Letter on Dirty Bomb Cleanup Standards to DHS Director Ridge
Honorable Tom Ridge
US Department of Homeland Security
Washington DC 20528
January 27, 2005
Dear Secretary Ridge:
We call on you to reject draft guidance for cleaning up "dirty bombs" that would allow cancer risk levels as high as 1 in 4 people. Such risks are completely unacceptable regardless of the cause of the contamination.
We live in communities impacted by hazardous, and in some cases, radioactive materials. Some of us are already living at or beyond the Environmental Protection Agency’s “acceptable” cancer risk levels of 1 in a million to 1 in 10,000 at Superfund sites. It is unacceptable for DHS to even consider permitting radioactive dirty bomb contamination at levels higher than EPA’s current cancer risk range.
The most recent DHS draft that has been made public indicates that DHS should rely on international and national recommendations to set permissible contamination levels, but ignores EPA’s recommendation that cleanups be required to be at least as protective as Superfund sites.
We are especially concerned that such guidance will be used to weaken existing EPA cleanup standards. There is continual pressure to allow more contamination at “cleaned up” sites and we foresee and oppose the use of the DHS dirty bomb cleanup levels to justify less protection at both radioactive and hazardous sites in this country.
We add our voices to the many other concerned organizations that contacted EPA and DHS in December 2004 on this matter expressing concern “that such lax cleanup standards, with associated high radiation and cancer risk levels, would even be considered. We urge you to assure that no cleanup guidance is adopted that—implicitly or explicitly—would permit radiation doses to the public of the magnitudes considered in earlier drafts.”
Attached are a summary of EPA’s radiation protection standards and charts comparing the risks proposed by EPA versus those envisioned in the DHS rough draft and interim final draft guidance on dirty bomb cleanups as well as the letters of concern sent to EPA and DHS in December 2004. Please do not publish draft dirty bomb cleanup guidance that results in less security and safety for the American public.
Sincerely,
National Organizations
Lois Gibbs
Center for Health, Environment & Justice
Falls Church, Virginia
Elizabeth Crowe
Chemical Weapons Working Group
Berea, Kentucky
Richard Miller and Tom Carpenter
Government Accountability Project
Washington DC
Seattle, Washington
Alice Slater
Global Resource Action Center
New York, New York
Jane Browning
Learning Disabilities Association of America
Pittsburgh, Pennsylvania
Tara Thornton
Military Toxics Project
Lewiston, Maine
Carah Ong
Nuclear Age Peace Foundation
Santa Barbara, California
Diane D’Arrigo
Nuclear Information & Resource Service
Washington, DC
Becky Luening
Women's International League for Peace & Freedom
Humbolt, California
Aimee Boulanger
Women’s Voices for the Earth
Bozeman, Montana
State and Regional Organizations
Rochelle Becker
Alliance for Nuclear Accountability
San Luis Obispo, California
Janet Marsh Zeller
Blue Ridge Environmental Defense League
Glendale Springs, North Carolina
Teresa Mills
Buckeye Environmental Network
Grove City, Ohio
Jon Rainwater
California Peace Action
San Francisco, California
Katie Silberman
Center for Environmental Health
San Francisco, California
Peggy Maze Johnson
Citizen Alert
Reno, Nevada
Deb Katz
Citizen Awareness Network
Shelburne Falls, Massachusetts
Coila Ash
Creative Commotion: Voices for Social Change
Santa Fe, New Mexico
Cynthia Babich
Del Amo Action Committee
San Pedro, California
Mitzi Bowman
Don’t Waste Connecticut
New Haven, Connecticut
Tracey Easthope, MPH
Ecology Center
Ann Arbor, Michigan
Jan Conley
Environmental Association for Great Lakes Education
Minneapolis, Minnesota
Judith Johnsrud, PhD
Environmental Coalition on Nuclear Power
State College, Pennsylvania
Albert Huang, Esq.
Environmental Health Coalition
National City, California
Mike Belliveau
Environmental Health Strategy Center
Bangor, Maine
Daniel Parshley
Glynn Environmental Coalition
Brunswick, Georgia
Gretel Munroe
Grassroots for Peace
Concord, Massachusetts
Max Obuszewski
Hiroshima-Nagasaki Commemoration Committee
Baltimore, Maryland
Helen F. Norris
Holyoke City Councilor
Holyoke, Massachusetts
Jan Conley
Lake Superior Greens
Minneapolis, Minnesota
Kathyrn Moyes
Lawrence Environmental Action Group, Inc.
Lawrence, Massachusetts
Cynthia Valencic
Legal Environmental Assistance Foundation
Tallahassee, Florida
Kathyrn Moyes
Merrimack Valley Environmental Coalition
North Andover, Massachusetts
Lana Pollack
Michigan Environmental Council
Lansing, Michigan
Phyllis Glazer
Mothers Organized to Stop Environmental Sins
Dallas, Texas
Joel Shufro
New York Committee for Occupational Safety & Health
New York, New York
Jason Babbie
New York Public Interest Research Group
New York, New York
Jim Warren
North Carolina Waste Awareness & Reduction Network
Durham, North Carolina
David Monk
Oregon Toxics Alliance
Eugene, Oregon
Jane Harris
Oregon Center for Environmental Health
Portland, Oregon
Mavis Belisle
Peace Farm
Panhandle, Texas
Matt Scholtes
Peace Action Wisconsin
Milwaukee, Wisconsin
E.M.T. O’Nan
Protect All Children’s Environment
Marion, North Carolina
Brian Imus
Public Interest Research Group in Michigan
Ann Arbor, Michigan
Erin Hamby
Rocky Mountain Peace & Justice Center
Boulder, Colorado
Lynda Marin
Santa Cruz Weapons Inspection Team
Santa Cruz, California
Maureen Mulligan
Small Business Owner
Harrisburg, Pennsylvania
Jeremy Maxand
Snake River Alliance
Jerome, Idaho
Doug Bullock
Solidarity Committee of the Capital District
Albany, New York
Inese Holte
TOXIC
Duluth, Minnesota
Matthew Wilson
Toxics Action Center
Boston, Massachusetts
Iris Salinas
La Raza Unida
Mission, Texas
Greg Wingard
Waste Action Project
Seattle, Washington
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