cc: Ward Valley and NEI Comments

[JMUCKERHEIDE@delphi.com]

Mike,

> I'm responding to your e-mail to Scott Peters at NEI on Ward Valley.
> 
> I'm Mike Alissi - NEI's Low-Level Waste Mgr.  Scott gave me a
> hard copy of your message, so I can't echo it.  Sorry.

Thanks for the response.  I appreciate the specific numbers from the NAS
report, and the reference to obtain the report. 

I am left, however, with my original questions regarding public statements
made by NEI and others in industry and other institutions that seem not to
have substantially picked up on the foundation of the NAS report, eg, 
regarding the comparison to natural radioactivity in the Colorado River (in
fact, from what reports I saw, undercut the conclusion); 

the failure to question the basis for the NAS statements that imply that
substantial additional scientific and monitoring work is needed to provide
assurance that the public health would be protected (conflicting with its own
conclusions and misleading the public and policy-makers); 

and the failure of industry and others to respond to the similar implications
of "conditions" on the transfer that are needed to protect public health, eg,
the requirement that a commitment be signed to limit Pu into the site not to
exceed the "plan" (presumably 10 Ci) though the numbers you present below make 
it clear that thousands of times more Pu poured directly into the river would
be within drinking water standards (or even the outrageous notion that this is 
a "worst case" condition vs an extreme comparison millions of times worse than 
the "worst case"). 

The failure to address these matters by NEI and our knowledgeable institutions 
is a failure to use this case, when some limited attention is being paid by
the more responsible and objective elements of society, as an opportunity to
put radioactive materials "in perspective", especially when most of the time
we complain that "people don't pay attention", and that they don't put
radiation "in perspective". Yet we fail dismally when given an opportunity to
do just that, in a moment of some conscious awareness (a "teachable moment" in 
the parlance :-). 

Clearly, there is little thought to the "message" that addresses the natioanl
issues on radiation and radioactive waste vs the limited, and rather trivial
context at this stage, of finally accomplishing the Ward Valley transfer. 
It's clear we have left a negative wake in this process to future public
dealings with radioactive materials by buying into the outrageous perspectives 
that Ward Valley is a marginal site that needs massive resources and
scientific investigations and extensive monitoring to provide a hope of
assuring htat we can protect public health.  Bad message. 

Finally, it is not appropriate to stake the case on the status and integrity
of the NAS, which begs to join the anti's issue of the integrity of the NAS
panel, in an environment where the President of the NAS has questioned the
integrity of the NAS, and begs as much credence to the naysayers on the panel
as to the majority re their "concerns". Use the panel report for facts and
conclusions, and their use in the "debate" without just saying "the NAS said
so".  

> The NAS report found it highly unlikely that any radionuclides
> could get to the river.  They specifically looked at Plutonium,
> because of the antinuclear groups' allegations about that
> nuclide.  The absolute worst case bounding calculation was that
> all of the estimated 10 Ci of Pu were released into the river
> over the 30 yr operating life of WV.  (NAS said this "has an
> incredibly low probability of occuring"]  Anyway, this would

A disingenuous and outragious statement that should have been objected to! It
is a comparison, not a "worst case" or "low probability of occurring". It is
millions of times more conservative than any "worst case"/"low probability"
release event. 

> have increased the Colorado River's concentration of
> alpha-emitting isotopes from 4.4 pCi/l to 4.47 pCi/l.  Even if

[ Sounds high, but without doing numbers... What's Pu solubility?  Only at the 
discharge assuming Pu is all dissolved?  And stays dissolved to the implied
drinking water intake? ] 

> the actual PU inventory was 1000 times higher, under this worst
> case calc, the concentration would be 7 pCi/l.  The health

"worst case"??  Did they say that? 

> based regulatory criterion is 15 pCi/l.  Resounding evidence
> that this is a non-issue.

I agree.  Too bad we did not see that stated to the public.  Or, again, is
there some public statement materials that I have not seen ??!  [ I keep
hoping !  :-)  ]  

> The NAS report, "Ward Valley: An examination of seven issues in
> earth sciences and ecology," is available by calling the
> National Research Council at 800-624-6242.
> 
> In communications to the media/public, it is important to
> emphasize that the NAS put to rest the safety issues that
> concerned Mr. Babbitt and the land should now be transferred.
> The CA Dept. of Health Services, BLM, USGS, and NAS all agree.
>  The site is safe; the feds should sell the land without
> politically-based conditions and let the state do its job.

Actually, we seem to have missed what is actually important to have emphasized 
to the media/public for the long-term benefit of dealing with LLW (again,
unless there is something I'm missing, which I would very much appreciate
seeing).  

> For technical background data  (as you requested), the best
> resources are the NAS report, CalRad Forum (510-283-5210), and
> USEcology (916-624-9316).

Thanks. I'll contact them, but it looks a little late now to take advantage of 
the window of opportunity lost to communicate with the public, and to recover
from "buying in" to the fostering of public misperceptions about the safety of 
Ward Valley, and radiation and radioactive materials, that Californians for
Ward Valley, and it seems others, including NEI have left us with.  (See my
concerns about the implications to siting at a site that is not as good as
Ward Valley being held up to the standard of this site that is seen as
"marginally acceptable" even by the industry.) 

We, of course, know that's not true; but that's the "message" and the public
perceptions delivered by our public positions (aiding and abetting the anti's
in other forums -- like here in Mass, including the Mass LLRW Management
Board.)  

> If you would like more info on this, please call me at
> 202-739-8119.  Thanks for your interest.

Thanks for your response.  I encourage you to try to establish a better
framework of understanding in your management and sponsoring utilities to try
to avoid continuing with these problems and missed opportunities in the
future. 

Regards, Jim Muckerheide 
Mass. State Nuclear Engineer
ANS Biology & Medicine Div, Low Level Radiation Health Effects Committee Chair

Standard disclaimer: Not speaking for either