My name is Gary Shaw and I live less than six miles from Indian Point.

IF NRC CAN’T DEFINE STANDARDS, THEIR JUDGMENTS CAN’T BE VALIDATED

My name is Gary Shaw and I live less than six miles from Indian Point.

I work as a designer of marketing research projects and a data analyst, so I am very familiar with the use of benchmarks and action standards. I spend considerable energy to ensure that the metrics in my research that are used as the basis for business decisions are well defined and consistent with established protocols. That is one of the reasons that I am so concerned about the NRC’s evaluations of Indian Point and the relicensing process overall.

One of the terms that the NRC uses repeatedly is “reasonable assurance,” and this term is used in evaluations of a range of operations and systems, but is not at all clearly defined. A primary example of this is the agency’s approval of the Indian Point Emergency Evacuation plan after James Lee Witt issued a report that the plan was “inadequate to protect the public from an unacceptable dose of radiation,” On a Friday in July of 2003, FEMA, under the infamous Michael Brown, approved the Evacuation Plan and that judgment was quickly accepted by the NRC, saying the plan provided reasonable assurance that it would be effective. Ironically, on that very day, all the major roadways in Westchester were jammed through the entire day because of a single accident on the George Washington Bridge during the morning rush hour. I still wonder how the NRC defined “reasonable assurance” for that ridiculous judgment. When I think of that day I have a mental image of those traffic jams happening while Indian Point’s sirens wailed. That is, if the sirens were working that day.

Now the NRC is considering extending the operating licenses of Indian Point units 2 and 3 for twenty more years beyond their expirations in 2013 and 2015 respectively, and will cite reasonable assurance that the plants will remain safe and environmentally benign for that twenty year extension. We know that there are an undetermined number of leaks of radioactive elements into the environment and that the sources of those leaks remain uncertain. Consequently, there are no known plans to stop the leakage. Especially disturbing is that large sections of pipes are not accessible to inspection, and the only way for the NRC to evaluate whether those pipes have corroded or will remain viable for twenty more years is to dig test wells and declare that there is not currently a leak at that site at that time. And since Indian Point 1 has been non-operational for decades and that plant is leaking with no plan for stopping the leakage, wouldn’t the discovery of additional leaks at some point in the future simply mean that we have more uncorrectable problems?

If the NRC is not capable of stating how many linear feet of piping are inaccessible or how many thirty-five year old welds are inaccessible, and where each of them is located, how will they define “reasonable assurance” that those pipes and welds will be viable until the years 2033 and 2035? Since we already know that this is the only nuclear plant in the country leaking Strontium 90 and Cesium 137, wouldn’t that information would be important.

We also know that prior test wells found concentrations of contamination at many times the EPA level for drinking water, but since the leaks are not currently going into known drinking water sources, the NRC has dismissed them as non-hazardous. I would like to know what specific radiological readings would define an unacceptable level that is not going directly into a known drinking source.

In other words, if the NRC cannot provide a well defined set of metrics, how can they establish standards that must be met to warrant twenty additional years of operations for this aging and leaking facility. We have already seen the NRC’s idea of reasonable assurance. With the potential danger of radiological contamination, how can we accept this agency’s judgments if they cannot define their standards and prove the validity of their metrics?

Gary Shaw
Member of the Steering Committees of Croton Close Indian Point (CrotonCIP) and the Indian Point Safe Energy Coalition (IPSEC).