TELL NRC AND ALL ELECTED OFFICIALS, UNTIL LIMERICK CLOSES, CHANGES MUST BE MADE TO LIMERICK’S
EVACUATION PLAN!
1. IMMEDIATE NOTIFICATION OF ACCIDENTAL RADIATION RELEASES.
• Establish INDEPENDENT radiation monitoring so the public can be informed immediately when Limerick has a higher than usual radiation release.
• Independent Regional Radiation Monitoring and Reporting Program For Limerick Nuclear Plant Radiation Releases, With Continuous Radiation Data Posted In Real Time On County Emergency Management Websites.
• Immediate Notification to the public of radiation levels exceeding background levels for more than one hour. Public notification should be made through the emergency broadcast system plus recorded notification message to telephones.
• Provide an immediate electronic public alert system for higher than usual radiation releases.
2. EXPAND LIMERICK’S EVACUTION ZONE TO 50 MILES
• Demand that Limerick’s evacuation zone be expanded to 50 miles, to better protect the health and financial interests of millions of people.
• Fukushima made it clear that high levels of radiation travel far more than 10 miles.
• U.S. citizens in Japan were advised to evacuate 50 miles from Fukushima.
3. EXPAND LIMERICK’S INGESTION PATHWAY ZONE TO 100 MILES
• Demand that Limerick’s ingestion pathway zone be expanded to 100 miles, to reduce radiation exposure to millions from radioactive food, water, and soil.
• Dangerous levels of radiation have been detected over 160 miles from Fukushima in water, soil, and food.
• Radioactive water and food cannot safely be consumed. Limiting use of radioactive food and water can minimize unnecessary risk of cancer and other diseases and disabilities .
YOUR VOICE IS URGENTLY NEEDED!
CONTACT LOCAL, STATE, AND FEDERAL OFFICIALS IN THE GREATER PHILADELPHIA REGION.
WITHOUT YOUR VOICE, THERE WILL BE NO CHANGES.
IT CAN HAPPEN HERE!
LIMERICK NUCLEAR PLANT CAN HAVE CATACLYSMIC MULTIPLE MELTDOWNS LIKE FUKUSHIMA.
• Fukushima revealed that multiple meltdowns could occur at Limerick Nuclear Plant too. With reactors and fuel pools like those that exploded at Fukushima, Limerick could release large amounts of radiation.
• It only takes loss of power and cooling water. Loss of power and water could be triggered by earthquakes, other natural disasters, cyber attacks, human error, terrorist attacks with planes or missiles, a host of safety and age-related structure and parts problems, mechanical breakdown, corrosion and aging of miles of buried pipes carrying highly radioactive, corrosive, and heated fluids.
MILLIONS IN THE GREATER PHILADELPHIA REGION COULD BECOME NUCLEAR REFUGEES, POTENTIALLY LOSING THEIR HEALTH, HOMES, BUSINESSES, JOBS, AND ALL THEIR POSSESSIONS.
Evidence from Fukushima and Chernobyl show the Radioactive Plume from Limerick Meltdowns would travel far beyond the arbitrary 10-Mile Evacuation Zone. Hundreds of thousands of our children would be transported to radioactive locations just outside the 10 miles.
• Radiation can start escaping off-site within 1/2 hour of a Limerick accident. Yet, Exelon is not required to immediately notify the public. History shows NRC waited days or weeks to notify the public. History shows the truth about the amount and kinds of radiation released will not be fully disclosed to the public until days or weeks later, if ever.
• In a severe Limerick radiation release, moving away from the plume as quickly as possible is imperative to limit radiation exposure and threats to health. Remaining in traffic far too long while exposed to Limerick’s radioactive plume can result in radiation sickness short term. Long-term it can result in increased cancers and many other diseases and disabilities.
• Massive populations on crowded roads, with bottlenecks and accidents, would create widespread chaos, anxiety, and fear. Normal Route 422 Traffic Jams Speak Volumes.
• NRC and elected officials knew In 1980, before Limerick construction was completed, that we had double the population density that could evacuate safely. Since then, population increased over 100%. Just as today, NO agency or elected official spoke out to protect public health, safety, and financial interests.
• FINANCIAL INJUSTICE. Millions of people in the Greater Philadelphia Region could become nuclear refugees losing their health, homes, businesses, and all their possessions. Over 8 million people live within 50 miles of Limerick Nuclear Plant.
• People cannot expect to be compensated for loss of personal property, including homes that would become permanently uninhabitable and businesses that would be unusable. In fact, industry and government could be expected to minimize all compensation costs for evacuated victims and would resist evacuating other victims outside the 10-mile zone to avoid costs. Victims outside the 10-mile evacuation zone wouldn’t even be compensated for temporary housing, even though they would still be in the dangerous radioactive plume.
• It is unclear which agencies are responsible for every aspect of a Limerick radiation accident / meltdown. NRC is already trying to claim no responsibility for off-site radiation. In Japan, the nuclear company claimed they had no responsibility for off-site clean-up.
The ACE Video-Blog Series Should Serve As A Wake-Up Call To Millions In The Greater Philadelphia Region, Related To Limerick Nuclear Plant’s Negligent Emergency and Evacuation Planning.
• This series identifies problems and flaws with Limerick’s Emergency and Evacuation plans.
• It provides evidence of NRC’s historical and current failures and corruption in policies and decision making that compromise and further jeopardize millions of people whose lives could be harmed or ruined permanently as the result of a Limerick Nuclear Plant Radioactive Accident and/or Meltdown.
• It reveals how NRC is refusing to make changes to evacuation planning that could actually reduce radiation exposures to millions in a radiation accident and/or meltdown.
• It reveals why our elected officials must demand a system for immediate independent public notification of a Limerick accidental radioactive release, and demand expanded evacuation and ingestion pathway zones.
The Alliance For A Clean Environment www.acereport.org
January to April, 2013
Part 1 – Reveals NRC’s Pared Down Emergency and Evacuation Plans Even After Lessons From Fukushima
Part 2 – Supports the Need for Immediate Notification And Expanded Evacuation and Ingestion Pathway
Zones
Part 3 – Reveals The Truth and Consequences of Radiation Exposure From Nuclear Plant Accidents or
Meltdowns
Part 4 – Reveals What Really Happened After Fukushima, Chernobyl, and TMI Meltdowns
Part 5 – Reveals The Financial Injustice To The Public From A Radiation Accident / Meltdown
Parts 6 and 7 – Reveal Fatal Flaws In Emergency – Evacuation Plans for Limerick Nuclear Power Plant
Part 8 – Identifies What Must Be Done to Minimize Radiation Risks From A Limerick Radiation Accident
or Meltdown
The Purpose Of This Series Is Minimizing Chaos And Reducing Radiation Exposure By Improving Limerick Nuclear Plant’s Fatally Flawed And Inadequate Emergency and Evacuation Plans.
1) IMMEDIATE NOTIFICATION OF ACCIDENTAL RADIATION RELEASES.
2) EXPAND LIMERICK’S EVACUTION ZONE TO 50 MILES
3) EXPAND LIMERICK’S INGESTION PATHWAY ZONE TO 100 MILES
YOUR VOICE IS URGENTLY NEEDED!
CONTACT LOCAL, STATE, AND FEDERAL OFFICIALS IN THE GREATER PHILADELPHIA REGION. WITHOUT YOUR VOICE, THERE WILL BE NO CHANGES.
ACE ANALYSIS OF:
Exelon’s Evacuation Time Estimate (ETE) For Limerick Nuclear Plant’s Plume Exposure Pathway Emergency Planning
ACE requested a copy of Exelon’s most recent 12/12 “Evacuation Time Estimate” (ETE), hoping to find ways to improve on unprotective evacuation plans for Limerick Nuclear Plant. Unfortunately, after careful review of Exelon’s ETE, we are more concerned than ever. This report confirms that safe and timely evacuation is an illusion.
This plan will result in extended radiation exposures, further jeopardizing health and safety for millions in the Greater Philadelphia Region, in the event of a Limerick Nuclear Plant radiation accident / meltdown.
Exelon’s ETE is self-serving fiction based on unrealistic, unworkable suppositions, assumptions, inconsistencies, and inaccuracies, with fact-free spin and illogical conclusions. Exelon’s letter accompanying its ETE concludes with: “There are no commitments in this letter”. That disclaimer speaks volumes.
Exelon’s ETE is a logistic fantasy that is clearly not either realistic or feasible. NRC officials for Limerick had not even evaluated Exelon’s ETE as of the NRC meeting 3-21-13. Any elected official in the region who reviews Exelon’s ETE objectively, should be alarmed. Exelon’s 12/12 ETE should be rejected by elected officials and NRC.
Elected and agency officials knew in 1980 that the population density around Limerick made safe evacuation impossible. They should have stopped Limerick construction. Since 1980, the region’s population soared, making an impossible situation far worse. It’s long past time for elected officials and NRC to protect the public’s health and financial interests, instead of Exelon’s profits.
Based on the impossibility of safe evacuation, NRC can and must shut Limerick down before it melts down.
OF GREATEST CONCERN: CHILDREN
More Than 65,000 Children In Limerick’s 10-Mile Evacuation Zone (Attending Over 230 Schools and Day-Cares) Could Be Transported To Reception Centers Just Outside Limerick’s 10-Mile Evacuation Zone.
Reception Centers Would Likely Still Be In Limerick’s Radioactive Plume.
MOST CHILDREN COULD BE TRANSPORTED TO RECEPTION CENTERS STILL IN LIMERICK’S RADIOACTIVE PLUME .
TO HAVE ANY HOPEOF MINIMIZING RADIATION EXPOSURE FOR OUR CHILDREN, RECEPTION CENTERS FOR EVACUEES SHOULD BE PLANNED AT LEAST 50 MILES AWAY BASED ON EVIDENCE FROM CHERNOBYL AND FUKUSHIMA.
• Based on evidence from Fukushima and Chernobyl meltdowns, Limerick Nuclear Plant’s 10-mile evacuation zone must be increased to at least 50 miles to keep vast numbers of children from unnecessary radiation exposure and the many health harms, including cancers, that would result from a Limerick Nuclear Plant radioactive accident / meltdown.
• Exelon’s ETE for Limerick, Unnecessarily Exposes Far Too Many Children To Limerick’s Radioactive Plume For Far Too Long. Reception centers are not far enough outside the 10 mile EPA. Most would still be in Limerick’s radioactive plume. Many mass care centers planned for Limerick evacuees could also still be impacted by Limerick’s radiation.
Evidence from Chernobyl and Fukushima meltdowns prove evacuating children just beyond 10 miles is negligent. NRC evacuated U.S. citizens that were within 50 miles of the Fukushima meltdowns.
Children far outside Fukushima’s 12-mile evacuation zone experienced radiation sickness symptoms.
Children over 40 miles away have radiation in their bodies at doses 20 times above recommended safety limits. Vast numbers of Chernobyl children, far distances from the meltdown, experienced devastating diseases and disabilities, especially leukemia, other cancers, and heart problems. See ACE Blog #4 about what really happened at Fukushima and Chernobyl www.acereport.org
• Exelon’s ETE plus ACE’s school mapping of Limerick’s 10-mile evacuation zone show there are over 230 schools, pre-schools, and day-care centers. It is difficult to account for all public and private pre-schools, day-cares, and schools. Most day-cares and pre-schools have no emergency plans.
• Some school districts straddle the 10-mile EPZ radius. That creates a different set of problems.
For example, parents of Methacton School District students believe that all of the school district is in the evacuation plan because all schools in the district are included on Exelon’s mailed evacuation brochure. However, Exelon’s ETE, which most parents won’t see, places Methacton High School outside Limerick’s evacuation zone. This causes confusion for school district officials, parents, teachers, and students.
SCHOOL BUSES
IT APPEARS EXELON’S ETE GROSSLY OVERESTIMATES SCHOOL BUSES AND CERTIFIED DRIVERS AVAILABLE FOR EVACUATION.
• Over 65,000 children would need to be evacuated.
• All children are assumed to be evacuated from all schools simultaneously. However, in reality, there are not enough school buses or certified drivers to evacuate all children from all schools simultaneously.
• We can only conclude that thousands of children would be left behind. Currently, many school busses make two separate trips every day – 1 trip for Elementary and 1 trip for Secondary Schools Within Districts. This fact is not addressed in Exelon’s ETE. Currently, public school districts are also responsible for bussing private school students. This factor is also not addressed. Complicating the problem, many bus drivers admit they wouldn’t return for a second trip.
DISCREPANCY:
1,224 ESTIMATED BUSES NEEDED (Page 1-9)
1,388 CHARTED BY SPECIFIC SCHOOLS (Pages 6-18 to 6-22)
PROBLEMS BEYOND THE 164 – BUS SHORTFALL:
• NO buses or drivers are planned for the schools and day-cares missed by Exelon’s ETE.
• Availability of certified licensed school bus drivers assumed in Exelon’s ETE is questionable at best.
• Assumed vehicle availability along with perfectly modeled traffic patterns make this ETE unworkable to protect children in a Limerick radiation accident / meltdown.
• Residential students from the Hill School and Ursinus College (possibly well over 1,000) are not even included in Exelon’s Time Estimate.
DISCREPANCY:
WHY SUCH A HUGE DISPCREPANCY WITHIN EXELON’S ETE?
Page 6-17 Itemized Total 1,706 Vehicles Needed For Hospitals, Nursing Homes, Retirement Communities and Other Special Facilities
Page 1-9 Their narrative total for the current study shows 442 vehicles needed
EXELON’S ETE ESTIMATES FOR AMBULANCES AND VANS:
1,706 AMBULANCES and VANS NEEDED
(To Assume That Such A Large Number Would Be Available Simultaneously Defies Logic.)
EXELON’S ETE CONVERSELY CLAIMS:
ONLY 442 AMBULANCES AND VANS ARE NEEDED (PAGE 1-9),
EXAMPLES FROM THE ITEMIZED LIST OF 1706
Pottstown Hospital – ETE Lists 332 Ambulances / Vans Needed
Phoenixville Hospital – 82 Ambulances and Vans
Pottstown Hospital Is Within 1 Mile Of Limerick. Phoenixville Hospital Is Also Within The 10-Mile Zone. Both Would Need To Be Evacuated Immediately.
Exelon’s ETE says 332 Ambulances / Vans would be available for Pottstown Hospital, and 82 would be available for Phoenixville Hospital.
Where would all these Ambulances / Vans, and Drivers come from to evacuate simultaneously?
There is no medical reception center specified in Exelon’s ETE to accommodate large numbers of patients requiring specialized care. Where would so many patients from several hospitals and nursing homes be evacuated to?
Some patients could become highly radioactive during an extended evacuation and be rejected by hospitals or other facilities, as the radioactive people were in Japan.
EXAMPLES FROM THE ITEMIZED LIST OF 1706 ALSO INCLUDE:
Montgomery County Rehabilitation Center – 330 Ambulances and Vans
Veterans Center – 146 Ambulances and Vans
INCONSISTENCY WITH PRISONS
Montgomery County Prison – 100 Vans and Buses (1,200 Inmates)
Where will all these prisoners go? There is no destination designated for these prisoners.
Graterford Prison Would NOT Be Evacuated. Instead Graterford Prisoners And Guards Are Supposed To Shelter In Place.
There is no mention of what will happen with guards and other prison employees.
How will prisoners sustain themselves if all employees evacuate?
Exelon’s ETE States 1,706 Ambulances and Vans Would Be Available Simultaneously To Evacuate In A Timely Manner.
ACE’s CONCLUSION:
To assert that 1,706 ambulances and vans would be available simultaneously is beyond irresponsible.
Exelon’s ETE drastically underestimated people without cars in places like Pottstown, Royersford, and Collegeville.
• Exelon’s ETE Listed Only 4500 People (.015% of 292,061 Population) As Transit Dependent Population Determined To Be Within Limerick’s 10 Mile Evacuation Zone By Exelon’s Report (Section 5.3 on Page 5-3)
4,500 is .015% of the estimated 292,061 population, a gross understatement of what could be a significant need.
Exelon’s report unbelievably suggests that 99.985% of people in Limerick’s 10-mile evacuation zone would have access to vehicles to evacuate.
Exelon’s ETE requires 150 Bus Trips To Evacuate People With No Transportation (Page 1-9).
ACE CONCLUSION: This defies logic!
EXELON’S ETE MUNICIPAL PICK-UP POINTS ARE UNREALISTIC
• The ETE required residents to call township, borough, or local officials to find out schedule of pick up points.
People who work for boroughs and townships are likely to want to evacuate immediately with their families, not man phones.
PROBLEM: The list of municipal pick-up points that are in Exelon’s mailed brochure for Montgomery County are all in Pottstown. What happens to people in Royersford and Collegeville? If they have no transportation, how do they get to Pottstown?
If the radiation accident / meltdown occurs from a natural disaster like an earthquake, contacting officials could become impossible because of loss of power.
EXELON’S ETE TELEPHONE SURVEY THAT WAS THE BASIS FOR DETERMINING RESIDENTIAL VEHICLE AVAILABILITY WAS NOT REPRESENTATIVE.
• Telephone Survey On Residential Vehicles Available For Evacuation (Appendix B – Pages 1-7)
The sample was too small to make valid conclusions.
Only .001 % of residents responded.
Only 317 responses were analyzed out of 292,000 total households.
Approximately 64% of the 317 were 55 years old or older.
- Survey Questions Failed To Accurately Identify Residential Vehicle Needs
Survey questions were centered on who in the family is working, how many vehicles they have, how long it would take to get to work and home, and what shift people worked.
ETE surveyors should have asked if that resident would have another vehicle available if other family members didn’t come home.
PROBLEMS:
Questions were omitted concerning household vehicles used by workers who were teachers or healthcare workers required to stay with students or patients by Exelon’s ETE.
Teachers would go to host center with students. Health care workers are expected to stay with patients or shelter in place.
Prison workers would be required to evacuate with prisoners or shelter in place with them.
ETE’S BLINKING LIGHTS AT INTERSECTIONS COULD CONTRIBUTE TO CONFUSION, CONGESTION,AND ACCIDENTS.
• Blinking Lights – (Page 4-2)
Exelon’s ETE Requires Manual Override of Traffic Lights by Undesignated Officials, supposedly to alleviate bottleneck points. In reality, under emergency conditions, a blinking signal would not alleviate congestion, but instead contribute to confusion, increased congestion, and accidents.
CONFUSION CREATED BY EXELON’S ETE HINDERS SAFE LIMERICK NUCLEAR PLANT EVACUATION
• Traffic Congestion – (Page E-3)
The ETE fails to assume worst case scenarios where traffic is stopped all together by adverse weather conditions or traffic accidents. At the most it assumes that the worst case scenario would add only 160 minutes due to adverse winter weather.
• Traffic Estimates for Employees of Many Businesses Were Excluded From Total Vehicle Estimates (Appendix A, Page 6 of 13)
For example: Under the list of major employers, many businesses which contribute to traffic congestion are excluded, including diners, restaurants, convenience stores.
Examples: Costco, Wawa and Turkey Hill Convenience Stores, Gas Stations, Banks, Car Dealers, Movie Theaters, Restaurants, Library
Numbers of vehicles from these businesses would clearly affect roadway congestion and traffic patterns during evacuation.
• Recreation and Shopping (Appendix A Page 8 of 13)
Estimates for numbers of people at shopping centers appear to be substantially underestimated.
Some parks have been overlooked. For example, Manatawny Park, Riverfront Park in Pottstown, Manderach Park in Limerick, and other local parks.
• Train Traffic – Possible Complications Not Addressed
There seem to be NO specific plans addressing train traffic for some of which carries hazardous materials, that goes through the Limerick site.
Would train traffic be stopped to facilitate evacuation?
Problems Created By Exelon’s ETE Faulty Assumptions:
• The worst problem of all is that this report places little priority on limiting radiation exposure to evacuees.
• Exelon’s ETE covers a 16-hour evacuation period (Appendix D – Maps of Average Speed by Hour for Road Network Pages 1-16.
• Each hour of exposure to Limerick’s radiation during an accident / meltdown critically impacts the health of residents, especially fetuses and children.
• Exelon’s ETE is a shameless sham that satisfies a regulatory requirement with little regard for reality. Exelon’s ETE includes 100 pages of filler devoted to the unrealistic expectation that its assigned speed limits will be maintained during evacuation on the roads listed and that volumes of traffic will not be exceeded. (Appendix C – Roadway Network Data Table – Pages 1 to 100)
• Exelon’s ETE allows too much time to elapse between public notification and actual evacuation.
This is about radiation exposure. Yet, initial notification could bypass residents until a response work force is brought in. People living near Limerick would be exposed to radiation the whole time, as long as that takes. (Section 5.2 – Page 5-3) The ETE time lapse warning process means the last 10% to 20% of the population learns too late that an evacuation order has been given.
• Time estimates are based on Exelon’s self-serving proposition that there will be no deviations from the plan. Survival instincts will compel people to flee in ways not anticipated in this ETE.
• Exelon assumes school, hospital, and other employees are going to abandon their loved ones to get on buses and ambulances and follow this plan to the letter. Exelon requires people to abandon their natural instincts to care for their families.
ACE Conclusions:
Exelon’s Self-Serving ETE Is Unworkable, Unprotective, and Irresponsible.
Exelon’s ETE confirms that Exelon still has no plan to safely evacuate the millions of people surrounding Limerick Nuclear Plant.
Exelon hasn’t produced an evacuation plan that ensures safe, timely evacuation from within 10 miles of Limerick Nuclear Plant.
Therefore, it is impossible to produce a plan for a 50-mile evacuation zone, which Fukushima has proven is minimally necessary to protect public health and safety..
To prevent unnecessary environmental devastation and health harm for millions, Limerick Nuclear Plant should close as soon as possible to prevent such a catastrophe from happening in the first place.
To Better Understand What We Could Face After A Limerick Radiation Accident / Meltdown, See ACE Video Blog At www.acereport.org – Part 4, For The Truth About Consequences Of Chernobyl and Fukushima Meltdowns.
Major Problems With Limerick’s Current Evacuation Plan:
1. A broad range of extremely dangerous radionuclides would be released in the radiation plume from a Limerick accident/meltdown. Yet, Exelon’s ETE is not based on radiation exposure risk. Emergency workers are not required to practice for a radiological event. This ETE shows why vast numbers of people would be harmed, why Limerick must close to prevent this unnecessary risk, and why even after Limerick is closed we must have truly effective evacuation plans.
2. NRC Should Require Exelon To Notify The Public Immediately In The Event Of A Limerick Nuclear Accident / Meltdown. Radiation Releases Could Start Within The First 1/2 Hour.
• PROBLEM: Radiation is invisible. You can’t smell it, taste it , feel it, or see it.
• NRC should not allow Exelon to wait hours or days. It took 3 days before officials told people to evacuate after TMI.
• Radiation sickness symptoms that would occur within 1 to 24 hours would mimic flu-like symptoms (nausea, vomiting, diarrhea, headache, fever). People wouldn’t realize it was from radiation exposure.
• Exelon’s track record suggests the public won’t be notified until Exelon can no longer hide the accident and can manipulate the messaging. For example, Exelon waited 23 days to notify the public about the 3-19-12 radioactive spill into the drinking water for almost 2 million people from Limerick to Philadelphia.
• Likely, there wouldn’t be an explosion. Increasing radiation could be pouring into our air and water, poisoning us and our life support systems, and go undetected by us. Radiation is invisible and odorless. We can’t see, smell, taste, or feel radiation.
• Radiation exposure symptoms within 1 to 4 weeks could also mistaken for other problems (dizziness, disorientation, weakness, fatigue, bloody vomit and stools, infections, poor wound healing, low blood pressure, and hair loss).
• Long-term radiation damage, such as tumors and cancer, could take years to develop.
• To minimize disaster, immediate evacuation is imperative and the public must heed the first warnings. This statement was made after Fukushima by Michael Chertoff, previous Homeland Security director.
3. Evidence proves Limerick Nuclear Plant’s radiation plume would travel far beyond our current 10-mile evacuation zone, yet:
• NRC is inexplicable and negligently refusing to expand Limerick’s evacuation zone to 50 miles as they did for U.S. citizens in Japan after Fukushima meltdowns.
• NRC is also refusing to expand our ingestion pathway zone from 50 to 100 miles, even though soil, food, water, buildings, animals, and people have documented to be radioactive far beyond 50 miles in Japan.
4. Evidence from actual meltdowns shows most people would be evacuating to centers inside highly radioactive areas, even though they go outside the 10 mile evacuation zone from Limerick.
• Children are the most impacted victims, far more vulnerable to impacts of radiation than adults.
• Children should be moved as far as possible, at least 50 miles away from Limerick in a radiation accident / meltdown.
5. A massive population would be trying to move on over-crowded roads where there would likely be bottlenecks and accidents that would extend the time people are forced to be exposed to Limerick’s radioactive plume,
• There would be widespread chaos, fear, and anxiety.
• Bus Drivers, first responders, and police would face enormous challenges as they attempt to manage and control certain chaos and gridlock on virtually every road in the region.
ACE talked to vast numbers of people in the community. Below are concerns expressed by some of them.
Many people do not realize what would be expected of them.
For example, ACE found most people would expect to evacuate with their families. However, workers at many institutions will be expected to remain behind to care for children, the elderly, prisoners, or patients.
• Health care staff would be expected to remain at their facilities to assist in the care and supervision of patients.
• Teachers would be expected to travel with their children to the locations just outside the 10-mile zone – likely still in the radioactive plume.
• Some prison workers would be expected to shelter in place with the prisoners.
• Municipal office workers in the heavily populated towns (where many people have no cars, like Pottstown, Royersford, Phoenixville, etc.) would be expected to remain in the building for hours, taking calls directing people to locations to wait for buses to evacuate them. Buses likely won’t even come for many.
• Pre-school workers would be expected to remain with the children until parents get there to pick up their children. That could take hours or may be impossible due to chaos.
Assumptions that just won’t work in reality:
• By the time people are notified, they will already have been exposed to radiation releases. Radiation can start escaping in the first 1/2 hour after an accident, but Exelon is not required, and likely won’t, immediately notify the public. People remained unnecessarily exposed far too long before being told to evacuate from Chernobyl and Fukushima.
• Hospitals would be unprepared and unable to treat so many victims of radiation sickness. Some victims could become so radioactive they would be turned away from hospitals and emergency care facilities outside the evacuation zone, as happened in Japan.
• Evacuation plans for schools assume parents will not rush to pick up their children. That just isn’t realistic. Most parents say that is just what they will do.
• Some school plans are contradictory. One school sent home a letter stating parents couldn’t pick up their children, but also told parents where to wait when picking them up.
• Most school bus drivers say that even if they could transport their first load of children to reception centers, they wouldn’t and couldn’t come back for the second.
• Emergency responders may be out in radioactive plumes for hours.
• There are not enough qualified drivers for school buses, ambulances, and other emergency vehicles, even if there were enough vehicles (which there are not).
• There are conflicts of roles for police officers, bus drivers, and first responders. They face challenges of whether to save themselves and their families or stay and save others. This becomes most difficult with a nuclear accident spewing radiation into the air.
CONTACT ALL ELECTED OFFICIALS
URGE ALL OFFICIALS TO:
1. DEMAND THAT LIMERICK NUCLEAR PLANT CLOSE AS SOON AS POSSIBLE TO PREVENT A MELTDOWN
UNTIL LIMERICK CLOSES DEMAND:
2. IMMEDIATE NOTIFICATION OF LIMERICK RADIATION ACCIDENT
Minimizing Chaos and Reducing Radiation Exposure By Improving Limerick
Nuclear Plant’s Flawed And Inadequate Emergency and Evacuation Plans.
Part #2 January 2013
Calls For Immediate Notification and Expanded Evacuation and Ingestion Pathway Zones
Many expressed concerns and are calling for more precautionary emergency and evacuation planning, including the National Resources Defense Council (NRDC), the Union of Concerned Scientists, Senator Bob Casey (D-PA), Associated Press Investigative Report, Pottstown Mercury, The Alliance For A Clean Environment (ACE), and many residents living around Limerick Nuclear Power Plant.
National Resources Defense Council (NRDC) filed an appeal in 2011, related to Limerick Nuclear Plant’s Outdated Severe Accident Mitigation Alternatives, Including Assessing Consequences of a Limerick Accident or Terrorist Attack.
NRDC won in the 3rd Circuit Court of Appeals in Philadelphia.
Due to Limerick’s location, the potential impact of a severe accident would be far greater than at most other U.S. nuclear plants (NRDC research). Over 8 million people live within 50 miles of Limerick, the radius NRC told Americans to evacuate in Japan during the Fukushima accident. There are 1,914 Public Schools and 176 Hospitals within 50 miles. (See NRDC Plume Map www.nrdc.org)
Evacuation planning for health risks from radiation exposure are being ignored, even though up to 1.4 million additional people now living downwind in the Philadelphia-Wilmington-Newark metropolitan area need to be addressed also.
In spite of the court ruling, NRC is refusing to consider increased population and health risks associated with a Limerick Nuclear Plant accident / meltdown.
NRC displayed a grotesque dereliction of duty when they joined Exelon in appealing the court’s decision.
During the hearing NRC made no pretense of being a neutral arbitrator, much less the public’s advocate and protector.
NRDC’s director of the nuclear program said, “After Fukushima, it seems just plain nutty not to require a new study. It’s hard to believe that after the severity of the Fukushima disaster, involving BWR reactors similar to Limerick’s, that Exelon and NRC blithely maintain they have no reason to take another look at Limerick’s Severe Accident Mitigation Analysis.”
The Union of Concerned Scientists senior scientist said, “…they have not taken into account the issues associated with uncontrolled population growth very close to [nuclear] plants.” (ABC news 6-27-11)
U.S. Senator Bob Casey (D-PA) urged immediate review of Nuclear Evacuation Zones in a March 2012 letter to NRC. Senator Casey Said, “My Constituents Are Deeply Concerned About The Emergency Evacuation Plans.They deserve to know that all aspects of our preparedness plans have been re-evaluated in the wake of the disaster in Japan. One year after Japan’s disaster, it is time that millions of Pennsylvanians living in close proximity to nuclear power plants know that unique characteristics of each plant are taken into account in the development of evacuation plans.” Population densities and transportation infrastructure changed since these plants were first built. Such changes must affect how NRC determines appropriate evacuation distances.
The Associated Press 2011 Investigative Report (PART III by Jeff Donn) “Populations Around US Nuke Plants Soar” has direct implications for Limerick Nuclear Plant Evacuation Plans. (See entire summary in ACE Blog at www.acereport.org). Highlights below:
Despite all that happened since nuclear plant radiation accidents at TMI, Chernobyl, and Fukushima, evacuation zones have remained frozen at a 10-mile radius since 1978.
Increased dangers and mounting risks have NOT resulted in more protective preparations.
AP reported that NRC, working with the nuclear industry, repeatedly weakened or failed to enforce safety standards.
1998 federal regulations show low-population areas were “preferred” for siting nuclear plants to limit exposure to radiation accidents as part of accident safeguards.
Limerick, about 21 miles from Philadelphia, was not a low-density population area in the 1970s and population has increased dramatically since then.
Radiation releases happen within the first 1/2 hour of an accident, a fact acknowledged by NRC and FEMA.
NRC has allowed profits to outweigh public health and safety.
NRC minimizes and rubber stamps evacuation plans, even though they are symbolic, rather than functional, just to keep nuclear plants operating.
NRC is playing with numbers to minimize presumed impacts of accidents.
Partial drills every two years, with limited accountability for effectiveness, is woefully inadequate.
If NRC required meaningful standards for evacuation emergency plans, there would be no nuclear power plants in populated areas. Population booms near nuclear reactor sites like Limerick minimally call for stronger evacuation standards, but little has been done. Compliance with comprehensive evacuation plans based on current demographics would necessitate closing nuclear plants in densely populated regions like Limerick.
Pottstown Mercury Articles and Editorials Identify Concerns Related To Limerick Nuclear Plant Emergency Planning and Evacuation http://www.pottsmec.com
“Population Soars Near Limerick Plant” Big population spike causes headache for any emergency plans. 6-27-11
“Casey Not Sure 10-Mile Evacuation Zone Around Nuclear Plants Is Enough”
“License Review Should Consider Evacuation Plan” 7-3-11
“…I’m Not Saying It Doesn’t Look Absurd, But Have You Looked At The Evacuation Plan?” Cartoon
“Casey Urges Immediate Review of Nuclear Evacuation Zones” 3-12
“Nuke Plan Evacuation Plans Need to be Realistic” Editorial 3-20-12
“Limerick Nuke Evacuation Plans Need An Update” 3-20-12
“GAO Examines Limerick Nuke Plant’s Evacuation Plan, In Response to Senator Bob Casey’s Request for a Study of Evacuation Plans” Limerick is 1 of only 4 of the nation’s nuclear plants profiled examining disaster evacuation plans. 7-18-12
“Limerick Nuclear Evacuation Study Must Eye Growth” Editorial 7-26-12
The long list of those concerned validates risks and cause for action.
ACE Calls On All Citizens and Elected Officials To Speak Out For Immediate Notification And Expanded Evacuation and Ingestion Pathway Zones.
Minimizing Chaos and Reducing Radiation Exposure By Improving Limerick
Nuclear Plant’s Fatally Flawed And Inadequate Emergency and Evacuation Plans.
Part #1 January 2013
In 2012, NRC Pared Down Emergency and Evacuation Plans
Problem: After Documented Evidence Of Widespread Radiation Harms From Fukushima, In 2012, NRC Negligently Pared Down Emergency and Evacuation Plans For Limerick and Other Nuclear Plants.
Widespread Radiation Contamination Far Beyond The Evacuation Zone And Devastating Consequences In Japan Make It Clear That Limerick’s Current Evacuation Zone Must Be Expanded and Emergency Plans Must Be Improved, NOT Pared Down.
During Fukushima 2011 meltdowns, NRC called for a 50-mile evacuation zone for U.S. citizens in Japan. ACE immediately urged NRC to expand Limerick Nuclear Plant’s evacuation zone from 10 miles to 50 miles to better protect people living in our region.
NRC overhauled community emergency planning for the first time in more than three decades, however NRC pared down emergency rules and evacuation plans, further jeopardizing the public and baffling many emergency responders and citizens across the nation.
Instead Of Attempting To Minimize Chaos And Reduce Radiation Exposure Through Better Emergency Planning and Drills For A Radioactive Accident / Meltdown:
1) NRC Deceived The Public
2) NRC Denied Radiation Risks and Harms
3) NRC Weakened Emergency Rules
4) NRC Failed To Expand Emergency Zones
NRC’s New Rules Make No Sense. Despite Devastating Lessons After Chernobyl and Fukushima:
1) NRC Requires FEWER Exercises for Major Radiation Accidents
2) NRC Recommends FEWER People Evacuate Right Away
3) NRC Allows Emergency Drills To Be Run Without Practicing for Radiation Releases
Many responders view NRC’s new rules as downright bizarre.
NRC Attempted To Hide New Pared Down Emergency Plans and Drills From The Public.
1) NRC Announced Revisions December 23, 2011, at the Peak of the Holiday Season.
2) NRC and FEMA 12/11 and 1/12 Web Archives show NO news releases on evacuation plan changes, so most people were unaware safeguards have been minimized and eliminated.
3) May 2012, the public had the first full disclosure on NRC’s Pared Down Emergency Rules, through an Associated Press Investigative Report by Jeff Donn, titled, “Evacuation Plans, Emergency Drills Pared Down Near Nuke Plants”(In Mercury 5/20/12 – http://www.pottsmerc.com)
NRC went to extraordinary lengths to deceive the public about radiation exposure revealing just how little NRC cares about people like us who live in the region of a nuclear power plant. News Articles Also Reveal That NRC:
1) Failed to Pursue Emergency Planning Related to Decision-Making, Radiation Monitoring, and Public Education.
2) Failed to Address Prolonged Station Blackout Conditions.
3) Failed to Address A Multi-Unit Event, Such As Simultaneous Meltdowns In Limerick’s Two Reactors and Two Fuel Pools.
4) Preparedness Focus Should Have Shifted To Dealing With Meltdowns Along With Natural and Severe Weather Events, Such As Earthquakes.
Why Did NRC Make New Emergency / Evacuation Rules Less Protective?
ü NRC is valuing Exelon’s profits over public health and safety.
From The Beginning, (In 1980), PECO, Limerick’s Original Owner, Attempted To Avoid Costs Associated With Evacuation Plans For Limerick Nuclear Plant
1980 Mercury News Article Reported – May 28, 1980
LIMERICK HEARINGS – PE Official Said,“EVACUATION PLAN IS UNNECESSARY”
NRC has long been aware original evacuation plans were deficient.
August 3, 1983, GAO said, “Nuclear Evacuation Plans Are Deficient”
Collusion in Japan reveals that values which place money before life and health can lead to unnecessary and devastating consequences.
ü A 7-12 independent report said the Fukushima disaster was man-made and caused largely as a result of collusive efforts by the government, regulators and TEPCO to avoid developing and implementing basic safety requirements.
ü It said failure to implement adequate measures to protect against nuclear accidents and poor planning by governments led to confusion over evacuation.
For more evidence of NRC’s Negligent Decisions, see list of news articles on NRC.
New Pared-Down NRC Nuclear Rules For Evacuation Are Neither Protective Nor Acceptable. We Must Work to Change Them BEFORE Meltdowns Happens At Limerick Nuclear Plant.
To Reduce Radiation Exposure, Fukushima Shows Us Immediate Notification Is Imperative, Limerick’s Evacuation Zone Should Be Expanded From 10 to 50 Miles, and the Ingestion Pathway Zone Expanded From 50 to 100 Miles.
ACE Is Starting A Campaign For Citizens and Elected Officials To Join Forces Now To Demand Better Protection For Millions In The Greater Philadelphia Region. An ACE You-Tube and Blog Series Will Summarize Issues and Actions Needed.
Starting in January 2013, ACE will begin a Video-Blog Series addressing the need to improve and update Limerick Nuclear Plant’s outdated, flawed, and inadequate emergency and evacuation plans. Each 15 minute video will be uploaded to YouTube, and also be included with an accompanying Blog Post with detailed information on our website. An overview of the series follows.
ACE REPORT VIDEO-BLOG SERIES:
Minimizing Chaos and Reducing Radiation Exposure By Improving Limerick Nuclear Plant’s Fatally Flawed And Inadequate Emergency and Evacuation Plans.
This ACE Report Video and Blog Series Should Serve As A Wake-Up Call To Millions In The Greater Philadelphia Region Related To Limerick Nuclear Plant’s Negligent Emergency and Evacuation Planning.
The Nuclear Regulatory Commission (NRC), Limerick Nuclear Plant’s regulator, is required to protect our health and safety, but a body of evidence shows that NRC is instead protecting the financial bottom line of Exelon. NRC’s deceitful claims and actions demonstrate that NRC is failing to fulfill their required duties to protect us.
NRC’s historical and current failures and corruption in policies and decision making are compromising and further jeopardizing millions of people whose lives could be harmed or ruined permanently as the result of a Limerick Nuclear Plant Radioactive Accident and/or Meltdown.
This series of ACE Report Videos and Blogs will identify problems and flaws with Limerick’s Emergency and Evacuation plans. It will reveal why we and our elected officials must demand a system for immediate independent public notification of a Limerick accidental radioactive release, and demand updated and improved planning for expanded evacuation and ingestion pathway zones.
The Alliance For A Clean Environment www.acereport.org
January to March – 2013
Video / Blog Part 1
In 2012, NRC Pared Down Emergency and Evacuation Plans, Even After Fukushima
Video / Blog Part 2
Calls For Immediate Notification And Expanded Evacuation and Ingestion Pathway Zones
Video / Blog Part 3
The Truth and Consequences of Radiation Exposure From Nuclear Plant Accidents / Meltdowns
Video / Blog Part 4
What Really Happened After Fukushima, Chernobyl, and TMI Meltdowns
Video / Blog Part 5
Financial Injustice To The Public From A Radiation Accident / Meltdown
Video / Blog Parts 6 and 7
Fatal Flaws In Emergency – Evacuation Plans for Limerick Nuclear Power Plant
Video / Blog Part 8
Regional Campaign To Improve Limerick Nuclear Plant’s Evacuation Plan, Including Immediate Public Notification and Expanded Evacuation And Ingestion Pathway Zones