Bridge the Gap’s presentation to the EPA Deputy Administrator and other senior EPA officials on efforts to weaken radiation standards and failures in EPA’s radiation monitoring system in the U.S. during Fukushima. Meeting included NRDC, Sierra Club, Friends of the Earth, Physicians for Social Responsibility, and Bridge the Gap, among others.
Under longstanding fundamental Environmental Protection Agency (EPA) principles, cancer risks should not exceed the acceptable risk range of 10-6 to 10-4. In addition, drinking water should not exceed safe drinking water levels (MCLs).
During the Bush Administration, Office of Information and Regulatory Affairs (ORIA) & Office of Emergency Management (OEM) proposed to weaken radiation standards to levels far outside the risk range and far above the MCLs, placing longstanding EPA fundamental principles at risk. Unfortunately, during the Obama Administration, the efforts to weaken those standards did not appear to cease.
As time goes on, science continues to find radiation to be more dangerous than previously assumed. At the same time, a political movement continues to push to relax, rather than strengthen, radiation protection standards in the United States.
According to National Academy of Sciences’ Biological Effects of Ionizing Radiation Studies (BEIR), BEIR V found radiation ~3 to 4 times more dangerous per unit dose than previously assumed. Then the BEIR VII study found that cancer incidence risks are 35% higher than what was found under the BEIR V study.
Despite the best studies indicating an increased risk from radiation, the standards set by the EPA and other agencies has not been strengthened accordingly. Instead, in the case of Protective Action Guides (PAGs), for example, there has been pressure to dramatically weaken standards further.
The Nuclear Regulatory Commission (NRC) and the Department of Energy (DOE), and ORIA use dose to determine radiation risk standards, which makes it hard for decisionmakers to readily judge the appropriateness of proposed radiation standards. This is in contrast to EPA’s guidelines which generally rely on risk, and not dose, for setting standards.
According to EPA’s “Blue Book,” EPA Radiogenic Cancer Risk Models and Projections for the U.S. Population (April 2011), cancer incidence risk is based on the exposure spread of radiation over a person’s lifetime, or exposure to someone of average age. EPA’s current risk factor (as of 2011) is 1.16 x 10-3/Rem. This risk factor matches closely to findings of the BEIR VII report (1.141 x 10-3/Rem).
In other words, any cumulative dose of .1 Rem (100 millirem) of radiation of total accumulated dose, to someone of average age in the U.S. would be the upper edge of EPA’s permissible radiation risk range of 10-4. (See: 87 mrem = 1×10-4 risk per EPA Blue Book. [0.087 rem x 1.16 x 10-3 cancers per rem = 1 x 10-4.).
Based on EPA’s Blue Book data for risk associated with age at exposure, however, the risk is greater for exposures at younger ages.