You can email comments to:
a-and-r-docket@epa.gov
Be sure to mention Docket ID No. EPA-HQ-OAR-2007-0268.
EPA and IAEA
An ANS blog post describes the guidelines: New EPA Guidelines for Response to Radioactivity Releases by Jim Hopf. Among other things, the new guidelines say that a public dose level of 2000 mrem the first year and 500 mrem in subsequent years is the guideline for evacuations. Apparently, this is not much of a change from previous guidelines.
Meanwhile, the IAEA has issued a publication called Actions to Protect the Public in an Emergency due to Severe Conditions at a Light Water Reactors. (Note: that link leads to a long pdf which will take time to download.) The IAEA publication might be considered the international version of the EPA proposed guidelines. It seems more complete in its analysis, and more liberal in its guidelines for health and safety.
Okay. I haven't done the hard work of comparing these two documents, but it seems that both sets of guidelines are well thought out. The EPA document has been broadly attacked, and it is worth supporting it with a brief email. I did.
A little context on the numbers. You can get about 500 mrem a year by living in the granite hills around here, for heaven's sake. According to the NRC, the average American gets 620 mrem per year: half from background and half from medical, air travel, etc. Move uphill on a granite mountain and the background dose will surely go up.
Hargraves Review of the EPA Guidelines
Dr. Robert Hargraves has reviewed the EPA and IAEA documents, and this is the email he wrote to the EPA in support of their new guidelines. Basically, he concludes that the EPA document is over conservative.
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| Dr. Robert Hargraves author THORIUM Energy cheaper than coal |
EPA,
I appreciate the importance of your work to guide emergency response in the event of a radiological emergency. The lack of such guidelines for Fukushima drastically increased the harm to the public from overly aggressive evacuation and relocation. Having rational guidelines in place will strike a balance between radiological harm and relocation harm. You published PAG Manual, http://www.epa.gov/radiation/docs/er/pag-manual-interim-public-comment-4-2-2013.pdf and asked for comments.
The IAEA has just published a similar document, Actions to Protect the Public in an Emergency due to Severe Conditions at a Light Water Reactor, http://www-pub.iaea.org/MTCD/Publications/PDF/EPR-NPP_PPA_web.pdf. I recommend that the EPA draft document be compared to this IAEA document and that the differences be explained, rationalized, or eliminated. It makes little sense for documents from EPA and IAEA to differ. Why should US guidelines be so different from international guidelines?
The differences are enormous. The EPA guideline document is far too conservative. For example, on page 7 of the EPA PAG draft, relocation of the public is recommended if radiation doses will exceed 20 mSv in the first year, or 5 mSv/year thereafter.
"2 rem (20 mSv) projected dose first year
Subsequent years, 0.5 rem (5 mSv)/year
projected dose"
In the IAEA document, page 59, relocation is recommended only for radiation doses exceeding 200 mSv/year (25 microSv/hour).
EPA's guidelines are excessively conservative, by a factor of 10 (200 mSv/20 mSv) in the first year, and a factor of 40 (200 mSv/5 mSv) in the subsequent years. Repeating my observation...
EPA RECOMMENDED DOSE LIMITS ARE TOO LOW BY A FACTOR OF 10 TO 40 !
Over 1000 people died near Fukushima from the stress of unnecessary relocation. The EPA-recommended guidelines will cause similar, unnecessary public harm in a US radiological emergency.
I recommend that the EPA review its draft recommendations and set radiological dose exposure limits based on evidence of observed public harm from ionizing radiation.
I sent a letter as requested. I largely used Dr. Hargrave's letter (I hope he will forgive the plaigerism) but removed a few sentences and added the following. I fear my addition is not as clear as I would ahve liked:
ReplyDelete==============================
In addition to examining the IAEA limits, the EPA should take normal background radiation into account. If exposure to natural background radiation in high background radiation regions does not cause harm in a population, why is an artificial release which does not exceed the natural background in other areas, which have higher natural levels, unacceptable?
E.g., if an artificial release in Florida only raises the radiation level to the natural background level of the Colorado Rockies, why should there be an evacuation? Of course, release of certain isotopes might require special action such as distribution of iodine pills, but if the general radiation level still does not exceed that of regions with high natural background radiation, what possible justification can there be for the danger, expense, risk, and misery of an evacuation?