ML12146A191
| ML12146A191 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/20/2012 |
| From: | Kranzdorf R - No Known Affiliation |
| To: | NRC/SECY/RAS |
| SECY RAS | |
| References | |
| 77FR25375 00134, NRC-2012-0046, PRM-50-104 | |
| Download: ML12146A191 (2) | |
Text
PRM-50-104 DOCKETED f
Rulemaking Comments (77FR25375)
USNRC From:
Richard Kranzdorf [rkranzdo@calpoly.edu]
May 23, 2012 (11:45 am)
Sent:
Sunday, May 20, 2012 5:33 PM OFFICE OF SECRETARY To:
Rulemaking Comments RULEMAKINGS AND
Subject:
Comments on PRM-50-104, Docket ID NRC-2012-0046 ADJUDICATIONS STAFF My specific comments are in the first three paragraphs!
I have commented on the inadequacy of the emergency plan to Diablo Canyon Nuclear Power Plant for more than 25 years!!!
I have commented that the Plan is a PAPER PLAN only. I have so commented whenever the NRC comes to town which is approximately once every six months.
My main criticism is that the comments are duly taken and nothing happens.
There is NEVER an attempt to have even a scaled-down version of TESTING the plan with public participation.
The letter of the plan is thus fulfilled but there is no digging deeper.
Let me give a specific.
Until I retired from Cal Poly State U. two years ago there was no testing of what would happen in an actual emergency.
NEVER!
The University sits about ten miles from Diablo Canyon.
On Monday through Friday, 8-5, approximately 20,880 people are on the premises of the University.
Never, never is the general university public asked to join in a drill.
Of course if such a drill were conducted, even in a limited form, there could be accidents.
So a paper plan is carried out and the exercise is over till next time.
The same would roughly be true for other institutions including hospitals.
The on-going events at Fukushima demonstrate that nuclear power disasters can have sustained and far reaching effects. A major concern associated with Fukushima and other nuclear disasters is the evacuation of affected populations. In the United States, emergency planning for nuclear emergencies has remained largely static since 1980, when regulations pertaining to emergency planning were initially enacted after the Three Mile Island accident. These plans are outdated and do not adequately protect the health and safety of United States citizens.
Specifically, the current 10-mile emergency evacuation zone does not adequately protect from the effects of ionizing radiation, despite what computer modeling and simulations may demonstrate.
The real world experiences of Fukushima and Chernobyl are direct evidence that radiation releases from nuclear accidents can be greater than computer modeling or simulations suggest. Indeed, the accident at Fukushima resulted in sustained and large releases of radiation for a period of several weeks.
More than 150,000 people evacuated near Fukushima, from as far as 25 miles away--50,000 of those, according to the Associated Press (5/16/12) evacuated from outside the mandatory evacuation zones. Meanwhile, the U.S. Nuclear Regulatory Commission and U.S. State Department recommended that Americans within 50 miles of Fukushima evacuate. Even so, as much as 88% of the airborne radiation released at Fukushima blew directly over the Pacific Ocean, rather than populated areas. The NRC cannot rely on favorable wind patterns to protect the American public.
According to the National Academy of Sciences BEIR VII report, there is no safe dose of radiation, and women and children are affected more by radiation than men.
Evacuation regulations must be protective of the most vulnerable in the population.
TEMPLATE = SECY-067 Oslo0
The ingestion pathway EPZ is also grossly inadequate, and should be expanded to 100 miles.
Food contamination at both Fukushima and Chernobyl has been far reaching and persistent. In Chernobyl, radionuclides tainted crops and animal products hundreds of miles away. More than 25 years after that accident, sheep in Wales--hundreds of miles away--remain interdicted.
Similarly, in Fukushima contamination of rice, milk, and other food has been exhibited 100 miles and more from the site.
Current NRC regulations do not require that emergency exercises take into consideration an initiating or concurrent natural disaster that might further complicate accidents and subsequent evacuation efforts. At Fukushima, a natural disaster (coupled with faulty reactor design) initiated the disaster. Both Fukushima and the U.S. experience with Hurricane Katrina demonstrate the difficulties associated with evacuating when a natural disaster strikes that causes roadways to wash out.
Weather patterns are growing more extreme and dangerous. In 2011, hurricanes, earthquakes, and flooding caused damage to U.S. nuclear reactors.
As such, emergency preparedness drills and exercises should include regionally appropriate natural disasters such as droughts, flooding, blizzards, earthquakes, wildfires, and hurricanes.
It is for all these reasons that I request that the NRC adopt the proposed rule expanding emergency planning zones to the respective 25, 50, and 100 mile zones and add a new requirement that emergency exercises include scenarios of regionally appropriate initiating or concurrent natural disasters.
Thank you, Richard Kranzdorf San Luis Obispo, CA 93405 US