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Comment on the Environmental Protection Agency (EPA) Notice: [Nonprotective Inaction ] “Guide for Drinking Water after a Radiological Incident” (PAG) here: https://www.regulations.gov/docket?D=EPA-HQ-OAR-2007-0268 by 11.59 pm on 25 July 2016. The US EPA insists that these are recommendations and a guide, rather than rules, in a clear effort to evade responsibility and liability.

On March 17, 2016 Gina McCarthy appeared before Congress in the context of lead in the water in Flint Michigan (Flint water crisis). One can see a similar MO (modus operandi) by Gina McCarthy in her testimony about the Flint crisis to that which appears in the EPA’s radiation in water recommendation guide (PAG). Furthermore, for the PAG guide, the US EPA is guilty of the same things of which she accuses Michigan. It takes one to know one?
Gina McCarthy and Gov Snyder Flint Hearings C-span
http://www.c-span.org/video/?406540-1/hearing-flint-michigan-water-contamination
And all our yesterdays have lighted fools
The way to dusty death… Life’s but a walking shadow, a poor player
That struts and frets his hour upon the stage
And then is heard no more. It is a tale
Told by an idiot, full of sound and fury…
” Macbeth (Act 5, Scene 5, lines 22-27)
Gina water infrastructure tweet  19 July 2016

Extracts from Gina’s testimony [Our comments non-italicized in brackets]: “Under the Safe Drinking Water Act, Congress gives states the primary responsibility to enforce drinking water rules for the nation’s approximately 152,000 water systems, but EPA has oversight authority. Typically, EPA has a strong relationship with states under the Act. But looking back on Flint, from day one, the state provided our regional office with confusing, incomplete and incorrect information.” [This aptly describes EPA’s radiation in water PAG guide, as will be seen further below. It is confusing, incomplete, incorrect, and muddled. ] “Their interactions with us were intransigent, misleading and contentious.” [The EPA’s PAG rule is misleading, too, and Gina seems rather contentious.] “As a result, EPA staff were unable to understand the potential scope of the lead problem until a year after the switch and had insufficient information to indicate a systemic lead problem until mid-summer of 2015.” [There will be similar excuses subsequent to a nuclear accident because the EPA’s supposed guide is confusing, incomplete, incorrect and muddled. Thus, well-meaning state and local governments may well give info to the EPA which is confusing, incomplete, incorrect and muddled. And, will they be able to call back Gina later? Even if were to be a major nuclear disaster in the US pre-election, it is doubtful that hearings will be held. In the case of the Mich DEQ, they have been accused of direct cheating, “tampering with evidence” : https://miningawareness.wordpress.com/2016/07/24/michigan-official-wanted-to-manipulate-lead-tests-8-yrs-ago-others-accused-of-doing-it If guilty of data falsication, as opposed to fall-guys, then their data should actually have been more clear. And, the EPA wants the public to depend on state and local officials after a nuclear accident with no virtually no guidance or oversight.]

Gina continues: “While EPA did not cause the lead problem, in hindsight, we should not have been so trusting of the State for so long when they provided us with overly simplistic assurances of technical compliance rather than substantive responses to our growing concerns…
Blarney Stone historic picture Via Wikipedia
[She kissed the blarney stone, didn’t she? “Overly simplistic assurances of technical compliance rather than substantive responses“. Yes, indeed, that is an apt description of the US EPA’s Guide for Drinking Water after a Radiological Incident. Oh, did she say incoherent? That’s a very good description of the EPA radiation in water guide.]

EPA’s efforts are part of a broader Federal response to the community, led by the Department of Health and Human Services….” [There she goes, as in the Rad in Drinking Water (PAG) Guide, the EPA throws almost everything back to other Federal agencies, to the states and local government and the local water system.]

I have also taken several concrete steps at the agency to address some of the systemic issues raised during this crisis. I directed a review of MDEQ and its ability to implement the Safe Drinking Water Act” [Yet, the EPA guide appears to assure everyone of the state and local government’s abilities to implement radiological monitoring of water, etc. The EPA leaves the states and local government hanging with no real guidance, so well-meaning people may be prone to screw-up. Perhaps EPA should issue coherent guidance ahead of time.]

I also recently sent letters to every governor and every state environmental and health commissioner in the country asking them to work with EPA on infrastructure investments, transparency, technology, oversight, risk assessment, and public education.” [Is this going to help in a nuclear emergency?] “And I have asked the states to join EPA in taking action to strengthen our safe drinking water programs, to ensure drinking water programs are working for our communities. Additionally, we are actively working on revisions to the Lead and Copper Rule…” [How about getting the radiation rule right? Lead is the end of the uranium chain, and so many radionuclides are not only radiologically dangerous but also can cause heavy metal poisoning, like lead does. There is even radioactive lead!]

In many areas across our country, water infrastructure is aging, it is antiquated, and it is severely underfunded – particularly in low-income communities, which may have the most difficulty securing traditional funding through rate increases or municipal bonds. This threatens citizens’ access to safe drinking water. We need to start having a serious conversation about how we advance the technologies and investments necessary to deliver clean water to American families.” [And, yet, the US EPA throws responsibility, liability, and cost upon the local communities in the event of a nuclear emergency. Nuclear reactors and facilities are disproportionately placed in poor, minority areas.]
https://oversight.house.gov/wp-content/uploads/2016/03/McCarthy-EPA-Statement-3-17-Flint-III-1.pdf

Excerpts from the for [Nonprotective Inaction ] “Guide for Drinking Water after a Radiological Incident” Drinking Water, comment in brackets:
This guidance only provides recommendations…” [This is an attempt to avoid liability. True or false, we have read that they are not allowed to officially weaken radiation standards, so they are trying to do it unofficially]. “The EPA determined, given the drinking water contamination that occurred in Japan following the Fukushima event, that a drinking water PAG is necessary.” [How does this make sense? Because an accident occurred in Japan and will probably occur in the US, Americans are supposed to plan on drinking highly radioactive water? How about preparing for clean water? Or, preventing the accident?] “This proposal intends to provide the necessary tools to inform the level at which local emergency responders should restrict consumption of drinking water contaminated during a radiological emergency” [But, it doesn’t. Instead it gives the maximum amount allowed for single radionuclides, whereas they do not occur singly. Also, because the EPA underestimates water intake, they also understate risks for these single radionuclides.] “The intermediate phase is defined as the period beginning after the source and releases have been brought under control (has not necessarily stopped but is no longer growing) and reliable environmental measurements are available for use as a basis for decisions on protective actions and extending until these protective actions are no longer needed…. The proposed drinking water PAG provides a level of protection for the general population consistent with PAGs currently in place for other media in the intermediate phase (i.e., the Food and Drug Administration‘s 500 mrem PAG for ingestion of food…” [No it doesn’t! It provides non-protection. It confuses people into thinking that if they test for Cesium 137, for instance, that this is the right number, but it is the right number only if Cesium 137 is alone, but it is not alone! And, even then it is not the right number because they underestimate water intake, and assume that 5 mSv is acceptable risk, whereas it is not. Furthermore, if the EPA really had a 5 mSv standard – it doesn’t but supposing it did – and the US FDA has a 5 mSv standard – it doesn’t but supposing it did – then that would already be 10 mSv! The FDA’s PAG (DIL) is apparently the maximum for several radionuclide groups combined. The FDA PAG (called DIL) is (frighteningly) in place all of the time and is very high based on the faulty assumption that only a small part of the food will be contaminated and apparently underestimating the food intake. They do have water recommendations too. The FDA seems to both underestimate food and water intake and assume that intake is only a small percentage. Based on what? Based on the fact that Chernobyl’s impacts (via food imports) on the US were not as bad as assumed! Mind-blowing! Both EPA and FDA appear to ignore tritium, which is the most difficult to filter. Tritium is addressed in the Clean Water rules, which these recommendations are meant to undermine. FDA is mostly reporting in Bq, and mSv, whereas EPA is using pCi and mrem. This alone may cause dangerous confusion. Thus, it is inconsistent with the FDA in multiple ways.]… “Intermediate phase doses can be projected using a one-year duration… The already promulgated FDA food PAG and this proposed EPA drinking water PAG are designed to complement each other, and allow emergency response officials to account for and address doses from both eating contaminated food and drinking contaminated water.” [No, they aren’t designed to complement each other. They use different units of measurement and approach the matter in different ways. FDA has a chart addressing multiple radionuclides which contaminate only part of the food supply. EPA’s chart addresses water contaminated by a single radionuclide. It’s up to everyone else to figure out how to work backward from 5 mSv (500 mrem) to small amounts of over one hundred radionuclides. If EPA wanted to help they would have made proper charts showing estimated percentages of radionuclides and the maximum allowed for several in the context of the over one hundred: “EPA regulates 179 man-made nuclides.” https://web.archive.org/web/20151014190302/http://www2.epa.gov/sites/production/files/2015-06/documents/compliance-radionuclidesindw.pdf ]

[The US EPA continues:] “The food ingestion and drinking water pathways are inherently related because both address exposure through ingestion. In addition, water may be used in the preparation of some food products, and radionuclides in water may affect crops and ultimately enter the food supply. The FDA food PAG accounts for water intrinsic in food as purchased and EPA’s proposed PAG accounts for drinking water, including water added to foods during preparation7.” [No it doesn’t! It doesn’t even account for the entire drinking water amount needed! Furthermore, the FDA specifically states that they assume that water used to reconstitute powdered milk is non-contaminated. ]

PAGs for both food and drinking water are needed because a radiological incident may affect the food supply and drinking water differently.” [The last part of this sentence may be true. However, many nuclear facilities appear to be in rural areas with food grown nearby, especially livestock grazing. Thus, food and water may be contaminated. And, who will be willing to deliver food to contaminated areas?] “In addition, because drinking water is usually locally controlled and food is frequently shipped in from distant locations, different and separate interdiction approaches would be appropriate.” [Sometimes but not always true]

Finally, as explained in the revised interim PAG manual (2013)8, the various PAGs are designed to work in concert, allowing emergency responders to choose the exposure reduction strategies that match the exposure scenario, community needs, and resources available in the particular emergency” [No they don’t work together! They use different methodologies and different units. If they are designed to do anything it is to create confusion.]

A PAG is intended as a point of reference to aid emergency response managers in their decision-making…” [So EPA needs to help them by giving clear, serious, guidance.]

DRLs are expressed in units of picocuries per liter (pCi/L) or becquerel per liter (Bq/L), and can be directly compared to measured radionuclide concentrations in finished drinking water. In the absence of site-specific DRLs developed by emergency responders acquainted with local conditions, EPA recommends using these DRLs, which are indicative of a worst case scenario in which there is no decay of isotopes over the exposure period, to guide actions to protect the public in the event of a radiological incident that affects drinking water sources” [So, they appear to be saying to pretend that there is only one radionuclide present? For nuclear reactor accidents, we know that Cs 134 will co-occur with Cs 137, and yet it’s not listed.]

[They refer to section 7 so we jump forward in the document.]
7.0 DERIVED RESPONSE LEVELS (DRLS) EPA developed the radionuclide-specific default DRLs by calculating the radionuclide concentrations in drinking water that would result in projected radiation doses of 100 and 500 mrem, assuming one year of continuous exposure and average drinking water intake rates for children and adults.” [They do not use average drinking water intakes. The DRLs are for single radionuclides, which is not realistic and will cause confusion.]

Several considerations should be kept in mind when using these pre-calculated DRLs. The DRLs presented in Table 1 are calculated on the assumption that each radionuclide is the only radionuclide present in drinking water. DRLs are additive. In situations where multiple radionuclides are present, DRLs should be combined using a sum of fractions approach to ensure that the projected dose does not exceed the PAG of 100 or 500 mrem. (An example calculation is provided in Section 7.1.) Table 1 does not present DRLs for all radionuclides that may occur in drinking water following a contamination incident. … )” [They show how to figure out if it’s too much, but not how much it should be to not exceed the level. A chart is needed showing this. They cannot assume that people will recall the mathematics needed, especially during an emergency. Nor, that it would be done right. If this is a guide, then they need to give guidance! They can also give exercises with the answers in the back.]

[Then we jump back in the document.]
EPA also considered the potential radiation dose people could receive from various other uses of contaminated water, including showering, bathing, and dishwashing. In the United States, people typically shower, bathe, and wash dishes using the same source of water that they use to drink,” [They are lying here! While bathing, etc., IS another problem, it is one that EPA clearly did not consider. They didn’t even allow enough for drinking water so what’s left for anything else!] “but, for the radionuclides of interest, dermal and inhalation exposures from these activities generally represent much smaller risk than drinking contaminated water“. [Maybe mostly true, but they still represent a hazard which has not been considered by this so-called PAG guide. And, some are more dangerous via inhalation than ingestion.] “Protection of a community’s drinking water supply based on assumptions about ingestion will also protect the population from undue risk from contaminated drinking water by other routes of exposure” [Huh?! The drinking water isn’t even adequately protected by this PAG. Other routes of exposure further increase risk.]

The two-tier PAG consists of 500 mrem for the general population (i.e., anyone over age 15, excluding pregnant women and nursing women), and a more stringent PAG of 100 mrem to inform protective actions for pregnant women, nursing women and children age 15 and under. Fetuses, infants and children are at greater risk from radiological exposures than adults due to the greater sensitivity of the developing body to the potential harmful effects of radiation and the longer dose commitment period for the longer-lived radionuclides that clear slowly from the body.” [The last part of this sentence is only true for the very long-lived radionuclides which have not been considered in the PAG – like Plutonium and Americium. It also makes assumptions about longevity which are sometimes false. Some people have children or grandchildren who die young and then they themselves live past 100. “A newborn that ingests radioactive material in water would be expected to be subject to the effects of that radiation for a longer period of time than if the same dose was experienced by an adult.” [Not necessarily so. And, surprisingly, 15 yr olds are most at risk for some radionuclides, presumably because they grow quickly in this period, eat a lot and build bone.]
[…]
The PAG of 500 mrem for the general population is designed to be used in concert with the FDA food PAG 17 since many of the considerations for a food PAG also apply to drinking water. It is also consistent with the guidance value of 500 mrem over one year established by the Department of Homeland Security as an intermediate-phase PAG for drinking water interdiction.” [No it’s not! It can’t be used in concert as the methodological assumptions used and the measurement systems used are different. These differences in assumptions and measurement systems are going to cause dangerous confusion. The EPA guidance also exceeds the 500 mrem (5 mSv) if true water intake is accounted for. And, there remains the risk that people will believe that the list is the standard, as appears to be the case for the FDA, and not that it’s the maximum for a single radionuclide. Furthermore, if there is Cs 137, there will be Cs 134 for a nuclear reactor accident. Just by failing to consider Cs 134 they understate risk enormously.]
[…]
The International Commission on Radiation Protection (19) recommends reference levels in the range of 2,000 to 10,000 mrem (20 to 100 mSv) for protection of human health in emergencies, and in the range of 100 to 2,000 mrem (1 to 20 mSv) for occupational exposure, exposure by caregivers, or residential radon exposure.” [What happened to the US EPA’s own rule of 0.25 mSv (25 mrem) max annual exposure due operating reactors? ICRP does not “recommend” these high levels. These levels do not “protect”. ICRP recognizes that they may be difficult to avoid in an emergency. In non-emergencies they say that consideration should be made for if the person gains any benefits, for multiple exposures, and long-lived radionuclides, meaning ICRP “recommends” more like 0.3 mSv (30 mrem) per year, slightly above the US EPA’s own 0.25 mSv (25 mrem) per year.

According to the more even-handed, US government funded, BEIR VII report, when a population is exposed to a total of 100 mSv, approximately 1% will get cancer due to this exposure alone, i.e. extra, excess cancers. This is 1% per 100 mSv total exposure. Approximately half will die of these life-shortening cancers. Life-shortening effects are of the order of 14 to 15 years, meaning that people will die, on average around retirement age. BEIR VII’s high end estimate was 3% excess cancers due to 100 mSv exposure. A recent government funded study of nuclear workers suggests an estimate of 15% or greater excess cancer risk due to 100 mSv exposure alone. These are unacceptable and unnecessary risks. See: https://miningawareness.wordpress.com/2015/12/19/another-look-at-the-recent-low-dose-radiation-exposure-study-inworks Are you willing to die for the profits of the nuclear industry?]

Based on a risk reduction approach EPA is proposing its drinking water PAGs at the lower (more stringent) end of the latter range as an added layer of precaution.” [This is not lower! It’s not more stringent! ]
[…]
The Japanese authorities applied a two-tier set of provisional emergency standards to I-131 in water: 300 Bq/L (about 8,100 pCi/L) for adults and 100 Bq/L (about 2,700 pCi/L) for infants (specifically for drinking water used to prepare baby formula).” [Is Fukushima to be a model? US EPA’s recommended level exceeds this I 131 contamination level. This I-131 contamination even exceeds the US FDA’s rule. Nonetheless, Japan has now lowered their radiation in food and water standard, so that it’s probably the most protective in the world, whereas the US appears to have the least protective standard, already. The Clean water rule was the only thing that the US had left to help compensate for the outrageous amounts of radioactive materials allowed in food. The FDA rule is in place all of the time, not just for emergencies.]
[…]
The National Primary Drinking Water Regulations (NPDWR) for radionuclides, set forth in 40 CFR Part 141, effectively adopt a dose-based limit of 4 mrem/yr for beta particle and photon radioactivity. These requirements are based on lifetime exposure criteria, which assume 70 years of continued exposure to contaminants in drinking water” [This is frightening. They choose when Americans die now? This is the world average and probably includes high levels of infant mortality in poor countries. Even in poor countries people can live to be very, very old. US female life expectancy is almost 82. But, it’s not the maximum life-span possible! Not by far! https://en.wikipedia.org/wiki/List_of_countries_by_life_expectancy ]

regardless of the cause of an incident, EPA expects that the responsible party for any drinking water system impacted during a radiation incident will take action to return to compliance with the NPDWR levels by the earliest feasible time” [What if the water provider doesn’t have the means to do so? Why is a nuclear emergency the problem of the local water provider and community and not the problem of the nuclear utility? Price-Andersen Act? Under that, local communities in the evacuation zones might get some help. Will they get help in the 50 mile food and water impact zone?]

The drinking water PAG is intended primarily to guide planning and decision-making efforts by local and state officials, including drinking water providers, during the intermediate phase of a radiological emergency when surface water sources are particularly vulnerable to contamination from deposition of radioactive material from the atmosphere.” [It is only a “guide” for planning and decision making and then EPA throw the ball to state and local government, who are almost always financially strapped. And, it doesn’t even provide needed guidance! It does suggest to close water intake, dilute water, borrow it, etc. But, that sort of advice is already available.] “Actions to protect water sources may be implemented at other levels and at any time following a radiological incident, and even before an anticipated release occurs…

EPA is proposing a two-tier PAG: 500 mrem for the general population (anyone over age 15, excluding pregnant women and nursing women) and 100 mrem for pregnant women, nursing women and children. / Authorities have flexibility on how to apply the PAG. In some cases they may find it prudent to use the PAG of 100 mrem as a target for the whole population, while in other circumstances, authorities may find that it makes sense to use both targets simultaneously…” [Because it’s only a guide…. EPA washes its hands of the matter.]

The PAG specifies a radiation dose to avoid via drinking water exposure projected over one year. In order to determine whether a PAG should be implemented, authorities will need to establish a relationship between the measured concentration of one or more radionuclides in finished drinking water and the radiation dose members of the population might experience as a result of drinking contaminated water” [There will be more than one. If they only measure one there is going to be gross overexposure, based on this PAG. That they might experience? If measurements are correct they will experience the exposure!]

Those responsible for implementing PAGs will need to convert PAGs into Derived Response Levels (DRLs) in units of Bq/L or pCi/L. Section 7.0 of this document provides DRLs and explains how they can be calculated.” [Shouldn’t the EPA do that in advance? Section 7 explains how to measure to see if the PAG is exceeded for one, two, or three radionuclides added together. It doesn’t explain how to determine what amounts of over 100 radionuclides should be in the water to total the 500 mrem (5 mSv) So, how will they know how much to filter or dilute? They may screw up the math, especially during a stressful emergency, if they even recall how to do the math. Then they can be easy fall-guys for the US EPA.]

While the PAG Manual is primarily for advance planning“,[planning, PLANNING, WHAT PLANNING!??? Those responsible had better make sure they find a real guide and plan before an accident occurs. The help’s not coming from this piece of crap by the EPA. People get degrees in planning. This isn’t planning. Nor does it provide the needed tools. Maybe the EPA should hire a planner! During the next nuclear accident, may the radioactive plume pass over and it start raining, while the EPA is having an outdoor picnic.] “there are specific radionuclides, including cesium-137 (Cs-137), iodine-131 (I-131) and strontium/yttrium-90 (Sr-90/Y-90) that are of particular interest for radiological incident scenarios where drinking water sources might be contaminated. Section 7.0 presents default DRLs for these radionuclides to aid emergency managers in making water restriction decisions involving these contaminants. DRLs for these radionuclides are presented as examples for purpose of illustration. If other radionuclides are present, DRLs should be calculated using the same methodology, as discussed in Section 7.0.” [See their trick! They say it’s to “aid” in making water restriction decisions, but then later say that if other radionuclides are presentAnd, Cs 134 will be present in an approximately one to one ratio with Cs 137. As discussed a few days ago, according to the reference manual written by Sandia, there will be even more Cs 134 : 1.6 Cs 134 per 1 Cs 137. Sandia National (Nuclear) labs are run by Lockheed Martin and are at the heart of the nuclear beast.]
….
This section does not constitute a complete handbook for radiological emergency response, but it describes considerations that can be included in comprehensive emergency planning at the state, local and utility level. Actions that public authorities and drinking water providers should take include water monitoring (described in Section 6.1), public notification (described in Section 6.2), and mitigation measures to protect the water supply and the water-consuming public (described in Section 6.3).” [Oh, now it’s not even a handbook or guide, it’s simply “considerations”!]

Preventive action, such as temporary closure of water system intake valves to prevent a contaminant plume from entering the system, may be taken in advance of an anticipated release;” [There most likely won’t be advance notice.] “it is not necessary to wait until drinking water contamination is detected“. [If there is no notification it is.] “Emergency response plans need to consider whether sufficient storage capacity is available to support the community’s fire suppression and sanitation needs while the intake valves are closed
[…]
A comprehensive radiological surveillance program to monitor concentrations of radionuclides of interest in both source water and finished drinking water would provide an indication of whether any adjustments are necessary or if the actions being taken are effective.

The NPDWR for radionuclides requires community water systems (CWSs) to conduct monitoring at each entry point to the distribution system to ensure that every customer’s water does not exceed the MCLs for radionuclides.22 All CWSs are required to monitor for gross alpha, radium-226/228, and uranium. In addition, CWSs designated by the state as “vulnerable” 23 and those using waters “contaminated” 24 by effluents from nuclear facilities must also conduct monitoring for beta particle and photon radioactivity“. [ https://www.epa.gov/ground-water-and-drinking-water/table-regulated-drinking-water-contaminants http://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=30006644.txt ]
[…]
In the event of a radiological contamination incident, state officials may require public water systems to immediately collect additional samples for radionuclides, including beta particle and photon activity. However, EPA recognizes that during an emergency situation it may be necessary to identify alternative sampling and analytical approaches to obtain data to inform short-term actions by emergency response personnel. Many states” [but not all] “have established Radiological Emergency Preparedness 25 programs designed to guide sample collection and analysis and to advise emergency managers in a radiological emergency. Additionally, the Federal Radiological Monitoring and Assessment Center (FRMAC)26 can deploy monitoring and sampling field teams and provide dose assessment expertise to assist states and local communities in responding to an emergency. See the National Response Framework, Nuclear/Radiological Incident Annex 27 for information on roles and capabilities.

Once the situation is better characterized and systems are working towards returning to compliance, monitoring should be conducted at entry points to the distribution systems using approved analytical methods. EPA provides rapid laboratory analysis methods for selected radionuclides to expedite the analytical turnaround time while simultaneously meeting measurement quality objectives.28 “Samples should be collected from entry points to the distribution system. Challenges may arise from variability in environmental matrices. Advance emergency planning can help to achieve sample representativeness and homogeneity relative to routine samples.” [EPA WILL FINALLY DO SOMETHING – LAB ANALYSES – BUT ONLY IF STATE OR LOCAL GOVERNMENTS GATHER THEIR OWN SAMPLES! What happened to their mobile lab. Didn’t they have a mobile lab?]

If members of the public are served by drinking water from household cisterns or private wells, local officials should consider how monitoring should be undertaken to determine levels of target radionuclides and assess the risks posed to these populations…

If compliance monitoring indicates that contamination levels exceed the MCL for any radionuclide, water systems are required to issue public notice on a “Tier 2” time frame (i.e., as soon as practical, but no later than 30 days after the system learns of the violation). CWSs should be able to issue repeat notices as required. However, states may determine that the notification requirement should be elevated to a “Tier 1” Public Notification (i.e., as soon as practical, but no later than 24 hours) based on a significant potential for serious adverse effects on human health due to short-term exposure29 “.[So, the public may not be notified for one day, or even maybe 30 days?]

During a response to a radiological incident, water systems may have difficulty with issuing public notifications in addition to managing the response to the contamination event. The state may issue public notification on behalf of the water system (40 CFR 141.210(a)). This would allow the state to deliver a consistent message to all affected customers and allow the system to concentrate its efforts on returning to operation or returning to compliance in the event of a radionuclides MCL violation. For more information see the Revised Public Notification Handbook (EPA 816-R-09-013, March 2010).

State and local authorities should be proactive in communicating about risks and uncertainties and providing clear instructions to the public

officials should benchmark observed concentrations against the default DRLs discussed in Section 7.0 or situation specific DRLs that account for specific isotopes present, release patterns, and decay. Officials would then be in a position to make informed decisions about the need to implement protective actions.” [They will be able to make confused and dangerous decisions if they benchmark against the maximum allowed for single radionuclides when multiple ones will be present.]

Options available to water systems to reduce radiation dose to drinking water customers include applying treatment technologies, relying on back-up storage, blending water, accessing alternative water sources, and rationing of uncontaminated water or a combination of these actions

If a source of uncontaminated water is available, a water system may choose to blend water from contaminated and uncontaminated sources of drinking water to minimize radiation doses from drinking water. The water may be blended using storage tanks or a common header to allow for complete mixing prior to distribution to customers” [EPA’s idea of guidance-planning. But, much is already recommended by them for cheap and easy compliance with the Clean Drinking Water rule.]
[…]
The default DRLs in the PAGs are provided for convenience to allow local entities to make decisions about drinking water provided by public water systems quickly in the event of a radiological emergency…

All radionuclides are covered by the assessment tools provided by FRMAC. For instance, if an alpha emitting isotope was of concern following a radiation contamination incident, it would be included in any calculations regarding protective actions for drinking water. As such, local officials may choose to work with FRMAC to calculate situation-specific DRLs that are based on information gained during the intermediate phase, including identification of specific isotopes, release patterns, and associated decay functions…” [FRMAC list by Sandia is incomplete. Notice EPA is throwing the responsibility elsewhere.]

Early exceedance of the default DRL does not preclude the possibility that doses will stay below PAGs as radionuclide concentrations in water decline by a combination of radioactive decay and natural attenuation. If the concentrations of radionuclides do not exceed DRLs over the course of one year, doses will remain below the PAG…” [?????????]

10,352 pCi/L Which is best rounded to 10,350 pCi/L considering the uncertainties…” [ They just rounded down! They allow “uncertainies” to increase risk? Why round down? ]

PAG is exceeded…” [Everyone needs to know how to keep it from being exceeded! ]

Ci = the concentration of radionuclide i in the water supply (pCi/L or Bq/L)
[Ci is a really poor choice for concentration of radionuclides, especially if they insist upon using Ci (curies) and even if they don’t people might think it’s curies!] Excerpts from the falsely named:
Draft Protective Action Guide (PAG) for Drinking Water, United States Environmental Protection Agency, June 2016 https://www.regulations.gov/contentStreamer?documentId=EPA-HQ-OAR-2007-0268-0211&disposition=attachment&contentType=pdf
Archive 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

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 [EPA trying to undermine the regulations and wash its hands of responsibility.]

From the US FDA:
With one exception (LOCs for I-131 in non-infant food), guidance levels or DILs for radionuclides established in the 1998 FDA document that FDA has adopted in the CPG are higher than guidance levels or LOCs for those same radionuclides contained in the CPG 7119.14. In deriving guidance levels or DILs contained in the 1998 FDA document, FDA employed updated international consensus values for intervention levels of dose (called PAGs by FDA) as well as updated dose coefficients and food intake estimates. In addition, information gained by FDA and others following the Chernobyl accident determined that the amount of food affected by an accident would be significantly lower than the level originally estimated.” [Since when is Chernobyl in the Americas?] “For this reason, DILs contained in the 1998 FDA document assume thirty percent of the dietary intake would be contaminated after a nuclear accident, compared to the 100 percent assumption of contamination employed in deriving LOCs. FDA’s decision to reduce the assumption for dietary intake contamination from 100 percent to thirty percent is the main reason that the guidance levels established in the 1998 FDA document and adopted in the CPG are higher than the guidance levels contained in CPG 7119.14

For food consumed by most members of the general public, ten percent of the dietary intakes was assumed to be contaminated. This assumption recognizes the ready availability of uncontaminated food from unaffected areas of the United States or through importation from other countries, and also that many factors could reduce or eliminate contamination of local food by the time it reaches the markethttp://web.archive.org/web/20151017135524/http://www.fda.gov/food/foodborneillnesscontaminants/chemicalcontaminants/ucm078341.htm#guides [So is it 10% or 30%? Plus they appear to seriously underestimate food intake.]

NB: Something which is lethal does not have to always cause death. But, it is capable of causing death. See: http://www.thefreedictionary.com/lethal