The draft EA inaccurately downplays the likelihood of an aviation accident at the irradiator because it uses data that are over thirty-years old and fails to consider that "air crash data for [Honolulu airport] is higher than the national average," noted Dr. Marvin Resnikoff, a physicist at Radioactive Waste Management Associates. Using the correct data, Dr. Resnikoff concluded the annual risk of an airplane hitting the proposed Pa'ina irradiator at more than 1 in 2,000. That is two and one-half times the risk the EA assumes and 500 times the crash probability the NRC customarily accepts. Dr. Resnikoff criticized the EA for refusing to look at alternatives involving moving the proposed irradiator a mere 10 miles away from active runways at the airport, which would reduce the risk of aviation accidents "by a factor of 1000."
The public should take no comfort from the EA's claim it has nothing to fear in the event an airplane strikes the irradiator, concluded Purdue University Professor of Structural Engineering Mete Sozen and Professor of Computer Science Christoph Hoffmann. Using a computer simulation model commonly relied on by government laboratories, Professors Sozen and Hoffman found that "the effects of a plane crash on an industrial building housing a nuclear irradiator would be devastating." The force of a crash or the associated "high-temperature conflagration" from burning fuel could damage the irradiator pool, "causing the water shielding the Cobalt-60 sources to drain out." In addition, "[f]lying debris could breach the [radioactive] source assembly or pool." In all of these instances, Professors Sozen and Hoffman found that "radioactive Cobalt-60 could be introduced to the human environment." They faulted the NRC for not analyzing these threats in the EA.
The EA also fails to discuss the potential for terrorist attack on the Pa'ina irradiator, which, according to Institute for Resource and Security Studies executive director Gordon Thompson, "might be especially attractive to attackers because of the proximity of military and symbolic targets including Hickam Air Force Base and Pearl Harbor."
"Only last year, the Ninth Circuit Court of Appeals told the NRC it has to examine terrorist threats before licensing nuclear facilities," explained Earthjustice attorney David Henkin. "So the NRC's refusal to respond to the public's concerns here is inexcusable."
Likewise, the EA fails to discuss the public health threats associated with increasing the supply of irradiated food for human consumption, the primary purpose of the proposed irradiator. Recent studies have shown that eating irradiated food, such as the mangoes and papayas proposed for treatment at the Pa'ina irradiator, may promote colon cancer, noted Dr. William Au, Professor of Preventive Medicine and Community Health at the University of Texas Medical Branch in Galveston, Texas. Dr. Au emphasized colon cancer is "a serious health problem in humans, causing approximately 60,000 deaths per year in the United States."
"The EA concludes the irradiator's economic benefits would be 'small' and the alleged reduction in invasive species would be not be significant," noted Earthjustice's Henkin. "While this project may be good for Pa'ina's bottom line, given all the risks involved, it clearly is not good for the people of Hawai'i."
The NRC is holding a public hearing to accept comments on its draft EA from 6 to 9 p.m. on Thursday, February 1, 2007, at the Ala Moana Hotel, 410 Atkinson Drive, Honolulu. The NRC is also accepting written comments until February 8, 2007, which should be mailed to: Chief, Rules Review and Directives Branch, Mail Stop T6-D59, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or emailed to: NRCREP@nrc.gov. Written comments should mention "Docket No. 030-36974."
David Henkin, Earthjustice, (808) 599-2436