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Never doubt that a small group of thoughtful committed citizens can change the world; indeed, it’s the only thing that ever does.   Margaret Meade

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NEW: White House Supports Rollback of Cleanup Standards for Nuclear Incidents

In a stunning reversal, it appears that the Obama Administration is poised to rollback cleanup standards for nuclear incidents:

The White House has endorsed a plan to relax long-held standards for cleaning up radioactive material released by a nuclear power plant disaster or act of terrorism, a group of federal officials say in a new draft report.

NTI reports.

Please comment by April 11, 2013- Pilgrim Watch's Comments below may serve as a guide.


April 4, 2013


National Council on Radiation Protection

Standards & Measurements

7910 Woodmont Ave., Suite 400

Bethesda, Maryland 20814-3095

Via Email: atwell@NCRPonline.org


RE: Pilgrim Watch Comment on NCRP’s Draft Decision Making for Late-Phase Recovery from Nuclear or Radiological Incidents- Optimization Approach

Pilgrim Watch (hereinafter “PW”) opposes NCRP’s draft optimization standard that replaces EPA’s guidelines for decontamination after a terrorist attack, nuclear power reactor accident or other nuclear incident with offsite consequences.

I.                NCRP’s Optimization - What’s wrong?

A.        Draft Dose Target -100 millirem to 2,000 millirem/yr: The draft recommends dispensing with the standard U.S. practice to cleanup so that not more than (1) in (10,000) would be expected to develop cancer from long-term exposure to residual radioactive contaminants. Instead NCRP recommends a loose cleanup target of between 100 millirem to 2,000 millirem per year.  An annual dose of 2,000 millirem means that from (1) in (23) exposed people would be expected to develop cancer from long-term radiation exposure to residual radioactive contaminants.  This is about 400 times more than what the U.S. has accepted in a worst-case scenario and 43,000 times less stringent than the superfund ideal of (1) in a million.  On the other end of the NCRP’s target cleanup is a recommended target annual dose of 100 millirem per year meaning that (1) in (466) exposed risk cancer over 30 years. Again, this target is far higher than the worst-case scenario for remediated Superfund sites, about 20 times higher.  

The draft targets run counter to the National Academy of Sciences BEIR VII report that projects a greater health risk.  Using NAS figures a 2,000 millirem per year dose for 30 years would cause (1) in (15) to develop cancer. Further NAS found both women and children are more at risk so that if NCRP’s targets were adjusted for age and sex the cancer risk would be even higher.

B.        NCRP’s Rationale for Sacrificing Public Health & Safety: NCRP explains that events like Fukushima necessitate relaxing standards.  According to the NCRP report, “one must realize that there are other important factors besides human health that should be considered in the decision-making process… public financial burdens, restoring key infrastructures, and resuming normal commercial activities, as well as balancing the roles and interest of affected stakeholders.”

PW agrees that some accidents will contaminate a huge geographic area so that for all practical purposes the sites will never be cleaned up. It would be too expensive; it is not technologically possible; there is nowhere to put or isolate the volume of waste.

Examples:  (i) The Chernobyl accident resulted in labeling some areas not habitable. (ii) It is estimated that Fukushima will ultimately cost $ 1 trillion and that is based on the spent fuel at Unit 4 remains stabilized. (iii) A 2007 French study of consequences of an accident at a single French reactor at Dampierre in north-central France would amount to over three times the country’s GDP. France could never deal with it. The study concluded that financially France would cease to exist as we know it. The study was done by the Institute of Radiological Protection and Nuclear Safety (IRSN), a government agency under joint authority of the Ministry of Defense and the Ministry of Environment, Industry, Research, and Health[1]. (iv)The Massachusetts Attorney General in Pilgrim’s license renewal adjudication estimated consequences from a spent fuel fire at the Pilgrim Nuclear Power Station from a 100% release of Cs-137. Estimated consequences ranged from $342-$488 billion dollars and 24,000 latent cancers[2]. The AGO’s projection used the outdated MACCS2 consequence code.  David Chanin, who wrote the FORTRAN for the code, testified that the code was incapable of analyzing economic consequences from a nuclear event[3]. (v) The National Academies of Sciences Public Report’s Safety and Security of Commercial Spent Nuclear Fuel Storage, April 2005 Findings that:

Finding 3B –… a terrorist attack that partially or completely drained a spent fuel pool could lead to a propagating zirconium cladding fire and the release of large quantities of radioactive materials to the environment. Details are provided in the committee’s classified report.

Such (zirconium cladding) fires would create thermal plumes that could potentially transport radioactive aerosols hundreds of miles downwind under appropriate atmospheric conditions.[4]

NCRP’s response to lessons learned is simply to re-define “clean” by lowering the cleanup standard is frankly criminal.  Just as “wrong” does not become “right” by rewriting the Commandments to “Thou shall” from “Thou shall not;” dirty does not become clean; nor harmful become harmless by a stroke of the pen to change the definitions.

Instead the government is obligated to protect public health, safety and the environment; and foremost to honestly inform the public of the risks to their family’s health and environment.

The only humane and sane approach would be for NCRP to recommend measures to reduce the risk of nuclear disasters in light of the potentially real and potentially devastating economic and human consequences; and then to recommend policies and a framework to deal with short and long-term offsite consequences. Currently there is no federal agency in charge of cleanup; there is no cleanup standard; and Price Anderson is underfunded and does not pay for cleanup[5]

C.        One-Size Does Not Fit All: The draft incorrectly recommends a one-size fits all approach. However many radiological incidents, such as dirty bomb scenarios, will affect areas substantially smaller than contaminated areas that traditional Environmental Protection Agency standards have been applied to in the past. The normal EPA benchmarks have been used at hundreds of sites, including nuclear weapons facilities owned by the Energy Department, mining grounds stretching across hundreds of square miles and the urban areas affected by the 2001 attacks on New York and Washington. The extent of cleanup will differ from one accident to another.[6]

D.        NCRP sets Dangerous Precedent: If the draft is finalized as it reads, it is likely to set a precedent to relax remediation standards beyond dirty bombs and severe nuclear reactor accidents to more routine nuclear cleanups such as required for decommissioning a nuclear reactor. The NCRP draft title refers to “incidents.” This tells us that the scope of the draft optimization plan is in fact very broad.

II.        Process

A.        Panel: PW believes that the National Academies of Sciences would be the appropriate choice to conduct this project. NCRP’s panel looks unbalanced, weighted towards those already in support of optimization. For example, Jonathan Edwards is a director of the EPA Radiation Protection Division - a division that had proposed adopting optimization and argued against the Superfund Protocol. A balanced or fair panel, for example, would have included experts from EPA’s cleanup office that works on the superfund approach to cleanup and experts.

Example bias: NCRP mischaracterized the consequences of Three Mile Island (TMI). The Draft (at 12) says that “The TMI incident did not result in any radiological injury or offsite contamination.” TMI facts show otherwise.  TMI’s radiation monitors onsite were off-scale. All radiation estimates are based upon off-site dose readings to which mathematical assumptions were applied. We know that:

·       Early on in the accident, the NRC estimated that 10,000,000 Curies of radiation were released. The NRC estimate is based on a report by NRC manager, Mr. Lake Barrett.NUREG-0637, Appendix C. Barrett used time averaged plume dispersion (Chi/Q); assumed the center (highest concentration) of the plume hits the detector; and then averaged many days of releases. Time averaged plume dispersion can be wrong, on the low side by a factor of 10. Center line Chi/Q can be wrong on the low side by a factor of a 1000. Averaging the data is wrong on the low side by a factor of 3.4. Barrett recorded the maximum curies released each day; the grand total of each day’s recording adds up to 36,062,000; yet NRC insists that only 10,000,000 curies were released.

·       During the 1994 TMI Trial, John Daniel (industry’s expert), determined that 17,000,000 Curies were released. Industry's own expert estimated that more radiation was released than the NRC, the guardian of public safety. Another industry expert report by Dr. Sinovy V. Reytblatt, structural engineer from the University of Bridgeport, estimated that 8-10% of containment was released as result of the spike in pressure inside the containment. The containment had 10 billion curies – 10%= 1 billion curies.

·       A thorough analysis of the TMI accident indicates that releases were 100 to 1000 times higher than the NRC estimated and that the containment failed after the hydrogen detonation.[7] 

·       TMI’s health effects in the population: subsequent studies show radiation-linked disease in the communities exposed from TMI. [8]

B.        NCRP Secrecy: The panel’s process has operated under the general public’s radar screen.  Had it not been for reporting by Global Security Newswire, PW would not have been aware of the draft and the date set to submit comment; other public interest groups have requested a time extension for comment. Also we understand that GSN going back to 2010 submitted numerous requests[9] under the Freedom of Information Act that were denied –a violation both in spirit and fact of the White House’s Open Government Initiative.

III.       Conclusion

For the reasons stated, PW respectfully disagrees with NCRP’s recommendations and believes that the project should be restarted with a new panel appointed by the National Academies of Sciences.

Respectfully submitted,

(Electronically signed)



 [1] http://www.lejdd.fr/Economie/Actualite/Exclusif-JDD-le-scenario-noir-du-nucleaire-595593

[2] The Massachusetts Attorney General’s Request for a Hearing and Petition for Leave to Intervene With respect to Entergy Nuclear Operations Inc.’s Application for Renewal of the Pilgrim Nuclear Power Plants Operating License and Petition for Backfit Order Requiring New Design features to Protect Against Spent Fuel Pool Accidents, Docket No. 50-293, May 26, 2006 includes a Report to The Massachusetts Attorney General On The Potential Consequences Of A Spent Fuel Pool Fire At The Pilgrim Or Vermont Yankee Nuclear Plant, Jan Beyea, PhD., May 25, 2006, available NRC’s Electronic Hearing Docket (Adams, EHD, Pilgrim Exhibits).

[3] http://chaninconsulting.com/index.php

[4] National Academies of Sciences Public Report’s Safety and Security of Commercial Spent Nuclear Fuel Storage, April 2005, pgs., 6 & 50

[5] Agencies Struggle to Craft Offsite Cleanup Plan for Nuclear Power Accidents, Douglas Guarino, Inside EPA, November 10, 2010 http://environmentalnewsstand.com/Environmental-NewsStand-General/Public-Content/agencies-struggle-to-craft-offsite-cleanup-plan-for-nuclear-power-accidents/menu-id-608.html

[6] Economic Consequences of a Rad/Nuc attack: Cleanup Standards Significantly Affect Cost Barbara Reichmuth, Steve Short, Tom Wood, Fred Rutz, Debbie Swartz, Pacific Northwest National laboratory, 2005;  Survey of Costs Arising From Potential Radionuclide Scattering Events, Robert Luna, Sandia National laboratories, WM2008 Conference, February 24-28, 2008, Phoenix AZ; The Massachusetts Attorney General’s Request for a Hearing and Petition for Leave to Intervene With respect to Entergy Nuclear Operations Inc.’s Application for Renewal of the Pilgrim Nuclear Power Plants Operating License and Petition for Backfit Order Requiring New Design features to Protect Against Spent Fuel Pool Accidents, Docket No. 50-293, May 26, 2006 includes a Report to The Massachusetts Attorney General On The Potential Consequences Of A Spent Fuel Pool Fire At The Pilgrim Or Vermont Yankee Nuclear Plant, Jan Beyea, PhD., May 25, 2006, available NRC’s Electronic Hearing Docket (Adams, EHD, Pilgrim Exhibits). 

[7] http://www.nirs.org/reactorwatch/accidents/tmipowerpoint.pdf

[8] Wing S, Richardson D, Armstrong D, Crawford-Brown D. A Reevaluation of Cancer Incidence Near the

Three Mile Island Nuclear Plant: The Collision of Evidence and Assumptions. Environmental Health

Perspectives 1997.105(1):52-67; and the utility paid out more than $15 million in settlements to citizens for damages.

[9] http://www.nti.org/gsn/article/epa-withholds-information-dirty-bomb-report-amid-cancer-concerns/





For updates actions focused on Pilgrim: www.pilgrimcoalition.org

Newspaper articles with nuclear news from around the world: http://www.state.nv.us/nucwaste/whatsnew.htm

Union of Concerned Scientist daily Blog:  http://allthingsnuclear.org/

Fairewinds Associates, Fukushima Updates - videos: http://fairewinds.com/reports

Other organizations listed under "links" are covering the story.


Comment: A Major Nuclear Reactor Accident Every 11 years

For years the nuclear industry’s mantra has been that there is “one chance in a million” of a nuclear accident?

We have had three accidents in 32 years - Three Mile Island accident in Pennsylvania, Chernobyl, and now Fukushima in Japan -in other words, one major nuclear reactor accident every 11 years.

Three Mile Island and Chernobyl were caused by human error.  Fukushima was brought on by the loss of offsite power, which in turn was result of the Tsunami.

Nuclear power plants do not generate their own electricity; we have tragically learned that offsite power is needed to run every active safety system that is depended upon to prevent major accidents. But loss of power can occur without a Tsunami. Hurricanes and snow storms cause power losses; so can human error, mechanical failures, terrorist actions - to say nothing of the fact that the submerged electric cables that the industry relies on to bring electric power into the reactor and to power safety systems are not qualified to operate in a moist environment – as is the case at Pilgrim.

Pilgrim’s chances of an accident are not “one in a million,” especially as the 39 year old reactor continues to age and NRC refuses to enforce its own regulations.

Pilgrim is the same design as the reactors in Fukushima, weak and outdated.  But it is more dangerous than Fukushima in an important way.  Fukushima has 60% of its highly radioactive spent fuel assemblies in a common ground level spent fuel pool.  All of Pilgrim’s spent fuel is stored in an overcrowded pool in the attic of the reactor, outside primary containment with a thin roof overhead. If, for example, the water level in that pool were to drop to the top of the assemblies from human error, mechanical failure or acts of malice, experts for the Mass. Attorney General Office estimated consequences up to $488 billion dollars of damage, 24,000 latent cancers and over a hundred miles contaminated.

What are your chances of evacuating, one in a million?  The US Nuclear Regulatory Commission recommended Americans in

Japan within 50 miles of Fukushima evacuate; yet, here, emergency planning zones are limited to only 10 miles around a reactor.



See www.pilgrimcoaltion.org