Friday, July 21, 2006

Setting The Record Straight with David Lochbaum and the Union of Concerned Scientists

We won'’t spend too much time dissecting or rebutting the Union of Concerned Scientists news release from yesterday. Mostly because it'’s the same rhetoric they have been spitting out for years. But I do have to set the record straight on a few things.

In a letter to James E. Dyer, Director, Office of Nuclear Reactor Regulation at the NRC, Lochbaum writes:

While your staff held two public meetings with the industry on this subject (and who knows how many secret phone calls), there was no publicly available documentation about the specifics of the rumored initiative other than the few words appearing in NEI's PowerPoint slides for the May 9th public meeting on June 28th when you proposed to deny our petition.

The truth is there were four public meetings, the first was held in December 2005. Two of which I attended with our chief health physicist Ralph Andersen.

And don'’t even get me started on the Mr. Lochbaum's quote in the news release:

"On June 28 of this year, the NRC proposed denying the coalition's petition based on a promise allegedly made by a nuclear industry lobbyist to provide information on tritium leaks on a voluntary basis. The Nuclear Energy Institute (NEI), a lobby group that only promotes industry interests, presented a sketchy outline of this voluntary initiative to the NRC on July 12 -- —two weeks after the NRC proposed denying the petition.."
If anybody questions our Groundwater Protection Initiative, I invite you to review a transcript of Ralph Andersen'’s briefing for journalists held May 8, 2006. Here'’s a snippet:
The objectives of the initiative are: 1) to improve the management of situations involving inadvertent radiological releases into the groundwater, and 2) to enhance trust and confidence on the part of local communities, states, the Nuclear Regulatory Commission and the public in our commitment and practices in maintaining a high standard of public radiation safety and protection of the environment. Most specifically it involves: 1) actions to communicate pro-actively on issues associated with inadvertent releases in the groundwater, and 2) actions intended to assure timely detection and effective response to those situations so that we prevent migration of materials off-site and are able to quantify impacts for decommissioning planning.

The commitments that are specific in the initiative are: 1) by July 31st that every site will have in place a site-specific action plan with a set of actions that will assure timely detection and effective response to situations involving inadvertent releases in the groundwater; and 2) to expand the scope of our existing requirements for notification and reporting such that we will document all of our on-site and off-site groundwater sample results on an annual basis so that additionally and on an annual basis we would document any significant on-site leaks or spills of groundwater.

Thirdly, that we would provide a 30-day report to the Nuclear Regulatory Commission on a voluntary basis of any water sample results that exceed the criteria that we currently have in our license that are only applicable to off-site monitoring. So what we would do is expand that program to include on-site monitoring results as well. That's a publicly available report. Finally, that we would notify our state and local officials --– and it would need to be determined exactly who that is at each site --– whenever we have a situation involving either a report of elevated samples of radioactivity in groundwater, either on-site or off-site, or of any significant spills or leaks of material into groundwater.
UCS had all the information and plenty of opportunity to comment on the initiative, given time to ask questions at NRC meetings. In fact, Ralph took their feedback and incorporated some items into the Initiative. In a nutshell, the industry has a zero-tolerance standard for unplanned releases of tritium at commercial nuclear facilities. We take our responsibility seriously as stewards of the environment and as neighbors in the communities in which we operate facilities.

Technorati tags: , , , , ,

8 comments:

Gunter said...

BTW...its more than UCS mobilizing on groundwater contamination from nuclear reactors, this petition has more than 20 organizations behind it.

The emergency enforcement petition seeks to have NRC issue a Demand for Information to industry under the penalty of perjury. The NEI "voluntary initiative" is simply relying upon the word of the nuclear industry for timely reporting despite a history of burying information on groundwater contamination that has moved offsite at a yet-to-be-determined number of sites.

The inititative is completely void of any enforcement capability. A number of operators are likely to blow off participation altogether.
What's NEI going to do? Nothing?
What's NRC going to do? No reason to do anything because the argreement under the voluntary initiative is with NEI.

Its a ploy to end run enforcement and disclosure under affirmation and penalty for continuing to hide the extent of ground water contamination past, now and into the future.

Look forward to your comments and a dialogue.

Paul Primavera said...

Well, I hate to agree with Paul Gunter on anything, but self-policing, no matter what the industry, simply doesn't work in the long run.

That being said, the radiological releases represented by these tritium spills is orders of magnitude LESS significant than the routine dumping of pollutants (including radioactive materials) from coal-fired power plants.

If the 20 organizations making the petition on these tritium releases were truly honest with themselves, then they would with far more vigor direct their limited resources in combating the 30000 public fatalities annually from coal plant pollution than myopically focusing on minor tritium leaks that have resulted in ZERO impact on public health and safety.

So Paul, you're right, but about the wrong issue.

BTW, I don't know that the criticism of Dave Lochbaum is warranted (perhaps, perhaps not). He has never stuck me as a person who didn't do his homework and he has always been honest and honorable. There is perhaps more to this than meets the eye or we see on a blogsite.

Melanie Lyons said...

We've been talking to you for months and even incorporated your suggestions into the Initiative.
Why arent you acknowledging you've participated in shaping this plan? Why do you continue to be dishonest with the public?

Paul Primavera said...

Thanks to Eric for pointing out in a separate message your response, Melanie.

Maybe I am wrong about Dave and Paul G. If NEI, UCS and NIRS have been communicating for months and if some of their suggestions have been incorporated into NEI's plan, then the response from Dave and Paul G. is disingenuous at best. I hate saying that because while I don't know Paul G. at all, I have had some communication with Dave and he has always been forthright with me. And frankly, I admire a guy who sticks up for what he believes in and tries to defend those who would otherwise be defenseless (I refer to a certain ex-system engineer from DB).

But I still think there is more to this than meets the eye. NIRS and UCS should acknowledge NEI's cooperation with them, but ultimately the NRC is the regulator and needs to act accordingly. I am not saying that the NRC isn't acting as regulator on this issue, for they have issued IN 2006-013 on "Ground-Water Contamination Due to Undetected Leakage of Radioactive Water". But that's not what Paul G. calls an "emergency enforcement petition" which "seeks to have NRC issue a Demand for Information to industry under the penalty of perjury". Of course, I think we all know all the information about these leaks that there is to know right now, so the point of a "Demand for Information" eludes me (and thankfully I am no lawyer!).

Now why exactly do 'we' go off the deep end on tritium leaks that just might cause 4 mrem of exposure in a year, but the megacuries of uranium, radium and thorium that coal plants dump into the environment we can safely ignore?

Again, thanks to Eric for being kind enough to correct me.

gunter said...

Melanie and Mr. Primavera---Shaping the plan for self policing on groundwater contamination?

Dont think for a moment that I believe simply having conversations with NEI and sitting in on Category 2 meetings up in Rockville, MD is going to constructively shape anything on this issue. I call that the responsibility of public interest groups to monitor NRC and NEI's ongoing and historic cozy relationship more like it.

Meanwhile, we are awaiting the predicatable final director's decision from NRR on our emergency enforcement petiion. Per usual, the draft decision reveals a spineless NRC looking to swallow this load of self-policing hooey AFTER Exelon and a growing number of others got busted w/ a lengthening list of past non-disclosures of unplanned and unmonitored radioactive releases into groundwater going back now more than a decade. Without any doubt, there are still more groundwater contaminations from unplanned and unmonitored releases from dates earlier than 1996 at Braidwood and elsewhere.

I repeat---we want enforceable actions, not more mai culpaes and regulatory dodges from federal apologists. Our work was never directed into this so-called "voluntary initiative." In fact, the joint petition to NRC put NEI in the position of coming up with this dodge.

Mr. Primavera--- thanks, but hey, there are groups working on coal fired emissions and more power to 'em. That's not me nor NIRS, OK. Its not the Coal Information and Resource Service. Its Nuclear Information and Resource Service. We are funded to work on "nuclear" issues. So think of me as a dedicated bird dog.

But that aside, do you think for a minute that the electric utilities that burn coal and fission uranium are even contemplating burning less coal? Come on!! Who is being disingenuous here?

Paul Primavera said...

I agree with Paul Gunter that the Regulator needs to act as the Regulator. In the case of the tritium leaks, I think that it is. Paul G. asks for "enforceable actions" concerning the unmonitored releases that have occurred at Braidwood, Byron, Dresdon and other plants. Yet none of these releases have had any detrimental impact on either environment or human health, and most (e.g., IPEC) were on property owned by the utility. So exactly what enforceable actions should there be for events that have no demonstrated ill-effect?

Now I am not by any stretch of the imagination diminishing the responsibility of the utilities involved in cleaning up their mess. In fact, in the case of the Exelon plants, restitution has been made (or least offered) to property owners on whose property tritium may have been leaked. What more could one ask for? Exelon screwed up and Exelon is trying to make it right. Entergy's predecessor owner (Con Ed) to IP2 and IP1 (whose spent fuel pool was leaking) screwed up in its maintenance of the IP1 pool and Entergy is trying to make it right. Again I ask, what more could one ask for?

As for the Coal Information Resource Service, I can only quote what Ayn Rand wrote some 30+ years ago: "City smog and filthy rivers are not good for men (though they are not the kind of danger that the ecological panic-mongers proclaim them to be.) This is a scientific, technological problem – not a political one – and it can be solved only by technology. Even if smog were a risk to human life, we must remember that life in nature, without technology, is wholesale death."

And with nuclear energy, that smog can all be obviated - a technological solution to a technological problem.

Not to change the subject, but I was just on the AWEA web site and learned that wind power could supply 20% of US electricity needs. Wouldn't it be great if nuclear went to 50% of US electricity and wind to 20%. That means that the other 30% could come various from hydro, geothermal, tidal, solar and fossil fuels. Think about how much reduction in that smog would occur!

Brian Mays said...

Paul Gunter wrote:

Mr. Primavera--- thanks, but hey, there are groups working on coal fired emissions and more power to 'em. That's not me nor NIRS, OK. Its not the Coal Information and Resource Service. Its Nuclear Information and Resource Service. We are funded to work on "nuclear" issues. So think of me as a dedicated bird dog.

Mr. Gunter,

Ahem ... funded by whom?

And did you really mean to say "bird dog" or "attack dog"?

Inquiring minds want to know.

Stewart Peterson said...

Oh, and it is a nuclear issue--I still have yet to see how discharging radioactive materials is not a "nuclear issue," whether they happen to be "unplanned and unmonitored release paths" or "planned and monitored release paths" (which are apparently OK).

Perhaps we should also put radiation symbols on orange juice trucks.