ML12262A328
| ML12262A328 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/13/2012 |
| From: | Lampert M Entergy Nuclear Operations |
| To: | Office of Nuclear Security and Incident Response |
| Shannon King | |
| Shared Package | |
| ML12185A180 | List: |
| References | |
| NUREG-0654 | |
| Download: ML12262A328 (14) | |
Text
EMERGENCY EMERGENCY PREPAREDNESS WHATS WRONG?
September 13, 2012 Mary Lampert Mary Lampert Pilgrim Watch, Director 1
FUKUSHIMAS LESSONS FUKUSHIMA S LESSONS Wake up Call or Snooze Alarm?
Wake up Call or Snooze Alarm?
2
WHATS FUNDAMENTALLY WRONG?
WRONG?
- 1
- 1 Rules Lack Specificity Requirements Requirements 3
RULES PROVIDE FLEXIBILITY LACK ACCOUNTABILITY LACK ACCOUNTABILITY Capability Based Rules =
Capability Based Rules
- Licensee given flexibility
- Licensee saves money
- Licensee saves money
- Licensee no real accountability Performance Based Rules =
- Enforceable/Accountability
- Public Safety First 4
WHATS FUNDAMENTALLY WRONG?
WRONG?
- 2 Wh t R l D
N t Add What Rules Do Not Address Until the basic issues are faced-no reasonable assurance no reasonable assurance 5
EMERGENCY PLANNING ZONE 20/25 MILES 20/25 MILES
- NRC advised U.S. citizens in Japan within 50 miles to evacuate
- NRC says advice was an ABUNDANCE OF CAUTION ABUNDANCE OF CAUTION Wh t th ABUNDANCE
- Why not the same ABUNDANCE OF CAUTION for citizens here?
6
DOSE PROJECTIONS Wh t W
?
Whats Wrong?
Likely Amount & Impact Radiation Likely Amount & Impact Radiation Released Minimized PAG t b d
BEIR VII
- PAGs not based on BEIR VII
- Large accidents ignored, e.g.
spent fuel pool fire hydrogen explosions hydrogen explosions core or containment breach
th 1% f l f il more than 1% fuel failure 7
PLUME MODELING Wh t W
?
Whats Wrong?
Key Hole Key Hole 8
PLUME MODELING Whats Wrong?
What s Wrong?
- Plume modeling based simplistic straight-line, Gaussian plume; not straight line, Gaussian plume; not suited for complex sites (non-temporal, non-spatial)
Whats Needed?
- Advanced variable models and Advanced variable models and multiple meteorological towers for both pre-planning & response 9
NOTIFICATION Wh t W
?
Whats Wrong?
Require Multiple Redundant Require Multiple Redundant Systems & Backup
- Reverse 911-indoor alert
- Electronic Reader Boards
- Emergency Alert System Emergency Alert System 10
PROTECTIVE ACTIONS EVACUATION WHATS WRONG?
EVACUATION-WHATS WRONG?
- Staged Evacuation (2 miles, followed Staged Evacuation (2 miles, followed by keyhole from 2-5 mi then perhaps extend keyhole 5-10) unrealistic
- Reception Centers equipped for only 20% population -conflicts guidance Shadow Evacuation assumes only 20% out to 15 miles-unrealistic
- ETEs (NUREG/CR 7002) based best case scenario 11
RADIOLOGICAL PROTECTION RADIOLOGICAL PROTECTION POTASSIUM IODIDE (KI):
O SS U O
(
)
- support stockpiling to 20 miles (Bioterrorism Act, 2002)
(
)
- require both tablets & liquid KI for young children 3-M TYPE MASKS:
- require stockpiling both adult &
childrens sizes in schools/shelters 12
EMERGENCY WORKERS EMERGENCY WORKERS Whats Wrong?
C i
ti R
i
- Communications: Require interoperability
- Protective Gear: Require
- Protective Gear: Require protective clothing/masks &
training for its use g
- REWMDs: Radiological Emergency Worker Monitoring D
t i
ti C
t i
Decontamination Centers - require multiple centers per EPZ, located
> 20 miles from reactor
> 20 miles from reactor 13
RETURN & RECOVERY Whats Wrong?
g
- No Agreed Clean-Up Standard
- No Federal Agency In Charge g
y g
- No Money-Price Anderson pays damages, not clean-up
- MACCS2 (MELCOR Accident
- MACCS2 (MELCOR Accident Consequence Code) used to estimate consequences - outdated & severely underestimates offsite consequences underestimates offsite consequences 14