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Science & Policy Update July 2014: Nuclear Threats

Radiation Should Not be a Privileged Pollutant
By: Denise Duffield, Associate Director

Organizational Letter submitted to the EPA August 1st, 2014

Organizational Letter submitted to the EPA August 1st, 2014

The EPA is soliciting public comment about whether to update the current nuclear power radiation protection standards. The current standards (titled “Environmental Radiation Protection Standards for Nuclear Power Operations, also known as 40 CFR 190) were established in 1977 to set legal levels for the acceptable amount of radiation released from nuclear facilities. Under the existing standards, radiation is treated as a “privileged pollutant,” and is held to weaker regulation than other pollutants and carcinogens. PSR-LA has joined allies Committee to Bridge the Gap, Nuclear Information Resource Service, and more than 60 other groups to demand that radiation pollution standards be raised to the protective standards of other pollutants.

Radioactivity is routinely released in nuclear power plant operations, and unintended leaks can and do occur, especially as a plant ages. An Associated Press investigation found that 75% of nuclear power plants experience leaks of radioactive tritium. At 37 of those sites, the tritium leaked exceeded the federal drinking water standards, with some hundreds of times over the limit.

Key issues in the potential changes to 40 CFR 190 include whether the EPA should regulate by “dose” or “risk” limits, change the definition of the dose units, include long term spent fuel storage, and support more reactors and reprocessing. According to the EPA’s Advanced Notice of Proposed Rulemaking, the proposed changes could weaken the current regulations, allowing increased exposure to many radionuclides.

Health advocates challenge radiation’s current standing as a privileged pollutant. For example, the EPA sets “acceptable risk” standards for non-radioactive pollutants at anywhere from a 1 in 10,000 to a 1 in 1,000,000 range, which means that one person in 10,000, or 1,000,000, can be expected to contract cancer from exposure to that amount. But for radiation, the EPA sets exposure limits by dose. It considers 25 millirems per year to be acceptable, even though this equals a 1 in 500 risk, which is 20 to 2,000 times higher than the EPA’s own acceptable risk range for other pollutants. For women and children, who are more vulnerable to radiation, the risk is even greater.

In 2006, the National Academy of Sciences affirmed that there is no safe level of radiation exposure, and that all doses increase cancer risk to some degree. The Academy further found radiation risks to be greater than previously thought, with current estimates several times higher than the official risk estimates in place when the EPA regulations were first established. However, rather than tightening the regulations accordingly, the EPA is proposing to further weaken them.

PSR-LA and other advocates urge the EPA to use greater protective standards that would protect the public from carcinogens, regardless of whether that carcinogen is a hazardous chemical or radionuclide. Radiation standards should account for age and gender, as is generally done for other carcinogens. In addition, as with other carcinogens, radiation risk should be based on cancer incidences – not mortality. Exposures should be limited with a goal of a one in a million lifetime risk, and should not exceed one in ten thousand.

And, perhaps most importantly, the EPA should enforce its standards, which to date it has failed to do. Real-time monitoring of all radiation releases, from all nuclear facilities, should be required.

Public comments are due to EPA by August 3rd. Click here to submit a comment.

You can view the organizational letter here.

For more information contact Denise Duffield at