Radiation Protection Guidelines

| Previous Part of This Section | Top of This Section | Next Section |

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 U.S. FOOD AND DRUG ADMINISTRATION ACTION LEVEL FOR RADIOACTIVE CONTAMINATION IN FOODSTUFFS AFTER THE CHERNOBYL ACCIDENT WAS 10,000 PICOCURIES (370 Bq) OF ^134,137Cs PER KILOGRAM.

This is the equivalent of seizing food with the contamination level of 22,000 cpm/kg, a far cry from the millions to hundreds of millions of counts per minute (cpm) tolerated in the guidelines just reviewed.

The FDA also issued these guidelines on May 16, 1986, as "levels of concern" for contamination which resulted from the Chernobyl accident:

iodine-131: 8,000 pCi/kg for general use foods
iodine-131: 1,500 pCi/kg for infant foods

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 federal standard for iodine-131 in drinking water is 300 pCi/l.
The federal standard for iodine-131 in air is 100 pCi/m³
RADNET has yet to locate and review the correct original reference for these two 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

The Federal Emergency Management Agency (FEMA), which sponsors local emergency planning for all U.S. commercial nuclear power installations, uses a standard of 300 counts per minute above background for a contamination (surface) guideline for authorized persons entering an emergency operations center (EOC) in the advent of a nuclear accident in the U.S. Emergency personnel registering in excess of 300 counts per minute above background upon entering an EOC facility, in this case either in Augusta, ME, or the Maine Yankee Atomic Power Company headquarters in Brunswick, ME, are considered contaminated and must undergo appropriate contamination procedures, including clothing placed in waste storage, use of sink and shower, follow-up registration, dose recording and use of a separate exit. (For a full annotation of Maine's RERP click on Maine Yankee: State of Maine, Radiological Emergency Response Plan, Sect. 7, pg. D-32.)
A response level of 300 cpm above background for surface contamination upon authorized persons provides a startling comparison with the monitoring of unauthorized persons (students) returning from Russia after the Chernobyl accident, when the NRPB (National Radiation Protection Board, England) had an "acceptance level" of 30 Bq/cm² for clearing contaminated clothing on returning students. 30 Bq/cm² = 300,000 Bq/m² = a rate of 18,000,000 counts per minute for one square meter of contaminated clothing.
Another comparison is with the intervention level in use for residents living in Goiania, Brazil, near the location of the accidental release of radiocesium from surplus medical equipment. This intervention level was 450,000 Bq/m² (27,000,000 cpm), a radically different response level for persons with a radically different social status than the authorized persons in an EOC.
The FDA/FEMA emergency PAG for ground deposition of radiocesium ^134,137Cs is 90 µCi/m² ( = 90,000,000 pCi/m² = 3,333,333 Bq/m² = 200,000,000 cpm/m²), one order of magnitude higher than the post Chernobyl response level for contamination per square meter for clothing of students returning to England.
Perhaps the most bizarre comparison of all is with the FDA emergency protection action guidelines reviewed above which indicate the action level for isolating contaminated food for infants occurs when the total accident intake of ^134,137Cs reaches 110 µCi (= 110,000,000 pCi/accident = 4,074,133 Bq/accident = 244,447,980 counts per minute/accident). Total accident intake can be spread over as many as 30 days allowing a daily intake of radiocesium up to 8,146,930 pCi before contaminated food is destroyed. This compares with the earlier protection action guideline in the old NCRP standards (FRC, 1961) of 14,500 pCi/day (537 Bq = 32,220 cpm/day) as the beginning of range III, which is that intake level requiring protective actions similar to those described in the FDA / FEMA publications reviewed above.
The editor of RADNET suggests a reversal of these protection action guidelines, with authorized persons in emergency operation centers (EOCs) continuing to wash, brush and peel their potatoes and their turnips at 8 million pCi/day for 30 days (below the emergency action guideline for isolating food), while 300 cpm above background for ground deposition or contamination of food or forage from radiocesium should be the response level where actions are taken to protect infants from fallout from domestic nuclear "incidents."

| Next Part of This Section | Top of This Section | Next Section |