When Michael Kohn of Pa`ina Hawai`i first publicly floated the idea of building an irradiator for quarantine treatment of exports of Hawai`i-grown produce in mid-2005, he talked of having the facility up and running by February 2006.
A year after Kohn’s anticipated start-up date, the plant still has not left the drawing board. A draft environmental assessment, which Kohn had argued was not required, was made public only in late December. The Nuclear Regulatory Commission scheduled a public meeting to accept comments on the document and the proposed Finding of No Significant Impact for February 1 in Honolulu.
For all the time it took to produce the document, it is surprisingly short – barely 12 pages for the text, plus two pages of references and an appendix consisting of five schematic drawings of the irradiator’s components. A separate draft study, the “Topical Report on the Effects of Potential Natural Phenomena and Aviation Accidents,” analyzes more thoroughly the probability of catastrophic events that could conceivably lead to the release of some of the 1 million or so curies contained in the irradiator’s Cobalt-60 heart, submerged in normal operations in an 18-foot-deep pool of water.
Kohn says he is happy, but not surprised, at the outcome. He did not want the EA to be prepared in the first place, arguing that the NRC’s rules make preparation of the document unnecessary. With no technical expertise of his own, he said, “I have to go along with what the NRC says… I think it is a thorough document. It addresses exactly the concerns of Concerned Citizens of Honolulu, which were tsunamis, hurricanes, and of course airline crashes.”
David Henkin, an attorney with the public interest law firm Earthjustice, represents Concerned Citizens, an ad hoc group opposing the planned irradiator. He does not share Kohn’s confidence in the NRC’s experts, pointing out – as just one example of their incompetence – the claim in the “Topical Report” that the island-wide blackout on O`ahu following the October earthquakes resulted from a power outage that had its source on the Big Island. “Any person in the street could refute one of the experts’ conclusions, which is that the earthquakes caused a ripple blackout in the state,” Henkin said. “Anyone who pays an electric bill is aware that we don’t have a statewide power grid. This is just the type of palpable, easy to counter example of why one should have no faith in this cursory analysis” of the safety and health risks of the irradiator.
‘Small Beneficial Impacts’
The irradiator, as proposed, will use a sealed unit containing up to a million curies of Cobalt 60 as the source of gamma radiation. The unit will be submerged in an 18-foot-deep pool, most of which will be below ground level. Cases of produce will be lowered in a box-like diving bell into the pool. There, the fruit will be irradiated to levels required to satisfy U.S. Department of Agriculture quarantine rules for irradiated exports from Hawai`i. (Because Hawai`i is infested with fruit flies, the USDA requires quarantine treatments for exports to the continental United States of many local-grown fruits, but irradiation is only one of the several accepted quarantine treatments.)
Based on the draft EA, the NRC staff issued a preliminary finding of no significant impact. Construction impacts would be limited because of the small size of the building, the document states. Also, operational impacts would be small: “there are no known land use restrictions that would be created by construction and operation of the proposed Pa`ina irradiator,” and “public and occupational health impacts are expected to be small as the expected doses would be well below regulatory standards.”
But if the impacts are small, so, too, is the benefit, if any, according to the draft EA. “The proposed irradiator would potentially have small beneficial impacts to socioeconomics… The NRC staff finds that the proposed irradiator would have no significant impacts on socioeconomics.”
Any benefit to the state’s flora and fauna, beleaguered by introduced pests, would be negligible as well, according to the draft EA: “The NRC staff finds that the proposed irradiator would have no significant impact on ecology.”
Kohn said, “I don’t know how they determined that the economic impact would not be significant. I don’t know their measure of what is significant. But I can tell you that for us, and farmers on O`ahu and on the Big Island, this is very, very significant.”
Henkin argues, “where there is minimal upside benefit, we should be loath to pursue a project with such potentially significant downsides, even if it is a once in 5,000 years chance – which, if they operate for 10 years, translates to a one in 500 chance.”
Accidents, Disasters, and ‘Abnormal Events’
One of the more controversial discussions in the brief draft EA concerns the analysis of possible consequences of aircraft accidents, natural disasters, and “abnormal events.”
The probability of an aircraft accidentally crashing into the irradiator building, NRC staff states, is about once every five thousand years. Even should that occur, the document states, “It is highly unlikely that a Co-60 sealed source would be breached in the event that an aircraft crashes into the proposed facility.”
The draft EA also discounts the likelihood that an earthquake could dislodge the radioactive source from the pool: “a seismically-induced radiological accident is considered negligible due to the nature of the facility and the seismic hazard for the site… The earthquake ground motions for the site are insufficient to damage the proposed facility to the degree necessary to dislodge Co-60 sources from the pools.”
Much the same determination was made with respect to possible tsunami damage. Not only would any tsunami wave have insufficient force to dislodge the irradiator source, the draft EA states, the force of even the greatest tsunami would be attenuated by the time it reached the irradiator pool “because [of] the distance between the coast and the irradiator facility and the barriers to water flow imposed by near-shore obstructions, including the building facility and the presence of other debris.” The distance between the proposed irradiator and the shore is just a few dozen yards. Hurricane damage would be even less likely, with “the wave velocity associated with a storm surge … significantly less than that associated with a tsunami.”
Consideration of “abnormal events” centers on possible disruptions in the normal operation of the irradiator. Could, for example, water be drained from the pool if an air supply hose breaks? (The air supply line keeps the produce to be irradiated dry while it is in the ‘diving bell.’) No, the document states: The worst that would happen is “the product would become wet” but it could still be removed from the pool. In any event, the EA says, “a curved stainless steel extension is fitted to the top of each bell to prevent radiation streaming and radiation damage to the flexible air line.”
Kohn said that with 330,000 operations (take-offs and landings) at the airport each year, the probability of any given aircraft crashing into the irradiator is 1.65 billion to one – “a very unlikely probability,” he said.
Even so, Kohn was asked, given the huge costs to the public of dealing with a catastrophe involving the release of up to a million curies, is it fair to ask the public to assume such a risk, especially given that the NRC determined the economic impact would be all but imperceptible?
“I understand what you’re asking about the public costs,” Kohn replied, “but nothing in the world is without risk. And what is the risk of not having the irradiator? If we don’t have irradiation any more in this country or in Hawai`i, that means we’ll have dirty medical equipment, no radiation treatment, no metal testing.”
Henkin dismissed the notion that denial of the irradiator license would have any bearing at all on the acceptability of other nuclear technologies, such as the beneficial use of X-ray machines, nuclear medicine, or engineering applications. “Each project needs to be evaluated on the costs to society as well as the benefits. Zapping fruit at a cheap location just so Kohn can earn some pocket change does not justify the risk to Hawai`i’s people,” Henkin said.
In any case, none of those applications involve anywhere near the 1 million curies that the irradiation facility Kohn wants to build would be licensed to contain.
True, Kohn said, “but we’re not going to use 1 million curies. More likely, we’ll have between 100,000 and 200,000 curies. It makes no economic sense to have 1 million.”
Unlike Kohn, Henkin finds the calculations of the likelihood of disaster scenarios unsettling. “It is incredible that the NRC would calculate a frequency of hitting the facility as a once-in-5,000 years likelihood. That’s a high likelihood, compared to the standards normally applied to nuclear reactors, where the likelihood has to be no more than one in 10 million. For nuclear storage of fissile waste, it has to be one in a million.
“Also noticeably lacking are any calculations or discussions as to what effect might be of an aircraft impact and subsequent explosion, assuming it’s weighted down with fuel, on the cobalt sources in the irradiator.”
Breaching the Source?
Kohn accepts the conclusion in the environmental assessment that the container holding the cobalt would not be breached in any case. “The cobalt is double encapsulated in some very special alloys … tested under very, very extreme circumstances. For that to break or melt, you’d have to have an enormous impact,” he said.
Henkin disagreed. The containers are designed to withstand an impact of a 2.5-centimeter, 2 kilogram object dropped from the height of one meter, he said. “So drop a heavy fishing weight off an ironing board onto this source – that’s the limit of what it is designed to withstand.
“But here you have the possibility of an airplane smashing into this facility and then blowing up, and in the process dispersing pieces of metal and fragments of the irradiator facility – presumably items in excess of an inch in diameter and more than four-and-a-half pounds that will be hurtling at speeds greatly in excess of the acceleration you’d get from dropping them from a one-meter high surface.”
Nowhere does the draft environmental assessment or technical report consider the possibility that radioactive material might be dispersed or the container for the cobalt breached. “They need to determine the probability for dispersal,” Henkin said. “There’s no discussion of the extent to which the containment could withstand heat. They literally wave a wand and say you’d need a larger force” than an airplane crash.
“You’d think there would be some calculation about the force of an explosion resulting from a commercial airliner crashing into this facility and how that might compare to the minimal standards that these sources must meet. But there’s no discussion of forces that have anything to do with accidental, much less intentional, impact on these sources.
“The discussion in the draft EA is grossly inadequate and provides no quantitative analysis that would give anyone any confidence in the qualitative statements made” that no impact would result from a crash, he said.
Alternatives?
An essential element in any environmental assessment is a discussion of alternatives. The irradiator draft EA states that the “no-action” alternative, which would be denial of Pa`ina Hawai`i’s application for a license from the NRC, would result in “small changes to current environmental impacts” and “small economic impacts.”
The document also considers “alternative quarantine control technologies,” including fumigation by methyl bromide gas and various types of heat treatment. Methyl bromide has drawbacks, the draft EA notes, including its cost and the harm it inflicts on stratospheric ozone when released into the environment. Heat treatment of fruit is another alternative mentioned in the draft EA, but the only type of treatment discussed is the hot-water bath. This, the document says, is not approved for papayas (although other forms of heat treatment are regularly used). In addition, it notes, the hot-water bath is not recommended for grapefruit, plums and peaches – none of which, however, are produced in Hawai`i in commercial quantities.
But the document does not mention alternative irradiation technologies that do not involve use of a radioactive source, such as electron-beam technology, in use on the island of Hawai`i for the last five years.
Nor does it analyze alternative sites. According to Kohn, this is because the stipulation between the facility’s opponents and the NRC that called for preparation of the draft environmental assessment – and to which Kohn was not a party – limited the evaluation of sites to the specific airport site. “The stipulation said that alternative sites will not be considered,” Kohn said. “So if anyone is to blame for the fact that they were not considered, it’s David Henkin, who agreed to the stipulation.”
Henkin disagreed vehemently: “The stipulation says only that ‘the NRC shall prepare an environmental assessment for the applicant’s proposed irradiator to determine whether to prepare an environmental impact statement or a finding of no significant impact.’ It does not say they can ignore considering reasonable alternatives, including alternative technologies and alternative sites, nor does it say they can fail to consider terrorism threats. The failure to consider reasonable alternatives alone renders this EA unlawful.”
Irradiator Documents Available Online
The draft environmental assessment for the Pa`ina Hawai`i irradiator is available on the NRC’s virtual reading room, [url=http://adamswebsearch.nrc.gov]http://adamswebsearch.nrc.gov[/url] Once on that site, you can call up the draft EA by typing the accession number ML063470231 into the query area. This will lead you to a link and allow you to call up the document either in a large pdf file or in HTML format. Comments are accepted through February 8.
On February 1, the NRC will sponsor a public meeting to present an overview of the draft EA and to accept oral and written comments. The meeting, at the Ala Moana Hotel in Honolulu, will begin with an informal open house at 6 p.m., with the NRC’s presentation beginning at 7. An opportunity for public comment will follow.
— Patricia Tummons
Volume 17, Number 8 February 2007
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