Department of Homeland Security Proposes Allowing Public Exposure to Massive Radiation Doses From "Dirty Bombs"
The Department of Homeland Security (DHS) has issued guidance for responding to a terrorist detonation of a radiological weapon, a so-called "dirty bomb."
DHS Preparedness directorate: Protective Action Guide for Radiological Dispersal Devise (RDD) and Improvised Nuclear Device (IND) Incidents;
Notice of draft guidance for interim use and request for comment.
71 FR 1, 174-196, January 3, 2006
In the guidance, DHS proposes
* allowing the public to be exposed to unacceptably high amounts of radioactive contamination after the cleanup is complete,
* setting a dangerous precedent for weakening existing cleanup standards
* setting a dangerous precedent for legalizing release of radioactive materials and wastes into commerce, the marketplace, our homes and communities, as has been repeatedly rejected by the American public
* minimizing existing potential dangers from nuclear power and fuel chain facilities and transportation.
* allowing use of radioactively contaminated water and food unnecessarily
COMMENT by APRIL 14th, 2006
It is necessary to identify your comments with
Docket Number DHS-2004-0029 and Z-RIN 1660-ZA02.
Email: FEMA-RULES@dhs.gov;
Mail: Rules Docket Clerk, Office of General Counsel, Federal Emergency Management Agency, Room 840, 500 C Street, SW., Washington, DC 20472; Fax: 202-646-4536; or
Comment via http://www.regulations.gov.
SIGN GROUP COMMENTS by APRIL 12, 2006
by contacting Cindy Folkers cindyf@nirs.org
Write DHS to
* oppose long-term(late phase) cleanup guidance for dirty bombs with radiation levels higher than what the US Environmental Protection Agency (EPA) permits for the most contaminated Superfund sites in the country. ie: oppose weakening existing cleanup standards,
* support strengthening existing cleanup, emergency preparation and transportation regulations,
* support isolation, not release, of contaminated materials
* support strict protections against use of radioactive food and water.
Background:
The DHS guidance identifies 3 phases in the response to Radiological Dispersal Devices (RDDs)which spread radioactivity via a conventional explosives and Improvised Nuclear Devices (INDs)—home made nuclear bombs. The guidance addresses planning for Immediate, Intermediate and Late Phases of response and recovery. We focus mainly on Late Phase as there is time to fully cleanup and assess before exposing the population in that phase.
* DHS Federal Emergency Management Agency (and its successor) would permit the public to move back into a contaminated area even if radiation doses would cause cancer in 1/4 to 1/3 of the people exposed according to the government's own official risk estimates. The guidance references recommendations as high as 10,000 millirem per year in supposedly cleaned areas. Over 30 years of exposure, that is the equivalent of 50,000 chest X-rays.
Dozens of organizations and individuals brought this major concern with the late phase guidance to DHS' and EPA's attention well before publication of this guidance, but we have been completely ignored by DHS for all practical purposes. Department of Homeland Security recommends reliance on documents that support levels up to 10,000 millirems per year for final cleanup. (p. 183)
* Even the lower levels discussed explicitly in the guidance, 2 rems per year and 500 millirems per year are too high for permanent unrestricted public exposures. The recommendations should be strong now for a better chance of protective cleanup if the unthinkable happens. The risks are too high.
* The guidance legitimizes dangerously high contamination levels that could be used as a precedent to weaken existing nuclear and hazardous cleanup and contamination standards (despite DHS claiming this is not their intent). (endnote 1)
* The guidance sets a dangerous precedent for legalizing release of radioactive materials and wastes into commerce, the marketplace, our homes and communities. It legitimizes and sets clearance levels for radioactive waste and materials to be released into commerce, the marketplace, our homes and communities—as has been repeatedly rejected by the American public. (Appendix 4 f, p.193)
* The Guidance minimizes existing potential dangers from nuclear power and fuel chain facilities and transportation.
The guidance makes numerous indefensible claims about the emergency preparedness at nuclear reactors, other "fixed" nuclear facilities and about the level of preparedness that exists along nuclear transport routes. These highly overstated claims give false assurance and should be challenged.
The Guidance sets up suggested task forces and committees to make the decisions on the final cleanup encouraging affected stakeholders to be included. But all affected stakeholders were not included in development of the guidance and in fact those that commented early on were ignored.
If such a situation occurs, there will inevitably be enormous economic and social pressure to ignore invisible but real radiation dangers. The advance guidance should set the stage for comprehensive cleanups at least as stringent as existing Superfund levels and stricter. Those risks, in the range of 1 in a million to 1 in 10,000 exposed people getting cancer are bad enough and understated considering likely synergism with other chemicals. Compared to the DHS guidance that would allow 1 in 3 to 1 in 4 to get cancer, DHS has a long way to go to protecting the public.
For more information:
http://www.committeetobridgethegap.org/urgentaction/urgentaction3.html
or http://www.nirs.org/radiation/radstds/radstdshome.htm
These sites link to:
NIRS/CBG Press Release. January 4, 2006
US Department of Homeland Security Dirty Bomb Cleanup Guidance published Jan 3, 2006 which would allow radiation levels that will cause cancer in 1 in every 3 to 4 people exposed for 30 years, using National Academy of Sciences BEIR VII or EPA risk estimates.
January 27-28, 2005: Two letters were submitted to Dept of Homeland Security (DHS) Director Ridge and Environmental Protection Agency (EPA) Administrator Leavitt from 54 national, state and regional organizations representing thousands of people working to clean up toxic and radioactive waste pollution. They oppose the expected DHS guidance for dirty bomb \"cleanup\" levels that would permit contamination that would cause cancer in a quarter of the population exposed (over 30 years after the attack). The groups note in their letter that, \"The guidance, which is expected to be published for comment shortly, is absolutely unacceptable as it would permit dangerously contaminated sites and serve as a precedent for weakening the EPA\'s existing cleanup standards, especially at Superfund sites.\"
Letter to DHS Director Ridge | Letter to EPA Administrator Leavitt
With supporting tables and summary of EPA standards.
Endnote 1 For some rough perspective, Environmental Protection Agency water levels are limited in the range of 4 millrems per year; the Nuclear Regulatory Commission permits only restricted release of property that gives doses of 500 millirems a year. Operating nuclear reactors, waste dumps and other fuel chain facilities are limited to 25 millirems per year. This guidance could allow regular neighborhoods to expose people to hundreds of times the amount from operating nuclear facilities. The risks are in the range of 1 in 3 or 4 exposed for 30 years getting cancer from the contamination. EPA's Superfund risk range is more protective, striving to limit the cancer incidence to 1 in a million or 1 in 10,000 exposed. People around Superfund sites would like even greater protection, yet FEMA and DHS are moving drastically in the other direction of causing enormous amounts of cancer in the populations so exposed. Call on DHS to reject weaker protections.
THANK YOU!!
More info: cbghirsch@aol.com
To sign group comments: cindyf@nirs.org
-30-
< Return to Previous Page
|
