor. Additionally, many are often down: “At the time of Fukushima, on March 11, 2011, 25 of the 124 installed RadNet monitors, or 20 percent, were out of service. They had been out of service for an average of 130 days. All monitors were reported to have been repaired by April 8, 2011. In addition, 6 of the 12 RadNet monitors sampled by the OIG had gone over 8 weeks without a filter change; two of those for over 300 days.” Read the ugly details here: https://miningawareness.wordpress.com/2013/11/26/us-radiation-network-failures-ongoing-before-during-after-fukushima/

We are also unable to find the status of the EPA PAGS document, which appears criminal in nature, (and needs to be discussed at a future date). We are not exaggerating. It is very bad. Part is dependent on current US FDA food standards which are 15 times less protective than Japanese ones, suggesting that Americans may be better off in Japan even without an emergency, because Japan is probably shipping their contaminated food to the US, along with Australia and Canada, who also have weak “standards”. Here is one comment about PAGS. To the extent that we have examined PAGS, along with the US FDA “standards”, he appears accurate. Since the US, Canada and Australia were mostly the unwanteds of Europe, maybe we shouldn’t be surprised?
Comment re PAGS by retired military
Another telling comment:
EPA not doing job comment Condoleeza
We have opted to make these comments anonymous though the originals have names, which are public record.

As published on August 14, 2014:
Wednesday wasn’t Assumption Day! And, it’s not a US holiday! So, where was the US EPA? Why weren’t they uploading public comments?
L'Assomption de la Vierge peint par Michel Sittow, vers 1500.
The Assumption of the Virgin by Michel Sittow, ca 1500
On August 15th, “The feast of the Assumption is a public holiday in many countries, including Austria, Belgium, Chile, Colombia, Croatia, Cyprus, Ecuador, France, Germany (Bavaria and Saarland only), Greece, Lebanon, Lithuania, Italy, Malta, Mauritius, Poland, Portugal, Romania, Senegal, Slovenia, Spain, Switzerland (8 cantons only) and Vanuatu. In Eastern Orthodox churches following the Julian Calendar, the feast day of Assumption of Mary falls on August 28,” A longer list is also here: http://en.wikipedia.org/wiki/Assumption_of_Mary

Countries like the USA, where the common people have rarely a holiday, outside unemployment, stand in wonder at those European countries which have an endless stream of religious holidays, such as Mary’s going to heaven (Ascension) day on Friday. But, where they need stand aghast is their highly paid EPA who appears always on holiday – even where making twice the median US household salary!

Unlike some people, we are pro-environmental protection and believe that government should protect the people and the environment. But, there is increasing evidence that the US EPA is not doing its job; on the contrary.

There are several conclusions that can be reached upon looking at the Federal Regulations comment pages and that only very few of the comments appear uploaded. For the recent nuclear regulations comments, only 365 or 367 (pages don’t even match) of 23,959 have been uploaded. Firstly, the web site appears designed by incompetents (probably grossly overpaid), because public comments to the Federal record should be automated, unless the intent is to censor and hide public opinion (in which case the web designers did their job). If the objective is not to hide public opinion, then it means that the people involved are really, truly lazy. In a day and age when there are so many highly educated, hard-working, underemployed or unemployed people, and when the US is supposed to be cutting its deficit, the laziness is appalling.

Or, perhaps EPA workers are too busy off visiting their apparent friends in the nuclear lobby? https://miningawareness.wordpress.com/2014/07/16/how-much-should-nuclear-facilities-leak-the-us-nrc-epa-travelled-to-a-nuclear-industry-workshop-shouldnt-they-visit-communities-instead/

Of the over 23,000 comments given to the EPA regarding new radiation rules, ZERO were uploaded on August 13th! Count it – zero! Some few were uploaded on Monday and Tuesday, probably because the EPA office received phone calls of complaint, but it now appears clear that they are lazy and really don’t give a damn about what the public thinks. August 13th is not Assumption and Assumption is not a US holiday so where were they? Why weren’t they working to upload comments?
EPA radiation regs comments 13 Aug 2014 none uploaded
EPA Regs comments received v. posted 13 Aug 2014
While Brian Littleton, responsible for the comments, a chemical engineer, is clearly an intelligent man, there are better educated people who are not making the $110,000 or more that one can guess that he makes based on EPA job postings. That government servants or preachers make over twice the median household income is obscene, even where they do their job.
Brian Littleton bio

Brian Littleton and his colleague Tom Peake (whose educational background cannot be found) are-were responsible for technical oversight-regulations at WIPP. How that turned out doesn’t exactly inspire confidence in them as anything other than bureaucratic hangers-on and survivors.
WIPP 22 May 2014
WIPP nuclear waste storage in May of 2014
Americans need to quickly think of a solution for the corruption in their government and governmental bureaucracy or think quickly of where to seek asylum. These radiation rules are the difference in living long and healthy lives or suffering and dying of cancer. If lucky one might die quickly of heart failure due to radionuclides. It is clear from the PAGS proposed last year by the EPA – only 4% of comments have been uploaded about it, even though it’s been 11 months – that the EPA, along with the FDA, are preparing for total radiological contamination and clearly do not give a damn about the health of their fellow Americans, nor ultimately of the world. A new Fukushima is coming, it’s just a matter of time, unless the nuclear industry is shut down and waste is handled and monitored properly.
PAGS update comments Sept. 2013
After the stealing of the 2000 election from Al Gore and the invasion of Iraq – despite widespread public opposition in the US and UK – it is unclear why we are shocked, but we are indeed shocked, after looking at the draft PAGS. We are also unable to find the current status of the draft PAGS. We are also shocked that while the US government calls for comment, which is supposed to be part of public record, they refuse to post those comments. If we recall correctly, Al Gore quoted his mother as saying that there is plenty of time to rest after you die. Bill Clinton said he liked to put Gore in charge of various things because he knew that Gore would read the requisite documents. This work ethic appears unknown by EPA bureaucracy. Love of people and the environment appears also unknown to the EPA. Is that why George Bush was the favored candidate? He too was always on holiday?

Median US income (dollars) $ 51,371 household
EPA jobs p. 2
EPA job p. 3
EPA job p. 4
Not only do they get great pay, but they get great perks too: http://www.epa.gov/careers/benefits.html
Although the Washington DC area has the reputation for high rent, the rent isn’t really so high anymore compared to other places. There are places with rents that are higher and better qualified people not making as much as most of these EPA people. They seem just bureaucratic nuclear brown-nosers, living high on the hog at taxpayer expense – taxpayers who they appear to disdain, by failing to upload public comment. http://www.census.gov/prod/2013pubs/acsbr11-07.pdf http://www.census.gov/prod/2013pubs/acsbr12-02.pdf
They need to be told that they are being watched!