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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.

When it comes to the estimating the hazard associated with radiation in drinking water after a nuclear disaster the US EPA says that adults need around 1.6 liters of drinking water, whereas when it comes to recommendations for drinking water systems to consider buying bottled water, diluting water to be less radioactive, etc., after a nuclear accident, the US EPA proposes one or more gallons per person. One US liquid gallon is 3.785 liters. There is a big difference. (See charts below).

The USDA puts adult average water needs at 3.7 liters, of which 3 liters would be as beverages (e.g. water, coffee, tea – note that water is required to make coffee and tea). However, the USDA adds 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

It remains a mystery if the US EPA really doesn’t know the difference between liters and gallons, or if they are intentionally trying to understate risk. Underestimating water intake means that they can leave more radioactive material in the water and pretend that the risk is less than it really is. Another apparent trick is that they seemingly won’t calculate risk for all of the radionuclides in water after an accident. Rather they only mention a few.

What about bathing? Radionuclides can be absorbed through the skin and at least some can be inhaled in the shower. How many years does the US EPA intend for people not to shower, bathe, wash clothes, wash dishes, or flush toilets?

US EPA is full of water nonsense. US nuclear reactors are constantly polluting water, even when there isn’t a disaster. But, EPA wants people to save water. https://www3.epa.gov/watersense/pubs/indoor.html Unless pollutants such as radionuclides are put in water it can be reused.

It’s not just the US EPA doing this. There are various tricks to understate risk from radioactive materials in water (and food). They include pretending that not all food or water will be contaminated, underestimating food and water intake, pretending that the problem will be short-lived, whereas Cesium 137 has a half-life of 30 years and many radionuclides have half-lives in the hundreds, thousands and millions of years, and pretending many of the radionuclides aren’t there. For a list of some of the long-lived radionuclides see: https://miningawareness.wordpress.com/2016/07/12/what-radionuclides-are-at-drigg-nuclear-waste-dump-near-the-irish-sea-many-still-lethal-after-natural-erosion-expected-to-undermine-it-still-time-to-oppose-drigg-decision-15th-july/

Thus, the risk associated with the US EPA’s PAG proposal for increased radiation contamination of drinking water will be even greater than believed, because people need more liters of water than the US EPA alleges.

Liters or Gallons?

The first is to assess hazard of ingestion of radionuclides in drinking water. The more you ingest, the greater the risk. Arrows and notes in red were added to the original.
US EPA liters of radioactive drinking water
US EPA bottle water, dilute, etc. cost community water
The second screen shot is from “EPA Document Number: 800B16001 Date: June 2016” Red arrows and notes added. Links to both documents here:

Not only is the US EPA apparently putting the responsibility for buying water upon what are often cash strapped local governments-water companies, but they are trying to place the liability on them too:
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 liability needs to fall on the nuclear utilities.

These two documents seem to be the same: https://www.regulations.gov/contentStreamer?documentId=EPA-HQ-OAR-2007-0268-0211&disposition=attachment&contentType=pdf

Click to access formatted_epa_drinking_water_pag_5-23-16_final.pdf

According to the USDA: “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.)

The gallon (/ˈɡælən/) is a unit of measurement for liquid capacity in both the US customary units and the British imperial systems of measurement. Three significantly different sizes are in current use: the imperial gallon defined as 4.54609 litres, which is used in the United Kingdom, Canada, and some Caribbean nations; the US gallon defined as 231 cubic inches (3.785 l), which is used in the US and some Latin American and Caribbean countries; and the least-used US dry gallon defined as 1⁄8 US bushel (4.405 l).
While there is no official symbol for the gallon (as there are for SI units), gal is in common use.