EPA is the agency responsible for protecting the public from ionizing radiation under the 1970 law that created the agency.
November 19, 2015. NIRS comments on three petitions for rulemaking advocating that the NRC adopt a hormesis finding for radiation exposure--i.e. that radiation exposure can be good for you. The hormesis concept has been thoroughly discredited over the years and is not accepted by any international regulatory authority. NIRS (and many others) urge speedy and complete denial of these petitions.
Comments of the Institute for Energy and Environmental Research on the hormesis petitions.
Comments of Radioactive Waste Management Associates on the hormesis petitions.
EPA Moves to Relax US Radiation
January 27, 2016. NIRS and several national and regional organizations and state government representatives met with the Office of Management and Budget to request their rejection of EPA’s proposal to adopt Protective Action Guidelines (PAGs) for Water which would increase allowable radioactivity in water tens, hundreds, or more times the Safe Drinking Water.
December 2015, EPA submitted to the US Office of Management and Budget (OMB) proposed Protection Action Guidance(PAGs) on radioactivity in water after a nuclear incident, not just big dirty bomb attacks or Fukushima/Chernobyl type accidents, but even smaller events like radiopharmaceutical transport spills. NIRS and organizations across the country oppose weakening the water protections—specifically in the phase after the immediate response—that is for the intermediate cleanup phase that could last years—EPA’s proposal had been to increase allowable radioactivity in water tens, hundreds or more times the Safe Drinking Water levels (Maximum Concentration Levels MCLs). Groups requested a meeting with OMB.
August 4, 2014. 70+ organizations tell EPA to make radiation standards comparable to standards for other pollutants (radiation standards currently are far less protective); slam EPA proposal to weaken them even further. Press release. Letter to EPA.
September 16, 2013. 100+ organizations call on EPA to withdraw its dramatically weakened radiation standards.
April 15, 2013. Comments from more than 100 organizations to National Council on Radiation Protection and Measurements (NCRP) “opposing their immoral report” which would greatly increase allowable radiation exposure standards in the aftermath of a nuclear accident or attack.
April 15, 2013. NIRS comments to NCRP emphasizing the increased risk radiation poses to females and the essential role female health has for the population.
April 15, 2013. NIRS, Committee to Bridge the Gap, California Federation of Scientists and Los Angeles Physicians for Social Responsibility provided more detailed comments to NCRP criticizing the conflicts of interest by the NCRP report authors and unjustified shifting of focus of the report from cleanup after a radioactive terrorist attack to allowing extremely high levels of radiation in more common radioactive release scenarios. Charts are provided showing allowable increases in radioactive contamination up to MILLIONS of times higher than currently permitted.
April 15, 2013. EPA dramatically weakening radiation protection. News release from NIRS & Committee to Bridge the Gap.
April 15, 2013: EPA has just issued new Protective Action Guides (PAGs) for dealing with radioactive releases. The new PAGs are much worse than the extremely weak PAGs Bush tried to push out in the last days of that Administration which Obama pulled back. Although EPA is taking comments on these PAGs for 90 days, they are effective immediately.
Additionally, the National Council on Radiation Protection and Measurements (NCRP) has published draft guidance for implementing the long-term cleanup portions of the PAGS. The NCRP guidance would allow the public to be exposed to extraordinarily higher levels of radiation than previously permitted.
Some of the major concerns with the new PAGs and the NCRP guidance are here.
Groups are commenting on NCRP’s report in short and long comments. The draft short version is here, with signatories to be added by the deadline.
April 2013: Proposals are pending to dramatically weaken radiation protection standards for the public from nuclear power accidents, "dirty bombs," and all other radiological releases that will increase the allowable radioactive contamination of our air, water, environment and communities. In 2010 The Department of Homeland Security hired the National Council on Radiological Protection and Measurements (NCRP), a strenuously pronuclear organization, to do a report on an Approach to Optimizing Decision Making for Late-Phase Recovery from Nuclear or Radiological Terrorism Incidents. In February 2012 the report Decision Making for Late-Phase Recovery from Nuclear or Radiological Incidents was released for public comment. The scope has expanded beyond dirty bomb cleanup to markedly raise allowable radiation exposures from other sources. The report essentially pushes for increasing allowable risks to the public from radiation to much higher than the longstanding EPA risk range from carcinogens of 1 in a million to 1 in 10,000. Indeed, NCRP recommends permitting exposures as high as 2 rem (2000 millirems) per year, the equivalent of about 1000 chest Xrays every year of one's life, which EPA estimates would produce an excess cancer in roughly every fifth person exposed. Comments Due April 15, 2013 to email@example.com.
Two years after major national organizations met with top EPA officials about our opposition to weakening radiation protection (November 2009), little has changed. EPA still intends to weaken its Protective Action Guidelines (setting incredibly high allowable public exposures for the public in case of dirty bomb or nuclear power disaster), has not committed to stopping the release of nuclear waste into unregulated places (like landfills and recycled consumer good and incinerators) and in the wake of Fukushima, has done regrettably inadequate monitoring and reporting of contamination in food, water, air, milk, vegetation, across the country to the point of preventing monitoring that was ready to implement. Letters to EPA’s top administrators in 2009 and 2011 from numerous national and regional groups and experts resulted in meetings with them but no action to prevent weakening of radiation protection on several fronts. In fact that weakening in now underway.
Also read information presented at the Oct 31, 2011 meeting that followed.
In 2009, a dozen organizations met with the Obama-appointed assistant administrators of the EPA to ask them to review and stop that agency's Bush-era efforts to weaken radiation protection. The concerns included:
- EPA’s Office of Radiation and Indoor Air is pushing to astronomically weaken Protective Action Guides PAGs that would increase the drinking water MCLs (Max Contamination Levels) orders of magnitude higher. (This has been one of the most protective fed radiation standards, so it is a very serious threat.)
- EPA’s ORIA is pushing to lower Federal Radiation Guidance to Outside EPA’s Long-Held Acceptable Risk Range (of one in a million to one in 10,000 cancer risk) this could weaken CERCLA cleanup standards.
- EPA’s ORIA is currently far along in the process of weakening radiation risk estimates compared to BEIR VII risk estimates.
- EPA’s ORIA is pushing to allow Radioactive Waste in Landfills neither licensed nor designed for it.
October 1, 2008: New EPA rule on Yucca Mountain would produce 1 cancer per 125 people exposed. Press release from Committee to Bridge the Gap.
April 20, 2007: Take Action Chernobyl Day on IAEA/WHO: Requesting
solidarity actions in US and around the world, Requesting
all to sign petitions, Lasting presence
in front of the WHO
Demand radiation standards that follow
the precautionary principle. NIRS Alert. February 21, 2007
2006: The EPA Office of Radiation and Indoor Air is requesting and
getting support from its Radiation Advisory Committee (of Scientific Advisory
Board RAC SAB) to change EPA’s existing (albeit old) risk estimates
but instead of making them more protective, as would be expected after
the NAS BEIR VII committee revealed that radiation is 30% more risky than
previously known, some of the risk estimates are being weakened. NIRS, Public Citizen and Committee
to Bridge the Gap determined that in 27 of 28 comparisons between
the NAS BEIR VII findings and the EPA recommendations, the EPA proposals
were more lax (i.e. would result in more risk to the public). Bridge
the Gap, Nuclear Information and Resource Service, and Public Citizen
made a statement at the first public meeting of the EPA (RAC SAB ) to consider the White
Paper proposed by EPA’s Office of Radiation and Indoor Air (ORIA).
on Radiological Protection
The International Commission on Radiological Protection (ICRP) is a self-appointed,
pronuclear advocacy organization that makes recommendations on radiation
standards that are often adopted by countries into enforceable regulations.
NIRS has done a 3 part series on the recommendations and encourages the
public to comment. The articles from the Nuclear Monitor are here:
U.S. Perspective on Weakening of International Radiation Standards in
Draft ICRP-2005. Article 1
in a Series by NIRS on Radiation Standards. Article
in a Series by NIRS on Radiation Standards. Article
in a Series by NIRS on Radiation Standards.
The International Commission on Radiological Protection (ICRP)’s
proposed 2006 recommendations are being finalized and public comments
taken on the www.icrp.org website until 15 Sept 2006 but late
comments may be accepted since there is still a public meeting to be held
OCT 24-5 in Bucharest for European input on the recommendations. The recommendations
are available on the website, too and have several important weaknesses
that the public can address including failure to incorporate of the Precautionary
Principle; exempting radioactive waste, materials, practices and sources
from regulatory control; ignoring greater damage from low-dose radiation
exposures in assessing ‘acceptable’ risks and doses; suggesting
setting acceptable contamination levels for animals, plants and ecosystems;
recommending against estimating the numbers of cancers caused by radiation
exposures to large populations and to people far into the future; failing
to protect the most vulnerable in the population by ignoring some and
averaging the risk estimates over women and men and age groups; continuing
to ignore non-cancer health effects and (relatively) new biology such
as the bystander effect and genomic instability in estimating risks.
Comments of Nuclear Information and Resource Service (NIRS) on International Commission on Radiological Protection (ICRP)’s proposed 2006 recommendations
DRAFT RECOMMENDATIONS OF THE INTERNATIONAL COMMISSION ON RADIOLOGICAL PROTECTION
02/276/06- 5 JUNE 2006
These are some of NIRS written comments that supplemented verbal presentations and participation at the North American meeting 28-29 August 2006 of the Organization for Economic Cooperation and Development Nuclear Energy Agency to gather input on the ICRP 2006 recommendations.
The document and comments can be also viewed, and additional comments submitted
on the ICRP website at www.icrp.org.
1998 Comments (still relevant today) by Mary Olson on current radiation
standards and why they are not conservative / protective enough.
Department of Homeland Security Proposes
Letting Public be Exposed to Massive Radiation Doses from “Dirty
The Department of Homeland Security (DHS) has issued guidance for responding
to a terrorist detonation of a radiological weapon, a so-called “dirty
bomb.” In that guidance, DHS proposes permitting the public back
into a contaminated area even if radiation doses are as high as 10,000
millirem per year. Over 30 years of exposure, that is the equivalent of
50,000 chest X-rays. The government’s own official risk estimates
say such exposure would cause cancer in a quarter of the people exposed.
Write DHS to oppose long-term cleanup standards for dirty bombs with
radiation levels higher than what EPA permits for the most contaminated
Superfund sites in the country.
Email FEMA-RULES@dhs.gov; fax
202-646-4536; mail to Rules Docket Clerk, Office of general Counsel, Federal
Emergency Management Agency, Room 840, 500 C Street, SW., Washington DC
20472; or comment via http://www.regulations.gov.
Identify your comments with Docket Number DHS-2004-0029 and Z-RIN 1660-ZA02.
For more information, see April
2006 Group Letter,
Bridge the Gap/Nuclear Information
& Resource Service news release,
Federal Register notice,
December 2004 Goup Letter to
DHS and EPA
US Department of Homeland Security Dirty
Bomb Cleanup Guidance published Jan 3, 2006 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.
NIRS Press Release. January 4, 2006.
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
Letter to DHS
Director Ridge | Letter
to EPA Administrator Leavitt
Multigroup letter to Department of Homeland Security
Secretary Ridge regarding dangerously lax proposed “dirty bomb”
Multigroup letter to EPA Administrator Mike
Leavitt regarding proposed “dirty bomb” cleanup standards
and EPA radiation standards.
Tables comparing proposed dirty bomb cleanup standards
to EPA standards.
Summary of US Environmental Protection
Radiation Affects Animals, Plants
and the Environment as well as Humans
Overview of Radiation and Animals.
NIRS is concerned about national and international efforts to legalize
or justify radiation exposure to animals and the environment. The Department
of Energy has a “biota” project underway to assess and allow
leaving radioactivity that contaminates the environment on which animals
and plants rely. The International Atomic Energy Agency is also moving
in this direction, as are some other nation’s nuclear regulators.
In the same way assumptions about radiation impacts on the “standard
man” have been misused to justify radiation to people, now a “standard”
fish or mammal is being suggested to represent and justify exposures to
all species. Read more here.