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Excerpted from a citizen comment: “I charge the EPA Director and Council to remember that they are bound my congressional mandate to safeguard the lives and well being of the general public. This proposal violates that mandate in many ways, and must not be allowed to stand.https://www.regulations.gov/document?D=EPA-HQ-OAR-2007-0268-0219

You can comment on the US 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 Monday 25 July 2016. One minute till midnight. It is quick, easy and can be anonymous.

On Gina McCarthy’s watch, the US EPA is recommending in the event of a nuclear accident a so-called PAG:
The maximum amount of Strontium 90 (28.8 yr half life) allowed in water is increased almost 1000 fold (x 925);
The maximum amount of Cesium 137 (30 yr half life) allowed in water is increased by 83 fold (83x);
Iodine 131 has an 3,450 times increase!
Cesium 134 (half-life 2 years) is not listed in the US EPA recommendations and is a major radionuclide emitted after a nuclear accident and is emitted in approximately the same amount as Cesium 137. However, its specific activity is almost 15 (14.9) times greater, meaning that gram for gram it emits more radioactive shots (Bq) per second.
Gina water infrastructure tweet  19 July 2016
Unless, of course, it has to do with people having clean water after a nuclear accident…

Currently the amount of Cesium 134 allowed in water 80 pCi/L. Because Cesium 134 and 137 co-occur in an approximately one to one ratio during nuclear fission and a nuclear accident, the recommendations given by the EPA would appear to represent an increase of over 3,000 fold. Where is Cesium 135? Where is Technetium 99? Where is the tritium? Where is plutonium, americium and other actinides? Does the 5 mSv (500 mrem) include alpha emitters like plutonium and americium? Or only the Beta-photon emitters? Where is Iodine 129?

In fact, for the EPA PAG recommendations, where are the 179 man-made radionuclides that the EPA is supposed to regulate? https://web.archive.org/web/20151014190302/http://www2.epa.gov/sites/production/files/2015-06/documents/compliance-radionuclidesindw.pdf There is nothing on the EPA list except Strontium 90-Yttrium 90, Cesium 137 and Iodine 131!
EPA nuclear disaster radionuclides - strontium 90,  I129, Cs 137

The EPA PAG “recommendations” supposedly lead to a radiation exposure from drinking water alone of 500 mrem (5 mSv) or 125 times more than the current clean water rule of 4 mrem (0.04 mSv) for Beta emitters, but actually would lead to even higher exposure due to underestimating water intake and perhaps in other ways. The US FDA already allows what seems to be the world’s highest amount of across the board radiation in food.

If the average adult male water (incl. tea, coffee, etc.) minimum intake is used (3 liters per day) for one year then it is 1095 liters, meaning that for Cesium 137 alone the radiation exposure would be 873 mrem (8.7 mSv) rather than the 500 mrem (5 mSv) alleged, and rather than the 4 mrem (0.04 mSv) which is the law. If people are active and/or there is a hot climate then the intake and thus the radiation exposure will increase further. If only Cs 137 and not Cs 134 is tested and the assumption is made that there is only Cs 137, then radiation exposure will be sky-high. The US FDA combines Cs 134 and Cs 137 (or so they claim) for food testing, since they are co-produced in nuclear reactors and are prevalent during nuclear accidents. The choice apparently will be to dehydrate and die or drink radioactive water and also possibly die from life-shortening cancers.

While the EPA alleges that a) these are just recommendations to help local water providers make decisions, and b) that the list is just of the maximum amount allowed, and that the amounts should be added to equal 5 mSv, we know that in practice that usually only one radionuclide is tested and that these numbers are assumed to be the acceptable amount. Sometimes several are tested-discussed. That was seen for the Pilgrim Nuclear Water Permit, discussed yesterday, where 20,000 pCi per liter was cited by the EPA as being the allowable amount of tritium, whereas this is false. It is the allowable amount, if and only if it is the only (Beta-photon emitter) radionuclide in the water. Apparently only water providers considered at risk (and the definition is very narrow) are required to test for radionuclides under the Clean Water Act meaning that most providers will lack the experience when a nuclear accident occurs. The few testing facilities may be overburdened, as well.

Instead of the EPA’s bogus PAG radionuclides in water list, there needs to be maximum filtration. And, barring that, there needs to be a consideration of ratios of radioactive materials which occur in nuclear reactors and waste and would co-occur in a nuclear accident. And an estimation based on the fact that if there is a certain amount of Cs 137, then there would be a certain amount of all of the other radionuclides that together would add up to the proposed amount of mrem (mSv).

There needs to be contingency, as well, meaning that they need to drop exposure back down from the proposed 5 mSv to either the US NRC 1 mSv exposure, or, better the US EPA’s 0.25 mSv exposure. The ratios would vary according to event type and fuel burnup. But, listing maximum amounts of single radionuclides, as the US EPA has done, is unacceptable and can but lead to confusion at best and abuse at the worst.

Even Sandia Nuclear Labs says:
FRMAC Assessment Manual“, Volume 1 (April 2015) 1.2-1 says;
1) Represent the external dose (or exposure) rate at which the total dose from all radionuclides in a release from the pathways included in the assessment would equal the PAG over the time phase under consideration.
2) Are based on the ratio of activities of each radionuclide in a mixture, not the individual activity values of those radionuclides.

FRMAC Assessment Manual“, Volume 2, 2-27:
Table V2.2.6. Isotopic Ratios for LWR Core-Damage Accidents
Purpose: This table (based on information from NRC96) includes the radionuclides most important during the Intermediate Phase (relocation and ingestion) for LWR core-damage accidents. Decay and ingrowth are considered. The table provides the concentration of each radionuclide relative to 137 Cs.
” It puts Cs 134 at 1.6 compared to Cs 137 at 1. We have treated it as 1 to 1 in our estimates, meaning that the Cs 134 exposure would be even higher than we estimate. The FRMAC manual still excludes a lot however and is only for up to 30 days post shutdown: http://www.nv.doe.gov/library/publications/frmac/Forms/AllItems.aspx?RootFolder=%2Flibrary%2Fpublications%2Ffrmac%2FFRMAC%20Division%2FFRMAC%20Assessment%2FFRMAC%20Assessment%20Manual%20Vol%202

Under the US EPA PAG recommendations, the Sr-90 allowed by the US EPA increases from 8 pCi/L to 1,000 pCi/L for children; pregnant or nursing women and 7,400 pCi/L for other adults. Cs-137 allowed increases from 200 pCi/L to 6,140 pCi/L and 16,570 pCi/L for other adults; I-131 from 3 pCi/L to 1,310 pCi/L for children/pregnant or nursing women and 10,350 pCi/L for other adults. Cs-134 initially exists close to the same amount (6.8% yield vs 6.1% for Cs 137) but it has a specific activity around 14.9 times greater.
http://web.archive.org/web/20160414162035/https://en.wikipedia.org/wiki/Fission_product_yield Thus, if there is 16,570 pCi/L (613 Bq/L) in water from Cs 137, it seems that there should be 246,893 pCi/L (9,135 Bq/L) from Cs 134. If true, this would be an increase from 80 pCi/L (less than 3 Bq (2.96 Bq) to 246,893 pCi/L (9,135 Bq/L). Based on the Sandia document, the number would be even higher. Where is Cs 135, which is 6.33% of fission product yield? And, Technetium 99 (Tc) which is 6% of fission product yield?

Instead of Trying to Protect the American Public from Lethal Radiation, Gina has flounced off to Vienna, supposedly to play-act at being an environmentalist, but one can suspect that it’s really to play-act at being Marie-Antoinette or just take a summer vacation.
Marie Antoinette and Gina McCarthy
(Marie-Antoinette was born in Vienna; married the King of France (Louis XVI) and was beheaded during the French Revolution).

Besides poisoning the people and the environment with lethal radiation, the latest goal of Gina and Moniz is reportedly to undermine air conditioning and refrigerators.

Newsflash: no air conditioning means that people in much of America are going to have to have a lot more water to drink than even the 3 liters which Gina doesn’t want them to have, as sweat rolls down like the mighty Mississippi River. We need to calculate cancer risk under those conditions, then. Air conditioners are needed as a front line tool to help filter out radioactive materials and remove some from the air via condensate. Americans need to stop overcooling, but many Europeans need to stop overheating, too.

Refrigerator and Air conditioner coolant are closed loops so besides using energy (which can be provided via solar where it’s hot) this is a bogus trip. It’s also a bogus topic because there is almost no air conditioning in Europe, anyway. Let Europe put restrictions on heating, not air conditioning, because there is almost none! Let the UK-Europe stop burning up the trees from the US Deep South to heat and then the Deep South can sit under trees as in the old days and save air conditioning.

And, Gina and Moniz probably are paying in the range 300 to 500$ per day, or more, to have air conditioning in their hotel rooms in Vienna and they probably will spend more just on their rooms this week than they propose that small communities spend for water after a nuclear accident.

U.S. Secretary of State John Kerry will travel to Vienna, Austria, on July 22 to join EPA Administrator Gina McCarthy and the U.S. Delegation in Vienna for the first day of high-level talks at the Extraordinary Meeting of the Parties to the Montreal Protocol.” Entire press release at bottom of this blog and also here: http://web.archive.org/web/20160719212015/http://m.state.gov/md260256.htm The US Delegation! How much will that cost?

Americans Don’t Want Nuclear Power and They Certainly Don’t Want Radioactive water:
This proposed change is blatantly harmful to the health and wellness of the population. While the proposal would only be in effect under a catastrophic situation, that is precisely why it must NOT be allowed to happen.

In the event of a catastrophe, normal safeguard and systems are not working. As such, the idea that energy plants containing toxic substances that can lead to cancer, mutation, and other server and permanent health defects must not be allowed.

It is the responsibility of the energy provider that chooses to use at risk methods to produce that energy, to satisfy the inherent need to do so safely in all situations. It must not be the provenance of the EPA to abandon its congressional mandate to protect the people by allowing those whose inherent responsibility it is to ensure safe and reliable power, to not take precautions to ensure that such is the situation always.

Nuclear energy as it stands is both incredibly powerful, and incredibly dangerous. The public already faces the everpresent danger of a runaway reactor or the leak of highly toxic spent nuclear fuel. It must not be allowed to assume the risk of being exposed in the event of a Fukushima type disaster, or whatever other natural or man-made disaster may occur.

I charge the EPA Director and Council to remember that they are bound my congressional mandate to safeguard the lives and well being of the general public. This proposal violates that mandate in many ways, and must not be allowed to stand.

Based on a government funded study of nuclear workers, published last October, cancer rates from radiation exposure may be estimated as around 15 times worse than even BEIR VII thought, perhaps even higher. This means that there will be around 15 excess cancers per 100 mSv per one hundred people. Around half will die, on average at around retirement – what BEIR calls life-shortening cancers (average life expectancy of 14 to 15 yrs): https://miningawareness.wordpress.com/2015/12/19/another-look-at-the-recent-low-dose-radiation-exposure-study-inworks/ Thus, even 5 mSv is a very high risk.

But, Gina McCarthy doesn’t care. She says “Let them drink radioactive water” as she dances the nuclear waltz in Vienna, along with the head of the US DOE, another nuclear lackey named Ernest Moniz. John Kerry will pass quickly through, but Gina and Moniz appear to be hanging out in Vienna.

Moniz as Louis XVI
Moniz as Louis XVI

We suggest that Gina be sent to do participant observation with the Savannah River Nuclear site “welfare to work” nuclear clean-up workers, and she can see just how life-shortening her radiation exposure will be. Moniz can help her and then go look for the lost corium at Fukushima in Japan. He can dig a tunnel to look for it. The guillotine would be a waste of nuclear clean-up man-power. And, Gina and Moniz deserve a painful, drawn-out death from cancer, not a quick one from a guillotine.

Let them eat cake” is the traditional translation of the French phrase “Qu’ils mangent de la brioche”, supposedly spoken by “a great princess” upon learning that the peasants had no bread. Since brioche was a luxury bread enriched with butter and eggs, the quote would reflect the princess’s disregard for the peasants, or at least a complete lack of understanding that the absence of basic food staples was due to poverty rather than a lack of supply.
While it is commonly attributed to Queen Marie Antoinette,[1] there is no record of this phrase ever having been said by her. It appears in Jean-Jacques Rousseau’s Confessions, his autobiography (whose first six books were written in 1765, when Marie Antoinette was nine years of age, and published in 1782). The context of Rousseau’s account was his desire to have some bread to accompany some wine he had stolen; however, in feeling he was too elegantly dressed to go into an ordinary bakery, he thus recollected the words of a “great princess”.[2] As he wrote in Book 6:
Enfin je me rappelai le pis-aller d’une grande princesse à qui l’on disait que les paysans n’avaient pas de pain, et qui répondit : Qu’ils mangent de la brioche.[2]

https://en.wikipedia.org/wiki/Let_them_eat_cake (Sorry to insult Marie Antoinette (and her husband). She was reportedly well-educated and liked to read. The big problem was apparently the refusal by the French upper classes (nobility and clergy) to pay taxes. But, due to the physical resemblance to Gina McCarthy one more abuse of Marie Antoinette was irresistible. “Let them Eat Yellowcake and Drink Radioactive Water” say Gina and Moniz.

Excerpts from:”Radionuclides in Drinking Water: A Small Entity Compliance Guidehttps://web.archive.org/web/20151014190302/http://www2.epa.gov/sites/production/files/2015-06/documents/compliance-radionuclidesindw.pdf
Radionuclides in Drinking Water: A Small Entity Compliance Guide p. 4 Rad Max Contam
Radionuclides in Drinking Water: A Small Entity Compliance Guide Requirements for Beta-Photon
Radionuclides in Drinking Water: A Small Entity Compliance Guide  Beta and Photon Derived concentrations drinking water, p. 11
Radionuclides in Drinking Water: A Small Entity Compliance Guidep. How to Meet the MCL p. 19

Press Statement
Mark C. Toner
Deputy Department Spokesperson
Washington, DC
July 19, 2016
U.S. Secretary of State John Kerry will travel to Vienna, Austria, on July 22 to join EPA Administrator Gina McCarthy and the U.S. Delegation in Vienna for the first day of high-level talks at the Extraordinary Meeting of the Parties to the Montreal Protocol.
The meeting is aimed at making progress on a hydrofluorocarbon (HFC) phasedown amendment for adoption later this year. Achieving such an amendment would build upon the climate change success achieved last year in Paris, and is one of the most consequential and cost-effective actions the global community can take this year to combat climate change.

Secretary Kerry will then travel to Paris, France, from July 22 to meet with Palestinian Authority President Mahmoud Abbas to discuss ongoing efforts to advance a two state solution.

The Secretary will travel to Vientiane, Laos, from July 25-26 to participate in the ASEAN Regional Forum, the East Asia Summit Foreign Ministers Meeting, the ASEAN-U.S. Ministerial Meeting, and the Lower Mekong Initiative Ministerial Meeting. At these ASEAN meetings the Secretary will discuss the region’s security architecture and shared transnational challenges including maritime security, Illegal, Unregulated and Unreported fishing, the denuclearization of the Korean Peninsula, and the South China Sea.

Next, Secretary Kerry will visit Manila, Philippines, from July 26-27, where he will meet with President Rodrigo Duterte and Secretary of Foreign Affairs Perfecto Yasay to discuss the full range of our cooperation with the new administration“.

Allows comparison of risk and conversion to mSv: “ANNEX F. EFFECTIVE DOSE COEFFICIENTS FOR INGESTION OF RADIONUCLIDES FOR MEMBERS OF THE PUBLIC Table F.1. Effective dose coefficients (e) for ingestion of radionuclides for members of the public to 70 years of age.http://www.icrp.org/docs/P%20119%20JAICRP%2041(s)%20Compendium%20of%20Dose%20Coefficients%20based%20on%20ICRP%20Publication%2060.pdf