Public Comments:

September 20, 2017
Comments by the Committee to Bridge the Gap on the Department of Toxic Substances  Control’s Proposed Regulations for Toxicity Criteria for Human Health Risk Assessment
DTSC Reference Number R-2016-8
CBG Toxicity Criteria Rule Comments (pdf)
DTSC Toxicity Criteria Excel Sheet Comparison (pdf)


Proposed Amendments to EPA Protective Action Guidance (RIN 2060-ZA19)
Read the group letter by clicking here.
Read our post on the subject here.

Over 100 Groups Call on EPA to Withdraw Dramatically Weakened Radiation Guides
Read the group letter here.

EPA Dramatically Weakens Radiation Protections
Summary of EPA PAGs Weakening Radiation Protections
Letter criticizing NCRP guide for relaxing radiation protections, being sent to NCRP.
Critique by CBG, NIRS, PSR-LA, and SCFS of NCRP Draft Report on Late-Phase Recovery from Nuclear or Radiological Incidents

DOE Proposes Unrestricted Recycling of Radioactive Metals Into Consumer Goods
Read CBG’s letter to the Department of Energy here.

Environmental Radiation Protection Standards for Nuclear Power Operations – Advance Notice of Proposed Rulemaking Docket, Docket ID No. EPA-HQ-OAR-2013-0689
Read our group letter here.

CBG & Other Organizations Oppose Petitions to NRC to Relax Radiation Protections and Declare Radiation Good For You
Comments to NRC Opposing Hormesis Petitions for Rulemaking
NRDC & CBG Comments LNT Docket 19 Nov 2015

Research Projects:

Nuclear Cleanup: The Standards Conflict (2004)

Download Link (.pdf, 1.8mb)

The U.S. Department of Energy has recently violated a longstanding Joint DOE-EPA Policy which commits DOE to clean up all its nuclear facilities nationwide to the Environmental Protection Agency (EPA) Superfund (CERCLA) standards. The focal point of this conflict between DOE and EPA cleanup standards is the Santa Susana Field Laboratory (SSFL), a 2800-acre facility on the Los Angeles-Ventura County line in Southern California.

Written Articles:

Powering the Automobile / Nuclear hydrogen — Lighter side of the energy bill

HOT, HOT, HOT: The Future of Nuclear Power

(2001 debate over nuclear power)

Beauty & the Humiliated

Featured in Fellowship magazine, July/August 1978


Proposed Relaxation of EPA Drinking Water Standards for Radioactivity

Download link (.pdf, 6.6mb) October, 2008

In the waning days of the George W. Bush administration, the U.S. Environmental Protection Agency (EPA) drafted extraordinary new radiological standards for the governmental response to a wide range of radiological release events.  Doug Guarino of the trade publication Inside EPA obtained a copy of the secret draft “Protective Action Guidance for Radiological Incidents,” dated August 2007 and marked “Please Do Not Distribute” and “Do Not Cite or Quote.”  Mr. Guarino has written about the concerns the document has triggered within EPA and other state regulators.

In late 2008, it became clear to CBG that EPA was contemplating the issuance of the draft.  In this report, we analyze this incredible proposal pushed by EPA leadership.  CBG’s report specifically focuses on the proposal to allow the public to ingest drinking water with radioactive concentrations orders of magnitude higher than EPA’s longstanding radiological drinking water standards.

The Proposed Ward Valley Radioactive Waste Facility:

Papers Submitted to the National Academy of Sciences

Download link (.pdf, 3.3mb) October 12, 1994

Comprehensive radiation monitoring data for the US Ecology LLRW site at Beatty, Nevada, published in the last few days, provide a unique opportunity to evaluate the validity of optimistic transport models that have been used to predict travel times to groundwater in the tens of millennia. The newly available data show gross alpha readings in groundwater in excess of action levels in eight different years, gross beta in violation of action levels seven years, and tritium in excess ofaction levels four years, with significantly elevated tritium (>1,000 pCi/L) but below action levels an additional four years. The data provide clear evidence that radioactive materials have migratedfrom the disposal trenches 10 groundwater, 300 feet beneath the surface, in a few decades. The presence of elevated gross alpha, gross beta, and Cobalt-60 in the groundwater, in addition to substantial tritium, rule out vapor-phase migration. These empirical observations of rapid radionuclide migration contrast sharply with predictions by Prudic (1994) for Beatty and Ward Valley using Chloride Mass Balance calculations.

Contamination at the Beatty, Nevada, Radioactive Waste Disposal Facility (1996)

Download link (.pdf, 15.5mb) [Note: this is a very large file and will take time to download]

In the 1990s, contaminants were discovered outside US Ecology’s

radioactive waste facility near Beatty, Nevada, and all the way down to groundwater. In this report, we evaluate this discovery and its relevance to the now defunct proposal to dispose of radioactive waste at Ward Valley.

News Reports:

Modern Marvels 19: Engineering Disasters — The Santa Susana Field Laboratory


GAO Stings Nuclear Agency; Obtains License to Buy Radioactive Materials

(2007 ABC News report)

SCRIPT: Radioactive Road Trip (Primetime)

Science Friday Interview, Nuclear Security

Dirty Bombs: Dangerous Materials
KPHO news story