Arjun's Science and Democracy Blog

The Voice of Russia Radio Host Jessica Jordan talks with Arjun Makhijani about greater U.S. energy production and the role of energy in the future of our economic stability.

Listen to the audio online: http://voicerussia.com/radio_broadcast/70924886/91723352.html

Download to read the complete comments.

Submitted via email October 10, 2012

Overview

The Institute for Energy and Environmental Research (IEER) is in general agreement with the comments, analysis, and recommendations filed by the Alliance for Nuclear Accountability (ANA) and others ^[1] on the Draft Supplemental Environmental Impact Statement DOE/EIS-0283-S2 (Draft SEIS). IEER’s main comments, including some drawn from ANA et al. 2012, can be summarized as follows:

• The DOE has not identified specific utilities that have agreed to use MOX fuel or utilities that have made commitments to test MOX fuel. The reactors belonging to TVA identified by in the Draft EIS do not meet this test, since the TVA has not agreed to use MOX fuel produced by the DOE. Further, three of the five TVA reactors identified by the TVA are boiling water reactors (BWRs). MOX made from weapons plutonium has never been used on a commercial scale in power reactors and has never even been tested in Boiling Water Reactors (BWRs).
• Given the that the waste confidence rule and decision of the Nuclear Regulatory Commission (NRC) has been vacated by a federal court, the NRC has suspended all licensing and relicensing decisions. Given the license expiry dates of the TVA reactors, among other factors, it is unclear if the identified reactors will be available to consume all the MOX fuel that DOE plans to produce.
• In view of the fact that the Tennessee Valley Authority has not agreed to use MOX fuel made from weapons-grade plutonium, the DOE’s “Preferred Alternative” is lacking an essential element. The additional MOX that is identified in the Preferred Alternative in the Draft EIS would add to the 34 metric tons previously slated for MOX fuel production. The two matters are linked since the additional MOX would aggravate the problem of finding a sufficient number of reactors to use it within a reasonable time frame or even to use it at all.
• There would be storage costs and impacts if some or all of the produced MOX fuel has to be stored for a long period at SRS, if sufficient reactor facilities are not available and licensed to use weapons-MOX fuel. The impacts of prolonged storage of MOX fuel in case sufficient reactor capacity to irradiate it is not available should be evaluated.
• The costs of the MOX program are escalating out of control. This increases the likelihood of the entire program failing, especially given the tight federal budgetary environment. It is therefore essential for DOE to identify cheaper alternatives for the entire amount of plutonium that has been declared surplus to US nuclear weapons requirements, including the 13.1 metric tons considered in the Draft SEIS and the 34 metric tons that was not considered in it because it was previously slated for MOX fuel production. Given that cost increases, delays, and technical issues have put these plans into jeopardy, it is essential for DOE, both on security and environmental grounds to evaluate disposition alternatives for the entire surplus plutonium inventory.
• The plutonium disposition EIS must contain a “[a] full discussion of revisions of facilities at SRS and Los Alamos to process plutonium from nuclear weapons “triggers”” as stated in ANA et al. 2012.
• The agreement with Russia on surplus weapons plutonium disposition is not a treaty and the US can proceed to treat plutonium as a waste to be disposed of, especially given that Russia is proceeding on its own path and is not going to use MOX fuel in light water reactors.
• In view of the analysis in these comments, we conclude that the Draft SEIS is partial and essentially incomplete. It does not identify a valid and complete Preferred Alternative. As such it does not meet the requirements of the National Environmental Policy Act. It is essential for DOE to prepare a new or supplemental Programmatic Environmental Impact Statement (PEIS) for the entire surplus plutonium disposition program. A number of other parties have also asked for this. ^[2]
• An alternative that would process all surplus plutonium, including the 34 metric tons previously slated for MOX fuel production, and the 13.1 metric tons under consideration in the Draft SEIS, as TRU waste for disposal in a deep geologic repository should be evaluated. If the volume of TRU waste thus produced cannot be accommodated within the present legal framework for WIPP, other repository options should be evaluated.

More detail on some of these points can be found in the complete comments [PDF].

Troubling Parallels Seen: The “U.S. Has the Same Colluding System Between Industry, Regulators and Government”

WASHINGTON, D.C. – July 12, 2012 – The same underlying “man-made” problems that contribute significantly to the Fukushima reactor disaster in Japan are in place in the United States and require preventative actions that go far beyond the limited steps taken far by the U.S. industry and its regulators, according to five groups commenting today on the English-language version of the official report of the Japanese Parliament’s Fukushima Nuclear Accident Independent Investigation Commission.

The 88-page executive summary of the report can be viewed in English at http://naiic.go.jp/en (Links) and at http://ieer.org/wp/wp-content/uploads/2012/07/Fukushima_NAIIC_report_lo_res3.pdf.

Physicians for Social Responsibility (PSR) Executive Director Catherine Thomasson said: “American regulators and the federal government should take heed. This report should serve as a warning that the U.S. has the same colluding system between industry, regulators and government. There are some reactors that will never have adequate evacuation plans as they are too close to human populations to be managed without severe consequences should a catastrophic accident occur. Others will remain problematic because there is the same mindset as in Japan that such accidents could not occur in our country hence there is inadequate preparation.”

Physicians for Social Responsibility (PSR) President-Elect Dr. Jeffrey Patterson said: “This report demonstrates that no government or industry is prepared to adequately deal with the short or long term consequences of disasters such as Fukushima. From a medical standpoint Fukushima, Chernobyl and other radiation disasters are dangerous experiments which are releasing unknown quantities of long lived radiation on non-consenting populations who will be repeatedly exposed as the radioactive materials recycle through the environment. The results of this unconscionable experiment will not be fully known for generations, if ever. There is no ‘safe’ dose of radiation.”

Other groups in the U.S. speaking out today include: Institute for Energy and Environmental Research, Southern Alliance for Clean Energy, Georgia WAND, and Nuclear Information and Resource Service.

Arjun Makhijani, president of the Institute for Energy and Environmental Research (IEER), said: “The report concluded that regulation in Japan was not rigorous. Sadly that applies to the United States as well. Just ten days after the start of the Fukushima disaster, the NRC extended the license of Vermont Yankee for 20 years, though it is the same design as the Fukushima reactors and it has more spent fuel in its pool than all four stricken reactors there put together. The report should jolt the NRC into implementing the lessons of Fukushima before licensing new reactors and relicensing existing ones.”

Dr. Stephen A. Smith, executive director of Southern Alliance for Clean Energy (SACE) said: “This is an extremely important report especially to those of us here in the Southeast given the high percentage of existing and proposed nuclear reactors in this region. Since Fukushima, we’ve listened to industry proponents and nuclear utilities constantly telling the public that a tsunami can’t happen here or an earthquake of the scale of Fukushima. But this report is saying that the devastating Fukushima accident was ‘man-made.’ That a ‘witch’s brew’ of regulator, utility and government negligence led to this tragedy. Unfortunately, that collusion and lack of oversight occurs right here. And it’s beyond time for the nuclear industry, its cheerleaders and its regulators to wake up and take notice so that Fukushima doesn’t ever happen here in the U.S.”

Bobbie Paul, executive director, Georgia WAND, said: “It is tragic that this report was not published before Southern Company’s reactors 3 and 4 in Burke County Georgia were given the green light by the NRC. Recalling the lone dissenting voice of NRC Chairman Gregory Jaczko in the 4-1 vote: ‘I cannot support issuing this license as if Fukushima had never happened.’ This report validates the NRC chairman and should cause every citizen to challenge claims made by the nuclear industry that ‘it can never happen here.’ Man-made disasters – whether made in Japan or made in the USA – can and do happen.”

Michael Mariotte, executive director of Nuclear Information and Resource Service (NIRS) said: “Japan didn’t learn the lessons of Three Mile Island and Chernobyl, and a Fukushima became inevitable. Unfortunately, the U.S. reality is no different: a powerful nuclear power industry consistently gets its way at a weak and accommodating Nuclear Regulatory Commission. And thus, another nuclear accident also becomes inevitable. One area where Japan flunked the test was emergency evacuation. In a move to incorporate the lessons of Fukushima, NIRS has proposed strengthening emergency planning regulations and expanding emergency planning zones. But the industry wants less, not better emergency planning. Comments on NIRS’ petition for rulemaking are due July 16. What the NRC does with this petition will go a long way toward defining whether the agency is prepared to take strong steps to protect the public, or whether it will continue to allow nuclear industry interests to rule.”

The NIRS petition and related documents are available at http://www.nirs.org/reactorwatch/emergency/emergencyhome.htm.

The groups highlighted segments of the Japanese independent commission showing the following troubling parallels to the situation with nuclear reactors in the U.S.:

• “The TEPCO Fukushima Nuclear Power Plant accident was the result of collusion between the government, the regulators and TEPCO, and the lack of governance by said parties. They effectively betrayed the nation’s right to be safe from nuclear accidents. Therefore, we conclude that the accident was clearly ‘man made.’”

• “The Commission concludes that there were organizational problems within TEPCO. Had there been a higher level of knowledge, training, and equipment inspection related to severe accidents, and had there been specific instructions given to the on-site workers concerning the state of emergency within the necessary time frame, a more effective accident response would have been possible.”

• “The Commission concludes that the residents’ confusion over the evacuation stemmed from the regulators’ negligence and failure over the years to implement adequate measures against a nuclear disaster, as well as a lack of action by previous governments and regulators focused on crisis management.”

• “The Commission recognizes that the residents in the affected area are still struggling from the effects of the accident. They continue to face grave concerns, including the health effects of radiation exposure, displacement, the dissolution of families, disruption of their lives and lifestyles and the contamination of vast areas of the environment. There is no foreseeable end to the decontamination and restoration activities that are essential for rebuilding communities. The Commission concludes that the government and the regulators are not fully committed to protecting public health and safety; that they have not acted to protect the health of the residents and to restore their welfare.”

• “Approximately 150,000 people were evacuated in response to the accident. An estimated 167 workers were exposed to more than 100 millisieverts of radiation while dealing with the accident. It is estimated that as much as 1,800 square kilometers of land in Fukushima Prefecture has now been contaminated by a cumulative radiation dose of 5 millisieverts or higher per year.“

• “The Commission has concluded that the safety of nuclear energy in Japan and the public cannot be assured unless the regulators go through an essential transformation process. The entire organization needs to be transformed, not as a formality but in a substantial way. Japan’s regulators need to shed the insular attitude of ignoring international safety standards and transform themselves into a globally trusted entity.”

The above-quoted experts and others are available to comment on the report findings.

MEDIA CONTACTS: Ailis Aaron Wolf, (703) 276-3265 or aawolf@hastingsgroup.com

Alan Stahler interviews Arjun Makhijani about the ongoing Fukushima disaster, the official report of the Japanese Parliament’s Fukushima Nuclear Accident Independent Investigation Commission, and the general role of nuclear power in global energy systems.

Recording of interview on KVMR, July 10, 2012.

IEER’s Official Comments (June 5, 2012; pdf) | IEER’s Statement (March 29, 2012; pdf) |
Analysis of Cancer Risks in Populations near Nuclear Facilities: Phase I

Comments of the Institute for Energy and Environmental Research (IEER) on Analysis of Cancer Risks in Populations near Nuclear Facilities:
Phase I, Prepublication copy ^[1]

Arjun Makhijani

June 5, 2012

These comments are being submitted a few days after the deadline of May 30, 2012, but we hope that they will be taken into account in the preparation of the final report. I am keeping my comments short and am covering only the points relevant to the follow-up studies that are proposed in the report.

Overall, this is a thoughtful and careful report regarding the difficulties and complexities of conducting successful epidemiologic studies to detect whether there is excess cancer in the neighborhood of commercial nuclear facilities. It has compiled the available data and noted the limitations of the data. The report’s emphasis on carbon-14 emissions and their importance is especially refreshing. The recommendation that a method should be developed for estimating carbon-14 discharges and emissions is especially important.

A. Critical data gaps

The following represents a list of critical data gaps that should be addressed. They are especially important for non-cancer effects as well as cancer risks as a result of in utero and/or early childhood exposure. These data gaps are especially important for the case-control study for children born near nuclear power plants.

1. Tritium releases to the atmosphere: There is no discussion in the report about tritium releases to the atmosphere. Light water reactors routinely release tritium to the atmosphere in the form of tritiated water vapor. Tritiated water comes down mixed with ordinary rainwater, contaminating land, locally grown produce, and groundwater. This is a serious omission, especially in view of the fact that private water wells are not covered or monitored under the drinking water act. The Nuclear Regulatory Commission does not require or recommend that licensees monitor drinking water from private wells, even if should the owners so desire. Under certain circumstances, the concentration of tritium in rainwater can far exceed the drinking water limit. There are multiple pathways of exposure to tritiated rainwater including absorption through the skin, various food pathways that include exposure to organically bound tritium, irrigation with contaminated well water, consumption of contaminated well water for drinking and cooking, inhalation of contaminated water during showers, and absorption of tritiated water via the skin.

2. Tritium discharges to surface waters: Sampling for tritium is periodic rather than continuous. Since discharges are part of primary water discharge, it is critical to know that measurements of concentrations in primary water have been made and to validate the surface water sampling results with primary water sampling data, if they exist. If they do not exist, it will be important to make estimates by independent methods, such as knowledge of reactor operation and primary water discharge protocols.

3. Tritium minimum detectable amounts (MDAs): The MDA’s for tritium are often on the order of 2,000 pCi/liter. This is far too high. An effort should be made to determine the concentration levels by estimating it from knowledge of amounts of tritium created in the reactor and discharged.

4. Strontium-90: I recognize that official data indicate that strontium-90 emissions and discharges during routine operation would be low. However, as the report recognizes, early data have gaps and older reactors with problematic fuel rods could have resulted in strontium-90 discharges to surface waters when primary water was discharged. In utero exposure as well exposure during infancy to strontium-90 could compromise immune system stem-cell development, creating greater vulnerability to cancer as well as a host of other diseases.

B. Analytical issues

1. Exposure to tritium during the first eight weeks: The proposed case control study is focused on health outcomes of children whose mothers lived near nuclear plants during pregnancy. It is therefore necessary to be able to calculate doses to the embryo/fetus during all stages of the pregnancy. ICRP 88 proposes that the doses during the embryonic stage – the first eight weeks – should be “taken to be the same as the dose to the uterus wall.” ^[2] While this may be appropriate for photon and high energy beta emitters, it is not suitable for the low energy beta of tritium or for alpha-emitting radionuclides. The recommendation that the case control study focus on the area where the mother lived during pregnancy is important. But for the study to be valid in regard to vulnerabilities acquired during the first eight weeks of pregnancy when most of the organs are formed, a better method of estimating doses during this period will be needed, especially for tritium. The validity of the method for carbon-14 and strontium-90 should be examined.

2. Exposure to multiple nuclear facilities: The study focuses on getting dose estimates from single facilities. But in certain cases, such as that of the Braidwood plant, many of the affected people are also affected by the Dresden plant. It will be important to consider exposures to the affected population from all nuclear fuel cycle facilities, including other nuclear power plants, of course.

3. Exposure to carcinogens from other facilities: The presence of chemical facilities or fields where pesticides are sprayed, especially by air, should be noted in the study. Petroleum refineries, for instance, may emit carcinogens. This may be a confounding factor in some situations.

4. Exposure geography: Defining the exposed populations will be complex. We have already pointed out the issue of tritiated rainfall, which will depend on rainfall patterns as well as air dispersion. The location of public drinking water systems downstream of the water discharge points is also important. For instance, there is a public drinking water system downstream of the Braidwood and Dresden plants in Illinois. The water quality data for such public drinking water systems should be examined to determine whether the women who were pregnant in these areas should be included in the studies. It is unclear whether babies born to mothers who lived within a 50-kilometer radius, which is proposed in the report (p. S.5), is the most appropriate geographic definition for these studies. One early step might be to examine weather data and water consumption patterns and choose the area for study that way.

C. Recommendations

Given the vast differences in risk of various types of adverse outcomes between those exposed in utero and in early infancy, the feasibility study should focus on the case control study for children. We recommend that the six proposed ecologic studies for entire populations living near nuclear facilities be dropped for the next phase. It will be difficult enough to do case control study for children and come up with statistically reliable results. To complicate that with an ecologic study would be to try to go in two rather different directions at once, scattering resources at a time when it is important to focus them. Further, the analysis and results of the case control study will also make much clearer whether it is worth doing the ecologic study.

As a result, we recommend that the next step should consist only of the proposed case control studies for children whose mothers lived near the six facilities proposed to be studied.

In the case of Dresden, the combined exposures from Dresden and Braidwood should be evaluated and the exposed populations should be selected with both these facilities in mind. In this regard, I strongly recommend that the data and analysis of childhood cancer prepared by and presented to the committee by Dr. Joseph Sauer be explicitly taken into account and included in the case control study for these facilities.

The following adverse health outcomes should be evaluated if possible. If one or more of these outcomes cannot be evaluated, a research program making such a study feasible should be done.

1. Cancer incidence for various cancers, including leukemias of various types, and brain and nervous system cancers
2. Cancer deaths
3. Early failed pregnancies
4. Malformations as affected by early embryo/fetus exposure (first 14 weeks).
5. Immune system function as affected by fetal exposure at the time of bone and bone marrow formation. The reliable determination of strontium-90 exposure is important in this context.

D. Bibliographic note

Analysis of tritium, strontium-90, and other matters with specific reference to women and children can be found in the IEER report Science for the Vulnerable. ^[3]

“As the search for cheap, safe and non-carbon emitting sources of energy continues, a band of scientists say the answer may be nuclear reactors fueled by thorium. Others caution that thorium reactors pose waste and proliferation risks. Ira Flatow and guests discuss the pros and cons of thorium reactors.”

Guests: Arjun Makhijani, Richard Martin

Listen to the program

Read the transcript (also includes audio)

Dr. Arjun Makhijani was a guest on “If You Love This Planet”, a weekly radio show with Helen Caldicott. In this episode Dr. Caldicott and Arjun discuss the dangers with thorium reactors, which some are now proposing. They also touch on how much less expensive it would be to move to greater solar power on rooftops. Visit Dr. Caldicott’s website or listen to the audio below.