Time for the public to speak out: Tell NRC to expand nuclear evacuation zones!

May 16, 2012

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.

We have prepared some sample comments for you to submit--you can do so below. However, we encourage you to edit these comments to reflect your own concerns, and to discuss emergency evacuation issues in your own communities. What happens if there is an earthquake in your area, or a hurricane? Has population growth in your area outstripped road networks? What about public transportation--how would people without cars be evacuated? Note: To assure that your comments are directed appropriately, the subject line of the letter cannot be edited.

The original petition, along with sample resolutions for local officials and other background information, can be found on our Nuclear 911 website here.

Important notes: The NRC asks that you not provide identifying information about yourself unless you want it published on their website. So we are not asking for street addresses or phone numbers. Only your name, city, state, and country (if outside the U.S.) will be included. International support for this effort is welcome. The comment deadline is July 16, 2012--that gives us all time to encourage our friends and colleagues, organization members, state and local elected officials, to comment as well. The nuclear industry will certainly be commenting--we need the widest possible outpouring from the vast majority of people who support this effort! Please use the icons at the top right of this page to help spread the word. Thank you!

Subject: Comments on PRM-50-104, Docket ID NRC-2012-0046

Your Letter:

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 80% 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.

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 intiating or concurrent natural disasters.

Thank you,

Nuclear Regulatory Commission

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