Tell the NRC to strengthen emergency planning rules

Comments on the Scope of Future Revisions to ‘‘Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants’’ (NUREG–0654/FEMA–REP–1, Rev. 1)

#1 Emergency planning zones must be expanded. The 10-mile emergency planning zone that is currently in place is completely inadequate. The NRC should adopt the Petition for Rulemaking (PRM-50-104) filed by Nuclear Information and Resource Service and 37 other organizations that calls for a three-tiered approach of a 25-mile plume Emergency Planning Zone, a 50-mile Emergency Response Zone, and a 100-mile ingestion pathway zone. These changes in emergency planning should be added to NUREG 0654. It is simply unacceptable that, given Fukushima’s and Chernobyl’s long lasting and far reaching effects, the United States does not have larger emergency planning zones. Japan has learned already, and in October 2012 established emergency response zones of 30 kilometers (18.6 miles).

#2: Given that the disaster at Fukushima was initiated by an earthquake and tsunami, emergency response planning efforts should be enhanced by amending exercises and drills so that alternating exercising and drills include initiating or concurrent regionally appropriate events. This is critical because 2011 and 2012 have exhibited extreme weather patterns. For example, in 2011 an earthquake knocked the North Anna nuclear power plant in Virginia offline for months while Hurricane Irene caused severe flooding on the east coast, particularly in Vermont. In 2012, Hurricane Sandy battered the east coast causing water level concerns and an alert at the Oyster Creek reactor on New Jersey’s shore. Had an evacuation been necessary during that event, it would have been nearly impossible.. Experts predict that these weather trends are not fluke occurrences but rather the “new normal.” Because natural disasters can greatly complicate the ability to evacuate a given area, or even provide sufficient communication to assure that sheltering in place or other protective actions occur, these changes to NUREG 0654 should be addressed by the NRC and FEMA.

#3: When amending NUREG 0654, the NRC and FEMA should give less credence to computer simulations and models and should rely more on the real world experience of Fukushima, Chernobyl and Three Mile Island. Nuclear accidents do happen, and do have real-life consequences. While computer simulations and models are valuable in identifying reactor design flaws and potential system failures, they can never encompass the full gamut of the limitless possibilities that real life can, and does, deliver, nor the scenarios of the future that may currently be beyond our imagination. In real life, reactors explode and release deadly radiation for large distances.

#4 Emergency planning regulations should take into consideration the risks of radiation exposure, both acute and chronic. A 10-mile emergency planning zone is not adequate to protect the public from the effects of radiation, particularly the effects from long term and sustained exposure to radiation. According to the National Academies of Science BIER VII report issued in 2006, there is no safe dose of radiation. Indeed, women are 50% more susceptible to radiation than men, and children are even more susceptible than women. The most vulnerable in our society—young girls—must form the basis for protection. Currently, radiation standards and emergency response decisions are based on exposures to “the average man.” This is no longer acceptable. In addition, the American public deserves protection from radiation exposures that could cause thyroid cancer and other cancers and diseases, not just acute symptoms.

#5 The distribution of Potassium Iodine (KI) should be extended in conjunction with the expanded Emergency planning zones. Emergency planning protective actions must include the prophylactic use of potassium iodide (KI) for the public. Requiring potassium iodide will protect public health and safety, as KI protects the thyroid gland, which is highly sensitive to radiation, from radioactive iodine released in nuclear accidents. KI saturates the thyroid gland with iodine in a harmless form. By doing so, it prevents inhaled or ingested radioactive iodine, which could lead to thyroid cancer, disease, and mental retardation or to other illness, from lodging in the thyroid gland. KI will be especially helpful in protecting the safety and well-being of populations like children and women, who are more susceptible to the dangerous effects of radiation

#6 Criteria for using sheltering-in-place as a protective strategy should be established, and must be clear and well-supported. Generally speaking, sheltering-in-place may be a preferred strategy in the case of some fast-moving or low-release accident scenarios. In most scenarios, including those where exposure could lead to chronic health impacts, evacuation and/or relocation will be the preferred strategy to protect against unnecessary radiation exposure.