ML052500258
| ML052500258 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon, San Onofre  |
| Issue date: | 09/06/2005 |
| From: | Becker R Alliance for Nuclear Responsibility |
| To: | NRC/FSME |
| References | |
| Download: ML052500258 (6) | |
Text
ALLIANCE FOR NUCLEAR RESPONSBRILITY Comments of the Alliance for Nuclear Responsibility on Emergency Preparedness Regulations and Guidance for Commercial Nuclear Power Plants in California Since California's two operating nuclear plants were licensed in the mid-1980's, the population of these coastal communities has grown by approximately 13 %
each decade. The populations near the communities closest to Diablo Canyon and San Onofre have also grown dramatically.
California has more schools, hospitals, and businesses within a 50 mile zone of these nuclear power facilities than when these nuclear plants began operation.
The state's road systems are often heavily impacted during rush hour, holiday and vacation traffic.
California's economy is under pressure as it rebounds from the energy crisis and the dot.com collapse. The governments' inadequate federal oversight to address defense-in-depth as mitigation of possible terrorism, acts of malice and/or malice and insanity at nuclear plants places the state's economy at risk. Any accident or terrorist attack would cripple the state's economy for years to come.
Reactor communities nervously laugh when officials attempt to convince them that it is possible to safely evacuate in the event of a radioactive release. There are so many "holes" in nuclear emergency plans, that they closely resemble Swiss cheese. Examples of "holes" include: not enough buses for school children or the non-driving public, elderly & convalescent transport concerns, pre-schoolers without transportation, children at home alone after school, impacted roads, roads unavailable in the event of an earthquake, and the list goes on.
Rectifying these, inadequacies could cost millions/billions of ratepayer and/or taxpayer dollars and there appears to be no funding for new buses, infrastructure, new equipment, expanded medical facilities, and training in either the federal energy plan or California's budget.
While the relatively small county of San Luis Obispo may have more state-of-the-art emergency equipment and more emergency training than many California
counties to deal with emergencies, few members of the public believe that implementation of evacuation plans are possible SONGS is located adjacent to a Marine base, but this could be a dual edge sword for our nation's security. It there was a radioactive release at SONGS, it could incapacitate one of the country's most valuable military resources.
SONGS is also located next to ten lanes of freeway (often traveling at a snail's pace), a state park (filled to capacity on weekends, summers and holidays), an active fishing area and world famous surfing beach, and sits next to railroad tracks and below a major air corridor.
NRC slides prepared for the Aug 31 St - Sept 1, 2005 workshop entitled "Emergency Preparedness in the Post 9/11 Environment, highlight that "Emergency preparedness is a partnership". Federal oversight is shared and EP is built on cooperation. The Alliance for Nuclear Responsibility takes issue with the NRC'S premises. First, we challenge the NRC to demonstrate that the agency has welcomed the public in this "partnership." Second, we request to know the hierarchy of oversight agencies - who has final approval? Third, EP must be based on cooperation and trust. Sadly the NRC does not have a history of earning public trust.
The Alliance for Nuclear Responsibility is aware that most other reactor states have similar concerns and their own special circumstances. We are also aware that emergency planning is at best an inexact science. Yet, ANR believes it is the mandate of the Nuclear Regulatory Commission to be forthcoming with those who live in the shadow of nuclear reactors and admit that evacuations are likely to leave many, perhaps most, behind. In fact, evacuation zones, as part of emergency planning guidance, appear to be dwindling and may soon only include the nuclear plant site itself Those who cannot evacuate must be trained and equipped to shelter themselves as effectively as possible. Sheltering has been underplayed in proceedings that address emergencies at U.S. reactors. Yet, sheltering is the most likely scenario in the event of a radioactive release.
In the section "Looking Forward" the NRC includes two bullet points on "stakeholders". The public are stakeholders, yet their input is rarely invited and often ignored and "feedback" is often presented as decisions in which the public has had little, if any, voice.
What our country has (or hasn't) learned From Three Mile Island
- Is there radiation protection equipment and adequate training for every employee at Diablo Canyon and SONGS while steam generator replacement and transfers to dry cask process is under way?
- Is there adequate protection gear and training for all first responders?
- What plans are in place in the event of an earthquake during steam generator replacement and transfer of highly radioactive fuel to dry casks?
Symbiotic effects of earthquakes and road conditions during an earthquake were ignored during licensing proceedings for California's nuclear plants, yet from 1984 to 2005, California experienced over 60 earthquakes of over 5.5 magnitude.'
During the December 2003 earthquake in SLO County, county roads were blocked to the public by falling rocks, landslides and debris.2 What potential problems does this portend for the 240,000 residents of this county and how are these problems thus being addressed in NRC emergency planning regulations?
- Are all sirens in working order with back-ups?
During the 2003 earthquake: "56 of the 131 emergency sirens were inoperable because of power outages. Alternate means of notifying people within affected areas were available..." 3 Ron Alsop, a county emergency services coordinator, said , 'The battery backups will add another layer of public safety and free up police and firefighters.
Currently, if sirens fail, police and fire agencies must alert the public using public address systems on their vehicles.' "Oatley (David Oatley-general manager of Diablo Canyon nuclear power plant) and Alsop stressed that, even without the battery backups, the siren system is 99.7 percent reliable. The county has fallback procedures for notifying the public if the sirens fail, including the use of police public address systems. 'The equation that 'no sirens' equals 'you are not safe" is not accurate, " Oatley said.4 No sirens, plus no electricity and no "signals" for emergency phones, could indeed, place the safety and economy of California at risk.
It took the December 2003 earthquake to reveal that a loss of power to the emergency siren system severely cripples it, even though the system is "static" tested every year. What additional procedures and policies will the NRC require at all facilities to create a testing model that truly takes into account all scenarios?
' http.//www.seismic.ca.gov/sscearth.htm 2
NRC Report Jan 30, 2004, page 14 3 California Seismic Commission pg 15 4The Tribune, March 26, 2004
Approximately 60,000 residents of San Luis Obispo County lost power from three to five hours at the time of the earthquake. Without power, how were these people going to turn on a television or radio in order to hear about any alerts that would have required evacuation from the area? Perhaps they would call on their cell-phones? Perhaps not, for as Ms Ferrara's report for the Seismic Commission revealed, "Cell towers connected to failed water tower tanks will also fail (and at a critical time). TCSD tanks had cell towers, epoxy connections all failed." So it looks like there was and will be the chance that wireless communications will fail. Christine Ferrrara, the utilities division manager for San Luis County said in her presentation at the State Seismic Commission hearing in Paso Robles when discussing the attempts to reach and notify people living in the further reaches of the county, "Power outage posed greatest challenge in sustaining customer service" and most significantly: "Informal emergency response plans don't work well even on small systems." 5 If there is this loss of communication, how will residents know about the evacuation or need to shelter? The assumption that local law enforcement will be going out and about making announcements to alert the public with megaphones flies in the face of logic. In fact, it was also pointed out at the Seismic Commission hearing that in both Morro Bay and in San Luis Obispo there were two fire department/police garages where the garage doors became derailed in their tracks and would not open. By coincidence, the fire trucks in Morro Bay had been moved outdoors the night before, but not for any planned event. I Were a stronger quake to strike, the chance of emergency vehicles becoming "shut in" would have been greater. In addition, as the earthquake proved, many first responders may be dealing with extricating victims from buildings which would compound the problem of notifying the public.
Unless the NRC looks at the coincident events of an earthquake and an accident at the California's nuclear, it will not see that an orderly evacuation is not possible if the access and exodus roads are damaged by the same event that shook the plant.
Unless the NRC is willing to admit that the loss of 56 out of 131 sirens was a warning which must be heeded, how does it expect to gain any trust of reactor communities located downwind of nuclear plants in a seismically active coast zones? The siren failure should have resulted in a category "red" rating not the "green" rubber stamp that Region IV bestowed upon Diablo Canyon for 2003 operations.
The NRC's recent decision to not require back up batteries is irresponsible.
PG&E has pledged to replace non-working sirens, but the status of back up 5 California Seismic Commission March 2004
batteries for these sirens is unclear. No such pledge has been made at San Onofre.
Emergency planning may fall into two categories: the exodus of the able-bodied with full tanks of gas that live by undamaged roads and triage for the majority left behind. To limit casualties, both immediate and long-term, the following questions must be resolved.
- 1) Do all emergency providers have adequate communications systems in the event of a radioactive release?
- 2) Do all emergency providers have necessary equipment and funding for maintenance in working adequate?
- 3) Are downwind medical facilities equipped to handle contaminated personnel or residents?
- 4) If so, how many?
- 5) If not, what alternative medical plans are in place?
- 6) Are the downwind counties equipped and trained in the event a seismic event occurs while highly-radioactive fuel assemblies are being transferred into casks licensed for only 20 years?
- 7) As fewer residents are able to afford full tanks of gas, what provisions are in place to provide fuel for evacuating vehicles?
- 8) Do pre-schools within EPZ have evacuation or sheltering plans in place?
- 9) Do these schools have onsite transportation for all children to leave in one trip?
- 10) As schools in California are not designed for harsh weather and many classrooms are in "temporary" trailers, what provisions are in place to assure that any radioactive plume will not penetrate classrooms?
- 11) What assurances do emergency personnel in downwind counties have that communication from nuclear plant will be timely, clear and adequate to inform the citizenry to evacuate and/or shelter?
- 12) What evacuation or sheltering plans are in place for the hundreds of school children who may be home alone after school?
Alliance for Nuclear Responsibility Recommendations for Emergency Planning at California's Nuclear Plants There is not practical personal protective equipment (PPE) to protect First Responders against externally penetrating gamma radiation. Monitoring devices are the only means to ensure that responders do not enter an area where exposure to external gamma radiation is excessive.6 Therefore, the Alliance for Nuclear Responsibility recommends:
6OHSA/NIOSH Interim Guidance August 2004 http://www.osha.gov/SLTC/emergencypreparedness/cbrnmatrixlradiological.html
- 1) Radiation detecting devices be distributed to all schools and facilities that cannot be evacuated in a timely manner in the event of a radioactive release.
According to the same study, PPE's are a barrier for alpha and beta particles.
Although those particles tend to dissipate, dense fog could result in slow moving and concentrated radioactive particles passing over vulnerable downwind areas.
Therefore the Alliance for Nuclear Responsibility recommends that the following be distributed to all students in all schools, and for all facilities and vulnerable populations that cannot be evacuated in a timely manner in the event of a radioactive release:
- 1) "turnout" gear or disposable protective clothing;
- 2) full-face air-purifying particulate respirators;
- 3) KI for all within EPZ All reactor communities have similar concerns regarding safety and security and how to protect our homes, families and businesses. The concerns of the "stakeholders" who live in the EPZ must be addressed and resolved. For this reason, the Alliance for Nuclear Responsibility endorses all of the Goals, Assumptions and Recommendations of Pilgrim Watch.
Finally, the Alliance for Nuclear Responsibility recommends that no further license renewals be granted and current renewals be placed on hold until all recommendations to improve emergency evacuations and sheltering in the event of a radioactive release are in place and tested.
Respectfully Submitted Rochelle Becker, Executive Director Date Alliance for Nuclear Responsibility www.a4nr.orcq PO 1328 San Luis Obispo, Ca 93406-1328 (858) 337 2703