From: "Russell D. Hoffman" <>
Subject: EPA Responsibilities to protect the citizens of America start with PREVENTION
Cc:, governor of California

Glenna Shields
Webmaster Radiation Protection Division,
Environmental Protection Agency
Russell D. Hoffman
Concerned Citizen
Carlsbad, CA
Date: December 26th, 2001

Re: EPA responsibilities in an age of reason

Dear Glenna Shields,

Thank you very much for both your recent letters (shown below).  However, they have left me very confused.  Are you saying that the Environmental Protection Agency has absolutely NO jurisdiction regarding nuclear power plants?

There should be at least one other government agency which cross-checks the Nuclear Regulatory Commission.  Who better than EPA?

I received a letter similar to yours from the Occupational Safety and Health Administration (OSHA), stating that they do not have any jurisdiction at nuclear power plants.  I also have received a letter following a FOIA request to CAL-OSHA, which, as far as I can tell, indicates they haven't been on site at San Onofre Nuclear Generating Station (my local nuclear power plant) in years, for any purpose whatsoever (despite having told me differently over the phone).  The California Coastal Commission refuses to consider possible disasters at the plant because they think (erroneously) that safety issues are not their concern, and that the Federal government (specifically the NRC) is supposed to worry about those sorts of things.

Accidents that can doom hundreds of thousands of Americans to cancers, leukemias, and birth defects, in less time than it takes you to read a single syllable of this letter, should not be the sole responsibility of one agency.  The EPA's job is to protect us.  It appears that the NRC thinks its job is to license reactors again and again, until they either melt down, or have so many forced shutdowns after accidents (termed "incidents" by the NRC) that the cost of operation becomes unjustifiable (even for the most subsidized industry in history).

All of the nuclear power plants in the United States are tempting targets for any diabolical terrorist.  These plants are also vulnerable to accidents of all sorts -- from earthquakes to operator errors, and a million things in between.  16 plants which have been shut down permanently still have their spent nuclear fuel located on site, according to a recent USA Today article.  103 more are operating on the brink of disaster, each with yet more spent fuel in pools and piles nearby.    What is EPA going to do about it?  Saying it's not your responsibility is what's called a "cop-out", and the term is very appropriate, since EPA has the authority to walk in today and shut every reactor down by Federal order.  Instead, the agency simply abdicates its responsibilities and authorities.

If the NRC has (according to you) complete responsibility for nuclear power plants, why does the EPA even maintain a Radiation Protection Division?  Because of other radiation in the environment?  Fair enough, in proportion -- but not in exclusion!  As Webmaster, you have a responsibility for providing information that will help the public decide how to spend our precious federal dollars in search of protection from a potentially unhealthy environment.

The NRC routinely ignores systemic problems at nuclear power plants, such as circular cracks around the reactor nozzles (the subject of one of my letters you responded to).  Circular cracks are extremely dangerous, and are suspected at not less than 13 nuclear power plants in America.  These cracks could cause the biggest environmental disaster in American history, and I'm not exaggerating in the least.

If circular cracks around reactor nozzles don't prove that the EPA needs to seriously consider the consequences of a full-scale meltdown at a nuclear power plant, then frankly, I wonder what the purpose of EPA is to begin with.  Every SuperFund site you clean up and check off your list is great, but there is no comparison to stopping the creation of a new SuperFund site in the first place -- especially a new SuperDuperFund site, which is what a nuclear meltdown would create.

Your main priority is not clean-up, it's prevention -- a key element of "protection" as in, "Environmental PROTECTION Agency" (my emphasis, but it should be yours too).

At what point would the Environmental Protection Agency take control, if the Nuclear Regulatory Commission is not doing its job?  I'm quite sure it's appropriate for EPA to take action now.  EPA helps regulate all sorts of industries so that chemical spills and other polluting events never happen in the first place.  Why not here?  My letters to EPA should have, by now, made it clear that there is a serious problem with enforcement of safety regulations throughout the nuclear industry.

The NRC is an ingrown, secretive, unchecked, rogue commission deeply intertwined with the industry it supposedly regulates.  None of the other government agencies at the Federal, State and Local level that normally look over each other's shoulders, look at anything the NRC does.  When it comes to dealing with nuclear power, EPA is surely one of America's last resorts, and after 9-11, we are clearly down to our last resorts.  Terrorists have only to decide it's time to hit America's nukes, and it's over with.  Reports have surfaced that the Al Queda terrorist organization trained 150 terrorists near Three Mile Island.  What warnings are we waiting for, a note hammered to the chain link fence that protects the plant?

The Spent Fuel Pools are particularly vulnerable to terrorists, or to airplanes falling out of the sky for any reason, and many other things such as earthquakes and tornados.  For example, David Lochbaum, Nuclear Safety Engineer at the Union of Concerned Scientists, recently sent me a copy of an NRC document which shows that, as Lochbaum put it, "The spent fuel at [San Onofre] Unit 1 is protected with locked doors to the fuel handling building that alarm if opened improperly. In addition, security personnel check out the area about once every eight hours or so.  If power fails, the alarms on the locks to the doors are disabled as are the closed circuit TV cameras.  Hopefully, security has been beefed up since September 11th with the posting of at least a NO TRESPASSING sign or two."

I'm sure there were many locked doors at the Pentagon (and some NO TRESPASSING signs as well).  In fact, the area hit on 9-11 was of the most modern construction.  It was designed to withstand a considerable intentional assault by heavily armed assailants.  The walls of the area which was hit had been rebuilt recently, and in doing so, were reinforced with Kevlar, which no nuclear plant containment wall has, let alone a Spent Fuel Pool (which were supposed to be temporary storage places).  The terrorists' hijacked airplane crashed through six to eight walls each up to 3 feet thick, making it nearly all the way to the center "Big Brass" ring.

Horrific, but not comparable in any way to a nuclear power plant meltdown.  Nor was what happened at the WTC that day, no matter who calls it "Ground Zero" now, and no matter what people thought they had been hit with at the time it happened, with all that awful dust billowing out, and debris raining down.  True, some major buildings were pancaked, but NYC did not suffer a total blitz like Hiroshima or Nagasaki, whose combined dead for those small cities was about two orders of magnitude more than NYC's losses on 9-11.  Millions would now be dead now if NYC had been attacked with nuclear weapons.  But how could the terrorists do such a thing?

Mentally, how they could do it, I don't have any idea, but as to what steps it would take, there are only two choices: Somehow acquire a nuclear bomb, smuggle it into the city, and then set it off.  Or simply attack Indian Point with a small but well-trained group of terrorists.  That too, would kill millions.  Right now, there is a combined sixty-five years of nuclear waste stored at Indian Point.  That's an awful lot of so-called spent fuel that has piled up there.  It's not going to Yucca Mountain any time soon, if it gets there at all (and there are, of course serious scientific and political problems with Yucca Mountain).  Where is EPA regarding the need to shut down Indian Point?  Asleep at the pool when you're supposed to be the lifeguard!  Well, nearly all the pools across the nation are dangerously overcrowded.

The NRC, who is supposed to be watching over our safety regarding nuclear power plants, so that the EPA can go worry about other things, is lax and ineffective.  In short, they use their isolation to hide problems and keep a deadly industry going when it should be shut down, rather than to protect the public within their special skills and training, as one would have hoped.  The fact is, the necessity for most of their jobs requires that the plants stay open.  Furthermore, most of them worked at the plants before switching to the regulatory side, so they have many friends and even family that work at the plants, or who were in the Nuclear Navy at some time, where most of them originally were trained, making them all fraternity brothers, etc..  They won't break ranks to save your life.  And I mean that quite literally.  Where we need whistleblowers, we have stoney silence or -- worse -- lies.

We need some new viewpoints -- new, unbiased experts looking at these problems in light of 9-11, and at the numerous indications of problems long before 9-11, regarding the NRC's failure to serve the public good by risking phenomenally more death and destruction than any other human endeavor in history, and for nothing in particular that we can't get some other way (renewable energy could easily replace nuclear's 18% contribution to our electrical energy grid).

The situation is truly madness.  How it got that way is another story, but here we are.  No one is really minding the ship, although the NRC say they are, and you say that's okay with the EPA.

Last summer the Primary Containment Vessel at Monticello nuclear power plant was found to have been inoperative since the plant was built, because four sets of shipping bolts were left on eight "bellows", when the bellows were installed 30 years ago (total: 32 huge bolts that had not been removed).  Nobody checked until last summer, when a similar problem was discovered at another plant.

I recommended a fine of $100,000,000,000.00 (one hundred billion dollars).  As far as I know, there wasn't any fine at all.  Why can't EPA impose a fine for such a blatant disregard of public safety?  Why can't EPA close Monticello down?  After all, it's a Mark 1 GE reactor -- probably the most dangerous type.  Some experts say that if we have a meltdown in America, it will almost surely be a GE Mark 1 reactor.

How many close calls does it take to scare America and wise us up?  Obviously, for the nuclear industry and the NRC, only an accident will do (or maybe two or three).  But EPA and the public should choose NOT to wait that long!

Frankly, after 9-11, it's clear that anyone who supports nuclear power has A LOT of explaining to do.

It's time to close the plants and move on to clean energy solutions.

Here's an example of information which should be available from EPA, not just from NRC (where basically none of it is available, at the moment).  It is a list of all nuclear power plants in America, with various facts and figures for each one:

USA TODAY also recently published a table of nuclear power plants (Dec. 13th, 2001), so these are hardly state secrets.  (The USA Today table doesn't have as much detailed information as the table I'm building, but all my information is publicly available, and sources are presented throughout my document.)  My list includes summary information from a report known as CRAC-2 (which is the Federal government's latest available estimations of casualties from nuclear power plant accidents (1982)).  It also includes the "Ultimate Heat Sink" for each plant.  Please review those two columns in particular.  The rivers, lakes, and oceans, which act as ultimate heat sinks for the plants, surely fall under EPA jurisdiction, as does the air and land, not just around the plant, but around the planet.

EPA should take on the job of updating CRAC-2, and post the updated version at the Radiation Protection web site you are the webmaster of.  Feel free, if you like, to start your project by using my Nuclear Power Plants In America list.

Here are some additions I plan to add to my list:

*** Multiple 24/7 web cameras aimed at each plant -- and on site (even in the control rooms of the plants, if I can swing it. It may require some sort of lawsuit for me to do this, but hey, no one said this would be easy for a small band of dedicated activists.  I imagine EPA might have an easier time of it.)

*** Geiger counters sending information to a centralized location where it is tabulated, checked for reasonableness (faulty reading, no reading, or perhaps a Chernobyl in the making), and turned into a graphical real-time display.  This will require getting lots of citizens to acquire Geiger counters, and then connect them to their PCs, and then connect their PCs to the Internet, but I'll offer tips on how to do that (as soon as I can figure it out myself!).

*** Wind Roses, including the current winds around each plant.  This is the most important piece of information, really.  If there is a large release of radiation, death will spread quickly downwind.  But since the plume will be odorless, colorless, and tasteless (in more ways than one), people will not know how to escape it, other than to get in their gas-guzzling car (if they have one) and head away from the plant.  That might not be nearly good enough.  I hope to be able to download NOAA information in real time for this feature, and not have to rely on the hard labor of yet more activists.

*** Evacuation plans -- who to contact, where to go, how to get there.  About 8% of Americans live within 50 miles of Indian Point Nuclear Generating Station in New York, while about 2/3rds of all Americans live within 50 miles of some nuclear power plant.  In searching for information about the plants online, I have only found one plant that had scanned in an evacuation map  (it was pretty low resolution), and it was only for 10 miles, and didn't have any real-time information about traffic conditions along the evacuation routes.  One or two other plants' web sites have contact information for the local police and fire departments, and which radio stations are supposed to announce bulletins.

*** Number of Curies of radioactive materials, and which materials, are at each site.

I hope that in the near future I will be able to cease my personal attempt at tabulating all this important information, because EPA will have taken it upon themselves to do an official government version which is vastly more comprehensive than mine can ever be.  I know you say you are short-staffed, but compared to me, I'd have to say you still have the edge.

If you build such a site, please be sure to include two important items that I've included in my list, namely, the local activist organizations and the history of accidents and incidents (and releases) at the plants.

Thank you again for your letters.


Russell D. Hoffman
Concerned Citizen
Carlsbad, CA

Below are three items:  First is a letter from Jack Shannon, followed by your two recent letters to me (the items they respond to, which were included in your emails, are posted online and links to those items have been included).


At 07:51 PM 12/25/01 , Jack Shannon <> wrote:

We have added a few pages to our web site to show how the EPA, DOE, NYS
Attorney Generals Office, Navy, NYS Governors office, NYS DEC as well as
others have undertaken illegal actions to cover-up the KAPL landfill and the
fact that NY State has had jurisdiction over this landfill since 1989 and
have been lying to us for 12 years concerning such jurisdiction.

As a matter of fact, earlier this year the NY State Attorney General's Office
[Judith Enck] told us that it would take years of litigation by 30 lawyers
for NY State to get jurisdiction to uncover the landfill so we could find out
what "really" is in the landfill.

We will keep you posted.

So much for honesty in government.

Jack Shannon
look under landfill for the various letters, especially the 1989 letter from
the NYS DEC to Andrew Seepo asking him to explain discrepancies between a Jan.
1986 letter and an April 1986 letter to the DOE. It is very interesting what
information was left out of the April 1986 letter compared to the Jan. 1986

These criminals should all be in jail, or worse.

Jack Shannon


At 04:59 AM 12/19/01 , wrote:

Dear Mr. Hoffman:

Thank you for your e-mail. EPA's only role in Yucca Mountain was to set
the Public Health and Environmental Radiation Protection Standards.  The
proposed Yucca Mountain repository is a project of the US Department of
Energy.  The Nuclear Regulatory Commission is charged with oversight of
civilian Nuclear Power Plants. The US Department of Transportation is in
charge of setting the routes for transport of nuclear waste to Yucca

I suggest that you contact these entities for assistance with your
concerns. If you have questions or comments that pertain to EPA's
mission, we will be able to assist you.


Glenna Shields


Note: Glenna Shields' above letter included my letter of Dec. 18th, 2001 to Deseret News, posted here:


At 07:48 AM 12/17/01 , wrote:

Dear Mr. Hoffman:

We have been receiving your letters, which began shortly after September
11th.  Your main focus seems to nuclear power plants.  This is the
perview of the Nuclear Regulatory Commission, rather than the
Environmental Protection Agency.  If you have questions relating
directly to the mission of EPA, we would look forward to receiving them.

However, we have limited staff to process incoming e-mails and need to
devote our resources to responding to those whom we can assist directly.


Glenna Shields
Webmaster Radiation Protection Division


Note: The above letter from Glenna Shields included my letter of Dec. 6th, 2001 to the Toledo Blade, which is posted here: