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C. Post-Chernobyl Levels of Concern: 1986 

After the Chernobyl accident in 1986, the FDA issued an update in the Federal Register (1986, Vol. 51, No. 122, pg. 23155) establishing the guidelines to be used for monitoring radionuclides in imported foods. While the notice in the Federal Register did not contain a specific action level, ad hoc press releases and other public relations materials issued shortly thereafter indicated that 10,000 pCi/kg of 134,137Cs would be the level of contamination that would result in the seizure and disposal of foodstuffs. As a result:


The FDA also issued these guidelines on May 16, 1986, as "levels of concern" for contamination which resulted from the Chernobyl accident: During the months following Chernobyl, the FDA admitted publicly to seizing and disposing of a small quantity of imported foods but failed to disclose that a delayed impulse of Chernobyl derived radiocesium had been observed in imported foods and had resulted in not only a secret report about contamination levels in imported foods but also the furtive and unpublicized seizure and disposal of much larger quantities of imported foods in 1987 and 1988. The full extent of actual contamination levels of the imported foods basket resulting from the Chernobyl accident is still unknown. Please refer to the summary of the secret FDA report at the end of RADNET, Section 9, Dietary Intake, as well as RADNET's review of the FDA's first public announcement of this contamination in 1994, also in Section 9 (Cunningham, 1994).

The action guideline of 10,000 pCi of radiocesium per kg after the Chernobyl accident in 1986 emphasizes the lack of credibility of the preventive or emergency guidelines issued in 1982 for domestic nuclear accidents (Federal Register, 1982. Vol. 7, No. 205, pg. 47073-47084). The 10,000 pCi "level of concern" is more compatible with and representative of the early FRC protective action guidelines issued in 1961 and represents that level of contamination which should be the response guideline for laypersons attempting to evaluate the impact of any nuclear incident.

Other Federal Guidelines:

The above cited FDA "levels of concern" issued after the Chernobyl accident sharply contrast with the revised 1982 preventive and emergency protection action guidelines issued as a component of the formation of the radiological emergency response plans and reviewed in the two citations cited above. These conflicting guidelines suggest a double standard for accident response levels, whereby the licensees of the Nuclear Regulatory Agency become the likely beneficiaries of these discrepancies. In fact, nowhere in the Maine FEMA Radiological Emergency Response Plans is there any reference to the FDA "levels of concern" which were issued and acted upon after the Chernobyl accident. There is no indication in the FEMA publication that contamination levels below 2,100,000 pCi/kg of 134,137Cs in foods consumed by the general public are of any significant interest to the authorized emergency personnel supervising the management of a nuclear accident at the Maine Yankee Atomic Power Company or at any other location.
D. Official Protection Action Guidelines for Authorized Persons: A Radiological Paradigm

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