Arnie Gundersen: Hi I'm Arnie Gundersen from Fairewinds and it's June 5th, Sunday.

I wanted to talk to you today about emergency planning.  Emergency plans are kind of unique to nuclear power plants; coal plants don't have them, oil plants don't have them, windmills and solar farms don't need them either.  Way back when nuclear regulations were started, the people recognized that nuclear plants were different, and there would be a need to evacuate lots of people in the event of a nuclear accident.  So they came up with a law to implement those concerns.  There is a thing called a Code of Federal Regulations.  Every agency has their own Code of Federal Regulations.  And the nuclear one is part 10 of the Code of Federal Regulations.  So 10CFR is nuclear law.  Within that, is a part 100.  Part 100 talks about how to site a nuclear plant.  Within that is a Chapter 11 that talks about emergency  planning.  So it's 10CFR nuclear law 100.11 is what we are going to talk about today.  That law says really, really simply that there is only one criteria for emergency planning.  And that is that nobody in the population get more than 25 rem of radiation during the course of a nuclear accident.  That is how the law is written.  That is the number, that is the goal that the utilities must stay below.  Now Chairman Jaczko has said that he is confident that 10 mile plans are adequate, and yet, in Japan, Chairman Jaczko recommended to the White House to evacuate out to 50 miles.  But there is no basis in the law in 10CFR to discuss what that distance is.  It is just whatever it takes to stay below 25 rem of radiation.  So, Congress then told the Nuclear Regulatory Commission that they have to come up with a way to calculate that exposure.  And this is where it gets interesting.  The law is clear:  25 rem is the most somebody can get.  But it is based on a lot of speculation about what is released from a nuclear power plant.  Now all that speculation is put into something called a NUREG and that is a regulation that implements the bigger law.  There are two NUREGs that apply, NUREG 0654 and NUREG 0396 are the two.  But anyway they are just a compilation of all of the speculation that the that the Nuclear Regulatory Commission assumes when they try to implement 10CFR100.  

Now let's talk about how this ten mile zone came to be.  The NRC was allowed to make some assumptions about how much radiation got out of a nuclear power plant.  It is just speculation.  
The NRC and the industry got together and they said let's speculate that 1% of the nuclear fuel fails in the event of an accident.  And of that 1%, let's speculate that 95% of THAT gets stuck on the inside of all of the containment boundaries that are inside of there.

And so, of the 1% of the 95% of that, all of the remainder is inside the nuclear containment.
And the NRC says lets assume that the containment then leaks at a half percent per day.  So this speculation that only 1% of the fuel fails and that 95% of that gets stuck on the walls, and that then only a half a percent of what remains is released everyday, is the basis that the nuclear industry and the Nuclear Regulatory Commission come up with when they determine the emergency planning zones around a nuclear reactor.

When you apply all those assumptions, you come up with a very small emergency planning zone, a couple miles.  So the NRC said, lets go out to 10 miles, and that is in NUREG 0396.  It appears as an assumption in a regulation, but it is really NOT part of nuclear law.  And it is based on a whole series of speculations that the Nuclear Regulatory Commission and the nuclear industry agreed to.  

Fukushima shows us that all of those assumptions went up in smoke quite literally on March 11th.  We know that ALL of the fuel failed not 1%.  We know that the containment leaked like a sieve.  So the speculation that was nuclear regulation on March the 10th, really has no basis in fact since March 11th.   

So the Nuclear Regulatory Commission makes a bunch of speculation and they determine that there is no way that anybody outside of 10 miles is ever going to receive an excess amount of radiation.  Then they have to develop a written evacuation plan for people inside that 10 mile zone.  And here is what that written plan speculates.  According to the Nuclear Regulatory Commission, school bus drivers who have families outside the 10 mile zone, will leave their families, hop in the school bus and drive INTO the nuclear accident to evacuate kids at the local high school.  According to the Nuclear Regulatory Commission, those school bus drivers will leave their families outside, drive INTO the accident to evacuate elders in elder housing.  According to the Nuclear Regulatory Commission, parents WILL NOT drive to school to rescue their kids.  They will drive away from the nuclear accident and wait for the school busses to come to them.  

Now it's actually a little worse than that because the most likely type of a nuclear accident is caused by a loss of offsite power.  That is what happened at Fukushima:  the power system AROUND the plant broke down.  If that happens, not only will the plant not have power, but the street lights won't work.  According to the NRC, the street lights DO work.  Not only that, but your home lighting won't work and your radio and TV won't work.  But according to the NRC, you will be able to contact the outside world by phones or by radio or by television.  

But remember the most likely cause of a nuclear accident is loss of offsite power and that has NEVER been part of an emergency plan, assuming that all of that does not work.

Again though, there are some other issues that need to be considered in addition, and that is infrastructure.  That means highways, for instance.  Let's look at Pilgrim for a moment.  Pilgrim is at the base of Cape Cod.  And if it has an accident and the wind is blowing as it was in Fukushima to the east, that is right across Cape Cod.

But the emergency plan for Pilgrim tells people to stay in place on Cape Cod; don't evacuate.
So the radioactive winds are blowing towards them, but the emergency plan assumes that they don't move.  Now anybody who has ever been to Cape Cod knows there are two bridges and they are always full of traffic.  So the traffic problems, the infrastructure problems, will limit the ability to evacuate people in a real drill.  

Another plant with similar problems is Indian Point.  Indian Point has two major highways heading north-south on one side of the plant, and the Hudson River on the other.  So it is trapped in a river valley corridor, where the radioactive plumes usually travel in the same direction, north-south.  It is hard to imagine that people will drive rationally and not have a seven car pile up on one of those highways, slowing the evacuation down.  But again, according to the NRC, every bit of traffic moves reasonably.

But let's look a little further south in another infrastructure problem.  Down in Florida, there is a plant called Turkey Point.  It was almost hit by hurricane Andrew about 20 years ago and afterwards, infrastructure was destroyed around the power plant.  The security systems did not work, the radiation detectors did not work, the highways were a mess, and there is no way that it could have been evacuated, had the hurricane caused an accident.

On the opposite coast, we have got Diablo Canyon in California which is right next to an earthquake fault.  But according to the NRC, all of the bridges will not collapse in the earthquake and people will be able to drive away from the accident on bridges that miraculously withstand the earthquake, when the power plant does not.  

So emergency planners at the Nuclear Regulatory Commission and in the nuclear industry would like us to believe two things:
That people behave rationally in an emergency and do what the plan was written to do.  And that Mother Nature is benign and there is no damage to infrastructure.

On March 10th, the day before Fukushima happened, if you had asked me who were the best people on the planet to be prepared in the event that an emergency happened, I would have said it was the Japanese.  And yet, look, here we are 3 months later and it is obvious that they were totally unprepared for the accident that actually occurred.

What I am proposing here is not that we take a look at the law.  It is a good law, and it says 25 rem, and that will protect the population.  

But what is more important is to look at all the speculation that goes into developing all that implementing stuff that goes behind this.  That goes into, let's take a look, what did we learn from Fukushima about how much radiation can be released from an accident, what did we learn from Fukushima about the condition of the infrastructure after an accident.  And take all of that and come up with better emergency planning.  When I factor in all the things I just discussed, fuel failures, containment failures, winds that blow in more than one direction, irrational behavior, destroyed infrastructure, I reach the conclusion that the NRC needs to demand emergency plans out to 50 miles, not 10, just like the United States required in Japan.  

If it is good enough for Americans living in Japan, it is good enough for us back home.  I am sure it will be more expensive.  But the goal of the Nuclear Regulatory Commission should be to protect us, not industry profits.