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Pilgrim’s Emergency Plan-Flawed

Emergency Preparedness

Pilgrim’s Radiological Emergency Plan and Procedures are inadequate to respond to a fast breaking accident of large consequence that could result, for example, from a terrorist attack; and current plans are not able to service our expanded population. Plans need to be updated.

    The former Federal Emergency Management Agency (FEMA) Director, James Lee Witt, after analyzing a plan similar to 
    Pilgrim’s (Indian Point, 2003) concluded, “...the current radiological response system and capabilities are not adequate to
    ... protect the people from an unacceptable dose of radiation in the event of a release..."

Emergency plans are particularly important today because; accidents can and do happen; nuclear reactors are on the short list of terrorists; nuclear reactors are showing age-related degradation; and regulatory oversight has become increasingly lax. Hurricanes Katrina and Rita demonstrated clearly what can go wrong. Those disasters were tracked well in advance, unlike a nuclear disaster.

Plans will never be adequate to justify re-licensing Pilgrim. This is because Pilgrim is located in a populated area - the fastest growing area of the state. The infrastructure is  inadequate for a nuclear emergency. Roads, for example, are clogged during regular commuting hours and summer week-ends, never mind a nuclear disaster. Support services required to respond to an accident are insufficient, too. Cape Cod is another reason. Its year-round population is increasing and it skyrockets during the summer. Most of its citizens live within the first year peak fatal zone, all within the peak first year injury radius. The Cape is downwind most of the year. Evacuation is not possible. Folks are trapped.

Emergency planning is not required when a reactor ceases operations. However the highly radioactive spent fuel is onsite - a prime terrorist target. Emergency response plans need to be maintained until the site is fully decommissioned.

Goal/ Assumptions Underlying Emergency Planning – False

Goal: The current Goal of emergency planning is to prevent lethal radiation doses not prevent radiation linked cancer, disease and genetic damage. NRC requires evacuation planning for only those within the “plume exposure” pathway – 10 mile radius. The choice of this radius was based in part on NRC’s analysis indicating that in a severe accident, dose rates high enough to cause early fatalities from acute radiation syndrome would be confined to about 10 miles. However dose rates outside this region, though on average not high enough to cause early fatality, could be high enough to cause significant risk of cancer, disease and birth defects unless effective measures are taken. NRC’s emergency planning was not designed to limit such exposures in the event of “worst core melt consequences” for which the protection goal is that “immediate life threatening doses would generally not occur outside that zone.” [NRC, Criteria for preparation and Evaluation of radiological Emergency Response Plans and Preparedness in Support of Nuclear Plants, NUREG-0654, 1980, p.12].  Emergency planning should be designed to prevent human suffering – not simply prevent immediate death; just as, for example, fire codes and fire drills for schools are designed not simply to prevent children from immediately burning to death but to prevent them from being hurt, period.

Assumptions: Emergency planning should be designed to deal with accidents of major consequence spreading over a large area. NRC and FEMA continue to assert that such events are unlikely to occur. This is no longer relevant in age of terrorists who have technical expertise and are actively targeting critical infrastructure facilities with the intent of maximizing casualties and economic disruption. If current emergency plans are incapable to cope with all credible terrorist-induced events, they should be upgraded. If upgrading is so cumbersome or impossible to a sufficiently protective level, then other operations, including shutdown should not be ruled out.

Deliberate accidents

It is true that a spontaneous occurrence of multiple system failures necessary to cause a serious accident is typically an improbable event. However, if one considers the possibility of sabotage or deliberate accidents, the low probability argument that NRC uses to justify the continued operation of plants, when plans are based on a deliberate event not occurring, completely breaks down.

Terrorists with readily available knowledge of how nuclear reactors work can design their attack to maximize the chance of achieving a core melt and large radioactive release; or worse, a spent fuel pool accident with greater release.


Rules and Responsibility for Planning   More

What’s wrong with Pilgrim’s Emergency Plans and Procedures? More
1.    Goals and assumptions underlying current emergency planning inadequate 
2.    Hazard Assessment- equipment to monitor and track plume inadequate 
    Plans/Procedures Fail to Adequately Address:

Notification of Public

Potassium Iodide (KI)

Plan/Procedures Fail to Adequately Address Evacuation Concerns

Plan/Procedures Fail to Adequately Address Sheltering Concerns

Plan/Procedures Fail to Adequately Address Increasing Staffing and Protecting Worker Safety
Plan/Procedures Fail to Adequately Provide for Large Number Injured and Contaminate

4.  Population Statistics and Demographic Characteristics, current and 2032 projections

What to do when told to shelter; what to do when told to evacuate  More
Potassium Iodide – Massachusetts’ Policy and Plan   More
Map: Pilgrim EPZ’s Evacuation Routes, Reception Center, Host Schools 

DHS/FEMA Biennial Emergency Exercises    More

Link: James Lee Witt Associates http://www.wittassociates.com/projects_NYdesc.html

Former Director FEMA; site contains analysis Indian Point’s Emergency Preparedness Plan commissioned by the State of New York


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