What’s wrong with
Pilgrim’s Emergency Plan and Procedures?
False Assumptions Underlying Current Planning
Authorities Assume Insignificant Release Radioactivity Offsite
Emergency plans assume an accident that involves an insignificant release of radioactive materials offsite likely to only require evacuating 2-miles around and perhaps a portion of the population within a “key-hole” or wedge from 2-5 miles.
Downplaying the potential consequences of a radiological disaster at a nuclear plant began after TMI when offsite emergency response plans were designed for commercial reactors. NRC mischaracterized the accident then and continues to do so today.
TMI Facts [Source: Arnold Gundersen, expert witness TMI 1994 trial, video link at http://www.nirs.org/reactorwatch/accidents/tmipowerpoint.pdf]
Perhaps Sir Walter Scott said it best, "Oh, what a tangled web we weave, when first we practice to deceive."
By minimizing the amount of radiation likely to be released and the geographic spread of that contamination, reactors seeking a license or a renewed license in now heavily populated areas will appear to have sufficient infrastructure to quickly evacuate/shelter the population in an accident. The numbers now fit on paper.
Pilgrim NPS, for example, has the potential to release more than twice the amount of Cs-137 than was released at Chernobyl. The amount of Cs-137 released during Chernobyl in 1986 was 2,403,000 curies; the amount of Cs-137 in Pilgrim’s Core during license extension will be 190,000 TBq or 190,000 X 27 Ci = 5,130,000 curies. In addition, during license extension there will be more than 44,010,000 curies of Cs-137 in Pilgrim’s spent fuel pool during license extension - 8 times more than a core release [Source: The Massachusetts Attorney General’s Request for a Hearing and Petition for Leave to Intervene With respect to Entergy Nuclear Operations Inc.’s Application for Renewal of the Pilgrim Nuclear Power Plants Operating License and Petition for Backfit Order Requiring New Design features to Protect Against Spent Fuel Pool Accidents, Docket No. 50-293, May 26, 2006 includes a Report to The Massachusetts Attorney General On The Potential Consequences Of A Spent Fuel Pool Fire At The Pilgrim Or Vermont Yankee Nuclear Plant, Jan Beyea, PhD., May 25, 2006.]
Emergency Planning Zone (EPZ) 10-Miles – Impact Much Wider
Emergency response plans and procedures [evacuation and sheltering] do not include plans for residents outside the 10-mile EPZ. However, according to federal government studies:
A core melt at Pilgrim NPS, would result in a 20 miles peak 1st year fatal radius; a 65 miles peak 1st year injury radius; and 23,000 peak cancer deaths. A spent fuel accident would be many times worse.
These estimates are conservative. - the federal study, CRAC II:
NRC's NUREG/CR 1433. It said that for children, the following dangers might occur from the inhalation of nuclear materials after a massive core-melt atmospheric accident.
Approximate Dangers of a Core-Melt Atmospheric Accident for Children
Spent Fuel Pool Accident is a credible event and the consequences could extend 500 miles. The National Academy of Sciences stated in a 2004 report, a redacted version made public in 2005 that, 
“Finding 2A: Spent fuel storage facilities cannot be dismissed as targets for such attacks because it is not possible to predict the behavior and motivations of terrorists, and because of the attractiveness of spent fuel as a terrorist target given the well known public dread of radiation…The committee judges that attacks by knowledgeable terrorists with access to appropriate technical means are possible.” NAS, p.4
“Terrorists view nuclear power plant facilities as desirable targets because of the large inventories of radionuclides they contain. The committee believes that knowledgeable terrorists might choose to attack spent fuel pools because: (1) at U.S. commercial nuclear power plants, these pools are less well protected structurally than reactor cores; (2) they typically contain inventories of medium – and long-lived radionuclides that are several times greater than those in individual reactor cores.” NAS, p.36
“A loss-of-pool-coolant event resulting from damage or collapse of the pool could have severe consequences. Severe damage of the pool wall could potentially result from several types of terrorist attacks, for instance: (1) Attacks with large civilian aircraft; (2) Attacks with high-energy weapon; Attacks with explosive charges.” NAS, p.49
“Finding 3B –… a terrorist attack that partially or completely drained a spent fuel pool could lead to a propagating zirconium cladding fire and the release of large quantities of radioactive materials to the environment. Details are provided in the committee’s classified report.” NAS, p.6
“Such (zirconium cladding) fires would create thermal plumes that could potentially transport radioactive aerosols hundreds of miles downwind under appropriate atmospheric conditions.” NAS, p.50
“The excess cancer estimates …to between 2,000 and 6,000 cancer deaths”[i] p.45
Implication: Pilgrim NPS's Implementing Procedures are out of sync with reality.
1. Plans should be based taking full account of the potential consequences of a terrorist attack or accident – planning must be for both the worst and best scenarios.
2. Currently there is (1) planning Zone, the 10-mile EPZ; it makes more sense to consider (3) planning zones.
Perhaps the inner zone would remain at the current 0-10 miles; mid zone at 10.01-20; and 20.01 – out, to be determined. As an example, potassium iodide would be pre-distributed to both inner and mid zones, out to 20 miles, as mandated by Congress - Bioterrorism Act. The mid zone would be instructed to shelter with KI followed by an evacuation – phased in after inner core evacuates.
3. Federal and State planners can not assume that equipment/supplies/personnel required in an emergency (such as radiation monitors, potassium iodide stockpiles) can be shifted from one EPZ site within the state to another. There may be multiple attacks, as occurred in 9/11.
Key Hole Theory of Plume Dispersion – ignores variability wind in coastal communities
Realistic modeling assumptions and meteorological data are the key to
forecasting and implementing appropriate
Plume Modeling – the key-hole:
Currently, the NRC bases regulation and guidance on outdated and simplistic
NUREG-0654 FEMA-REP 1 Rev. 1 Supp.3- Appendix I states that,
Licensees are not required by the NRC to use complex models (Class B models)
Implications for emergency planning
By relying on the straight –line Gaussian
model to construct a “key hole” planners are likely to make the wrong call -
Although the “key hole” is contradicted by
actual weather analysis; it allows for limited resources to appear
The Radiological Emergency Response
Plan and Implementing Procedure for Pilgrim’s EPZ says that school
Recommendation: Planning and targeting resources on the “key hole” should be taken out of all plans and procedures. Communities should refuse to move their resources to service another community in a nuclear disaster and not count on resources from other near-by communities to provide service to them in a nuclear disaster. Help should be contracted with communities realistically not expected to be affected by the disaster; and more important from communities whose own population will not react to the news of a nuclear disaster which would strain their services.
Slow Breaking Accident – Post 9/11 not realistic
However, the plan and tests of the plan are designed to address a slowly-evolving emergency, in which it is assumed that evacuation could occur over a 10 hour span or more.
Example: The precautionary transfer of schoolchildren is widely claimed and in most, if not all, communities parents/guardians are not instructed how to pick up their children at school in the event of a disaster (route and parking) so not to interfere with an orderly evacuation.
Current Goal Emergency Plans -Prevent Lethal Doses not Prevent Cancer, Disease, 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 fatalities could be high enough to cause significant risk of cancer unless effective measures were 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.”
The National Academy of Sciences (NAS) June 2005 report, The Biological Effects of Ionizing Radiation Report (BEIR Vll) conclusion was simple: No amount of radiation is safe and women and children are the most at risk.
Women and Children Most at Risk:
The National Academy reported that overall cancer
mortality risks for females are 37.5 percent higher than for men,
and the risks for all solid tumors (lung,
breast, and prostate) are
almost 50 percent higher.
The differential risk for children is even greater. The
same radiation in the first year of life for children produces three
to four times the cancer risk as
exposure between the ages of 20 and 50. Female infants have almost double
the risk as male infants.
Heart Disease and Stroke: The National Academy stated that No amount of
radiation exposure is safe; and noted that relatively high levels of
radiation exposure increase risk not only of cancer but also of heart
disease and stroke.
Currently what is the exposure level that determines emergency classification and protective action calls? How do those levels have to be readjusted after BEIR Vll?
Clearly preventing cancer, disease and genetic damage must be the goal not simply preventing death.
Calculation of Reactor Accident Consequences U.S. Nuclear Power
 Safety and Security of Commercial Spent Nuclear Fuel Storage -Public Report, National Academy of Sciences, April 2005
 US NRC Description: Principles of Evacuation, source: http://www.nrc.gov/what-we-do/emerg-preparedness/evacuation-sheltering/principles-evac.html; 2004 Emergency Public Information Calendar, Pilgrim, page 17.
 James Lee Witt Associates, Review of Emergency Preparedness of Areas Adjacent to Indian Point and Millstone, March 2002, Executive Summary, page X.
 NRC, Criteria for preparation and Evaluation of radiological Emergency Response Plans and Preparedness in Support of Nuclear Plants, NUREG-0654, 1980, p.12.
 National Academy of Sciences, Health Risks from Exposure to Low Levels of Ionizing Radiation: BEIR VII – Phase 2 (2005) http://lab.nap.edu/nap-cgi/discover.cgi?term=Beir+VII&restric=NAP&GO.x=31&GO.y=11
Hazard Assessment – equipment to monitor and track the plume - Inadequate
Equipment to monitor and track the plume
Managing an event – making the proper emergency call - requires first grappling with what has happened. Plans incorrectly assume that data regarding the status of plant conditions, radiological release and weather are reliable, accurate and timely.
The state is dependent on the licensee’s reports and accuracy of the licensee’s equipment. Radiation monitors and weather equipment is not computer linked to the state and local authorities from all points that radiation is released from Pilgrim and from appropriate off-site locations. Local communities are dependent on the state’s interpretation of Pilgrim’s accident reports of what is happening and how it may affect the population. The state sends a team to take samples and sends those samples back to state labs for analysis. However that takes time – too much time. For a complete analysis, refer to the monitoring section.
Recommendation: Upgrade Pilgrim’s monitors and computer link those monitors to the state and local authorities; install high-tech computer radiation monitors in local communities.
Plans/Procedures Fail to Adequately Address Notification of Public
Notification Emergency Responders & Public - Inadequate
Rapid notification of emergency responders and the public is central to planning.
Emergency Responders: Emergency responders must have communication equipment that is interoperable. Example radios in Duxbury are off frequency; this means, for example, the Emergency Operations Center (EOC) can not communicate with the schools.
Public notification: At present notification systems are inadequate in that they essentially rely on one system - sirens. Sirens can not be heard in all parts of town and can not be heard inside if the windows are down - they are simply an outdoor warning system. Sirens can and have failed. Pilgrim’s sirens have been unreliable. They failed 12 times from January 2000 to January 2004. The latest siren failure came after a brand-new siren system was installed. All systems require battery back-ups.
A combination of warning systems is recommended - redundancy. This should be funded by the licensee and/or Homeland Security, recognizing that some upgrades are multi-purpose.
Warning/communication systems should all have backup power so that they operate when off-site power is lost. This is a logical extension of NRC’s requirement that the telephone system used by licensees to inform the NRC about meltdowns have a backup power source so the NRC will get this notification even if offsite power is lost. The same logic applies to assuring communication to the public and state/local officials.
What is needed?
Outdoors: sirens in sufficient number with an audible, but simple, voice message and battery back-up.
Indoors: rapid dialing systems that have the capability to notify workers and every household and business within the EPZ in less than 15 minutes. Systems are on the market today that can do the job – for example Sigma Reverse 911 and DCC. Sigma Reverse 911’s MassCall System allows 2,000 calls to be sent out at once, 30 second message. DCC’s phone bank has 500 phones capable of making 1,000 calls a minute, based on a 30 second transaction. Either using Sigma’s MassCall or contracting with DCC to use two of their phone banks would permit contacting 30,000 households within 15 minutes, the approximate number of households in Pilgrim’s EPZ. More phone banks could be added, as required.
Upgrading the notification system would not only save lives in an emergency but also reduce the need for Police to try to perform this function. If sirens fail, current emergency plans call for local police to drive up and down streets to warn residents over their PA system - a waste of resources and unlikely to accomplish the task.
Potassium Iodide (KI)
Potassium Iodide (KI) is a U.S. Food and Drug Administration (FDA) approved over-the-counter drug that should be taken immediately to protect the thyroid gland from radiation injury caused by radioactive iodine released during a nuclear accident.
About KI: KI saturates the thyroid gland with stable (non-radioactive) iodine, thus preventing or reducing the amount of radioactive iodine that will be taken up by the thyroid. Radiological emergencies release radioactive iodine in the environment. Since iodine concentrates in the thyroid gland, inhalation of air or ingestion of food contaminated with radioactive iodine can lead to injury to the thyroid, including an increased risk of thyroid cancer.
To be most effective, KI should be taken shortly before or shortly after exposure to radioactive iodine. Even if taken three to four hours after exposure, it would still reduce radioactive iodine from being absorbed by the thyroid and still have a substantial effect – more than six hours is getting too late. The protective effects of KI last approximately 24 hours.
Where to Stockpile KI - Distance from Accident Site
Congress passed the Bioterrorism Act, 2002, and stated that KI should be made available to citizens within 20 miles of reactor sites. They charged in Section 127 the U.S. Health and Human Services with implementation. HHS has dragged their feet and Congress’ mandate to HHS remains unfulfilled and the public not protected.
The American Thyroid Association recommends that: Potassium iodide should be made available to populations living within 200 miles of a nuclear power plant and should be “pre-distributed” to households within 50 miles of a plant. Massachusetts Medical Society advised that KI be provided to all Massachusetts residents.
U.S. Nuclear Regulatory Commission, NUREG/CR 1433 showed that for children, the following dangers may occur from the inhalation of nuclear materials after a massive core-melt atmospheric accident (like Chernobyl).
Approximate Dangers of a Core-Melt Atmospheric Accident for Children
Chernobyl: NRC’s NUREG-1623 points out that radioactive iodide can travel hundreds of miles on the winds. An increase in cancer caused by Chernobyl… was detected in Belarus, Russia and Ukraine. Notably, this increase, seen in areas more that 150 miles from the site, continues to this day and primarily affects children who were 0-14 years old at the time of the accident…the vast majority of the thyroid cancers were diagnosed among those living more than 31 miles from the site. The 2001 figures were 11,000 thyroid cancers at 31 miles. The increase in disease was attributed to both inhalation and ingestion of contaminated foods.
World Health Organization: (1999) World Health Organization (WHO) Guidelines for Iodine Prophylaxis following Nuclear Accidents states in its abstract regarding thyroid cancer caused by the Chernobyl disaster:
"This increase in incidence has been documented up to 500 km from the accident site." ...And therefore...”"That stockpiling (KI or KIO3) is warranted, when feasible, over much wider areas than normally encompassed by emergency planning zones, and that the opportunity for voluntary purchase be part of national plans."
Evacuation Concerns - Inadequately Addressed
A normal day on Route 3.
Include communities beyond the 10-miles in planning. In this case, advocate sheltering as a first response for those communities followed by a phased evacuation/ entry on to the major egress routes after the core has evacuated. This would save lives for those likely-to-be affected, In recent research near Indian Point demonstrated that sheltering individuals in the 10.7-25 mile region would be preferable to evacuation – evacuation tends to increase population doses by placing more people in direct contact with the radioactive plume. [Source: Chernobyl on the Hudson? - The Health and Economic Impacts of a Terrorist Attack at Indian Point Power Plant," was authored by Dr. Edwin Lyman, a senior staff scientist Union of Concerned Scientists.http://riverkeeper.org/document.php/317/Chernobyl_on_th.pdf]
Cars running out of gas will delay evacuation for everybody. Unfortunately not everyone keeps their tanks full. Town Emergency Management Agencies that do not have 24- hour service stations should develop Letters of Agreement (LOAs) or Memoranda of Understanding (MOUs) outlining the specific procedure to open pumps in an emergency after business hours.
Transportation dependent - bussing school children and those without cars in an evacuation, inclusive of latch-key children.
What should be done to provide greater assurance that transportation will arrive?
Mobilize Transportation Resources at Alert:
Transportation Providers have an approximate 3 hour mobilization time. However, the best time estimate for this procedure is 3-5 hours. Therefore:
Transportation providers must be required to mobilize at the Alert Stage of an accident – defined as sent out, to arrive on location, ready to load evacuees. Information from NRC documents explains that large amounts of radiation can be released within as little as 30 minutes from the start of some types of accidents/ attacks. If plans wait until a later stage of an accident to mobilize busses, they may arrive too late. If the accident de-escalates, the busses can be called off; and at worse a real-time response drill is achieved. There is no “precautionary Transfer” of school children in anything but a very slow breaking accident.
Would mobilizing transportation resources at Alert risk too many false alarms? “No” simply look at the number of Alerts reported by the NRC that have occurred nationwide. NRC Emergency Event Dataf busses are mobilized and the accident deescalates, then the area has had a good reality-based exercise to base time estimates and fix any glitches.
Contracts/Transportation Matrixes Annually to Town:
Assure Back-up Drivers – National Guard:
Busses Housed in a likely-to-be-impacted Community for Exclusive Use of that
Community in a Radiological Disaster:
Real-time Test time to mobilize Transportation:
Evacuation route signs
Capacity: Plans assume that only one in five (20%) will go to the Reception Center and Reception Centers are only equipped with personnel and materials to handle 20%– despite NUREG 0654 (J-12) that states that Reception Centers should be capable of monitoring 100% of the population within 12 hours.
This policy leaves 80% without an opportunity to be monitored and decontaminated risking their health. The policy is based on the Krimm’s Memorandum – a FEMA official who came up with the 20% based on the response of resident’s to a hurricane warning.
You can’t base policy on hurricanes. People react very differently to a nuclear disaster than to a hurricane warning. Public warning for a hurricane is ample –TV & Radio Storm Watch reports give ample warning, often days in advance; in contrast, the time of official notice of a nuclear attack/accident can be very short –less than 30 minutes.
Consequence: if 80% are not monitored and decontaminated they will not only put at unnecessary risk their physical and psychological health; they will contaminate populations in other areas with dirty vehicles. Also, it is likely many more than 20% will go to the Reception Center and it will be overwhelmed so none will be served.
Institutionalized populations may not go to
the Reception Centers at all. School children, the most vulnerable
population, may simply be sent to the “Host School,” facilities that do not
have monitors or decontamination capability. Residents at Nursing Homes,
Group Homes and detainees in jail are not brought to the Reception Centers.
They will be brought to other locations – locations without monitors and
Unique Geographic Locations
Phased Entry to Major Evacuation Routes
Sheltering instructions for the public
Recommendation: Masks should be stockpiled in schools; group homes, shelters etc and the public recommended stockpiling them, along with KI, for home use.
How to determine what type of mask: one key issue is the radioactive particle size we
might expect to see following a nuclear accident. No one really knows. In
part this is because the particle size is very dependent on the
circumstances of the release (isotopes released, temperature of the fire,
weather, etc.). But it also appears that there is simply a lack of data on
this question.Most analyses of the particle sizes following a nuclear accident appear to
assume an aerosol with particle sizes of either 1 or 10 microns. However,
it also appears to be possible for aerosols with a particle size well below
1 micron to be produced, particularly if very hot fires are involved. Dr.
Ed Lyman, Union of Concerned Scientists, thought cesium and some other
isotopes could easily form aerosols of with sub-micron diameter.
Example: Kimberly-Clark makes 'child sized' masks : Suitable for ages 3 - 10; Technical data: particle filtration efficiency >97% at 0.1 microns. Kimberly Clark Adult Face Masks : NIOSA approved and designed to provide an effective facial fit for N95 respiratory protection. Technical data: particle filtration efficiency 99% at 0.1 microns. Given all the uncertainties regarding the nature of the plume and how effective the masks would be, there may be no justification to purchase the more expensive N100 masks.
Evacuation versus Sheltering
Dr. Edward Lyman in analyzing Indian Point stated that evacuation and sheltering are equally effective in eliminating risk of early fatalities among residents of the 10-25 mile radius. On the other hand one sees that evacuation also tends to increase the number of latent cancer fatalities relative to normal activity, while sheltering reduces the number. It appears that sheltering in the 10.7 to 25 mile region would be preferable to evacuation. Evacuation tends to increase population doses by placing more people in direct contact with the radioactive plume. Other models (Lyman used MACCS2) and other shielding parameter choices may lead to different conclusions. Lyman urges emergency planning officials to evaluate degrees of shielding that structures in region may provide to determine the types of actions would provide greatest protection of residents of regions outside the 10-mile EPZ (page 49, Lyman)
Protecting Worker Safety
Protective Gear needed: Emergency workers should have sophisticated protective gear. The licensee and state have opposed – an economic, not a health based decision.
Currently protective gear is not provided even in a general emergency described in the Emergency Calendar as “…the most serious type of emergency. It could involve serious damage at the plant and a release of radioactive materials.” However Police and DPW workers are outside on duty at this time. Worse protective gear is not provided for those who volunteer for lifesaving missions that is to go outside after their dosimeter has exceeded the recommended “safe” level.
Clearly workers need to be provided with uniforms/clothes to cover all exposed skin; and some sort of breathing apparatus to prevent inhalation of radioactive materials. The protective gear should be in the local community, ready for use.
Until the community is properly equipped, workers should be advised to cover all exposed skin, no shorts or short-sleeved shirts.
Stockpile: Tyvek suits, boots and gloves; 3-M type masks (N-95); KI; and advise that cars/trucks do not provide adequate radiation shielding. Multi-purpose breathing masks -biological, chemical and radiological - should be made available to emergency workers who have received training for their use. Eventually workers should get a gas mask with attached canister.
Searching the web in spring 2005 the Direct Safety for example lists clothing costs (without mask) to be in the range of about $12.50- $23.00 per person per set of clothing. The total cost is dominated by the gas mask, $140.50 each. [Tychem QC coveralls: $9.28-10.42 (depending on size); Tychem SL coveralls: $17.20-19.99; Nitrile Gloves: $0.16 (4 mil thick), $0.31 (6 mil), $0.46 (8 mil); Latex over-boots: $3.00 pair; Gas mask (54400) plus canister: $140.5 (in quantities of ten or more)]
REWMDS: The center to decontaminate
emergency workers (REWMDS) must be outside the peak fatal zones – preferably
20-25 miles away. At Pilgrim NPS, the REWNDS is within the “peak injury
zone” and close to the “peak fatal zone.” It is located in Carver, directly
across the street from the 10-mile demarcation line. It should be moved.
There should be more than one center – so that there is an alternative site
if the wind is blowing towards one of the centers.
Injured and Contaminated – Medical Facilities
NUREG 50.47 (b) (12) requires that arrangements are made to treat the contaminated and injured. However, the plan does not acknowledge that some accident scenarios will result in large numbers of injured and contaminated individuals.
Hospitals listed to serve those within the 10-mile EPZ of Pilgrim, for example, cannot handle monitoring and decontaminating large numbers of people. Also, some hospitals listed to serve the EPZ are too close to the reactor site to be of use.
Mobile Medical Tents: The Commonwealth of Massachusetts has stated that they intend to set up mobile decontamination tents. Do they have an adequate supply of monitors, decontamination equipment, KI and trained personnel? Because of the possibility that there may be multiple attacks, as occurred in 9/11, States can not rely on moving needed equipment from other reactor sites.
Hard Data Provided: Local communities should be provided annually with LOA’s and MOU’s to verify providers have agreed to participate; are equipped, inclusive of monitoring/decontamination equipment; the number of patients that they can handle per hour; annual training provided and completed; emergency testing completed, date and results.
Example: Pilgrim NPS – only 11 facilities are under agreement. What is the maximum number of contaminated/injured that each hospital can handle within 12 hours?
Population Statistics - Pilgrim NPS's Emergency Planning Zone
 Calculation of Reactor Accident Consequences, U.S. Nuclear Power Plants (CRAC-2), Sandia National Laboratory, 1982. “Peak” refers to the highest calculated values – it does not mean worst case scenario. This is due to uncertainties in the meteorological modeling acknowledged by Sandia. The model only considered one year’s worth of data and does not model for precipitation beyond a 30-mile radius. This is significant because the highest consequences are predicted to occur when a radioactive plume encounters rain over densely populated area. Peak Early Fatalities are deaths that result within the first year. Peak Early Injuries are radiation-induced injuries occurring in the first year that require hospitalization of other medical attention – such as sterility, thyroid nodules, vomiting and cataracts. Peak Cancer Deaths are predicted to occur over a lifetime. However, this is not the case with leukemia which is assumed to have occurred within the first 30 years following the accident.