EPA, Federal Agency oversight, Federal Government, France, Fukushima, Germany, government oversight private contractors, Homeland Security. Nuclear safety, Japan, NAREL, Office of Air and Radiation, Office of Inspector General, OIG, Radiation Network Europe, Radiation Network Germany, Radnet, Radnet failures, Romania, United States of America, US, US environmental protection agency, US Federal Government, US radiation network, US. Radiation monitoring, USA, Wyoming
At the time of the Fukushima disaster 1/5th of the US’ radiation monitors had been out of service for, on average, 130 days. Additionally half of those sampled had not had their filters changed as required. The RadNet program was supposed to be prioritized for Homeland Security and has been reprimanded repeatedly. Perhaps more shocking is that there were only 124 fixed radiation air monitors on the entire US territory and only 99 were operational. Currently there seem to be only 125 fixed monitors. The State of Wyoming, where Russia now owns a uranium mine, has no fixed air monitor and appears to have no US EPA radiation monitoring at all. http://www.epa.gov/radnet/radnet-data/index.html#states We hope that the state EPA (i.e. DEQ) is monitoring.
The US Environmental Protection Agency (EPA)’s Office of Inspector General (OIG) calls the problems “weaknesses”, but we consider them failures. Note that unlike some, we do not take joy in bashing government workers. Many government agencies suffer from staff shortages and those that remain work very hard. Still, we can see no justification for these failures. In fact, if you make it to the end of this post you may, like us, feel sorely tempted to hang the Head(s) of the US EPA’s Office of Air and Radiation upside down suspended by their toenails, due to their response to the Office of Inspector General. The Office of Air and Radiation says that they have as goal to keep a minimum of 80% operational (i.e. 20% broken) and intend to continue using less than 1/3rd of the required filters. http://www.epa.gov/oig/reports/2013/12-P-0417_Agency_Response_Initial.pdf In other words the Office of Air and Radiation intends to change little to nothing despite the Inspector General (OIG) Report. With the overinflated US budget the EPA appears committed to cutting corners on this.
According to the 2012 OIG report on the situation, the problem was (is?) due to lack of oversight of private contractors by the EPA. Although the EPA OIG calls for the contractors to be held responsible, their report was only produced after most of the contracts had expired, so that contractors could not be penalized, or so claims the Office of Air and Radiation. It appears that only those contractors who had failed to install the new monitors could be held accountable and were supposed to have installed the additional monitors by September 30, 2013. It is unclear if these have been installed as we count only about 125 fixed air monitors on the RadNet site. Those who failed to deliver parts for repairs apparently could not be held accountable, according the Office of Air and Radiation.
At the time of Fukushima, on March 11, 2011, 25 of the 124 installed RadNet monitors, or 20 percent, were out of service. They had been out of service for an average of 130 days. All monitors were reported to have been repaired by April 8, 2011. In addition, 6 of the 12 RadNet monitors sampled by the OIG had gone over 8 weeks without a filter change; two of those for over 300 days. The filters are supposed to be changed twice a week. There are about 125 monitors; 52 weeks in the year, so this should be 13000 filters, whereas one Office of Air and Radiation letter to the OIG http://www.epa.gov/oig/reports/2013/12-P-0417_Agency_Response_Initial.pdf says that NAREL counts on processing only 4000 filters per year. This may be why the Office of Air and Radiation was arguing endlessly to the EPA OIG Inspector that they did not need to change all filters so frequently. 4000 filters for 125 monitors would be only 32 filters per year, which would mean changing the filters between every one and a half to two weeks rather than twice a week, barring emergencies! If the 4000 filters are also for the portable radiation monitors then change would be even more infrequent.
Arrogantly, the Office of Air and Radiation expressed to the Inspector General, an intent to maintain as many as 20% of the RadNet monitors down:
Response: The RadNet mission and objectives provide a broad framework for providing data and information; therefore, the network does not lend itself to defining one number as indicating ‘operational readiness.’ However, EPA keeps as many monitors operating as possible and has established a goal ofhaving at least 80% ofthe monitors operating at all times. http://www.epa.gov/oig/reports/2013/12-P-0417_Agency_Response_Initial.pdf These people are not serious in their work!
Although RadNet is supposed to be prioritized for Homeland Security, its larger importance lies in monitoring nuclear power plants. Lack of appropriate monitoring of US Nuclear Power Plants can have international repercussions.
It is very shocking to compare the US Radnet to Europe’s Radiation network, and especially to Germany’s.
United States Area is 3.794 million sq miles (9.827 million km²); 104 nuclear reactors; 125 fixed monitoring stations
Germany, with an area of 137,846 sq miles (357,021 km²) is about 1/27th of the US (if it were a state it would be only the 5th largest) has 9 nuclear reactors and 1800 monitoring sites
http://odlinfo.bfs.de Yes, that’s right: one thousand and eight hundred gamma monitoring sites for Germany. And, they are phasing out nuclear energy whereas the US is constructing more-compare to US 104 reactors and 125 fixed air monitoring sites.
The EU has 131 nuclear reactors (this may or may not include the Swiss ones which lie outside of the EU), compared to 104 for the USA. The USA appears to have about 125 fixed (stationary) RadNet air monitors (as well as 40 mobile ones), which are checked in “almost real time” for gamma and possibly beta radiation, with what is supposed to be detailed filter evaluation checks twice weekly (but in reality the EPA-NAREL wants it to be twice monthly). There is also some monitoring of precipitation, drinking water, and milk, although not necessarily at the same site as the air monitoring. Europe has around 4612 gamma measuring sites, with 201 air, water and soil sites (Germany reports having 6 more than listed here). Of the 201 air, water and soil radiation monitoring sites, 27 are in Russia.
France has 58 or 59 nuclear reactors with 686 gamma monitoring stations but no air, water, soil testing stations, which is really very shocking, but not surprising to us. The only countries with air, water, soil testing for the European area are Switzerland (not in EU, it has 10 AWS sites); Czech Republic (10 AWS sites); Germany (41 AWS sites); Estonia (3 AWS sites); Spain (3 AWS sites); Finland (8 AWS sites); Croatia (2 AWS sites); Netherlands (14 AWS sites); Norway (5 AWS sites); Poland (7 AWS sites). Romania should be especially mentioned as with 92,043 sq miles (238,391 km²) and only 2 reactors it has 105 gamma monitoring sites and 70 air, water and soil sites.
With these thoughts in mind, here is the EPA’s OIG reprimand of those responsible for the US RadNet program – apparently the EPA’s Office of Air and Radiation:
“Weaknesses in EPA’s Management of the Radiation Network System Demand Attention, Report No. 12-P-0417, April 19, 2012” by US EPA, Office of Inspector General
EPA, Office of Inspector General quote:
EPA’s RadNet program will remain vulnerable until it is managed with the urgency and priority that the Agency reports it to have to its mission, and that is also reflected in the National Response Framework for Nuclear Radiological Incidents. If RadNet is not managed as a high-priority program, EPA may not have the needed data before, during, and after a critical event such as the Japan nuclear incident. Such data are crucial to determine levels of airborne radioactivity that may negatively affect public health and the environment.”
Although this was reported on April 19, 2012, this remains shocking and worrisome. Why was and presumably still is something so important as US Environmental Protection Agency (EPA) Radiation Monitoring being run on volunteerism in a country with such a huge budget as the USA? How is that an excuse for not changing filters, etc? Volunteerism can be professionally run!
p. 11: “…operators are unpaid volunteers from a variety of federal/state/local agencies, universities, and colleges, RadNet filter changes may not be the top priority for all operators.”
Why all the foot-dragging on a topic so essential? This reminds us of the US Department of Energy’s foot-dragging over the Hanford Nuclear Waste site. The US EPA’s Office of Air and Radiation, and the US DOE, both seem to have taken Scarlett O’Hara’s mantra to heart – “After All Tomorrow Is Another Day!” and forgotten the older mantra of Ben Franklin: “Don’t put off until tomorrow what you can do today!”.
New monitors were to be in place by September 30, 2013. Were they? Is that sufficient? From the report, it seems that the primary problem was the parts contractor failing to send the parts for repairs in a timely manner. However, replies to the OIG by the Office of Air and Radiation make it appear that they did not want them repaired or did not care. The Office of Air and Radiation has as its goals to maintain up to 20% broken and to save filters. Where’s the news reporting on this? It seems that the case file was closed with the Office of Air and Radiation trying to figure out excuses to change the filters less frequently and the EPA’s OIG accepting this. It is clear that the stated problems remain. Those in the US may want to avail themselves of the phone number listed below.
What are the repercussions of having no real baseline predating the Fukushima disaster? What about for a Fukushima like disaster in the US or Canada? What are the repercussions of having so few monitors and a decision to keep up to 20% inoperable at all times? And to not change the filters often? This means that there will be fewer in operation than there are nuclear reactors in the US. How can-could the EPA monitor US nuclear sites without adequate or accurate monitoring devices?
Some excerpts from this document (followed by 2013 letters discussing the case):
“Weaknesses in EPA’s Management of the Radiation Network System Demand Attention
The U.S. Environmental Protection Agency (EPA) Office of Inspector General (OIG) sought to determine whether EPA is following quality control procedures to ensure that data submitted from Radiation Network (RadNet) monitors nationwide are reliable and accurate, and whether EPA effectively implemented corrective actions in response to the EPA OIG’s January 27, 2009, audit report on RadNet.
EPA’s December 2004 Critical Infrastructure and Key Resources Protection Plan identified RadNet monitors as critical infrastructure. The mission of RadNet is to monitor environmental radioactivity in the United States to provide high-quality data for assessing public exposure and environmental impacts resulting from nuclear emergencies, and to provide baseline data during routine conditions. RadNet played a critical role in monitoring radiation levels in the United States during the March 2011 Japan nuclear incident.
For further information, contact our Office of Congressional and Public Affairs at (202) 566-2391.
What We Found
Broken RadNet monitors and late filter changes impaired this critical infrastructure asset. On March 11, 2011, at the time of the Japan nuclear incident, 25 of the 124 installed RadNet monitors, or 20 percent, were out of service for an average of 130 days. The service contractor completed repairs for all monitors by April 8, 2011. In addition, 6 of the 12 RadNet monitors we sampled had gone over 8 weeks without a filter change, and 2 of those for over 300 days. Because EPA managed RadNet with lower than required priority, parts shortages and insufficient contract oversight contributed to extensive delays in fixing broken monitors. In addition, broken RadNet monitors and relaxed quality controls contributed to the filters not being changed timely. Out-of-service monitors and unchanged filters may reduce the quality and availability of critical data needed to assess radioactive threats to public health and the environment.
EPA remains behind schedule for installing the RadNet monitors and did not fully resolve contracting issues identified in the OIG’s January 2009 report. Until EPA improves contractor oversight, the Agency’s ability to use RadNet data to protect human health and the environment, and meet requirements established in the National Response Framework for Nuclear Radiological Incidents, is potentially impaired.
What We Recommend
We recommend that the Assistant Administrator for Air and Radiation establish and enforce expectations for RadNet operations readiness. We recommend improved planning and management of parts availability, monitoring of filter replacement and operators, and monitoring of the installation of the remaining RadNet monitors. Further, we recommend that the Assistant Administrator, in conjunction with the Assistant Administrator for Administration and Resources Management, hold contractors accountable by establishing milestones, using incentives and disincentives, requiring contracting officers and contracting officers’ representatives to formally evaluate RadNet contractors annually, and ensure that the Agency’s Management Audit Tracking System is accurate and current. The Agency concurred with the recommendations except for developing metrics for evaluating frequency of filter changes and completing contractor performance evaluations, which is considered unresolved. The Agency also proposed revised language, which we incorporated where appropriate.
“EPA’s RadNet System
RadNet, a national network of monitoring stations, provides real-time monitoring of environmental levels of radiation in the United States. Monitoring stations regularly collect air, precipitation, drinking water, and milk samples for analysis of radioactivity. RadNet has three objectives:
Provide data for nuclear emergency response assessments
Provide data on ambient levels of radiation in the environment for baseline and trend analysis
Inform the general public and public officials about radiation levels
EPA’s RadNet system consists of 124 stationary (fixed) monitors and 40 deployable air monitors that can be sent to take readings anywhere in the country (figure 1). Our audit focused on EPA’s stationary RadNet air monitoring system.
EPA Not Managing RadNet as a
Broken RadNet monitors and late filter changes impaired this critical infrastructure asset. On March 11, 2011, at the time of the Japan nuclear incident, 25 of the 124 installed RadNet monitors, or 20 percent, were out of service for an average of 130 days. In addition, 6 of the 12 RadNet monitors we sampled (50 percent) had gone over 8 weeks without a filter change, and 2 had gone unchanged for over 300 days because they were broken. Unless EPA grants an extension, the repair services contract requires a service contractor to fix broken monitors within 14 days of EPA’s notification that a monitor is out of service. The EPA 2010 QAPP required operators to change filters on fixed RadNet real-time monitors twice a week. Because EPA did not manage RadNet as a high-priority program, parts shortages and insufficient contract oversight contributed to the extensive delay in fixing broken monitors. Out-of-service monitors and unchanged filters may reduce the availability and quality of critical data needed to assess radioactive threats to public health and the environment.
Contract and QAAP Define Repair and Filter Change Time Frames
EPA included terms and conditions in the RadNet repair and maintenance services contract to define the period of time for repair. In May 2008, EPA awarded a RadNet repair and maintenance service contract that requires the contractor to fix broken monitors within 14 days of being notified by the COR. EPA may permit an extension of this 14-day period for a specific repair for reasons including unavailability of government-furnished property (GFP), operator unavailability, and physical disruption of the site. EPA acquires the GFP from the contractor that was awarded the propriety spare parts contract.
EPA’s 2010 QAPP states that RadNet air station operators collect air particulate filters twice a week and mail the filters via the U.S. Postal Service to NAREL for analysis. When elevated levels of radioactivity are anticipated or known to exist, EPA may request RadNet station operators to increase the sampling frequency and use priority shipping.
One in Five RadNet Monitors Out of Service an Average of 130 Days
At the time of the Japan nuclear incident, 25 of the 124 installed monitors, or 20 percent, were out of service for an average of 130 days (appendix B and figure 2). The 25 out-of-service monitors were located throughout the country, except for the northwest portions of the United States (figure 3).
Figure 3: Map of 25 monitors out of service at the time of the Japan nuclear incident
While the RadNet repair services contract requires the contractor to make the repair within 14 days of being notified by EPA, unless extended, EPA permitted 9 of the 25 monitors to remain out of service for more than 140 days because it did not notify the contractor until parts were available. In addition, two monitors were out of service because no operator was available (table 2).
EPA’s RadNet program will remain vulnerable until it is managed with the urgency and priority that the Agency reports it to have to its mission, and that is also reflected in the National Response Framework for Nuclear Radiological Incidents. If RadNet is not managed as a high-priority program, EPA may not have the needed data before, during, and after a critical event such as the Japan nuclear incident. Such data are crucial to determine levels of airborne radioactivity that may negatively affect public health and the environment.
EPA Should Improve RadNet Contract Oversight
EPA did not fully resolve contracting issues identified in the OIG’s January 2009 report. We found that incentives and disincentives for contractors were not included in each of the three RadNet contracts covered by this review, monthly progress reports (MPRs) were not included in terms and conditions of all three contracts, and required contractor performance evaluations were not completed or were late. The OIG’s January 2009 report addressed the need to improve contract administration and accountability for the RadNet initiative. EPA concurred with the prior report recommendations and established corrective action plans to monitor and improve contractor performance and oversight issues. The report contained five recommendations, of which EPA has listed four in MATS as completed as of August 2011. However, OIG analysis demonstrated that EPA only completed one of the recommendations (appendix A). As a result, contractor performance issues remained because EPA did not implement prior report recommendations to hold contractors accountable. Until EPA corrects the shortfall in contract oversight, the ability of the RadNet to protect human health and the environment is potentially impaired.
OAM and OAR did not adequately oversee the three RadNet contracts we reviewed and did not fully use contract requirements, including using contract incentives and disincentives, MPRs, and annual performance evaluations, to hold contractors accountable. As a result, contract issues raised in our January 2009 report continue to exist because EPA believed it could oversee and hold contractors accountable without them. EPA should implement recommended actions from this report to hold RadNet contractors accountable. Doing so will help ensure that EPA’s network of monitors is fully installed and operational so it can meet requirements established in the National Response Framework for Nuclear Radiological Incidents.
Note from p. 11:
…operators are unpaid volunteers from a variety of federal/state/local agencies, universities, and colleges, RadNet filter changes may not be the top priority for all operators”
Entire document here (50pp) (We added bold for emphasis) http://www.epa.gov/oig/reports/2012/20120419-12-P-0417.pdf
We find the whole debate below, which turns largely around the issue of filter changes, strange and annoying. There is little logic or science to this approach. There must be machine specifications for filter change and there must be a scientific basis. The only justification for random changes would be so that nuclear power plant operators would not know the dates that the filters are changed, and that should be truly random. It should be obvious that people should not change the filters during a hurricane or wildfire, but this does not warrant debate. Nor will most events warrant an extended delay. Volunteer or paid operators need to have a schedule. It should really be part of a paid EPA position. This is really bizarre and suggests a possible hidden reason they do not want to change filters:
“In response, there are many variable, site-specific conditions which preclude identifying a specific number or frequency of filter changes for each monitor. These variables include, but are not limited to, conditions that could affect the safety of operators (such as extreme weather conditions, construction activity or environmental hazards), the amount of particles in the air (such as wildfires, construction or abnormal weather), and the availability of operators (such as variations in an operator’s primary, non-volunteer work schedule).” http://www.epa.gov/oig/reports/2013/12-P-0417_Agency_Response_Second.pdf
In this letter, http://www.epa.gov/oig/reports/2013/12-P-0417_Agency_Response_Initial.pdf , it is mentioned that NAREL expects to evaluate only 4000 filters, whereas if there are 125 monitors with filters changed twice a week then 13000 filters would be required. So, for some reason they are trying to process less than 1/3rd of the required filters. It is also unknown if these 4000 filters are for the 40 portable ones as well.
Memorandum dated February 14, 2013
SUBJECT: Recommendations and Revised Agency Corrective Actions for Office of Inspector General (OIG) ‘Weaknesses in EPA’s Management of the Radiation Network System Demand Attention’ Report No. 12-P-04 17 dated April 19, 20 12 and ‘ EPA Plans for Managing Counter Terrorism/Emergency Response Equipment and Protecting Critical Assets’ Report No 09- -0087 dated January 27, 2009
FROM: Gina McCarthy Assistant Admini ator
TO: Arthur A. Elkins, Jr. Inspector General
Thank you for the opportunity to provide an updated corrective action plan in response to the recommendations in the subject audit reports. This document outlines the actions the Office of Air and Radiation (OAR) has completed in response to recommendations in the subject audit reports. In accordance with OIG’s memorandum, dated October 18, 2012, detailing acceptance of corrective actions 3.c and 5 of Report No. 12-P-0417, OAR is attaching a copy of the National Air and Radiation Environmental Lab (NAREL)’s Quality Assurance Project Plan, as well as the following revised corrective action plan for the remaining recommendation 8 for OIG’s consideration.
In response to recommendations 3.c and 8 in the ‘Weaknesses in EPA’s Management of the Radiation Network System Demand Attention’ Report No. 12-P-04 17:
Recommendation 3.c: Direct that NAREL improve planning and management for RadNet to include, at a minimum: How often filter changes are needed to provide consistency in throughput at NAREL’s analytical laboratory and implement a metric for these filter changes.
Corrective Action: NAREL developed a Quality Assurance Project Plan (attachment) which incorporates a discussion of site-specific variables and their impact on filter change frequency.
Completion Date: November 30, 2012
Recommendation 8: Track the installation of the RadNet monitors against the revised schedule and use the contract requirements in recommendations 4 and 5 to hold the contractor accountable.
Revised Corrective Action: All RadNet monitors have been delivered and installations are being conducted as sites are prepared. The contracting officer representative (COR) is working with the contracting officer (CO) to negotiate consideration for late deliveries.
Planned Completion Date: September 30, 2013
Additionally, as identified in Appendix A of Report 12-P-0417, OAR recognizes that the remaining recommendation 2-5 of’EPA Plans for Managing Counter Terrorism/Emergency Response Equipment and Protecting Critical Assets’ Report No. 9-P-0087 corresponds directly with Report No. 12-P-0417’s recommendation 8 as identified above, and has prepared the following revised corrective action.
In response to recommendation 2-5 in ‘EPA Plans for Managing Counter Terrorism/Emergency Response Equipment and Protecting Critical Assets’ Report No. 9-P-0087:
Recommendation 2-5: Monitor the upgrade of the RadNet system against the planned schedule in the CIP P until completed.
Revised Corrective Action: All RadNet monitors have been delivered and installations are being conducted as sites are prepared. The contracting officer representative (COR) is working with the contracting officer (CO) to negotiate consideration for late deliveries.
Planned Completion Date: September 30, 2013 See letter here: http://www.epa.gov/oig/reports/2013/12-P-0417_Agency_Response_Third.pdf (bold added)
Response by the OIG:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D .C . 20460
MAR – 1 2013
THE INSPECTOR GENERAL
SUBJECT: Close-Out of OIG Report No. 12-P-04-17 Weaknesses in EPA’s Management of the Radiation Network System Demand Attention, issued April 19, 2012
FROM: Arthur A. Elkins, Jr.
TO: Gina McCarthy, Assistant Administrator Office ofAir and Radiation
Thank you for your response dated February 14, 2013. Your response indicated the corrective actions that the Office of Air and Radiation plans to take on recommendations 3.c and 8.
To address recommendation 3.c, OAR provided the December 3, 2012, National Air and Radiation Environmental Laboratory Quality Assurance Project Plan. This QAPP discussed site specific variables and their impact on filter change frequency. These actions meet the intent of our recommendation, so we will close out recommendation 3.c in the Office of Inspector General’s audit tracking system.
In response to recommendation 8, the agency stated that all monitors have been delivered and installations will be completed by September 30, 2013. In addition, the contracting officer representative is working with the contracting officer to negotiate consideration for late deliveries. We agree with OAR and Office of Administration and Resources Management actions, so we will close out recommendation 8 in the OIG” s audit tracking system.
The OIG’s 2009 report. EPA Plans for Managing Counter Terrorism/ Emergency Response Equipment and Protecting Critical Assets Not Fully Implemented, Report No. 09-P-0087, recommendation 2-5, required the agency to … Monitor the upgrade of the RadNet system against the planned schedule in the CIPP [Critical Infrastructure and Key Resources Protection Plan] until completed.’ This is the same as recommendation 8 in the 2012 RadNet report, which required the agency to ‘track the installation of the RadNet monitors against the revised schedule and use the contract requirements in recommendations 4 and 5 to hold the contractor accountable.’ For recommendation 8, the agency stated all monitors have been delivered and installations will be completed by September 30, 2013. These actions meet the intent of our 2009 report recommendation 2-5, so we will close out recommendation 2-5 in the OIG’s audit tracking system. http://www.epa.gov/oig/reports/2013/12-P-0417_IG_Comment_on_Response_Third.pdf (bold added)
EPA OIG Reports
Various References and Useful Links:
Rad Net: http://www.epa.gov/radnet/radnet-data/index.html
Since the citizens cannot depend on their government:
Do it yourself radiation network: http://radiationnetwork.com/index.htm