Friday, June 17, 2016

EPA's Proposed New Protective Action Guidelines for Drinking Water (Post II): Radiation Risks Described by Japanese Physicist

In pursuing research on radiation risks, I found this excellent article published in the Asia-Pacific Journal that I had somehow missed previously. I strongly recommend reading it:
Sawada Shoji. 2013. Scientists and Research on the Effects of Radiation Exposure: From Hiroshima to Fukushima. The Asia-Pacific Journal, Vol. 11, Issue 23, No. 2. June 10, 2013.
Professor Emeritus Sawada Shoji is a physicist at Nagoya University. In 1999 he co-authored The Truth about Radiation Damage from the Hiroshima and Nagasaki Blasts (Kyodo Kenkyu Hiroshima Nagasaki Genbaku Higai No Jisso), published by Shin-Nihon Publishing. 
(page 8) The main form of radiation exposure at the recent Fukushima nuclear incident was internal exposure through inhalation and ingestion. However, by following the ICRP standards and ignoring the properties of internal exposure, the government and its advisors willfully underestimated the related health effects. We therefore demand that lives be protected from radiation damage through rigorous scientific understanding of internal exposure.

(Page 9) Exposure to 1 mSv of radiation will cause damage to around 500 biomolecules per cell over the entire body from ionisation. Most will repair, while approximately one of the biomolecules will repair incorrectly or will be unable to repair. Thanks to base pairs in a double helix, if a portion of DNA, the key to life, is damaged, it will be almost completely repaired to its former state. Because of this, life on earth has evolved into its current state despite the varying degrees of damage caused by natural radiation.

However, in addition to excessive radioactive exposure, if radioactive isotopes that resemble elements essential to the living body are introduced into human bodies, they will concentrate in specific organs and cause exposure effects. Even a dose of 10 mSv will cause a near proportionate increase in the rate of late-onset disorders from chromosomal abnormality such as cancer.
Excessive radiation exposure (over 1mSv) leads to genetic damage, most of which will be repaired, but not all. Even more importantly, internalized exposure to radioisotopes will result in magnified effects because of bioaccumulation in organs. Even 10mSv can cause "late-onset disorders."

These conclusions have very significant implications for people in Fukushima, which I will discuss in a later post. 

But for now I turn instead to the EPA's proposed new Protective Action Guidelines for drinking water....

 It is interesting to compare Dr. Shoji's data points with the proposed US Protective Action Guidelines  which stipulate 500 mrem exposure for adults and 100 for infants, children, and pregnant or nursing women (100 mrem = 1 millisieverts) / 500 mrem = 5 millisieverts):

PAGE 5 EPA is proposing a two-tiered intermediate phase drinking water PAG of 100 mrem projected dose in the first year for infants, children and pregnant or nursing women and 500 mrem projected dose in the first year for the general population.
(see link:
So, the EPA is recommending 1 millisievert of annual exposure for infants/pregnant mothers and 5 millisieverts for adults annually from water alone. Levels in food, air, and other beverages will contribute substantially to these dose levels. 

Many environmental and health organizations in the US are outraged by these standards, as illustrated here:
EPA Proposal Allows Radiation Exposure in Drinking Water Equivalent to 250 Chest X-Rays a Year. June 8, 2016, Food & Water Watch
The U.S. Environmental Protection Agency (EPA) quietly issued proposals Monday to allow radioactive contamination in drinking water at concentrations vastly greater than allowed under the Safe Drinking Water Act. The new guidance would permit radiation exposures equivalent to 250 chest X-rays a year....
The EPA proposed Protective Action Guides (PAGs) would allow the general population to drink water hundreds to thousands of times more radioactive than is now legal. For example, radioactive iodine-131 has a current limit of 3 pico-curies per liter (pCi/L), in water but the new guidance would allow 10,350 (pCi/L), 3,450 times higher. For strontium-90, which causes leukemia, the current limit is 8 pCi/L; the new proposed value is 7,400 pCi/L, a 925-fold increase. 
...Radiation doses (in rems) cannot be measured but are calculated based on some measurements and many assumptions. The current Safe Drinking Water Act limits are based on 4 millirems per year. The PAGs would allow 500 millirems per year for the general population. A single chest X-ray gives about 2 millirems. Because of the way EPA is changing the definition of dose, for many radionuclides, the allowable concentration would be thousands, tens of thousands and even millions of times higher than set under the Safe Drinking Water Act.  
Internal EPA documents obtained under the Freedom of Information Act show that the EPA itself concluded that the proposed concentrations “would exceed MCLs [Maximum Contaminant Limits of the Safe Drinking Water Act] by a factor of 100, 1000 and in two instances, 7 million.” The EPA internal analysis showed that for one radionuclide, “drinking a very small glass of water of approximately 4 ounces … would result in an exposure that corresponds to a lifetime of drinking … water … at the MCL level.”
As illustrated by this analysis, the new guidelines allow much higher concentrations of dangerous radionuclides in water, posing increased risks of diseases (and not just cancer!).

It is important to note that the EPA is not saying these levels are safe and it is not recommending that these levels permanently replace Maximum Contaminant Levels that prevail by law under ordinary conditions, as noted in their proposal:
PAGE 4 The PAG Manual is not a legally binding regulation or standard and does not supersede any environmental laws; PAGs are not intended to define “safe” or “unsafe” levels of exposure or contamination. As indicated by the use of non-mandatory language such as “may,” “should” and “can,” the Manual only provides recommendations and does not confer any legal rights or impose any legally binding requirements upon any member of the public, states or any federal agency. Rather, the PAG Manual provides projected radiation dose levels at which specific actions are recommended in order to reduce or avoid that dose

Page 6 Ultimately, a PAG does not represent an “acceptable” routine exposure; a PAG is a dose at which protective action is advised in order to reduce or avoid that dose. Every PAG is developed with the same three principles: prevent acute effects, balance protection with other important factors and ensure that actions result in more benefit than harm, and reduce risk of chronic effects...
PAGE 6 Under the Safe Drinking Water Act (SDWA), the Agency has established maximum contaminant levels (MCLs) for radiological contaminants in drinking water. 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. While the SDWA framework is appropriate for day-to-day normal operations, it may not provide the necessary tools to assist emergency responders with determining the need for an immediate protective action.
I discuss the proposed guidelines here:

Although the EPA is not promising safety and is not recommending a permanent substitution in guidelines, nuclear states of emergency are rapidly becoming the new status quo as the world's aging nuclear infrastructure leaks ionizing radiation into the atmosphere and ground water, contributing to decades of careless radioactive contamination by military, industrial and medical nuclear waste.

In this context, Protective Action Guidelines that are officially designated for "emergency" situations may in fact become normative as radiological emergencies grow.

The EPA is well aware of this fact, having recently "walked away" from a major radiation cleanup in Florida:
EPA abandons major radiation cleanup in Florida, despite cancer concerns.
[Excerpt] The Environmental Protection Agency is walking away after a decades-long battle with Florida politicians and industry officials over cleaning up phosphate-mining waste in an area that could expose more than 100,000 residents to cancer-causing radiation levels. 
Under a decision quietly finalized two weeks ago, the federal agency will leave it to state officials to decide the fate of the sites in and around Lakeland, an approximately 10-square-mile residential area midway between Orlando and Tampa. 
However, Florida officials have long argued that the affected area need not be cleaned up in the absence of radiation levels well above what EPA policy would normally permit. 
The decision not to enforce the usual federal rules could have far-reaching implications for how the United States deals with future radioactive contamination anywhere across the country — regardless of whether it is caused by conventional industrial activities or illicit radiological weapons, critics say.[end]

Welcome to the Radioactive New World Order.



  1. Post your comment to the EPA here:

  2. Not much time left by any standard