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EPA PAG comparisons to MCIs (Clean Water Act)
PEER had to sue to get this document. And, yet, the list of radionuclides is still incomplete. There are less than 90 radionuclides listed of the almost 200 which are covered by the Clean Water Act MCIs (See blog post bottom). Conspicuously absent is Cs 134. If 629 Bq/l (629 Bq/kg) Cs 137 is allowed by the US EPA then there would presumably be approximately 8554 Bq/l (8554 Bq/kg) of Cs 134, in the event of a nuclear reactor accident. The Cs 134 levels would be much lower in nuclear waste. The US FDA combines Cs 134 and 137. Why, and what it means, is explained in more detail here: https://miningawareness.wordpress.com/2017/01/27/us-officially-allows-radiation-in-drinking-water-1000s-of-times-greater-than-clean-water-act-in-event-of-nuclear-accident-private-interim-nuclear-waste-storage-comment-deadline-today-11-59-pm-et-even/

[Update: Although the deadline is past, the nuclear industry has submitted things one year late. However, if you submit late it won’t be anonymous unless you use a disposable or other anonymous email.]
The information from PEER is especially critical with the upcoming Private Nuclear Waste “Interim” Storage Facility Comment deadline in less than 3 hours – Tonight 11.59 PM Eastern Time (NY-Boston-DC-Atlanta, Miami, etc.) 11.59 PM is 1 minute to midnight. Comment here: https://www.regulations.gov/document?D=DOE_FRDOC_0001-3256 ID: DOE_FRDOC_0001-3256. It is easy and can still be anonymous. The radiological emergency which can make the PAGs kick in could be from transport of nuclear waste and presumably from an interim storage facility. The proposed private interim facility is open-air like an open parking lot offering no protection.

PEER News Release:
For Immediate Release: Dec 22, 2016
Contact: Kirsten Stade (202) 265-7337
EPA Hid Planned Exposure Levels 1,000s of Times Safe Drinking Water Act Limits

Posted on Dec 22, 2016 | Tags: Drinking Water, EPA
Washington, DC — In the last days of the Obama Administration, the U.S. Environmental Protection Agency is about to dramatically increase allowable public exposure to radioactivity to levels thousands of times above the maximum limits of the Safe Drinking Water Act, according to documents the agency surrendered in a federal lawsuit brought by Public Employees for Environmental Responsibility (PEER). These radical rollbacks cover the “intermediate period” following a radiation release and could last for up to several years. This plan is in its final stage of approval.

The documents indicate that the plan’s rationale is rooted in public relations, not public health. Following Japan’s Fukushima meltdown in 2011, EPA’s claims that no radioactivity could reach the U.S. at levels of concern were contradicted by its own rainwater measurements showing contamination from Fukushima throughout the U.S. well above Safe Drinking Water Act limits. In reaction, EPA prepared new limits 1000s of times higher than even the Fukushima rainwater because “EPA experienced major difficulties conveying to the public that the detected levels…were not of immediate concern for public health.”

When EPA published for public comment the proposed “Protective Action Guides,” it hid proposed new concentrations for all but four of the 110 radionuclides covered, and refused to reveal how much they were above Safe Drinking Water Act limits. It took a lawsuit to get EPA to release documents showing that –
* The proposed PAGs for two radionuclides (Cobalt-60 and Calcium-45) are more than 10,000 times Safe Drinking Water Act limits. Others are hundreds or thousands of times higher;
* According to EPA’s own internal analysis, some concentrations are high enough to deliver a lifetime permissible dose in a single day. Scores of other radionuclides would be allowed at levels that would produce a lifetime dose in a week or a month;
* The levels proposed by the Obama EPA are higher than what the Bush EPA tried to adopt–also in its final days. That plan was ultimately withdrawn; and
* EPA hid the proposed increases from the public so as to “avoid confusion,” intending to release the higher concentrations only after the proposal was adopted. The documents also reveal that EPA’s radiation division even hid the new concentrations from other divisions of EPA that were critical of the proposal, requiring repeated efforts to get them to even be disclosed internally.

“To cover its embarrassment after being caught dissembling about Fukushima fallout on American soil, EPA is pursuing a justification for assuming a radioactive fetal position even in cases of ultra-high contamination,” stated PEER Executive Director Jeff Ruch, noting that New York Attorney General Eric Schneiderman has called for the PAGs to be withdrawn on both public health and legal grounds. “The Safe Drinking Water Act is a federal law; it cannot be nullified or neutered by regulatory ‘guidance.’”

Despite claims of transparency, EPA solicited public comment on its plan even as it hid the bulk of the plan’s effects. Nonetheless, more than 60,000 people filed comments in opposition.

“The Dr. Strangelove wing of EPA does not want this information shared with many of its own experts, let alone the public,” added Ruch, noting that PEER had to file a Freedom of Information Act lawsuit to force release of exposure limits. “This is a matter of public health that should be promulgated in broad daylight rather than slimed through in the witching hours of a departing administration.”
View ultra-high proposed PAG allowable concentrations (and explanation for the chart) http://www.peer.org/assets/docs/epa/12_22_16_PAG_Chart.png
See briefing memo explaining why EPA wants water PAGs

Click to access 12_22_16_PAG_briefing_memo.pdf

Read letter of opposition from New York Attorney General

Click to access 12_22_16_NY_AG_ltr.pdf

Revisit PEER lawsuit

Emphasis our own. See original and more info here: http://www.peer.org/news/news-releases/radical-drinking-water-radiation-rise-confirmed-in-epa-plan.html See how to donate to PEER.org in the upper right hand corner of their web site: “Give”.

Safe Drinking Water Act requirements
US EPA: Radionuclides in Drinking Water: A Small Entity Compliance Guide, p. 3
Radionuclides in Drinking Water: A Small Entity Compliance Guide p. 4 Rad Max Contam
Picocuries (pCi) per liter needs to be converted to Becquerels per liter (one liter of water is approximately 1 kilogram (kg). 100 mrem is 1 mSv. 4 mrem (millirem) is 0.04 mSv (millisieverts)
Radionuclides in Drinking Water: A Small Entity Compliance Guide  Beta and Photon Derived concentrations drinking water, p. 11