Thursday, April 03, 2008

DHS Dirty Bomb Cleanup Guidelines: Is Flexibility Desirable?

DHS has published guidelines for cleaning up radiation following a dirty bomb attack, but not without criticism:

The guidelines issued Tuesday by the Homeland Security Department would allow cleanup standards that in some cases would be far less stringent than what is required for Superfund sites, commercial nuclear power plants and nuclear waste dumps.

The guidelines, which have been several years in the making, are designed to help local, state and federal officials plan how they would deal with a terrorist attack where radioactivity was released.

Long-term radiation exposure using some of the cleanup standards in the guidelines could be as high as 10,000 millirems a year, equal to more than 1,600 chest X-rays or 30 times the average background radiation from natural sources.

By comparison, the Nuclear Regulatory Commission limits public exposure from the facilities it licenses to no more than 100 millirems a year. The radiation exposure limit proposed for the future Yucca Mountain nuclear waste site is 15 millirems per year.
The thing about a dirty bomb is, it's not really a weapon of mass destruction. It's a weapon of mass disruption, designed to scare people away from areas where excessive radiation may be present, resulting in potentially significant economic damage.

Given that this is the risk - that citizens will be excessively anxious about returning to areas where radiation may or may not be dangerous - it would seem that Job #1 of the cleanup effort should be reassuring people that any areas opened up will be safe.

As a state or local official, your first priority must be restoring confidence.

But DHS has specifically avoided publishing a clear guideline:
Donald Tighe, a spokesman for the White House Office of Science and Technology, said the guidelines specifically avoided setting a numerical cleanup standard because there is such a wide range of potential cleanup scenarios.

In the long term a community would "have to evaluate not only public health, but the health of the community as well," said Tighe. "This is the feedback we've gotten from state and local officials. (They want) a flexible approach."

So the guidelines direct local, state and federal officials to various benchmarks used by other agencies as well as international organizations.
Let's imagine this realistic scenario:

A terrorist group, already skilled in bomb-making, acquires three radioactive sources, out of the tens of thousands which may be potentially usable for such an attack. One day, the group simultaneously explode three dirty bombs in Philadelphia, Chicago, and Houston.

After an initial period of high anxiety, local leaders in the three cities use three different sets of guidelines to determine what level of radiation will be considered safe so that people can return to their homes and businesses. Philadelphia sets the highest standard; Chicago a slightly lower standard, and Houston the lowest.

Would this really be a politically viable position for local officials in Chicago or Houston to take? Or would the citizens in Chicago and Houston insist that their cities adopt a standard that is at least as strict as Philadelphia's?

And what if Philly's standard isn't even as strict as the NRC's guideline? Are we really suggesting that the leaders in Philadelphia wouldn't get flayed in the media for adopting a guideline that's not the strictest possible?

The response to such questions might be: With the right information, local leaders can accurately determine what level is safe.

But that's not the issue. It's not about what level is safe It's about what level will inspire confidence. Because that's what a dirty bomb is designed to do - destroy confidence.

Update 2008-04-03: Sometimes as a blogger you get egg on your face.

A tip-o-the-cap to Arnold, who notes in the comments that the SF Chronicle article I quoted is not current. The guidelines are in the news, but the current story is that they are nearing completion. However, questions remain, per Global Security Newswire:
Proposed U.S. guidelines for responding to “dirty bomb” attacks are approaching final approval, but concerns persist that the federal rules could permit radioactivity levels outside U.S. environmental standards, Defense Environment Alert reported yesterday.
We'll have to see what the final guidelines say.


Arnold said...

I agree with your assessment, but I'm not sure the guidelines have been officially released yet (the article you link to is over a year old). Here is a short piece published this week on the Global Security Newswire:

U.S. "Dirty Bomb" Guidelines Approach Completion

Proposed U.S. guidelines for responding to "dirty bomb" attacks are approaching final approval, but concerns persist that the federal rules could permit radioactivity levels outside U.S. environmental standards, Defense Environment Alert reported yesterday (see GSN, Dec. 5, 2007).

The proposed guidelines are in the clearance process, according to a U.S. Homeland Security Department spokeswoman.

The Protective Action Guidance for Radiological Dispersal Device and Improvised Nuclear Device Incidents would instruct emergency responders, all levels of government and the public at large on appropriate actions in the immediate and longer-term aftermath of a "dirty bomb" attack.

Environmental Protection Agency officials, Democratic legislators and environmental activists have voiced opposition to the rules, which would allow responders to handle environmental recovery at Superfund sites using case-specific standards rather than mandating strict, long-term cleanup goals. Resulting cleanup efforts could allow radioactivity to remain at levels thousands of times greater than EPA regulations permit (Defense Environment Alert, April 1).

John Bowen said...


Many thanks for the correction. That's what I get for not checking the date on the story.

I'd seen the report on the Global Security Newswire and then went looking for more information. I just assumed the SF Chronicle article was current.

Lesson learned.

It will be interesting to see what the guidelines say.