ML12193A511
| ML12193A511 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 07/09/2012 |
| From: | Kalson V Monroe County, FL, Emergency Management |
| To: | Cindy Bladey Rulemaking, Directives, and Editing Branch, NRC/SECY/RAS |
| SECY RAS | |
| References | |
| 77FR25375 00160, PRM-50-104 | |
| Download: ML12193A511 (3) | |
Text
PRM-50-104 (77FR25375) DOCKETED USNRC 1(0 )
July 10, 2012 (9:10 am)
July 9, 2012 OFFICE OF SECRETARY RULEMAKINGS AND Submitted Via Email to Rulemaking.Comments@nrc.Rov Ms. Cindy Bladey Chief, Rules, Announcements, and Directives Branch Division of Administrative Services Office of Administration U.S. Nuclear Regulatory Commission Washington DC 20555-0001
Dear Ms. Bladey,
I have the following comments to submit in response to the Petition for Rulemaking ( PRM-50-104 or Petition ) noticed in the Federal Register on April 30, 2012.1 The detail comments are as follows:
As regards to the suggested increase in the existing radius of the EPZ boundary, the petitioner fails to provide sufficient justification as to how the change will enhance dose saving to residents living near nuclear plants. Resources in an emergency are always limited. Emergencies never follow a watch.
Regardless of the manpower available during normal business hours, when an emergency happens at 3am the response will not be as robust or as timely. One of the tenants of Emergency Management is to strategically place resources where they provide the most effective protection for the residents affected by a natural and / or man-made threat. Sufficient argument can be made that increasing and expanding the EPZ boundary will serve to dilute the effectiveness of offsite response agencies/ resources (law enforcement, route alerting, traffic control, fire rescue, EMS, communication) subsequently reducing their numbers and effectiveness from those areas most in need of coordinated response resources.
Clearly, the best outcome of any offsite EPZ evacuation is to move people out of harm's way well before any release has a possibility of happening. Expanding the EPZ will bring with it a cost of those very resources which would normally be available to relocate those residents nearest the release. Alert and notifications will take more time. The evacuation procedure then becomes more complicated and time consuming. Traffic control, management, accidents, and being stuck "exposed" in traffic may very well pose new risks to those evacuees who may be seeking shelter and may have been safer sheltering in place.
Evacuating is not always the safest protective action. The risks must be weighed with the risk of moving hundreds of thousands or millions of residents. Particularly vulnerable residents those under direct medical care have significant risks and challenges in evacuating. Transporting, providing for continuity of care and providing the special needs of infirmed patients who need 24/7 medical attention can have significant risks and will stress both public and private resources. Hurricane Rita in 2005 prompted mass evacuations in Texas, and while the storm was not catastrophic, 24 lives were lost when a private charter bus hired to transport residents of a nursing home caught fire on 1-45 a major evacuation route.
The petition indicates changes are needed because "The Fukushima Daiichi and Chernobyl experience affected areas more than anticipated by the NRC," however, I would contend that those are bad comparisons with the facilities licensed in the United States. The Chernobyl plant design dated back to the 1950's and was obsolete. The Japanese plants we do not simply have all of the data yet. In other TEMPLATE = SECY-067 Oslo0
words, of the 2 comparisons, the first one, the Chernobyl design would not be constructed today. The second example we really do not have the complete data yet to make any decisions. Of the data that is known in the Japanese incident, the protective actions appeared conservative. Evacuations in Japan were ordered extending 12.4 miles from the Fukushima plant, thus exceeding the Emergency Planning Zone by 2.4 miles on the second day of the accident. That deviation in action appears slight and would hardly be worth re-examining standards that have worked well for 30 plus years in practice.
Last, the petitioner indicated that planning and exercises have not applied concurrent natural disasters to their scenarios. This is not accurate in our region. The petitioners should elaborate further and distinguish between foreseeable and non-foreseeable "natural disasters" in their argument for modifying the evaluated exercise. In the event of foreseeable natural disasters such as hurricanes, power plants can power down a day or more before a storm comes. The petitioner should know in South Florida there is no Seismic or Tsunami risk. There remains a risk of a EF1 or EF2 Tornado ( no F3 and F4 Tornados have ever been recorded in S Florida). A tornado would need to be a strong EF4 to damage the Turkey Point Nuclear Plant and none have been recorded. In theory our region has been exercising concurrent natural disasters for years as he/she suggests we should.
If you have any questions concerning these comments please feel free to call me at Mr. Vince Kalson Radiological Emergency Preparedness Administrator Monroe County Emergency Management 490 6 3 rd St Suite 150 Marathon, Florida 33050 Email: Kalson-Vince@monroecounty-fl.gov Phone: 305 289-6019 Vey truly yours, 77 Fed. Reg. 25,375 (April 30, 2012).
SHAILA DEWAN, SIMON ROMERO & JERE LONGMAN "Hurricane Lashes Texas and Louisiana Coastlines" New Your Times on the Web September 24, 2005
< http://www.nytimes.com/2005/09/24/nationaI/nationaIspecia1/25cnd-storm.htmI?fta=y&pagewanted=aII>
Rulemaking Comments From: Kalson-Vince [Kalson-Vince@MonroeCounty-FL.Gov]
Sent: Monday, July 09, 2012 12:05 PM To: Rulemaking Comments
Subject:
Comments on PRM-50-104 or 77 Fed. Reg. 25,375 (April 30, 2012).
Attachments: DOC021.pdf Good afternoon, Attached is a scanned copy of my comments regarding PRM-50-104 or 77 Fed. Reg. 25,375 (April 30, 2012).
Thank you!
VINCE KALSON Monroe County Emergency Management Department Radiological Emergency Preparedness Administrator 490 63rd Street Suite 150 Marathon, Florida 33050 Cell: 305-797-1030 Office: 305-289-6019 Fax: 305-289-6333 1