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Comment on the Environmental Protection Agency (EPA) Notice: [Nonprotective Inaction ] “Guide for Drinking Water after a Radiological Incident” here: https://www.regulations.gov/docket?D=EPA-HQ-OAR-2007-0268 by 11.59 pm on 25 July 2016.
idaho National Lab INL gov Fukushima 4 reactors
A large scale radiation contamination incident could impact the United States, driving the need for a pre-established drinking water PAG“, says the US EPA.

US EPA calculates adult drinking water needs as 1.6 liters, compared to 3.8 liters (1 Gallon) recommended by multiple governmental agences (FEMA, CDC, Homeland Security and more). This means that if people drink the required amount of water to avoid dehydration, then radiation exposure should be around double what EPA alleges. This is if and only if this were the only mistake they’ve made, but it’s not the only mistake. They exclude Iodine 129 from evaluation, for instance. Increased exposure is increased risk of cancer, cataracts, and more. Is the US EPA ignorant or playing tricks?

Be advised that death due to dehydration can occur in 3 days (or less in hot weather) and no one normally lives more than about 5-6 days without water…http://rehydrate.org/dehydration In a legal case, “The judge found that death by dehydration is extremely painful and uncomfortable for a human being… [the] attending physician described death by dehydration as cruel and violent.http://masscases.com/cases/sjc/398/398mass417.html

According to US Homeland Security, there are two emergency planning zones in the event of a nuclear power station accident: “The second zone covers a broader area, usually up to a 50-mile radius from the plant, where radioactive materials could contaminate water supplies, food crops and livestock.
Pilate washing hands of Jesus Duccio 1308 cropped
Painting by Duccio, 1308 https://en.wikipedia.org/wiki/Pontius_Pilate
US EPA Also Tries to Wash Itself of Liability-Guilt of Betraying People and the Environment by Throwing Responsibility To Lower Levels of Government – Says PAG Are Non-Legally Binding Recommendations. Is that water radioactive? Or is it bottled? Purified? Filtered? While the masses drink radioactive water? PAG means Pilate Administrative Guide?

The US EPA radiation in water rules are based on an assumption that your lifetime exposure is only 70 years!!! This is for actual rules, as well as these recommendations. Furthermore, since the EPA assumes you don’t need much water, you may die of dehydration if local officials depend upon EPA recommendations for water distribution quantities.

The EPA’s underestimating water needs and lifetime exposure is either because they are incompetent or because they intentionally wish to underestimate radiation exposure. If one drinks what is needed in order to remain hydrated, the radiation exposure would be much greater than what the EPA claims.

If this were the only mistake they’ve made (it’s not), for adults, the 500 mrem (5 mSv) exposure would really be around 1000 mrem (10 mSv). For children, EPA estimates would provide only around 25 to 45% of their water needs, meaning that exposure is greatly underestimated and their exposure may be closer to the supposed adult level (e.g roughly 2 to 4 mSv, rather than the 1 mSv alleged). While women appear to come out slightly better than men, as their average water needs are less, their cancer risk is higher than men for the same exposure levels. Those who wish to calculate dehydration rate and exact water intake may look at this USDA document: https://fnic.nal.usda.gov/sites/fnic.nal.usda.gov/files/uploads/73-185.pdf (Averages from the document are found at the bottom of our blog post.)

These are very high exposure rates, as explained here: https://miningawareness.wordpress.com/2015/12/19/another-look-at-the-recent-low-dose-radiation-exposure-study-inworks/ According to the BEIR report, 100 mSv cumulative exposure means that approximately 1% of the exposed population would get excess cancers. Recent research suggests that it may be 15% or higher. And, it is unnecessary risk from which there are no benefits.

It is important to recall that this is only the exposure from ingested water. The US FDA allows high levels of radiation in food too – all of the time, not just in an emergency. These are called DIL (Derived Intervention Levels). The US EPA is using the old picocurie and mrem system mixed with the metric system, in contrast to the US FDA which uses the international system of Becquerels (Bq) and mSv. This can but add to confusion and mistakes. Beware, because they mix and match picocuries (pCi), microcuries, curies, rems, mrems, sometimes per liter, sometimes per milliliter, sometimes per gram, sometimes per kilogram. There is a lot of room for error to enter in – error which could be lethal . The US isn’t metric so liters, milliliters, kg, etc., are not readily understood by most. The world uses Sv, mSv, and Bequerels, rather than Curies, rem and mrems. Curies, picocuries and microcuries are total nonsense and difficult to work with. Becquerels are radioactive disintegrations (shots) per second. One can’t get more logical than that. Becquerels have been taught in US universities for decades. Why is the US using the more difficult to work with curie (Ci), picocurie and even microcurie? One curie is 37 billion becquerels. One becquerel is 27 picocuries (pCi). One picocurie is 0.037 becquerels. Many people online apparently can’t even convert between disintegrations per minute (dpm) and per second (dps), which is really pitiful. 1 dps is 60 dpm, because there are 60 seconds in a minute. Thus, 1 dpm is 1/60th of a dps; 1 dpm is 1/60th of a Becqerel (Bq). The EPA further muddies the waters by bringing in Gy: “Excerpts from the NCRP Report No. 174, Supporting & Related Material Posted: 07/01/2016 ID: EPA-HQ-OAR-2007-0268-0260
https://www.regulations.gov/contentStreamer?documentId=EPA-HQ-OAR-2007-0268-0260&disposition=attachment&contentType=pdf For external radiation Gy is equal to Sv. However, we aren’t talking about external but rather internal (ingested water), where there must be a weighting factor. For alpha radiation 1 Gy is estimated as equal to 20 Sv. In mSv this is 1,000 mGy is 20,000 mSv and 20,000 mSv x 100 is 2 million mrem, which just shows how they are trying to mess with people’s minds.

Local and state governments, federal agencies, and the electric utilities have emergency response plans in the event of a nuclear power plant incident. The plans define two “emergency planning zones.” One zone covers an area within a 10-mile radius of the plant, where it is possible that people could be harmed by direct radiation exposure. The second zone covers a broader area, usually up to a 50-mile radius from the plant, where radioactive materials could contaminate water supplies, food crops and livestock“. (US Homeland Security, Ready Gov https://web.archive.org/web/20160621151603/https://www.ready.gov/nuclear-power-plants ) After Chernobyl and Fukushima we know that even more distant water supplies may be contaminated, but 50 miles is official.

FEMA and an older CDC document both say to set aside at least one gallon of water per person for a minimum 3 days. The US EPA is using the international standard of liters, all while keeping the non-international standard of picocuries. One Gallon is 3.785 liters. And, indeed this corresponds to the 3.7 liter average minimum recommended by the USDA for adult men for total water intake. While only 3 liters is considered beverages, according to the USDA, there is a good chance that food will be dry, meaning that 3.7 liters may be closer to what is needed. More is needed for hot weather and sweating too. If one has to boil water to kill bacteria (or to make coffee or tea), then some will evaporate meaning water quantity will be lost AND radionuclides will concentrate. https://web.archive.org/web/20160621172322/http://www.fema.gov/media-library-data/1390846764394-dc08e309debe561d866b05ac84daf1ee/checklist_2014.pdf Homeland security does warn you to “Avoid foods that will make you thirsty.https://web.archive.org/web/20160621152026/https://www.ready.gov/food (We would recommend one week or two minimum, especially for water, but you must properly clean and sterilize containers, change the water frequently enough and check for leaks.)

The US EPA thinks adults need a mere 1.643 liters per day – only 43% of what is recommended by FEMA to set aside for daily use; about half of what the USDA considers average needs, as beverages, for adult males. Much less for children, even as a percentage of need. Children may get only 25 to 45%, or less, of their water needs, using quantities recommended by the US EPA. This may be based on the supposition that the balance of liquids would be tea, coffee, milk cola, etc. But, tea and coffee require water to make. Milk will probably be powdered and powdered formula for infants. USDA considers that some water comes from food, but if food is dried then more water would be needed – approximately the amount recommended by FEMA.

Thus, if adults drink their local water rather than dehydrate, it means that the radiation exposure and cancer risk will be around twice what the US EPA alleges, if and only if US EPA’s other assumptions are true. But, the other assumptions are not all true.

Is the US EPA going to drop people cola and bottled water or milk? Almost certainly not. Their new rule is so that people can be forced to drink water contaminated with radioactive materials for up to a year (While they claim it could be one year, it may also be temporary which becomes permanent). That way they avoid dropping you anything. There is also a possibility that those providing water, where there is none, may follow EPA’s low amount, rather than the larger amounts . This risk is higher since the EPA gives the amounts in liters, rather than gallons, so that local workers are less likely to realize how little it is. Thus, the choice may be die soon of dehydration or die later of cancer or other radiation-induced diseases. And, there may not even be a choice. Based on this faulty EPA document, inadequate amounts of water may be distributed.

EPA elected to use the intake values for males to represent each age group in the calculation of DRLs in Table 1. In addition, for the calculation of the adult DRL, EPA made the conservative assumption that the ingestion rate would be assigned the highest value within the adult category, the 50 year old male, at an estimated 1.643 L/day.” ( https://www.epa.gov/sites/production/files/2016-06/documents/formatted_epa_drinking_water_pag_5-23-16_final.pdf These two documents seem to be the same: https://www.regulations.gov/contentStreamer?documentId=EPA-HQ-OAR-2007-0268-0211&disposition=attachment&contentType=pdf ) Since women are more at risk for cancer with the same radiation exposure, calculating as though they are men won’t help them very much. Additionally, those with children will probably give their water portion to their dehydrated children, as may the men.

Will People Be Able to Evacuate Even the Inner 10 Mile Zone? Probably not.

In their nuclear reactor renewal request for the America’s largest single nuclear reactor at Grand Gulf, Entergy states: “Entergy analyzed evacuation travel times for the Mississippi and Louisiana sides of the Mississippi River within the 16-km (10-mi) emergency planning zone (Entergy 2011). The analysis stated that 100 percent of the population would be prepared to begin evacuation within 195 minutes from emergency notification for evacuation and 100 percent of the population could be evacuated in 250 minutes or less following an evacuation order.http://www.nrc.gov/docs/ML1432/ML14328A171.pdf This appears slow. It is for 8,806 people according to PSR: http://www.psr.org/resources/evacuation-zone-nuclear-reactors.html Compare to 258,848 within 10 miles for Indian Point: http://www.psr.org/resources/evacuation-zone-nuclear-reactors.html On March 17, 2011, shortly after the start of the Fukushima accident, Jefferson County Mississippi Supervisor Cammie Hutcherson noted that President Obama told Americans to distance themselves from Fukushima by 50 miles and that they were within 25 miles of Grand Gulf Nuclear Power Station: http://youtu.be/v5nNz0Wb3ck See: https://miningawareness.wordpress.com/2016/05/04/nearby-communities-sunk-deeper-into-poverty-since-the-arrival-of-grand-gulf-nuclear-lack-emergency-resources-nearby-jefferson-co-need-to-participate-in-evacuation-planning-ignored/

No Evacuation Means Shelter in Place, Suffocate, Dehydrate, or be Irradiated?

A US CDC document, which appears no longer available, except in archives states:
Before entering the shelter, turn off fans, air conditioners, and forced-air heating units that bring air in from the outside. Close and lock all windows and doors, and close fireplace dampers.

When you move to your shelter, use duct tape and plastic sheeting to seal any doors, windows, or vents for a short period of time in case a radiation plume is passing over (listen to your radio for instructions). Within a few hours, you should remove the plastic and duct tape and ventilate the room. Suffocation could occur if you keep the shelter tightly sealed for more than a few hours.
[…]
* Water—In preparation for an emergency, purchase and store bottled water or simply store water from the tap. Each person in the household will need about 1 gallon per day; plan on storing enough water for at least 3 days.
* […]
* Paper plates, paper towels, and plastic utensils—Store disposable dishware and utensils because you will not have enough water to wash dishes and because community water sources may be contaminated
.” https://web.archive.org/web/20090109032051/http://www.bt.cdc.gov/radiation/shelter.asp
Don’t you think you will sweat and need more water sealed up like that, depending on the temperature? WHAT IF THE PLUME DOESN’T STOP PASSING? WILL YOU BE ABLE TO GET RADIO RECEPTION IN YOUR SHELTER? WILL THE AUTHORITIES NOTIFY YOU IN TIME?

1 us liquid gallon = 3.785 litres

EPA elected to use the intake values for males to represent each age group in the calculation of DRLs in Table 1. In addition, for the calculation of the adult DRL, EPA made the conservative assumption that the ingestion rate would be assigned the highest value within the adult category, the 50 year old male, at an estimated 1.643 L/day.http://web.archive.org/web/20160718023157/https://www.epa.gov/sites/production/files/2016-06/documents/formatted_epa_drinking_water_pag_5-23-16_final.pdf

However, as the USDA explains: “Several analyses have attempted to quantify the effects of hot weather on increasing daily fluid (total water) requirements (Brown, 1947b; Lee, 1964; Sawka and Montain, 2001; U.S. Army, 1959). These analyses (Figures 4-16, 4-17, and 4-18) suggest that daily fluid requirements range in sedentary, active, and very active persons from 3 to 6 L/day in temperate climates and from 4 to 12 L/day in hot climates (Brown, 1947b; Lee, 1964; Sawka and Montain, 2001; U.S. Army, 1959).

“Physical activity and heat strain can elicit high rates of total water loss via sweat loss. A person’s sweating rate depends on the climatic conditions, clothing worn, and exercise intensity and duration.” (p. 127) https://fnic.nal.usda.gov/sites/fnic.nal.usda.gov/files/uploads/73-185.pdf (Charts and details on calculating exact amounts of water loss in various temperatures, etc., found at the link.)

According to the USDA average water needs are (note that the document has a lot of details to calculate more exactly):
AI for Men 19 and up years 3.7 L/day of total water. This includes approximately 3.0 L (≈ 13 cups) as total beverages, including drinking water.”
AI for Women 19 and up years 2.7 L/day of total water. This includes approximately 2.2 L (≈ 9 cups) as total beverages, includ-ing drinking water.
(pp. 145-50)
For pregnancy: “3.0 L/day of total water. This includes approxi-mately 2.3 L (≈ 10 cups) as total beverages, including drinking water“, (p. 152)
For lactation (breast-feeding): “3.8 L/day of total water. This includes approximately 3.1 L (≈ 13 cups) as total beverages, including drinking water.” (p. 153)
[…]
Total Water AI Summary, Ages 0 Through 12 Months
AI for Infants 0–6 months 0.7 L/day of water, assumed to be from human milk. 7–12 months 0.8 L/day of total water, assumed to be from human milk, complementary foods and beverages. This in-cludes approximately 0.6 L (≈ 3 cups) as total fluid, including formula or human milk, juices, and drinking water
. (p. 142)
AI for Children 1–3 years 1.3 L/day of total water. This includes approxi-mately 0.9 L (≈ 4 cups) as total beverages, includ-ing drinking water.5
4–8 years 1.7 L/day of total water. This includes approxi-mately 1.2 L (≈ 5 cups) as total beverages, includ-ing drinking water.
AI for Boys 9–13 years 2.4 L/day of total water. This includes approxi-mately 1.8 L (≈ 8 cups) as total beverages, including drinking water. 14–18 years 3.3 L/day of total water. This includes approxi-mately 2.6 L (≈ 11 cups) as total beverages, includ-ing drinking water. boys 14–18 years 3.3 L/day of total water. This includes approximately 2.6 L (≈ 11 cups) as total beverages, including drinking water…
“(p. 143)
AI for Girls 9–13 years 2.1 L/day of total water. This includes approximately 1.6 L (≈ 7 cups) as total beverages, including drinking water, 14–18 years 2.3 L/day of total water. This includes approximately 1.8 L (≈ 8 cups) as total beverages, including drinking water“. (p. 143-144)
https://fnic.nal.usda.gov/sites/fnic.nal.usda.gov/files/uploads/73-185.pdf
http://web.archive.org/web/20160717220933/https://fnic.nal.usda.gov/sites/fnic.nal.usda.gov/files/uploads/73-185.pdf

Even the regular US Drinking water standards are based on an assumption of 70 years lifetime exposure! The US EPA washes their hands of responsibility:
The drinking water PAG will help federal, state, local, tribal officials and public water systems make decisions about use of water during radiological emergencies. The drinking water PAG is non-regulatory guidance.
[…]
A protective action guide (PAG) is the projected dose to an individual from a release of radioactive material at which a specific protective action to reduce or avoid that dose is recommended. Emergency management officials use PAGs for making decisions regarding actions to protect the public from exposure to radiation during an emergency. Such actions include evacuation, shelter-in-place, temporary relocation, water and food restrictions.
[…]
A large scale radiation contamination incident could impact the United States, driving the need for a pre-established drinking water PAG.
[…]
The National Primary Drinking Water Regulations (NPDWR) for radionuclides are based on lifetime exposure criteria and assume 70 years of continued exposure to contaminants in drinking water
[…]
The PAG levels are guidance for emergency situations; they do not supplant any standards or regulations, nor do they affect the stringency or enforcement of any standards or regulations. The PAG levels are intended to be used only in an emergency when radiation levels have already
https://web.archive.org/web/20160705222114/https://www.epa.gov/sites/production/files/2016-06/documents/epa_drinking_water_pag_fr_notice_6-1-16r_pre-pub.pdf

The proposed PAGs are developed for up to one year of exposure. In comparison, the Maximum Contaminant Levels (MCL) were developed assuming 70 years of continuous exposure. The PAGs are intended to 1) prevent short-term health effects, 2) balance protection with other important factors that may arise during an emergency (ensuring the actions result in more benefit than harm), and 3) reduce the potential for longer term health effects. In considering these key principles, EPA is proposing drinking water PAGs of:
* 500 mrem projected dose, for one year, to the general population.
* 100 mrem projected dose, for one year, to the most sensitive populations (e.g. infants, children, pregnant women and nursing women)
“. https://web.archive.org/web/20160706002043/https://www.epa.gov/radiation/protective-action-guides-pags
500 mrem (5 mSv) and 100 mrem (1 mSv) is a multifaceted lie. Underestimating water intake is but one angle.

Related interest: https://web.archive.org/web/20160423151627/https://www.remm.nlm.gov/typesofevents.htm


Some of the USDA Information on Dehydration (they have more):
Dehydration can adversely influence cognitive function and motor control. (p. 107)
Humans can lose 10 percent of body weight as water and have little increased risk of death unless the dehydration is accompanied by other severe stressors (Adolph, 1947a). Reports from persons in survival situations indicate that those who dehydrated to greater than 10 percent of their body weight required medical assistance to recover (Adolph, 1947a). Experimental studies regarding dehydration and death in animals have been performed (Adolph, 1947a; Keith, 1924; Wierzuchowski, 1936). When investigators infused sugar solutions to dehydrate dogs (Keith, 1924; Wierzuchowski, 1936), most could tolerate 7 to 10 percent dehydration; however, beyond this point body temperature rose rapidly and often led to death. Adolph (1947a) reported on experiments in which dogs were slowly dehydrated by water deprivation in temperate conditions and were then exposed to heat stress. When the dogs were dehydrated by 10 to 14 percent of body weight and exposed to heat, their core temperature “explosively increased,” and they would only survive if removed from the heat stress or given water to drink (Adolph, 1947a). Deaths began as core temperatures approached 41.6°C (107°F) and would always occur when core temperatures reached 42.8°C (109°F). Lethal core temperatures were similar in the dehy-drated and euhydrated dogs (Adolph, 1947a). Cats showed similar responses, but with water deficits of up to 20 percent body weight loss and core temperatures of up to 43°C (110°F) before dying. There are many reports from civilian and military communities of persons being stranded in very hot conditions (such as desert con-ditions in the summer) for extended durations in which those who had water survived and those without water died. Dehydration is believed to contribute to life-threatening heat stroke. In view of physiological changes (e.g., elevated body temperatures and re-duced tissue perfusion from inadequate cardiac output), this pre-sumed association is reasonable (Bouchama and Knochel, 2002). Dehydration contributed significantly to an outbreak of serious heat illness of Massachusetts State Police recruits who had limited water availability during summer training sessions. Eleven of a class of 50 had serious rhabdomyolysis and/or heat injury and were hospital-ized—two underwent kidney dialysis and one required a liver trans-plant and later died (Commonwealth of Massachusetts, 1988). In 1987, three collegiate wrestlers died of cardiorespiratory arrest while undergoing severe and rapid weight loss combined with stressful exercise in the heat (Remick et al., 1998). Dehydration was impli-cated in these three deaths; however, those athletes appeared to be employing exercise-heat dehydration procedures that were similar to those used by other interscholastic and collegiate wrestlers. Since these were the first deaths since record keeping was initiated in 1982, it is probable that some other unknown factor may have con-tributed. Thus dehydration is a serious health risk, particularly when associated with febrile illness or extreme heat and exercise
“. (pp. 120-121) Much more at link: https://fnic.nal.usda.gov/sites/fnic.nal.usda.gov/files/uploads/73-185.pdf

Archived USDA water document: http://web.archive.org/web/20160717220933/https://fnic.nal.usda.gov/sites/fnic.nal.usda.gov/files/uploads/73-185.pdf
Archived of one of the EPA documents: http://web.archive.org/web/20160718023157/https://www.epa.gov/sites/production/files/2016-06/documents/formatted_epa_drinking_water_pag_5-23-16_final.pdf