I am going to explore political dimensions of their proposal in a series of posts.
Here is a pre-publication draft of the proposed changes:
This first post explores the politics of current regulatory standards and distinguishes between protection action guidelines and ordinary federal guidelines.
Accordingly, there is an important difference between the PAGs and the Maximum Contaminant Level (MCL). The MCL is the ordinary maximum level of contaminants, while the PAGs apply to emergency situations.
Here is the EPA's definition of MCL from the document linked above:
Maximum Contaminant Level (MCL) - The highest level of a contaminant that is allowed in drinking water. MCLs are set as close to MCLGs as feasible using the best available treatment technology and taking cost into consideration. MCLs are enforceable standards https://www.epa.gov/ground-water-and-drinking-water/table-regulated-drinking-water-contaminants#RadionuclidesHere is the MCL Table for radionuclides in drinking water:
Before examining the new PAG, I think it is helpful to take a look at this table to explore the politics inherent in our ordinary safety standards.
There are a couple of aspects to this table that are noteworthy.
First, notice that the "potential health effects" are exclusively LIMITED TO INCREASED RISK OF CANCER, with the exception of uranium which is also linked to "kidney toxicity."
Second, notice that all of the contaminants are attributed to EROSION OF NATURAL DEPOSITS, with the exception of beta particles and proton emitters, which are also attributed to "decay of man made products."
I will demonstrate that this table is a SOCIAL CONSTRUCTION that selectively frames audience perceptions of the risks and sources of radionuclide contamination in water.
Let us start with a question about a single radioactive element to deconstruct this ideological table: Where does uranium in drinking water come from?
According to the World Health Organization (WHO), uranium in drinking water comes from multiple sources:
World Health Organization. 2004. Uranium in Drinking-water: Background document for development of WHO Guidelines for Drinking-water Quality. http://www.who.int/water_sanitation_health/dwq/chemicals/en/uranium.pdf
Page 1 Uranium is present in the environment as a result of leaching from natural deposits, release in mill tailings, emissions from the nuclear industry, the combustion of coal and other fuels and the use of phosphate fertilizers that contain uranium.
As illustrated here, uranium comes from many human engineered sources, including mining, nuclear industry emissions, combustion of coal, and phosphate fertilizers containing uranium. Yet, the EPA is strangely silent about these sources of contamination, attributing uranium exclusively to "natural" causes.
The WHO report is more inclusive than the EPA's account, but still missing an important source of uranium that is made clear in this account from the Comprehensive Test Ban Treaty Organization. This organization describes contamination from the US Nuclear Testing Programme as spreading thousands of miles:
The United States' Nuclear Testing Programme. https://www.ctbto.org/nuclear-testing/the-effects-of-nuclear-testing/the-united-states-nuclear-testing-programme/As noted here, fallout from testing "contained radionuclides and gases which were transported thousands of miles from the NTS by winds."
Between 1951 and 1958, around 100 nuclear weapons tests were conducted in the atmosphere at the Nevada Test Site (NTS). Located about 100 km northwest of Las Vegas, the NTS was larger than many small countries, offering some 3,500 square km of undisturbed land.
The average yield for the atmospheric tests was 8.6 kilotons (kt). The fallout from the tests contained radionuclides and gases which were transported thousands of miles away from the NTS by winds. As a result, people living in the United States during these years were exposed to varying levels of radiation.
The CTBTO showcases the video produced by Japanese artist Isao Hashimoto featuring every publicly recorded nuclear test from 1945 to 1988:
Watch the video. There is no doubt that fallout from detonation of nuclear weapons and waste from atomic production processes contribute significantly to uranium content in drinking water in some areas of the world.
This is not simply my "opinion." Rather, it is the conclusion reached by the US President's Cancer Panel, Reducing Environmental Cancer Risk:
U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES National Institutes of Health National Cancer Institute2008–2009 Annual Report President’s Cancer Panel. REDUCING ENVIRONMENTAL CANCER RISK What We Can Do NowThe Navajo population in Arizona and New Mexico were particularly subject to uranium contamination, as noted in the environmental cancer panel report:
Radioactive Contamination p. 79
Hundreds of thousands of military personnel and civilians in the United States received significant radiation doses as a result of their participation in nuclear weapons testing and supporting occupations and industries, including nuclear fuel and weapons production, and uranium mining, milling, and ore transport. Hundreds of thousands more were irradiated at levels sufficient to cause cancer and other diseases. These populations include the families of military and civilian workers, and people—known as “downwinders”—....
p. 81 The Navajo banned uranium mining and milling in 2005. More than 1,000 uranium mines and mill sites exist in the region, and most have not been sealed or cleaned up389 since mining declined following the Cold War years; some are designated Superfund sites. Many of the miners and mill workers were Navajo who worked without respirators or other protection and still live with their families near the work sites, where they continually breathe uranium dust and drink uranium-contaminated water. Both the Navajo and Laguna tribes have experienced markedly higher than average rates of lung cancer, as well as kidney disease, birth defects, and other health problems.
The increased diseases suffered by the Navajos as a result of contaminated drinking water include birth defects, a very significant affliction that the EPA doesn't bother to include in their table of possible health effects.
Ok let us return to the EPA's selective framing of the source of radionuclide contamination. The EPA has framed uranium contamination as derived from natural erosion but we have seen above that uranium contamination of drinking water is caused by myriad human-made sources, especially from the nuclear weapons/energy complex.
The EPA has spun a deception through their selective framing of the source of uranium contamination.
In addition to selectively framing the contamination sources, the EPA has selectively framed the "health risks" from uranium exposure (and from all radionuclide exposure), ERASING BIRTH DEFECTS as a known risk despite clear evidence and peer reviewed research documenting transgenerational effects from uranium exposure.
The EPA has spun a second deception through their selective framing of the risks from uranium contamination.
EPA biopolitics are infused with a politics of death, of thanatopolitics.