ML12145A541

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Comment (5) of John Papandrea on PRM-50-104 Regarding Emergency Planning Zone
ML12145A541
Person / Time
Site: Crane  Constellation icon.png
Issue date: 05/16/2012
From: Papandrea J
- No Known Affiliation
To:
NRC/SECY/RAS
SECY RAS
References
77FR25375 00005, PRM-50-104
Download: ML12145A541 (1)


Text

PRM-50-104 DOCKETED 5

Rulemaking Comments (77FR25375)

USNRC From:

john papandrea [papl00@aol.com]

May 23, 2012 (11:45am)

Sent:

Wednesday, May 16, 2012 3:51 PM OFFICE OF SECRETARY To:

Rulemaking Comments RULEMAKINGS AND

Subject:

Nuclear Safety ADJUDICATIONS STAFF The nuclear disasters at Fukushima and Chernobyl provide real-world and plain evidence that the current 10-mile emergency evacuation zones in the U.S. are simply too small, and cannot adequately protect the public from the possibility of acute radiation exposures. Moreover, as we have learned in recent months and years, women and children are more susceptible to radiation than men: regulations must protect the most vulnerable in society.

At both Fukushima and Chernobyl, actual evacuations took place far beyond 10 miles. And at Fukushima (as at Three Mile Island in 1979) far more people than those who were told to evacuate actually did evacuate--about one-third of the Fukushima evacuees left areas that were not part of the evacuation zones.

Improving emergency planning rules is obviously not a substitute for closing nuclear reactors. We all would prefer that such rules not be needed at all--because all reactors are closed. But that's not the world we live in; with 104 operating reactors in the U.S.,

it is essential that emergency evacuation rules reflect the real dangers each of these reactors presents.

Our petition calls for a three-tiered Emergency Planning Zone: the current 10-mile zone would expand to 25 miles, with all current requirements intact. A new zone from 25-50 miles would be established; utilities would be required to notify residents of these zones of evacuation routes if needed, but would not conduct biannual exercises. The Ingestion Pathway Zone, designed for interdiction of contaminated food, milk, and water, would be expanded from the current 50 miles to 100 miles. And a new rule would be established that would require emergency exercises to include scenarios of initiating or concurrent regionally-appropriate natural disasters.

john papandrea new york, NY 10024 US TEMPLATE = SECY-067 Oslo0