ML16152A570
| ML16152A570 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/30/2016 |
| From: | Specter M - No Known Affiliation |
| To: | Stephen Burns, Kristine Svinicki, Ostendorff W, Jeff Baran NRC/Chairman, NRC/OCM/KLS, NRC/OCM/WCO, NRC/OCM/JMB |
| References | |
| LTR-16-0301 | |
| Download: ML16152A570 (18) | |
Text
CHAIRMAN Resource From:
Sent:
To:
Subject:
Attachments:
M.H. Specter < mhspecter@verizon.net>
Monday, May 30, 2016 1:09 AM CHAIRMAN Resource; CMRSVINICKI Resource; CMROSTENDORFF Resource; CMRBARAN Resource
[External_Sender] A safer emergency plan for Indian Point CV for Emergency Planning.doc; Malatras pgl.pdf; Advanced Energy Conference revl.pptx; Malatras pg2.pdf May 30,2016 Stephen G. Burns, Chairman Kristine L. Svinicki, Commissioner William C. Ostendorff, Commissioner Jeff Baran, Commissioner U.S. Regulatory Commission Washington, D.C. 20555-0001
Dear Commissioners:
On November 16, 2015 Mr. Jim Malatras, New York State's Director of Operations, wrote to you arguing that the applications for extending the licenses of the two operating nuclear plants at Indian Point be denied. His central reasoning was" Indian Point's proximity to a major population center in New York City and surrounding areas make it absolutely impossible to have an effective safety and evacuation plan". This is just not so.
Malatras repeated an often used straw man that since it would be impossible to evacuate the 20 million people who lived within 50 miles of these plants, the plants should be shut down. No basis can be found in science or found in reviews of actual nuclear power plant accidents for evacuating out to 50 miles. Such a massive evacuation itself would likely be more dangerous than the near term radiological health effects of any nuclear power plant accident.
Only the 20,000 or so people who live within two miles of the Indian Point plants need be evacuated, a number a thousand times smaller than the one Malatras used. This much smaller group would be evacuated prior to the release of any radioactive material.
Other people, downwind from the damaged plant, would be advised to take shelter, and some, if they were in a "hot spot" would be relocated, even if this hot spot were beyond the present ten mile Emergency Planning Zone (EPZ). Food and water would be monitored to prevent improper ingestion. There would be ample time to take all of these sim ple protective actions.
Such a simple emergency response would be highly effective. Zero near term radiological health effects, such as injuries and fatalities, would be expected because the range of such hazards is very short, between zero to two miles from the site. This is the 1
basis of having a two mile pre-emptive evacuation. Long term radiological health effects beyond two miles, if any, would be too small to be detectable, statistically. Sheltering beyond two miles is the preferred emergency response.
How do we know that there would be such limited radiological health effects if a meltdown at Indian Point occurred? First, modern computer analyses developed at our national laboratories, e.g., the SOARCA program developed by Sandia Laboratory, give a very different picture of what nuclear accidents might look like compared to severe accident estimates generated years ago. Today we know that nuclear accidents would release far less radioactive material into the environment, that many hours would pass before this radioactive material first entered the environment, and that the release would occur more slowly, i.e., radioactive releases would be smaller, later, and more gradual than what old technology indicated. These accident characteristics greatly simplify emergency planning for all nuclear power plant sites.
Second, we have the lessons learned from the three simultaneous reactor meltdowns five years ago at Fukushima. The emergency situation at Fukushima was extreme: the most powerful earthquake ever to hit Japan, a tsunami much higher than what had been planned for, a complete loss of electric power at the three nuclear plants, flooding in the lower areas of the plants, most instrumentation inoperable, a significant loss of communications, and hydrogen explosions.
Emergency workers outside of the power plants had to simultaneously deal with the earthquake, the tsunami, and three simultaneous meltdowns. Yet the World Health Organization concluded that there were no near term radiological health effects and that long term radiological health effects would be too small to be detectable. Since the emergency response at Fukushima was highly effective even under such extreme conditions, a similar emergency response would also be highly effective in greatly limiting radiological health consequences at Indian Point, or for that matter, at all nuclear power plants.
Attached are slides that I presented in April, 2016 at the Advanced Energy Conference.
These slides show that the actual releases of radioactive material at Fukushima were smaller, later, and more gradual than what would have been predicted years ago, such as those in Sandia's 1982 severe accident analyses. The actual releases of radioactive material at Fukushima is consistent with the general accident characteristics-smaller, later, and more gradual-calculated by SOARCA.
Further, as shown in the attached slides, the Fukushima emergency response used to minimize radiological health consequences is consistent with the emergency response recommended here for Indian Point. At Fukushima the innermost two miles near the power plants were evacuated prior to the release of radioactive material, there was downwind sheltering and, later, people were relocated from hot spots, some of which were beyond the Fukushima EPZ.
Although the radiological health effects of the Fukushima accident were near zero, there was a large over-evacuation and, to date, 1600 non-radiological fatalities have occurred from this over-evacuation. Three years after the Fukushima accident there were about 2
80,000 people still in emergency shelters, too afraid to return to their homes even though dose rates were very low. Having once been told by the government that they had to evacuate, they became resistant to returning to their homes out of fear and a mistrust of their government. EPA guidance on emergency planning clearly states that one has to balance the benefits of taking protective actions against the consequences of taking these protective actions. This was not done in Japan, but the Indian Point emergency response described here would achieve this balance by minimizing both radiological and non-radiological consequences by avoiding an over-evacuation. Not only should 50 mile evacuations be avoided, evacuating the whole 10 EPZ is far too much.
With the implementation of the FLEX program and other actions taken within the power plants themselves, much has been accomplished in further reducing the already quite low frequency of releases of radioactive material from nuclear power plants. However, I am under the impression that the lessons learned from Fukushima on off site emergency planning have not received the same level of scrutiny from the NRC or the nuclear industry. For example the NRC still requires Evacuation Time Estimates (ETEs), at least at Indian Point, where the time to evacuate the whole EPZ is calculated. ETEs based on evacuating the whole EPZ sends the wrong message to the public and may help to encourage letters like the one you got from Mr. Malatras. It is my view that the public would be well served if the balanced approach to emergency planning, described above, were universally adopted.
Thank you for your attention.
Sincerely, Herschel Specter Former AEC Licensing Manager for Indian Point 3 mhspecter@verizon.net 3
Herschel Specter, President Micro-Utilities, Inc.
mhspecter@verizon.net 1-914-761-3748 BS Applied Mathematics, Polytechnic Institute of Brooklyn 1955 MS Nuclear Engineering, MIT 1957 Professional Engineer, State of New York AEC ( Now Nuclear Regulatory Commission) Licensing Manager for Indian Point 3.
Formerly, Technical Advisor to the Executive Vice President, New York Power Authority (NYPA).
Manager of NYPAs Indian Point Adjudicatory Hearing.
Chairman of two National Committees on Emergency Planning.
Guest Lecturer on Emergency Planning at Harvards School of Public Health.
Performed State-of-the-Art Emergency Planning Analysis for Indian Point, Assuming a Successful Terrorist Attack.
Provided Testimony to the National Academy of Sciences on Fukushima and on the Safety of Spent Fuel Pools at Nuclear Plants.
Published a Number of Emergency Planning and Energy Policy Papers Served, at Diplomat rank, for 5 years at the International Atomic Energy Agency. Headed up the international standards effort on the safe design of nuclear power plants.
1 Fukushima and the Indian Point Emergency Plan Herschel Specter, President Micro-Utilities, Inc.
mhspecter@verizon.net
2 Indian Point Needs a Safer Emergency Plan
- With a safer Emergency Plan, even if there were a core melt accident at Indian Point, the expected health consequences would be:
- From radiation:
- Zero near term (early) fatalities
- Zero near term (early) injuries
- Long term effects that would be too small to be detectable statistically
- From non-radiation causes:
- Very limited because over-evacuation would be minimized
3 Choosing the Best Mix of Evacuation and Sheltering for Indian Point
- The best evacuation to sheltering mix is a 5%/95% mix within the Emergency Planning Zone (EPZ) population, with later relocation from hot spots, even if they were beyond the 10 mile EPZ.
- The 5% (~20,000 people) that would be evacuated would be from the innermost two miles and would be evacuated prior to the release of radioactive material. This action would eliminate the early fatality and early injury risks. This was done at Fukushima.
- Downwind areas in the EPZ would be ordered to shelter. It is unlikely that all of the remaining 95% of the EPZ population would have to shelter. This sheltering, plus later relocation from hot spots, would limit long term effects to the point that they would be statistically undetectable. Sheltering and relocation from hot spots were done at Fukushima.
4 This Safer Emergency Plan is Based on Modern Science and Analyses of Fukushima Health Consequences
- Compared to earlier studies, modern severe nuclear accident studies developed at Sandia National Laboratories show that these very rare melt down events would (1) release far less material into the environment, (2) such releases would start much later, and (3) these releases would be far more gradual. All three of these general characteristics are beneficial and help shape safer emergency plans.
- The Fukushima accident supports the major conclusions reached by modern accident studies. Releases of radioactive material at Fukushima were smaller, later, and more gradual than those predicted years ago in earlier Sandia accident studies.
- The World Health Organization studied the health consequences of the Fukushima accident and concluded that there were no early injuries or fatalities and that long term effects, even when estimated very conservatively, would be too small to be detectable statistically.
- The National Academy of Sciences reported that no worker received a dose that resulted in acute radiation death or sickness.
5 Near Zero Radiological Health Consequences are Achievable at Indian Point and all other nuclear power plant sites.
- Achieving near zero radiological health effects at Indian Point should be straight forward because it is comparatively simple. It was done in Japan in spite of losing over 18,000 people to the earthquake and tsunami, loss of all electric power at the nuclear plants, flooding in lower plant areas, loss of most plant and off site instrumentation, severe losses in communication, hydrogen explosions, and the huge burden on general emergency workers to simultaneously deal with the worst earthquake ever to hit Japan, a tsunami much larger than people planned for, and multiple simultaneous melt downs. If near zero radiological health effects can be achieved under such extreme conditions in Japan, near zero radiological health effects can be achieved at Indian Point.
6 What Must be Avoided
- The Fukushima emergency response did not balance radiological and non-radiological risks. The response was already successful when it pre-emptively evacuated people from the innermost 3 kilometers and sheltered downwind. Far too many people were evacuated (150,000) and about 1600 fatalities have occurred from the non-radiological risks of evacuation and subsequent sheltering in very crowded circumstances.
Some, when told that it was now safe to return to their homes, refuse to do this out of continuing fears of radiation. This refusal to return to a home that is safe continued for years, with 80,000 people still sheltered 3 years after being evacuated. Fear of radiation causes depression, anxiety, and post-traumatic symptoms and other health effects not attributable to the radiation itself.
- OVER-EVACUATION MUST BE AVOIDED BY BALANCING RADIOLOGICAL AND NON-RADIOLOGICAL RISKS.
7 Next Steps
- Convey the substance of this modern and safer emergency response to the public, their elected officials, regulatory bodies, and the media.
Discourage misinformation that could lead to over-evacuation, such as false statements about needing to evacuate out to 50 miles. There are about 20 million people within 50 miles of Indian Point. Suggesting that so many people might have to evacuate has no basis in science or actual accidents. It is about 1000 times too large compared to the ~ 20 thousand pre-emptive evacuees within two miles of Indian Point. Such misinformation needlessly stresses people now, and could cause serious non-radiological harm in the unlikely event of an accident at Indian Point. Unfounded fear of radiation itself causes health effects and that should be cause enough to discourage issuing misinformation.
8 Detailed Information-1
- 1. If a General Emergency is declared at Indian Point, pre-emptively evacuate the innermost one mile (about 4000 people or about 1.2% of Indian Point EPZ population). Evacuees would be directed to a predesignated shelter(s). This step would virtually eliminate the early (acute) fatality risk.
- 2. If conditions deteriorate further or if no progress in two more hours, pre-emptively evacuate the 1 to 2 mile ring ( about 15,600 people or about 4.2% of Indian point EPZ population). Evacuees would be directed to a predesignated shelter(s). This step would virtually eliminate the early (acute) injury risk.
- 3. If a release of radioactive material starts, order all people in the EPZ beyond the two mile evacuation zone east of the Hudson River to take shelter and to apply other protective actions. People west of the Hudson River should be ordered to shelter in those areas where elevated dose rates are measured.
Recommend that downwind people beyond EPZ take shelter if elevated dose rates are measured. All should continue to listen to updates from news media.
9 Detailed Information-2
- 4. After release is effectively over, look for hot spots, even if they are beyond the 10 mile EPZ. Relocate people from these hot spots to predesignated shelter(s). Steps 1-4 would limit long term latent fatalities below a statistically detectable level.
- 5. End sheltering. This could be done county by county, depending on measured dose rates.
- 6. Monitor and control food ingestion pathways and water sources.
- 7. Return evacuees to their homes if dose rate levels warrant this.
10
11 Measurements from Fukushima Support Modern Severe Accident Analyses.
N/A Start of release after shutdown Duration of release 1982 Sandia Report, SST-1 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Two hours Fukushima Earthquake on March 11, 2011 at about 15:00, releases start March 12, 2011, more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> later.
[Later than thought before]
March 12, 2011 to March 25, 2011
[More gradual than thought before]
% of reactor core inventory Iodine Cesium 1982 Sandia Report, SST-1 0.450 0.670 Fukushima ( average of three plants) 0.017 -0.083
[Smaller than thought before]
0.009 -0.029
[Smaller than thought before]
12 Fukushima Evacuation and Sheltering History Time (in year 2011)
Distance from plant, Km.
Action MARCH 11, 20:50,21:23 2,3 Two pre-emptive evacuations March 12, 05:44 10 Compulsory evacuation March 12, 18:25 20 Compulsory evacuation March 15 20-30 Shelter in home March 25 20-30 Self evacuation April 22 Areas with dose rate>20 mSv/year Evacuation within one month June 16 Hot spots with dose rate>
20mSv/year Recommended for evacuation