This EPA petition, in full below the fold, may be the most important EPA petition of the decade. It is based on the report entitled "
Bad to the Bone: Analysis of the Federal Maximum Contaminant Levels for Plutonium-239 and Other Alpha-Emitting Transuranic Radionuclides in Drinking Water," by Arjun Makhijani of the Institute for Energy and Environmental Research.
Please TAKE ACTION by signing on to the letter.
August 1, 2005
Cynthia Dougherty
Director, Office of Groundwater and Drinking Water
U.S. Environmental Protection Agency
Ariel Rios Building
Mail Code 4601M
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Dear Ms. Dougherty,
As you go into your 2006 review of standards for radionuclides
in drinking water, we urge you to carefully examine the report entitled
Bad
to the Bone: Analysis of the Federal Maximum Contaminant Levels for
Plutonium-239 and Other Alpha-Emitting Transuranic Radionuclides in
Drinking Water prepared by the Institute for Energy and
Environmental Research. The careful scientific analysis in this report
shows that the present Maximum Contaminant Limit of 15 picocuries per
liter for gross alpha contamination, which includes plutonium-239 and
other alpha-emitting, long-lived transuranic radionuclides, no longer
fulfills the letter and intent of the drinking water regulations in
terms of protection of public health.
The changed scientific understanding in regards to the dangers of
plutonium and related radionuclides in the three decades since the
drinking water regulations were first promulgated shows that a much
tighter MCL should be set for alpha-emitting, long-lived transuranic
radionuclides. The MCL should be 0.15 picocuries per liter. The limit
today is a hundred times greater - 15 picocuries per liter in the
absence of any other alpha-emitting radionuclides in the water.
The EPA did not revise the MCL during its last review of
radioactivity in drinking water in the year 2000, despite the fact that
the EPA itself has published dose conversion factors and other
information that indicated that the MCL for alpha-emitting, long-lived
transuranic radionuclides was outdated and no longer fulfilled the
intent of the regulation as it was promulgated in 1976.
We, the undersigned, endorse the recommendations of the IEER
report on the MCLs for alpha-emitting, long-lived transuranic
radionuclides in drinking water. Specifically, we are asking you to
adopt its central recommendation that the combined MCL for
alpha-emitting, long-lived transuranic radionuclides be set at 0.15
picocuries per liter. The regulation should also reflect the
corresponding IEER recommendation for a lower detection limit. Please
contact Dr. Arjun Makhijani, the author of the report and president of
IEER, at 301-270-5500 or arjun[at]ieer.org if you have any questions
about this letter or the report.
Thanking you in anticipation,
Arjun Makhijani, Ph.D.
Institute for Energy and Environmental Research
Takoma Park, Maryland