EPA Documents Raise Doubts Over Intent of New Nuclear-Response Guide

Destroyed unit 3 reactor building of Tokyo Electric Power Co.'s tsunami-crippled Fukushima Dai-ichi nuclear power plant is seen in Fukushima prefecture, northeastern Japan, Monday, Feb. 20, 2012. Japan next month marks one year since the March 11 tsunami and earthquake, which triggered the worst nuclear accident since Chernobyl in 1986.
Sept. 11, 2013, 11:02 a.m.

WASH­ING­TON — Newly ob­tained gov­ern­ment doc­u­ments are prompt­ing con­cern among crit­ics that En­vir­on­ment­al Pro­tec­tion Agency of­fi­cials are seek­ing to use the or­gan­iz­a­tion’s new guide for nuc­le­ar-in­cid­ent re­sponse to re­lax pub­lic health stand­ards, but the agency is deny­ing the claim.

The Free­dom of In­form­a­tion Act re­lease comes as the agency has yet to fin­ish col­lect­ing pub­lic com­ments on the so-called pro­tect­ive-ac­tion guide, which it is­sued in April after years of in­tern­al in­fight­ing and pub­lic con­tro­versy. The doc­u­ment is meant to give fed­er­al, state and loc­al of­fi­cials ad­vice on re­spond­ing to a wide range of ra­di­olo­gic­al in­cid­ents, such as “dirty bomb” at­tacks, nuc­le­ar power plant melt­downs and in­dus­tri­al ac­ci­dents.

The doc­u­ments ob­tained by Glob­al Se­cur­ity News­wire show EPA of­fi­cials have sug­ges­ted at meet­ings around the world that the new guide could al­low for the use of long-term cleanup stand­ards dra­mat­ic­ally less strin­gent than those the agency has en­forced for dec­ades at hun­dreds of sites throughout the United States, crit­ics say.

In some cases, EPA of­fi­cials have not only sug­ges­ted that a drastic event akin to the Fukushi­ma nuc­le­ar power plant melt­down in Ja­pan would ne­ces­sit­ate more flex­ible guidelines, but also have made state­ments that crit­ics say chal­lenge the very sci­ence be­hind the agency’s every­day ra­di­ation rules.

“I think [EPA Ad­min­is­trat­or] Gina Mc­Carthy has an out-of-con­trol agency,” Daniel Hirsch, a nuc­le­ar-policy lec­turer at the Uni­versity of Cali­for­nia-Santa Cruz, told GSN after re­view­ing the doc­u­ments. “She has some people who are act­ing as nuc­le­ar cow­boys, on be­half of EPA, un­der­min­ing EPA’s policies and I think the pub­lic could get very badly hurt by it.”

One of the doc­u­ments ob­tained by GSN is a present­a­tion that Mike Boyd, an of­fi­cial in the agency’s ra­di­ation of­fice, gave about the new pro­tect­ive-ac­tion guide dur­ing a May meet­ing of the Par­is, France-based Nuc­le­ar En­ergy Agency, a di­vi­sion of the in­ter­gov­ern­ment­al Or­gan­iz­a­tion for Eco­nom­ic Co­oper­a­tion and De­vel­op­ment.

The present­a­tion sug­gests the ap­proach to cleanup de­scribed in the new EPA guide “re­call[s] the concept of op­tim­iz­a­tion,” a con­tro­ver­sial term the Obama ad­min­is­tra­tion had stripped from pri­or, Bush-era drafts of the doc­u­ment, even though “the word may be go­ing out of style.”

The slides con­tin­ue: “It is a flex­ible ap­proach in which a vari­ety of dose or risk bench­marks may be iden­ti­fied from vari­ous reg­u­lat­ory agen­cies, state gov­ern­ments, or oth­er stake­hold­ers.”

The EPA doc­u­ment goes on to list re­ports of the private Na­tion­al Coun­cil on Ra­di­ation Pro­tec­tion and the non­gov­ern­ment­al In­ter­na­tion­al Com­mis­sion on Ra­di­olo­gic­al Pro­tec­tion as among the po­ten­tial sources for such bench­marks.

It is the re­com­mend­a­tions of these very groups that EPA and state cleanup of­fi­cials, along with en­vir­on­ment­al act­iv­ists, have cri­ti­cized in the past on the grounds they sug­gest re­medi­ation goals thou­sands of times less rig­or­ous than what has ever been per­mit­ted in the United States.

Most re­cently, a Feb­ru­ary NCRP re­port fun­ded by the U.S. Home­land Se­cur­ity De­part­ment sug­ges­ted im­ple­ment­ing ICRP cleanup goals un­der which an an­nu­al ra­di­ation dose of up to 2,000 mil­lirems per year is per­mit­ted — a rate at which as many as 1 in 20 people would be ex­pec­ted to de­vel­op can­cer from long-term ex­pos­ure. Nor­mally, EPA does not per­mit ac­tions that would leave more than 1 in 10,000 people at risk for can­cer from 30 years of ex­pos­ure, pur­su­ant to rules its Su­per­fund pro­gram es­tab­lished in the 1980s.

“It’s bait and switch,” said Hirsch, who as pres­id­ent of the watch­dog group Com­mit­tee to Bridge the Gap has been tapped by nu­mer­ous en­vir­on­ment­al or­gan­iz­a­tions throughout the coun­try to cri­tique the agency’s hand­ling of the new guid­ance. “They took out the hor­rible lan­guage, left it vague enough and then you’ve got [EPA of­fi­cials] act­ing as though the lan­guage is still there.”

A “˜fun­da­ment­al shift’

As it was, watch­dog groups already were rais­ing alarms over com­ments that Paul Kuda­rauskas, an of­fi­cial with the EPA Con­sequence Man­age­ment Ad­vis­ory Team, made earli­er this year sug­gest­ing events like Fukushi­ma would cause a “fun­da­ment­al shift” to cleanup.

Kuda­rauskas in March said that U.S. res­id­ents are used to hav­ing “cleanup to per­fec­tion,” but would have to aban­don their “not-in-my-back­yard” men­tal­ity in such cases. “People are go­ing to have to put on their big-boy pants and suck it up,” the EPA of­fi­cial said.

The Chica­go-based Nuc­le­ar En­ergy In­form­a­tion Ser­vice, a crit­ic of the new EPA guide, cited GSN‘s re­port­ing of Kuda­rauskas’ re­marks in Aug. 1 com­ments on the new guide. The act­iv­ist group’s com­ments ask that the agency res­cind the doc­u­ment and fire Kuda­rauskas.

In a state­ment to GSN, the agency main­tains that the new guide “does not su­per­sede or al­ter en­vir­on­ment­al laws or reg­u­la­tions,” however. While Boyd’s present­a­tion in France “cited NCRP and ICRP doc­u­ments as use­ful re­sources … to an in­ter­na­tion­al audi­ence from lead­ing or­gan­iz­a­tions in the field of ra­di­ation pro­tec­tion,” the guide it­self notes that the Su­per­fund can­cer risk guidelines are “gen­er­ally con­sidered pro­tect­ive” in the United States, ac­cord­ing to the EPA state­ment agency spokes­wo­man Ju­lia Valentine provided to GSN.

Crit­ics of the guide have ar­gued, however, that such lan­guage does not overtly rule out the use of less-strict guidelines, and have asked that the doc­u­ment ex­pli­citly state the agency will stick to its reg­u­lar can­cer-risk rules fol­low­ing a ra­di­olo­gic­al in­cid­ent.

The EPA re­sponse to GSN ac­know­ledges that the new guide says “the [Su­per­fund] risk range may not be achiev­able in a large ra­di­olo­gic­al in­cid­ent.” Over the ob­jec­tions of act­iv­ists and some loc­al of­fi­cials, the new doc­u­ment also elim­in­ates a re­com­mend­a­tion that ap­peared in the agency’s pri­or nuc­le­ar-re­sponse guide from 1992 that stated people should not be ex­posed to more than 5,000 mil­lirems of ra­di­ation over 50 years. This bench­mark would ap­pear to have pre­cluded the pos­sib­il­ity of fol­low­ing the NCRP re­com­mend­a­tion that people could be ex­posed to as much as 2,000 mil­lirems per year.

Boyd’s present­a­tion, mean­while, says long-term cleanup con­duc­ted un­der the guide could only “po­ten­tially” strive to meet EPA’s tra­di­tion­al rules.

De­tract­ors have long feared the guide is part of an ef­fort to chip away at those stand­ards, not­ing that in­dustry and gov­ern­ment of­fi­cials are already ar­guing against the use of Su­per­fund pro­tocol at sev­er­al sites. Those in­clude the site of a nuc­le­ar re­act­or melt­down at the Santa Susana Field Labor­at­ory in Cali­for­nia and an area in cent­ral Flor­ida where EPA of­fi­cials fear some 40,000 people liv­ing on former phos­phate mines may be ex­posed to dan­ger­ous ra­di­ation levels.

Ex­pos­ure vs. can­cer risk

Now present­a­tions EPA of­fi­cials are mak­ing re­gard­ing cleanup after ra­di­olo­gic­al in­cid­ents sug­gest some agency staffers are look­ing to chal­lenge the can­cer-risk sci­ence un­der­ly­ing nearly all of the agency’s ra­di­ation reg­u­la­tions by sug­gest­ing there are sci­en­tific­ally val­id al­tern­at­ives, act­iv­ists say.

May 2012 present­a­tion to Ja­pan­ese of­fi­cials deal­ing with the af­ter­math of the Fukushi­ma dis­aster led by John Cardarelli — an of­fi­cial in EPA’s emer­gency man­age­ment of­fice and a col­league of Kuda­rauskas on the EPA Con­sequence Man­age­ment Ad­vis­ory Team — says of­fi­cials should “can­didly ac­know­ledge [the] lim­it­a­tions of risk-ana­lys­is mech­an­isms.” That is a ref­er­ence to math­em­at­ic­al mod­els sci­ent­ists use to pro­ject the cor­rel­a­tion between can­cer in­cid­ents and ra­di­ation ex­pos­ure.

In ac­cord­ance with the re­com­mend­a­tions of the Na­tion­al Academies of Sci­ence, of­fi­cial EPA policy en­dorses what is called the “lin­ear no-threshold” mod­el, which — based largely on stud­ies of atom­ic-bomb sur­viv­ors in Ja­pan and some oth­er data — as­sumes there is no safe level of ra­di­ation ex­pos­ure. The mod­el pre­sup­poses that can­cer risk in­creases pro­por­tion­ally with the size of the ra­di­ation dose an in­di­vidu­al re­ceives.

Cardarelli’s present­a­tion, however, presents al­tern­at­ive the­or­ies pre­vi­ously re­jec­ted by NAS and EPA sci­ent­ists, in­clud­ing one, called “hormes­is,” which ar­gues that low levels of ra­di­ation ex­pos­ure are ac­tu­ally be­ne­fi­cial.

The EPA state­ment to GSN de­fends the present­a­tion, ar­guing that “tech­nic­al in­form­a­tion is avail­able to sup­port all of the mod­els” it cites — in­clud­ing hormes­is, an­oth­er the­ory that as­sumes ra­di­ation is less harm­ful than NAS sci­ent­ists have found, and a third that sug­gests it could be more harm­ful. The “sci­entif­ic com­munity is not uni­fied on ra­di­ation health ef­fects,” the EPA state­ment claims.

Hirsch slammed the EPA de­fense of the present­a­tion, call­ing the cited al­tern­at­ive the­or­ies “kooky stuff from the mar­gin of sci­ence.

“The sci­entif­ic com­munity is not united on this?” Hirsch con­tin­ued. “It went to the Na­tion­al Academies of Sci­ence, which un­an­im­ously con­cluded: Yes, [the cor­rect mod­el] is lin­ear no-threshold. If you par­don the ex­pres­sion, it is a little bit like the cli­mate den­iers say­ing that the sci­ence com­munity is not united on this mat­ter. “¦ They’re mak­ing it sound like the Na­tion­al Academies of Sci­ence are just one little play­er in this and that EPA is just one little play­er.”

A sep­ar­ate Septem­ber 2012 present­a­tion by Cardarelli to an in­ter­agency group led by the Home­land Se­cur­ity De­part­ment ap­pears to sug­gest that EPA reg­u­la­tions are the op­pos­ite of sci­ence and that com­ply­ing with EPA can­cer risk rules is the op­pos­ite of con­duct­ing a “prac­tic­al cleanup.”

Echo­ing Kuda­rauskas, the present­a­tion says the Fukushi­ma dis­aster has ne­ces­sit­ated “a fun­da­ment­al shift in our think­ing” and cites a 100 mil­lir­em per year ra­di­ation dose lim­it as an al­tern­at­ive. About 1 in 300 people would be ex­pec­ted to de­vel­op can­cer if ex­posed to this level for 30 years, ac­cord­ing to cal­cu­la­tions per­formed us­ing the NAS and EPA-ap­proved risk fig­ures.

Even the In­ter­na­tion­al Com­mis­sion on Ra­di­olo­gic­al Pro­tec­tion’s pro­jec­tions would put the risk at roughly 1 in 400, which is about 25 times great­er than what EPA rules would nor­mally al­low un­der the worst cir­cum­stances.

“˜Many con­sid­er­a­tions’

The agency re­sponse to GSN says, however, that there “was no in­tent to dis­cred­it EPA reg­u­la­tions” in the Cardarelli present­a­tion. The EPA state­ment said the present­a­tion ref­er­enced “the many con­sid­er­a­tions that need to be made when deal­ing with com­plex large scale in­cid­ents such as Fukushi­ma” and that the 100 mil­lir­em per year dose lim­it is the tar­get used in Ja­pan.

This dose lim­it also rep­res­ents the low end of the 100-2,000 mil­lir­em per year cleanup-tar­get re­com­men­ded by the Feb­ru­ary NCRP re­port that Boyd’s present­a­tion to the Par­is-based Nuc­le­ar En­ergy Agency im­plies could be ac­cept­able un­der the new EPA re­sponse guide. Jonath­an Ed­wards, dir­ect­or of the EPA ra­di­ation of­fice and Boyd’s su­per­i­or, helped draft the NCRP re­port, as did Cardarelli.

Boyd’s present­a­tion, mean­while, ap­pears to mis­rep­res­ent the cri­ti­cism that state cleanup of­fi­cials and en­vir­on­ment­al act­iv­ists have levied against the new EPA guide, Hirsch says. Boyd says those op­posed to the new guide ad­voc­ate for “a single cleanup num­ber” that would dic­tate the amount of ra­dio­act­ive con­tam­in­a­tion that can be left be­hind at all sites and that lacks “any flex­ib­il­ity” to ac­com­mod­ate for dif­fer­ing cir­cum­stances.

However, most state of­fi­cials and en­vir­on­ment­al groups that have offered pub­lic cri­ti­cism of the guide have ac­tu­ally called for the use of Su­per­fund pro­tocol. Hirsch notes the Su­per­fund meth­od­o­logy does not provide a single, ri­gid cleanup num­ber. Rather, it presents a series of soph­ist­ic­ated cal­cu­la­tion tools that can be ad­jus­ted to ac­com­mod­ate for the ex­pec­ted use of a par­tic­u­lar site, how much time people are likely to spend at a giv­en loc­a­tion and un­der what con­di­tions. It also in­cludes a range — rather than a single tar­get — for can­cer in­cid­ents, with a 1 in 10,000 risk con­sidered the worst case scen­ario and a 1 in 1 mil­lion risk con­sidered the ideal.

The EPA re­sponse to GSN in­sists that “some state and loc­al gov­ern­ment part­ners have in­deed ex­pressed a pref­er­ence for a pre­scribed single cleanup num­ber.” The agency de­clined to identi­fy which state and loc­al of­fi­cials made such re­quests, however, say­ing they were made “dur­ing in­form­al con­ver­sa­tions” and were “not re­cor­ded “¦ of­fi­cial state po­s­i­tions.”

Act­iv­ists con­tend of­fi­cials in the agency’s ra­di­ation and emer­gency-man­age­ment of­fices are look­ing to mar­gin­al­ize the Su­per­fund pro­gram and its sup­port­ers. They ar­gue that doc­u­ments the two of­fices helped de­vel­op mis­rep­res­ent how the cleanup pro­gram works and the types of prob­lems it is meant to ad­dress.

Like the Feb­ru­ary NCRP re­port that he and Ed­wards helped de­vel­op, Cardarelli’s present­a­tions por­tray the Su­per­fund pro­gram as one that deals primar­ily with small, res­id­en­tial cleanups, which he con­trasts with the wide­spread con­tam­in­a­tion fa­cing the area sur­round­ing Fukushi­ma, act­iv­ists say.

Hirsch ar­gues these as­ser­tions omit the fact that the Su­per­fund ap­proach is used for clean­ing not only small res­id­en­tial areas, but also massive nuc­le­ar weapons sites, such as the 586-square-mile Man­hat­tan-pro­ject site at Han­ford, Wash­ing­ton. In con­trast, the gov­ern­ment has said some dirty-bomb at­tacks and oth­er ra­di­olo­gic­al in­cid­ents that the new guide is meant to ad­dress might only af­fect sites span­ning less than a few square miles.

Some EPA of­fi­cials agree

Based on April EPA com­ments on the Feb­ru­ary NCRP re­port that GSN ob­tained un­der a sep­ar­ate FOIA re­quest, it would ap­pear some agency of­fi­cials share act­iv­ists’ con­cerns that the Su­per­fund ap­proach to cleanup is be­ing mis­rep­res­en­ted.

The com­ments, un­like the NCRP doc­u­ment and EPA present­a­tions, were de­veloped with in­put from the agency’s Su­per­fund and drink­ing-wa­ter of­fices. They re­ject the NCRP au­thors’ use of the term “simplist­ic in nature” to de­scribe the Su­per­fund pro­gram’s ap­proach to risk as­sess­ment and urge de­le­tion of the lan­guage.

The EPA com­ments say the lan­guage in the NR­CP re­port, to which Ed­wards and Cardarelli con­trib­uted, should be re­placed with a de­tailed dis­cus­sion of the nu­mer­ous cal­cu­la­tions that Su­per­fund of­fi­cials per­form in or­der to de­term­ine re­medi­ation goals.

Like­wise, in in­tern­al emails from 2011 that GSN also ob­tained un­der a FOIA re­quest, EPA Su­per­fund of­fi­cial Stu­art Walk­er sug­gests to Cardarelli that in­form­a­tion about how the pro­gram se­lects cleanup goals could be help­ful to Ja­pan­ese of­fi­cials grap­pling with the Fukushi­ma con­tam­in­a­tion.

Walk­er also re­com­mends shar­ing guid­ance doc­u­ments the Su­per­fund pro­gram de­veloped on spe­cif­ic top­ics about which Ja­pan­ese of­fi­cials were seek­ing in­form­a­tion. The fo­cus of Ja­pan­ese in­terest, ac­cord­ing to Cardarelli’s e-mails, in­cluded how to talk to the pub­lic about ra­di­ation risk, how to re­duce the volume of ra­dio­act­ive waste and how to tem­por­ar­ily store con­tam­in­ated ma­ter­i­als.

The ma­ter­i­als re­leased un­der FOIA also show that Walk­er, the EPA Su­per­fund of­fi­cial, de­veloped a de­tailed present­a­tion ex­plain­ing how the Su­per­fund meth­od­o­logy could be used spe­cific­ally to clean up after ma­jor ra­di­olo­gic­al events, in­clud­ing dirty-bomb and nuc­le­ar-weapon at­tacks.

Left out of the mix

None of this in­form­a­tion ap­pears on a web­site that Cardarelli, who has led EPA ef­forts to as­sist the Ja­pan­ese, cre­ated as a re­pos­it­ory for in­form­a­tion that could be use­ful to those in­volved with the Fukushi­ma cleanup. It is also largely ab­sent from the new EPA guide for mop­ping up after such events in the United States.

A com­mon theme among pub­lic com­ments the agency has so far re­ceived on the new guide is that the doc­u­ment lacks spe­cif­ic de­tails that would tell re­spon­ders ex­actly what they should do dur­ing and after a crisis. In­stead, re­spond­ents say it provides a largely the­or­et­ic­al over­view that is largely un­help­ful. Even com­menters who sup­port re­lax­a­tion of the agency’s usu­al stand­ards after such an event com­plain that the guide is short on prac­tic­al in­form­a­tion.

The Pennsylvania De­part­ment of En­vir­on­ment­al Pro­tec­tion — which in its com­ments sug­gests a 100-fold re­lax­a­tion of EPA drink­ing-wa­ter stand­ards after a ra­di­olo­gic­al in­cid­ent — says the sec­tion of the doc­u­ment that deals with long term cleanup “is of mod­est value as a gen­er­al ref­er­ence.” The cri­ti­cism is based on the lack of “nu­mer­ic­al cleanup cri­ter­ia or lim­its” and a view that the guide only “sketches the broad is­sues in­volved in cleanup.”

The Ju­ly 10 com­ments were co-au­thored by Pennsylvania ra­di­ation bur­eau dir­ect­or Dav­id Al­lard, who — along with Ed­wards and Cardarelli — con­trib­uted to the Feb­ru­ary NR­CP re­port ad­voc­at­ing for re­laxed cleanup guidelines.

The Pennsylvania com­ments also take aim at the por­tions of the guide that deal with the more im­me­di­ate af­ter­math of a ra­di­olo­gic­al crisis. They com­plain that rather than provide nu­mer­ic­al lim­its on the amount of spe­cif­ic ra­dio­act­ive sub­stances people should be ex­posed to, the EPA guide in­stead dir­ects read­ers to oth­er re­sources main­tained by the En­ergy De­part­ment and the Nuc­le­ar Reg­u­lat­ory Com­mis­sion.

This “will res­ult in un­cer­tainty and am­bi­gu­ity over the best val­ues to use, and cause con­fu­sion and delay in eval­u­at­ing ac­ci­dent/emer­gency con­di­tions,” the Pennsylvania state en­tity says.

The Or­ange County, Cal­if., Sher­iff’s De­part­ment sim­il­arly com­plains the doc­u­ment does not provide tables of nu­mer­ic­al lim­its, “only the al­gorithms to work them out.” It main­tains that such an ap­proach would be par­tic­u­larly prob­lem­at­ic in the event that com­puters fail dur­ing a crisis.

“This makes the [pro­tect­ive ac­tion guide] manu­al much less use­ful as a one-stop doc­u­ment, and will be very dif­fi­cult to use in an emer­gency,” the Ju­ly 3 com­ments say. “This will cause sig­ni­fic­ant delay in cal­cu­la­tions and thereby cre­ate an un­due risk to the health and safety of the pub­lic.”

The Or­ange County com­ments fur­ther com­plain that the EPA guide in­cludes ref­er­ences to En­ergy De­part­ment cal­cu­lat­ors that “are not avail­able from any source.”

Un­like their Pennsylvania coun­ter­parts, the Or­ange County of­fi­cials do not sup­port the re­lax­a­tion of con­ven­tion­al EPA stand­ards, however. Their com­ments say the agency should use its usu­al drink­ing-wa­ter rules fol­low­ing a ra­di­olo­gic­al in­cid­ent.

The Cali­for­nia Gov­ernor’s Of­fice of Emer­gency Ser­vices is tak­ing a sim­il­ar po­s­i­tion. It says leav­ing out nu­mer­ic­al lim­its for spe­cif­ic con­tam­in­ants “and dir­ect­ing the read­er to myri­ad ad­di­tion­al ref­er­ences re­duces the use­ful­ness” of the guide.

“In ad­di­tion, some of the ref­er­enced re­ports are copy­righted ma­ter­i­als and re­quire a fee to ac­cess. In an emer­gency the abil­ity to ob­tain the many ref­er­enced doc­u­ments may be severely lim­ited, caus­ing an un­due risk to the pub­lic,” the Cali­for­nia of­fice states.

As far as cleanup is con­cerned, Cali­for­nia says the Su­per­fund guidelines, un­der which no more than 1 in 10,000 people are to be put at risk for can­cer, should be made the rule for long-term re­cov­ery rather than simply be­ing presen­ted as an op­tion, as the guide cur­rently does. And like its coun­ter­parts in Or­ange County, the gov­ernor’s of­fice also re­com­mends us­ing ex­ist­ing EPA drink­ing-wa­ter rules after a ra­di­olo­gic­al in­cid­ent.

The drink­ing-wa­ter is­sue has been one of the most con­ten­tious as­pects of the new guide since an earli­er draft of the doc­u­ment leaked in 2007. Un­like the Bush-era ver­sion, the April guide does not in­clude dir­ectly in its text drink­ing-wa­ter guidelines thou­sands of times weak­er than stand­ard EPA rules. In­stead it sug­gests that sim­il­ar re­com­mend­a­tions by the In­ter­na­tion­al Atom­ic En­ergy Agency and oth­er groups might be worth con­sid­er­ing.

The Ohio De­part­ment of Pub­lic Safety sup­ports re­laxed drink­ing-wa­ter guidelines, ar­guing “the con­ten­tion that al­tern­ate sources of clean wa­ter can be ob­tained and shipped to an area as­sumes the in­fra­struc­ture around the af­fected area is in­tact.” Its June 24 com­ments say the “Fukushi­ma ac­ci­dent demon­strated that areas af­fected by the ra­di­olo­gic­al emer­gency could suf­fer severe in­fra­struc­ture chal­lenges and that out­side sources of wa­ter and sup­plies may not be avail­able.”

En­vir­on­ment­al­ists have re­jec­ted this ar­gu­ment, in the past not­ing that the 2007 draft of the guide sug­ges­ted re­laxed drink­ing-wa­ter guidelines could re­main in place for months, or even years, after a ra­di­olo­gic­al in­cid­ent.

In Ju­ly 15 com­ments, the Nat­ur­al Re­sources De­fense Coun­cil states, “Giv­en that bottled wa­ter is widely avail­able com­mer­cially through the coun­try, NRDC sees no ne­ces­sity in re­lax­ing the es­tab­lished en­force­able drink­ing-wa­ter stand­ards for ra­di­o­nuc­lides un­der the Safe Drink­ing Wa­ter Act.”

The NRDC com­ments also op­pose de­part­ing from Su­per­fund guidelines dur­ing long-term cleanup. The or­gan­iz­a­tion fur­ther sug­gests that the new doc­u­ment’s ra­di­ation-dose lim­its for the im­me­di­ate af­ter­math of an in­cid­ent be more strin­gent, giv­en that the Na­tion­al Academies of Sci­ence in 2005 de­term­ined that ra­di­ation is more harm­ful than the agency pre­vi­ously as­sumed.

The agency is ac­cept­ing pub­lic com­ments on the new guide through Sept. 16.

Ed­it­or’s Note: This is the first of a two-part series on is­sues re­lated to the new EPA re­sponse guide. Watch for the second part in Thursday’s GSN.

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