Statement of

Thomas B. Cochran, Ph.D.

Matthew G. McKinzie, Ph.D. Senior Scientists, Nuclear Program

Natural Resources Defense Council, Inc.

on the

Fukushima Nuclear Disaster and its

Implications for Nuclear Power Safety

before the Nuclear and Radiation Studies Board

National Academies Washington, D.C.

May 26, 2011

Natural Resources Defense Council, Inc. 1200 New York Avenue, N.W., Suite 400

Washington, D.C. 20005 Tele: 202-289-6868 tcochran@nrdc.org

mmckinzie@nrdc.org

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Introduction This statement summarizes the Natural Resources Defense Council’s (NRDC’s) assessment of the nuclear disaster at Fukushima Daiichi, Japan, and its implication for nuclear power safety. These written remarks follow closely and update the April 12th Senate testimony on the same subject by one of us, Thomas Cochran. We also draw on the excellent report prepared by the staff of Congressman Edward J. Markey, “Fukushima Fallout, Regulatory Loopholes at U.S. Nuclear Plants,” May 12, 2011.1 Scale of the Fukushima Accident After Chernobyl, the Fukushima nuclear accident ranks as the second most disastrous civil nuclear power reactor accident. Recent assessments by Tokyo Electric Power Company (TEPCo) reveal the damage to Unit 1 was worse than previously believed.2 TEPCo now believes most of the fuel in the Unit 1 reactor core was uncovered, melted and dropped to the lower plenum and bottom of the reactor pressure vessel (RPV) within the first 16 hours following the earthquake.3 The fuel is believed to have re-solidified and is being cooled by continuous injection of 8 to 10 tons of water per hour into the leaking RPV. TEPCo suspects that the molten fuel may have created holes in the RPV and damaged the containment vessel, allowing radioactive water to leak into the basement of the reactor building.4 TEPCo said on May 14 that 3,000 tons of water found in the basement of the Unit 1 reactor building had likely leaked from the containment vessel.5 It is still unclear whether the core melt at Unit 1 was due to the earthquake or loss of power following the tsunami.6 TEPCo acknowledges that meltdowns also occurred in Units 2 and 3, although the extent of fuel damage in these reactors is not as well known.7 On April 12, 2011, the Japanese government indicated that the Nuclear Safety Commission of Japan (NSC) estimated 1.5x1017 Bq (4x106 Ci) of I-131 and 1.2x1016 Bq (3.2x105 Ci) of Cs-137 were released from Fukushima Daiichi Nuclear Power Station.8

1 “Fukushima Fallout, Regulatory Loopholes at U.S. Nuclear Plants,” prepared by the staff of Congressman Edward J. Markey, May 12, 2011http://markey.house.gov/docs/05-12-11reportfinalsmall.pdf 2 On 27 April TEPCo provided an update of the estimated percentage of core damage for Units 1, 2 and 3: for Unit 1 the core damage was revised from an estimated 70% to 55%; for Unit 2 the core damage was revised from an estimated 30% to 35%; and for Unit 3 the core damage was revised from an estimated 25% to 30%. This reflected a revised assessment since 15 March rather than any recent changes in conditions in the reactor cores. International Atomic Energy Agency (IAEA), “Fuskushima Updates, 4-11 May 2011” May 13, 2011 http://www.iaea.org/newscenter/news/tsunamiupdate01.html 3 World Nuclear Association, World Nuclear News, 16 May 2011; http://www.world-nuclear-news.org/newsarticle.aspx?id=30066&terms=reactor%20pressure%20vessel%20(RPV)%20%2016%20hours. 4 Ibid. 5Hidenori Tsuboya, Asahi 15 May 2011 http://www.asahi.com/english/TKY201105150169.html . 6 Japan Times,16 May 2011 http://search.japantimes.co.jp/cgi-bin/nn20110516a3.html.. 7 Chico Harlan, The Washington Post, May 18, 2011 http://www.washingtonpost.com/world/tepco-revises-plan-for-cooling-reactors/2011/05/17/AFvd7g5G_story.html. 8 Japanese Ministry of Economy, Trade, and Industry, Press Release, April 12, 2011 http://www.nisa.meti.go.jp/english/files/en20110412-4.pdf

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These data suggest the source term for volatile fission products at Fukushima was on the order of one-tenth that of Chernobyl. We have updated an earlier rough estimate of the collective radiation dose from external exposure based on radiation monitoring data from Japan to include additional data for two prefectures, and additional data reported through May 23, 2011 (see Appendix A). We should be mindful that the uncertainties in the estimated exposures are quite large, the external gamma exposure dose excludes dose via inhalation, ingestion of water and dietary intake pathways, and there is a lot that we simply do not know. With these cautionary notes, we find the collective dose from external exposure to date is between 500 thousand person-rem and 850 thousand person-rem, with a mid-value of 600 thousand person-rem. Consequently from 570 to 960 excess cancers are projected to result from this exposure pathway. Thus, in terms of collective dose and radiological consequences, on a logarithmic scale Fukushima appears to be roughly mid-way between TMI and Chernobyl, i.e., a collective dose two to three orders of magnitude worse than TMI (probably closer to two) and one to two orders of magnitude less than Chernobyl (probably closer to two).9 We hesitate to guess what the economic toll from Fukushima will be, and in any case it will be difficult to separate the economic consequences of the nuclear accident from the widespread devastation caused by the tsunami and earthquake. On May 20th, TEPCo stated that to date the “direct cost of emergency measures at the Fukushima Daiichi site” has cost $5.21 billion; maintaining the six undamaged reactors at Fukushima Daiichi and Fukushima Daini in cold shutdown has cost $2.59 billion; starting to decommission the Fukushima Daiichi Units 1, 2, 3 and 4 has cost $2.53 billion; and terminating plans for two new reactors at Fukushima Daiichi represents a loss of $480 million – expenses together totaling $10.81 billion.10 Another cost directly attributable to the accident will be the expense of replacement fossil power generation due to the permanent shutdown of Fukushima Daiichi Units 1-4, and the indefinite shutdown of Hamaoka Units 3-5 (see below), which alone will cost several billion dollars per year. The total direct cost of 9 The U.S. Nuclear Regulatory Commission (NRC) estimates that as a consequence of the accident at Three Mile Island (TMI) Unit 2 “the average dose to about 2 million people in the area was only about 1 millirem”, in other words, a collective dose of approximately 20 person-Sieverts (Sv) (2,000 person-rem), and the “maximum dose to a person at the site boundary would have been less than 100 millirem.” U.S. NRC, “Backgrounder on the Three Mile Island Accident,” August 2009, updated March 15, 2011. http://www.nrc.gov/reading-rm/doc-collections/fact-sheets/3mile-isle.html. The United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR) has estimated the collective dose from Chernobyl at 378,700 person-Sv (37,870,000 person-rem). UNSCEAR 2008 Report, Volume II, Scientific Annexes C, D and E, Table 2, p. 54; recovery operation workers: 61,200 person-Sv; evacuees: 3,600 person-Sv; inhabitants of contaminated areas of Belarus, Russia & Ukraine: 58,900 person-Sv; inhabitants of Belarus, Russia & Ukraine: 125,000 person-Sv (continuing to accumulate to perhaps 25% higher for the whole lifetime); inhabitants of distant countries: 130,000 person-Sv (continuing to accumulate to perhaps 25% higher for the whole lifetime), http://www.unscear.org/docs/reports/2008/11-80076_Report_2008_Annex_D.pdf. The U.S. National Academies’ BEIR VII Committee Phase 2 report (2006) provides the best estimate of the cancer risk associated with low radiation exposures. Applying the BEIR VII best estimates of cancer risk to the collective dose estimate, one would expect to see from the TMI accident, about two excess cancers, of which one is expected to be fatal, and from Chernobyl about 40,000 excess cancers, of which 20,000 are expected to be fatal. 10 “Trillion-yen cost of tsunami,” World Nuclear News, May 20, 2011.

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plant site and local regional decontamination and the added costs of plant decommissioning attributable to the accident is likely to reach tens of billions of dollars. Other indirect economic consequences will be global in scope, as for example, the shutdown of reactors in Germany: in sum far exceeding the economic consequences of TMI. Beyond the yen and dollars, the human cost is severe. The widespread radioactive contamination has ripped farmers from their livelihoods and lands that in some cases have been in their families for generations. Limiting Radiation Exposure to Plant Workers and the Public The Japanese government has taken steps to limit radiation exposure to plant personnel and the public. Immediately following the earthquake and tsunami residents within 10 kilometers (km) (6.2 miles) were advised to evacuate by the Japanese National Industrial Safety Agency (NISA). By the next day, Saturday afternoon, NISA advised everyone within 20 km (12.4 miles) to evacuated, and those between 20 and 30 km (12.4 to 18.6 miles) were advised to remain in their homes as shelter or voluntarily evacuate. Subsequently, on a county-by-county basis the government called for a mandatory evacuation of all areas where the estimated annual exposure exceeded 20 milli-Sieverts/year (mSv/y; or 2 rem/y), the same limit the U.S. governments sets for average annual occupational exposures. This affected people out to about 75 km (46.5 miles) from nuclear power station in the northwest direction (see Figure 1). Based on the National Academies BEIR VII, Phase 2 best estimates, 1000 people of mixed ages and both genders exposed to 20 mSv (2 rem – one year of exposure at the limit) would be expected to result in 2.3 excess cancers of which 1.1 would be fatal.11 The government required the evacuation to be completed within one month. Given the dose rate at the centerline of the plume was in the range between 21.7 and 125 microSv/h (0.2 to 1.1 Sv/y), we believe the rate of evacuation called for by the government was too slow.

Figure 1: NNSA Aerial Measuring Results, Joint US/Japan Survey Data, Ground Level Dose Rate Normalized to 29 Apr (see http://blog.energy.gov/content/situation-japan/). Japanese counties under mandatory evacuation include: Iitate, Katsurao, Kawamata, Minamisoma, and Namie.

11Committee to Assess Health Risks from Exposure to Low Levels of Ionizing Radiation, National Research Council, Health Risks from Exposure to Low Levels of Ionizing Radiation: BEIR VII, Phase 2 (2006), Table ES-1, p. 15. http://www.nap.edu/catalog.php?record_id=11340

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The Japanese government established the same dose limit, 20 mSv/y (2 rem/y), for schools and playgrounds. Prof. Toshiso Kosako of Univ. of Tokyo, a senior advisor to the Prime Minister on radiation protection, resigned over this decision, saying that he would have to stop being a radiation expert if he allowed this decision without questioning. Based upon BEIR VII best estimates, the frequency of expected excess cancers due to a 20mSv exposure to a population of 10 year old children of both genders (i.e., one year’s exposure at the limit established for Fukushima schools and playgrounds) is one excess cancer per 250 children. The corresponding frequency for excess cancer fatalities is one excess cancer fatality per 550 children of 10 years of age.12 This allowable exposure limit established by the Japanese government for children (and pregnant women) is far too high in our opinion. We were told by a Japanese senator that the government initially set the allowable limit for children at 10 mSv/y (1 rem/y). But soon the government discovered that 52 schools outside of a 30 km radius of the Fukushima reactors would be over that limit, so they raised the limit from 10 to 20 mSv/y. There are perhaps as many as 30,000 children in these 52 schools, although this is just a rough approximation. The government’s explanation, we were told, was that since the children will be inside most of the time, they won’t be exposed to that level of radiation. Thus, one of the lessons from Fukushima is that after such a catastrophic accident, among the first thing to be jettisoned are the safety standards designed to protect the public. On April 5, 2011, the Japan Atomic Energy Commission (JAEC) announced that: “We are gravely concerned about this accident which can fundamentally undermine public trust in safety measures, not only in Japan but also in other countries.” JAEC also indicated that it would suspend for the foreseeable future its deliberation process for a new Framework for Nuclear Energy Policy which had been underway since last December. Some other nations with leading economies are doing the same. Chubu Electric Power Company has agreed to comply with a request from Japan's prime minister Naoto Kan that it shut down its Hamaoka nuclear power plant until its tsunami defenses are strengthened. Prime minister Kan had asked Chubu on 6 May to shut down units 4 and 5, and not to restart unit 3 of its Hamaoka plant in Shizuoka prefecture, which is currently offline for regular inspections. Units 1 and 2 have already been permanently shut down. Kan said that analysis from earthquake experts under the Ministry of Education predicted an 87% chance of a magnitude 8 earthquake in the Tokai region within 30 years and the risk of a major tsunami.13 On May 10, 2011, Prime Minister Naoto Kan said that Japan would scrap its current plan to build new nuclear reactors, saying his country needed to “start from scratch” in

12 Ibid., Tables 12-6 and 12-7, p. 281 13World Nuclear Association, World Nuclear News, May 9, 2011. http://www.world-nuclear-news.org/RS-Chubu_agrees_to_Hamaoka_shut_down-0905115.html

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creating a new energy policy that allowed for a larger contribution from energy efficiency and renewable sources.14 Response to the accident in other countries. Other than Japan, Germany is the only countries that to date has shut down reactors as a consequence of the Fukushima disaster. China, Germany, Italy, Japan, Philippines, Switzerland, Taiwan, and Venezuela have suspended some or all new reactor developments and/or announced that nuclear would play a reduced role on the future.15 Other countries, e.g., the United States, France and the European Union, are reviewing the safety of existing plants. Germany. German Chancellor Angela Merkel announced a temporary shutdown of Germany's oldest (pre-1980s) nuclear power stations and a three-month review period to run tests and reassess nuclear technology. Subsequently, on April 8, 2011, the German Association of Energy and Water Industries (BDEW), which represents about 1,800 utilities, approved the following statement: “The catastrophe at the Fukushima reactors marks a new era and the BDEW therefore calls for a swift and complete exit from using nuclear power.” BDEW had been fully behind nuclear energy prior to the Fukushima disaster, and EON and RWE, two biggest operators of nuclear plants in Germany, opposed the BDEW Board decision. Nevertheless, some observers believe it is likely that that seven or eight of Germany's 17 reactors will never resume activity. United States. In the United States, the Nuclear Regulatory Commission (NRC) has initiated a 90 day review of the 104 operational reactors, to be followed by a 6-month or longer review. Congressman Edward Markey and his staff have raised serious concerns regarding limitations placed on the 90-day review (See Appendix B). The NRC’s regional and resident inspectors staff have conducted walk down inspections at all the operational reactors in response to NRC Temporary Instruction 2515/183, “Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event.”16 The inspection reports document numerous deficiencies at several of the reactor. For example, as summarized by Peter Behr, an E&E reporter, at Diablo Canyon the NRC investigators reported:17

• The plant had a single diesel-driven pump to provide emergency cooling water to a single reactor in case an earthquake cut off normal water flow. The pump could not have serviced both of the plant's reactors if they lost normal water supply simultaneously, the NRC staff said.

14 Martin Fackler, New York Times, May 10, 2011 http://www.nytimes.com/2011/05/11/world/asia/11japan.html. 15 “Fukushima Fallout, Regulatory Loopholes at U.S. Nuclear Plants,” prepared by the staff of Congressman Edward J. Markey, May 12, 2011, p. 24. 16 U.S. NRC, “Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event,” NRC Inspection Manual, Temporary Instruction 2515/183, March 23, 2011 http://pbadupws.nrc.gov/docs/ML1107/ML11077A007.pdf 17 Peter Behr, ClimateWire,May 19, 2011 (subscription required). The full inspection report can be found at http://pbadupws.nrc.gov/docs/ML1113/ML11133A310.pdf

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• Some doors at the plant required to protect against flooding of major safety equipment would not self-latch as required. One latch was “degraded,” they said.

• The plant's six emergency diesel generators were located in the same plant area, and thus vulnerable to a “common mode” failure.

• An earthquake could cause a structural failure in the building where the fire truck is stored, and debris could block crews from using the truck.

• PG&E planned for a contractor to provide seawater for emergency cooling, but had no backup plan if an earthquake and tsunami blocked highways to the plant. PG&E intended to rely on the California National Guard to deliver diesel fuel for emergency generators if roads were impassable, but had no memorandum of understanding in place for the deliveries.

• Four 20-foot extension cables, used to operate fans that cool portable generators, were missing from their storage location.

Among the findings in other NRC inspection reports, Peter Behr has highlighted:18

• Entergy's Arkansas Nuclear One plant safety plan is directed against the loss of offsite power to one of its units, and does not anticipate a simultaneous additional threat such as an earthquake.

• Numerous manhole inspections in the past year have revealed safety-related cables submerged in water, a problem the NRC inspectors identified as minor.

• At Duke Energy's Oconee Nuclear Station in South Carolina, pumps that would be used to remove water from auxiliary buildings in a flood could not be used because the plugs did not fit any outlets in the area.

• Instrumentation on spent fuel pools would be unavailable if power were lost, which would require workers to visually inspect water levels – “an unacceptable requirement under some scenarios,” the NRC said. One such scenario would be a loss of water in the pool to a level that permitted fuel rods to ignite and release perilously high radiation levels.

• The Palo Verde nuclear plant, operated by the Arizona Public Service Co., determined that some seals that were not hardened to withstand seismic shocks could fail in an earthquake, allowing water to enter rooms containing electrical equipment used to shut down the plant. Three tanks at the plant could rupture, leaking water into the plant, and a backup diesel generator and electrical switch gear were vulnerable to flooding in such an emergency.

• The report on Dominion Resources’ Millstone Power Station in Connecticut noted that some equipment is classified as “seismically qualified” and must function

18 Ibid.

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during and after the maximum earthquake anticipated for the site (based on historical data plus a safety margin).

• However, most sump pumps and flooding detectors are considered “non-safety related” and thus are not hardened to withstand earthquakes, the report said. Firefighting equipment staged to respond to severe fires or explosions was not stored in hardened buildings because a severe fire and an earthquake “were not assumed to occur coincidentally.”

• An “isolation valve” for unit 1 would have to be operated to pressure the fire main to fight fire. But the valve would be under water following an anticipated flood that occurred at the same time as a fire. These issues are under review, the NRC said.

• At Entergy's Indian Point 2 station on the Hudson River above New York City, inspectors reported that fire fighting equipment is not designed to withstand earthquakes, which could compromise the fire protection system. Generally, plants are not required to survive a simultaneous loss of outside and internal alternating current power (“station blackout”) and an earthquake, the NRC said.

• In a severe accident at Indian Point, where it was crucial to relieve pressure inside the reactor containment, high pressures could damage equipment required to carry out the venting and “potentially prevent containment depressurization,” the NRC said. Workers at Fukushima were forced to vent hydrogen and steam after fuel assemblies melted in order to prevent an even more catastrophic damage to reactor containment structures and a far greater radiation release.

• Ameren's Callaway nuclear plant in Missouri assigns operating staff to make up the fire brigade, but trying to fight two fires at once would be “very difficult” because of limited staffing, the NRC said.

• The company had not assessed the capability of a halon fire suppression system that protects essential switchgear rooms. “The licensee determined that this equipment does not need to be evaluated based on an industry frequently asked question,” the NRC said. The company has trained workers to use water to fight electrical switchgear fires if halon is not available, the report said, raising the risk of flooding in adjacent rooms with electrical controls because flood doors have not been established. The NRC said issues at both Indian Point and Callaway are being evaluated.

Despite these deficiencies the NRC staff informed the Commission on May 12, 2011, that, “To date the task force has not identified any issues that undermine our confidence in the continued safety and emergency planning of U.S. plants.”19 The fact that these deficiencies were discovered only after the walk down following the Fukushima disaster is evidence of the failure of the NRC and industry to conduct timely

19 Bill Borchardt, NRC Executive Director for Operation, “Briefing on the Progress of the Task Force Review of NRC Processes and Regulations Following the Events in Japan,” PowerPoint slides, May 12, 2011. http://www.nrc.gov/reading-rm/doc-collections/commission/slides/2011/20110512/staff-20110512.pdf

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rigorous safety inspections to insure that nuclear plants meet current regulations and good safety practices. With regard to the 6-month review, on May 9, 2011, NRDC, jointly with other NGOs, wrote the Commission requesting that in preparation for the 6-month review it direct the Staff to document for each of the 104 operational reactors all deviations from the current “best practices” as set forth in the most up to date regulations, regulatory guides, standard review plans, information bulletins and the like, including exemptions from license conditions granted pursuant to 10 CFR §50.12. In other words, we want the NRC to create a list for each reactor of all variances or exemptions from current best practices required of new licensees. If we are to improve the safety of existing nuclear power plants in light of the Japanese disaster, understanding and precisely documenting those variances and exemptions from current best practices will be a critical element of a meaningful six-month review. In Appendix C we offer several reasons why we believe an objective independent technical review of the Fukushima accident is need, and why we cannot rely on the NRC to implement the full scope of corrective actions that are needed. On March 11, 2011, NRDC President Frances Beinecke wrote President Obama, requesting that “The administration should appoint a truly independent commission, similar to the Kemeny Commission that investigated the Three Mile Island accident in 1979, that can help to engender public confidence by thoroughly examining nuclear safety issues, including assessing the conclusions and proposed corrective actions arrived at by both the nuclear industry and the NRC in its ‘90-day safety review’.” (NRDC’s letter is attached as Appendix D). NRDC has received no response to this request from the Administration. The Administration appears to favor limiting the safety review to the NRC, no doubted recognizing that this is the “safer” course if one objective is to insulate future use of nuclear power in the United States from the potential implications of a genuinely independent review of the safety implications of Fukushima in which the public is invited to participate. Reassessing the frequency of partial core melt accidents There have been enough partial core-melt accidents that we can ask whether the operational nuclear power plants throughout the world are safe enough as a group. As we see from Table 1, 12 nuclear power reactors have experienced fuel-damage or partial core-melt accidents: The Sodium Reactor Experiment (SRE), Stationary Low-Power Reactor No. 1 (SL-1), Enrico Fermi Reactor-1, Chapelcross-2, St. Laurent A-1 and A-2, Three Mile Island-2, Chernobyl-4, Greifswald-5 and Fukushima Daiichi-1, -2 and -3.20

Eleven of these (all except SL-1) produced electricity and were connected to the grid during some period of their operation, and all are now permanently shut down. In

20 Notably absent from this list is Windscale Pile 1, an air-cooled, graphite-moderated plutonium production reactor. It was destroyed by a fire in October 1957. Windscale Pile s 1 and 2 were both permanently shut down following the fire in Pile 1. Production reactors that were not dual-use and connected to the grid are not included in the analysis here, and their reactor-years of operation are not counted.

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assessing the historical core melt frequency among nuclear power reactors, the number counted depends on how the issue is framed. SL-1 is excluded because it was an experimental reactor, and the design was abandoned after the accident. Although it was the first U.S. reactor to supply electricity to the grid, the SRE could be excluded because it was primarily a research reactor. Chapelcross-2 and St. Laurent A1 and A2 were dual use military reactors, producing plutonium for weapons and electricity for civilian use. From the data available to this author it is unclear whether any fuel actually melted in Greifswald-5. In five cases then, i.e., SRE, Chapelcross-2, St. Laurent A1 and A2, and Greifswald-5, the fuel melt or damage did not result in immediate closure of the plant; rather the damage was repaired and the reactor was restarted. Worldwide, there have been 137 nuclear power plants that have been shut down after becoming operational with a total generating capacity of about 40,000 MWe and 2,835 reactor-years of cumulative operation.21 Thus, one in twelve (137/11 = 12.5) or fourteen (excluding SRE: 136/10 = 13.6) shut down power reactors experienced some form of fuel damage during their operation. Of the power reactors that have been shut down one in 23 (137/6 = 22.8) were shut down as a direct consequence of partial core melt accidents; one for every 500 reactor-years (2,835/6 = 472.5) of operation. Only about seven of eight giga-watts (GW) (40,000-5,250.5)/40,000 = 0.87≈ 7/8) of nuclear power plant capacity have been closed without experiencing a fuel damage accident. One out of 13 GW (40,000/3,011 = 13.3) of nuclear power plant capacity have been closed as a direct result of a fuel melting accident. Worldwide, there have been 582 nuclear power reactors that have operated approximately 14,400 reactor-years.22 Thus, to date, the historical frequency of core-melt accidents is about one in 1,300 reactor-years (14,400/11 = 1,309), or excluding SRE, about one in 1,400 reactor-years. Worldwide, there have been 115 Boiling Water Reactors (BWRs) that have operated approximately 3,100 reactor-years. Thus, to date, the historical frequency of core-melt accidents in BWRs is about one in 1,000 reactor-years (3,100/3 = 1,033). Worldwide, there have been 49 BWRs with Mark 1 containments (the type at Fukushima) and 12 with Mark 2 containments. Five with Mark 1 containment (Millstone Unit 1 and Fukushima Daiichi Units 1-4) have been permanently shut down. These 61 BWRs have operated for 1,900 reactor-years to date. Thus, to date, the historical frequency of core-melt accidents in BWRs with Mark 1 and 2 containments is about one in 630 reactor-years (1,900/3 = 633).

21 This sum excludes the US reactors, SL-1, Ml-1, PM-1, PM-2A, PM-3A, SM-1, SM-1A and Sturgis. The German KNK-I and KNK-II reactors are treated a one reactor. 22 Ibid.

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We can compare these core melt accident frequencies with current U.S. Nuclear Regulatory Commission’s (NRC) safety requirements. In July 1985, the NRC Advisory Committee on Reactor Safeguards (ACRS) stated:23

We believe that the Commission should state that a mean core melt frequency of not more than 10-4 per reactor year (one in 10,000 reactor-years) is an NRC objective for all but a few, small, existing nuclear power plants, and that, keeping in mind the considerable uncertainties, prudence and judgment will tend to take priority over benefit-cost analysis in working toward this goal.

On August 4, 1986, the NRC published a final policy statement on safety goals, which said:24

Severe core damage accidents can lead to more serious accidents with the potential for life-threatening offsite release of radiation, for evacuation of members of the public, and for contamination of public property. Apart from their health and safety consequences, severe core damage accidents can erode public confidence in the safety of nuclear power and can lead to further instability and unpredictability for the industry. In order to avoid these adverse consequences, the Commission intends to continue to pursue a regulatory program that has as its objective providing reasonable assurance, while giving appropriate consideration to the uncertainties involved, that a severe core damage accident will not occur at a U.S. nuclear power plant.

Richard A Meserve, then Chairman of the NRC, noted in 2001:

In 1990, the Commission provided additional guidance to the staff regarding the Safety Goals, endorsing surrogate objectives concerning the frequency of core damage accidents and large releases of radioactivity.2

The numerical value of one-in-ten-thousand for core damage frequency (CDF) was cited as a “very useful subsidiary benchmark....” In addition, a conditional containment failure probability of one-tenth was approved for application to evolutionary light water reactor designs. This resulted in a large release frequency of one in one-hundred-thousand, since containment failure is necessary for a large release to occur. These values

23 ACRS letter from D. A. Ward to N. J. Palladino, Subject: ACRS comments on proposed NRC safety goal evaluation report (17 July 1985); cited in David Okrent, “The Safety Goals of the Nuclear Regulatory Commission, Science, 236, 296-300 (17 April 1987). 24 U.S. NRC, “Safety Goals for the Operation of Nuclear Power Plants; Policy Statement,” Federal Register 30028, August 21, 1986. See also, U.S. NRC, Federal Register 51, 28044 (4 August 1986); cited in David Okrent, “The Safety Goals of the Nuclear Regulatory Commission, Science, 236, 296-300 (17 April 1987). See Also: Richard R. Meserve, Chairman, NRC, “The Evolution of Safety Goals and Their Connection to Safety Culture,” Speech before the Atomic Energy Society of Japan/American Nuclear Society Meeting on Safety Goals and Safety Culture, Milwaukee, Wisconsin, June 18, 2001 http://www.nrc.gov/reading-rm/doc-collections/commission/speeches/2001/s01-013.html

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have evolved into the “benchmark” values of 10-4 for CDF and 10-5 for

large early release frequency (LERF), as discussed in Regulatory Guide 1.174 for use in risk informed regulatory decision-making.3

2. U.S. NRC, Staff Requirements Memorandum on SECY-89-102, “Implementation of the Safety Goals,” June 15, 1990. 3 U.S. NRC, Regulatory Guide 1.174, “An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, July 1998.

Regulatory Guide 1.174 states:

While there is no requirement to calculate the total CDF [core damage frequency], if there is an indication that the CDF may be considerably higher than 10-4 per reactor year, the focus should be on finding ways to decrease rather than increase it. Such an indication would result, for example, if (1) the contribution to CDF calculated from a limited scope analysis, such as the individual plant examination (IPE) or the individual plant examination of external events (IPEEE), significantly exceeds 10-4, (2) a potential vulnerability has been identified from a margins-type analysis, or (3) historical experience at the plant in question has indicated a potential safety concern.25

Clearly, the historical frequency of core melt accidents worldwide does not measure up to the safety objectives of the NRC. On the whole the operational reactors worldwide are not sufficiently safe. If one believes U.S. reactors on the whole are safer that those in most other countries, the logical conclusion is that the reactors in these other countries are even less safe than indicated by the worldwide historical frequency of severe fuel damage. If nuclear power is to have a long-term future greater attention must be given to the safety of current operational reactors worldwide. Older obsolete designs should be phased out rather than having their licenses extended.26 We should also revisit whether the newer reactor designs currently under construction worldwide and those on the drawing board are safe enough? We offer to additional observations regarding the use of probabilistic risk assessments (PRAs) and the NRC safety goals. First, the NRC increasingly relies upon core-melt frequency estimates from PRA studies. For example, the NRC cites assessments of core melt frequency due to component cooling water system failure that range from 2 x 10-5 to 1 x 10-4 event/reactor-year, i.e., from 0.2 to 1 per 10,000 reactor-years, , but “[t]his estimate does not include the probability of station-blackout, which is another mode of

25 NRC, Regulatory Guide 1.174, “An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis” November 2002. http://www.nrc.gov/reading-rm/doc-collections/reg-guides/power-reactors/rg/01-174/ 26 In the United States 66 of the 104 operational reactors have been granted 20-year license renewals by the NRC. http://www.nrc.gov/reactors/operating/licensing/renewal/applications.html

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failure.”27 While PRA analyses provide a useful relative measure of safety, given the large uncertainties of many input assumptions we do not believe quantitative risk calculations reliably measure the absolute frequency of low-probability catastrophic accidents. As but one example of why the absolute frequency values are unreliable, currently PRAs analyses do not include scenarios where major events such as a hurricane, tornado or other severe weather conditions result in the loss of offsite power for more than 24 hours. Rather the PRA analyses assume offsite power is restored within a few hours, and thus the PRAs are typically not run for more than 24 hours after the accident is initiated. Second, in its 1986 statement of its safety goals the NRC stated:

The Commission has decided to adopt the following two health effects as quantitative objectives concerning mortality risks to be used in determining achievement of the qualitative safety goals—

• The risk to an average individual in the vicinity of a nuclear power plant of prompt fatalities that might result from reactor accidents should not exceed one-tenth of one percent (0.1 percent) of the prompt fatality risks resulting from other accidents to which members of the U.S. population are generally exposed.

• The risk to the population in the area near a nuclear power plant of cancer fatalities that might result from nuclear power plant operation should not exceed one-tenth of one percent (0.1 percent) of the sum of cancer fatality risks resulting from all other causes.

These risk limits are typically compared against PRA estimates of frequency of accident scenarios times their consequences. Taking a different approach, it can be shown that the Fukushima Daiichi nuclear plants, even accounting for the radioactive releases from the disaster, meet these two NRC safety goals. There were no prompt radiation fatalities due to the Fukushima accident. There were about 60,000 persons living within 20 km (12.6 mi) of Fukushima Daiichi. Over their lifetimes one would expect about 12,000 (20 percent) cancer fatalities from other causes. One-tenth of one percent of this amount is 12 cancer fatalities. Since the population was evacuated less than 12 cancer fatalities are expected in this population from Fukushima. Thus, the Commission needs to reconsider the adequacy of these safety goals. At the very least, an additional criterion related to the economic consequences of a severe accident should be included. Other implications for U.S. Nuclear Power Reactors There are a host of concerns raised by the Fukushima nuclear disaster that bear directly on the safe operation and regulation of nuclear power reactors in the United States and abroad. While others will add to this list, our concerns include: 27U.S. NRC, “Resolution of Generic Safety Issues: Issue 65: Probability of Core-Melt due to Component Cooling Water System Failures (Rev. 1) (NUREG-0933, Main Report with Supplements 1-33),” updated March 13, 2011. http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr0933/sec3/065r1.html

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• Are old GE BWRs with poorly designed Mark 1 and Mark 2 containments and

subsequent upgrades imposed by the NRC safe enough to continue operation or have their licenses extended?

• What additional improvements should be made to cope with hydrogen production in the event of Zircaloy fuel clad interactions with steam?

• What improvements must be made to extend the time reactors can cope with loss of off-site power?

• The NRC is overdue in requiring that spent fuel be removed from wet pools to hardened dry casks as soon as the spent fuel has cooled sufficiently to be passively cooled in air.

• Which reactor sites are located in areas that cannot be adequately evacuated? • Which reactor stations impose an undue economic risk to the local, state or U.S.

economy in the event of a partial core melt accident? • Which U.S. reactors should be upgraded or phased out due to the risk of an

earthquake, flooding or tornado that is beyond the design basis? • Potential radiological accidents caused by earthquake or tsunami should be

addressed in emergency response plans for US reactors. • Nuclear plant owners/operators must assume a larger share of the financial risk in

the event of a catastrophic nuclear accident. Price Anderson Act (which defines the federal government’s assumption of liability and economic burden in the event of catastrophic nuclear accident) should be repealed or, at a minimum, significantly revised?

• What are the implications of continued failure of the NRC to fully implement a fire protection rule?

• Additional reliable gauges should be required so that the water level in reactor pressure vessels and spent fuel pools can be monitored during an accident.

• The MACCS2 computer code used to calculate offsite consequences is outdated and underestimates environmental consequences and economic damage associated with a severe accident lasting for weeks.

• What changes should be implemented regarding radiation monitoring during routine plant operations and following an accident?

• What are the implications of predicted sea-level rise and increased storm surges due to climate change on the safety of nuclear reactors near coasts?

We now offer observations regarding these concerns. Are the old GE BWRs with poorly designed Mark 1 and Mark 2 containments and subsequent upgrades imposed by the NRC safe enough to continue operation or have their licenses extended? There are 23 operational U.S. GE-designed boiling water reactors (BWRs) with Mark 1 containments and the 8 operational U.S. BWRs with Mark 2 containments. The U.S. BWRs with Mark 1 containments are similar to Fukushima Daiichi Units 1-4, and the Mark 2 containments are similar to the Mark 1s. The design of the BWRs with Mark 1 containments by GE grew out of an effort to reduce construction costs by reducing the volume of the containment structure and rely more heavily on controlled venting of steam

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and radioactive contaminants in the event of reactor core fuel melting to prevent a larger disaster. This design was highly controversial when it was proposed for licensing by the AEC, and has been subjected to review and subsequent upgrades required by the NRC. A principal upgrade of the Mark 1 containment was the requirement to install a hardened exhaust vent from the torus-shaped suppression chamber to prevent the buildup of hydrogen gas. “American officials had said early on that reactors in the United States would be safe from such disasters because they were equipped with new, stronger venting systems. But Tokyo Electric Power Company, which runs the plant, now says that Fukushima Daiichi had installed the same vents years ago.”28 The failure of the vent systems at Fukushima are believed to have been due to a combination of operator error and mechanical failure of the vent system. “One reason the venting system at the plant, which was built by General Electric, did not work is that it relied on the same sources of electricity as the rest of the plant: backup generators that were in basements at the plant and vulnerable to tsunamis. But the earthquake may also have damaged the valves that are part of the venting system, preventing them from working even when operators tried to manually open them, Tokyo Electric officials said.” 29 Our preliminary view is that the nuclear disaster at Fukushima illustrates the inherent design deficiencies in these 31 operational U.S. BWRs—a significant fraction of the 104 operational nuclear power reactors in the United States. In our opinion none are sufficiently safe despite upgrades that have been imposed by the NRC. Others will argue that the BWR Mark 1s and 2s are safe noting that a) these U.S. reactors will not experience the same type of earthquake and tsunami as occurred on Japan, b) the NRC has a good handle on the magnitude and frequency of accident precursors, and c) upgrades to manage hydrogen releases in the event of a core-melt accident make controlled venting of steam and radioactive contaminates more acceptable. In other words, the claim is that it will not happen here, and if something comparable does happen we can cope with it. Still others will say that we should await a careful independent safety review of the issues and not rush to judgment. We do not think that the 31 older BWRs in the United States should be shut down forthwith. Rather, they should not have their licenses extended. The current course of safety review and reactor relicensing charted by the NRC and Department of Energy (DOE) is unacceptable. After a limited safety review, sometimes taking less than 18 months, the NRC has been routinely handing out 20 year license extensions, including license extensions to these older BWRs, e.g., the troubled Vermont Yankee plant which received its license extension on March 21, 2011, as the events at Fukushima were unfolding.30 In addition, other older BWR units are undergoing, or are soon scheduled to undergo, thermal power uprates, which only compound the residual heat removal and

28 Hiroko Tabuchi, Keith Bradsher and Matthew L. Wald, The New York Times, May 18, 2011 http://www.nytimes.com/2011/05/18/world/asia/18japan.html. 29 Ibid. 30 Also, Palo Verde Units 1, 2 and 3—PWRs which together constituting the largest U.S. nuclear power plant—received license renewals on April 27, 2011.

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radioactive gas venting problem in the event of a station blackout. Meanwhile, DOE is engaged in an R&D effort with industry to see if licenses can be extended beyond 60 years. On this course we could be saddled for years with inherently unsafe reactors—a potential commitment of more than one thousand reactor-years of operation using old reactor designs with inherent safety deficiencies. In sum, the 20-year license extensions already granted to 20 U.S. operational BWRs with Mark 1 containments and the 3 extensions granted to BWRs with Mark 2 containments should be revisited and the their license extension periods should be shortened. Similarly, no 20 year license extension should be granted to the remaining three BWRs with Mark 1 containments and the five with Mark 2 containments, which have not yet received 20 year license extensions. What additional improvements should be made to cope with hydrogen production in the event of Zircaloy fuel clad interactions with steam? In 2001, the OECD Nuclear Energy Agency reported that computer analyses using “[t]he available Zircaloy-steam oxidation correlations were not suitable to determine the increased hydrogen production in the [CORA and LOFT LP-FP-2] experiments.”31 The LOFT LP-FP-2 experiment, conducted in 1985, is considered “particularly important in that it was a large-scale integral experiment that provides a valuable link between the smaller-scale severe fuel damage experiments and the TMI-2 accident.”32 Furthermore, an Oak Ridge National Laboratory report from 1990, discussing the CORA-16 experiment, states that “[t]he predicted and observed cladding thermal response are in excellent agreement until application of the available Zircaloy oxidation kinetics models causes the low-temperature [1,652-2,192°F] oxidation to be under-predicted.”33 The NRC is currently reviewing a petition for rulemaking PRM-50-93,34 that among other things, requests that the NRC require that the rates of energy release, hydrogen generation, and cladding oxidation from the Zircaloy-steam reaction considered in computer analyses of postulated loss-of-coolant accidents (LOCA) be based on data from multi-rod bundle severe fuel damage experiments (e.g., the LOFT LP-FP-2 experiment). If indeed, as experimental data indicates, computer analyses under-predict the total amount of hydrogen that would be generated in an accident, such computer analyses should be considered in the NRC’s review of U.S. nuclear power plant safety. And the

31Nuclear Energy Agency (NEA) Groups of Experts, OECD Nuclear Energy Agency, “In-Vessel and Ex-Vessel Hydrogen Sources,” NEA/CSNI/R(2001)15, October 1, 2001, Part I, B. Clément (IPSN), K. Trambauer (GRS), W. Scholtyssek (FZK), Working Group on the Analysis and Management of Accidents, “GAMA Perspective Statement on In-Vessel Hydrogen Sources,” p. 9. 32NEA. OECD, “In-Vessel Core Degradation in LWR Severe Accidents: A State of the Art Report to CSNI,” NEA/CSNI/R(91)12, January 1991, S.R. Kinnersly, et. al. p. 3.23. http://www.oecd-nea.org/nsd/docs/1991/csni-r91-12.pdf 33 L. J. Ott, Oak Ridge National Laboratory, “Report of Foreign Travel of L. J. Ott, Engineering Analysis Section, Engineering Technology Division,” ORNL/FTR-3780, October 16, 1990, p.3. http://www.osti.gov/bridge/servlets/purl/6434331-64LUUI/6434331.pdf 34 Mark Leyse, PRM-50-93, November 17, 2009, located at www.nrc.gov, ADAMS Public Documents (Accession No.: ML093290250).

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NRC should not approve any thermal power uprates until it is conclusively demonstrated—by comparison with experimental data from large-scale integral experiments—that the plants (including the previously mentioned older BWRs) at their proposed elevated power levels, would not exceed the parameters of a design basis accident, in the event of a loss-of-coolant accident. What improvements must be made to extend the time reactors can cope with loss of off-site power? At Fukushima, in what is termed a “common mode failure,” the tsunami took out both the off-site power and the backup diesel generators. The backup battery power was designed to last for eight hours. After battery power expired the operators could no longer maintain core cooling. At some U.S, reactors backup battery power is only designed to last four hours. Clearly, battery backup energy requirements should be increased. Other forms of portable on-site power generators must be stored out of harm’s way and kept available for use in a crisis; and licensees must be required to demonstrate that additional AC power supplies can be brought to the site under all conceivable accident scenarios in time to provide uninterrupted core cooling. “Despite decades of reported problems and NRC warnings, a review of NRC documents conducted by the staff of Congressman Edward J. Markey indicates that there have been recurrent and prolonged malfunctions of emergency diesel generators at nuclear power plants in the U.S. In the past eight years there have been at least 69 reports of emergency diesel generator inoperability at 33 nuclear power plants. A total of 48 reactors were affected including 19 failures lasting over two weeks and 6 that lasted longer than a month.”35 There never have been any requirements in the U.S. for spent fuel pools to include technologies to prevent the same kind of hydrogen explosions that reportedly occurred at spent nuclear fuel pools in Fukushima. Alarmingly, NRC’s regulations do not require emergency diesel generators to be operational at times when there is no fuel in the reactor core, even though this could leave spent nuclear fuel pools without any backup cooling systems in the event of a loss of external electricity to the power plant.36 We share the conclusion of Congressman Markey’s staff:

A weeks-long failure of the emergency diesel generators leaves these nuclear power plants with only 4-8 hours’ worth of secondary emergency battery-powered generation in the event of a loss of offsite electricity. And even these minimal requirements do not apparently apply to spent nuclear fuel pools at nuclear reactors whose cores have been emptied of fuel assemblies. It is clear that the NRC has historically done little to address long-standing and serious problems associated with licensee maintenance

35 “Fukushima Fallout, Regulatory Loopholes at U.S. Nuclear Plants,” prepared by the staff of Congressman Edward J. Markey, May 12, 2011, p. 3; for fuller discussion see p. 9 and Table 2, p. 25. 36 Ibid., p. 4.

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of emergency diesel generators that leaves reactors vulnerable to a loss of offsite power.”37

The NRC is overdue in requiring that spent fuel be removed from wet pools to hardened dry casks as soon as the spent fuel has cooled sufficiently to be passively cooled in air. The Fukushima disaster provides further evidence that the safety of spent fuel storage would be improved if spent fuel were removed from wet pools to hardened dry casks as soon as the spent fuel has cooled sufficiently to be passively cooled in air. This was NRDC’s position prior to Fukushima. In May 25, 2010, testimony before the Blue Ribbon Commission on America’s Nuclear Future (BRC), we said, and we still believe:

There is a need for a new spent power reactor fuel storage policy that ends the practice of dense compaction of spent fuel assemblies in wet pools, and moves spent fuel into interim hardened dry cask storage. Fuel pools were originally designed for temporary storage of a limited number of irradiated fuel assemblies in a low density, open frame configuration. Since it is going to be decades before there is a geologic repository, to improve the safety of wet storage of spent fuel we should bite the bullet and decide as a matter of policy to end the practice of dense compaction of spent fuel in wet pools. The Commission should recommend that the Nuclear Regulatory Commission (NRC) establish appropriate licensing criteria for this purpose. While dry cask storage of spent fuel at existing reactor sites is relatively safer than the operation of the reactors, dry cask storage can be made even safer by storing the dry casks in a hardened building such as the Ahaus Spent Fuel Storage Facility in Germany. The Commission should recommend that the Ahaus approach be adopted at most operational reactor sites and any new off-site interim spent fuel storage facility. The added security of such hardened enclosed storage is worth the small additional cost. NRDC believes it makes sense to provide for consolidated dry storage of spent fuel from permanently shut down reactors that are not at sites with reactors still operational. This would facilitate decommissioning of shut down reactor sites. NRDC is opposed to off-site consolidation of spent fuel from any reactors at sites where there are operational reactors, because a) it is unnecessary, b) it does not reduce significantly security risks at the reactor sites, c) it increases risks associated with transportation of spent fuel, and d) it reduces the pressure to obtain a geologic repository.38

It appears the BRC is not going to take a position on whether older fuel should be removed from wet pools to dry casks, or whether dry cast storage should be hardened in the fashion of the Ahaus Spent Fuel Storage Facility.

37 Ibid., p. 9. 38 Thomas B. Cochran, Statement before the Blue Ribbon Commission on America’s Nuclear Future, Washington, D.C., May 25, 201, p. 3. http://docs.nrdc.org/nuclear/files/nuc_10062201a.pdf

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Which reactor sites are located in areas that cannot be adequately evacuated? As noted previously at Fukushima immediately following the earthquake and tsunami residents within 20 km (12. 4 miles) were evacuated and those between 20 and 30 km (12.4 to 18.6 miles) were advised to remain in their homes as shelter or voluntarily evacuate. Subsequently, the Japanese government considered extending the evacuation zone to 30 km. but ended up establishing a 20mSv/y (2 rem/y) dose limit for establishing which areas would be evacuated. Also notably, shortly after the Fukushima accident began to unfold the NRC was so concerned regarding how the accident might progress that it recommended that U.S. citizens stay at least 50 miles away. Some criticized the NRC Chairman for this action. Given the Japanese mandatory evacuation standard, 20 mSv/y, impacted people out to about 75 km (46.5 miles), it is now clear that the NRC action was appropriate. Based on Japanese census data, we estimate that before evacuation there were 69,000 people within 20 km, 160,000 within 30 km, and 2 million within 50 miles of the Fukushima Daiichi reactor station. As seen from Table 2, worldwide there are 135 reactor sites that have a greater number of people residing within 30 km of the reactor station than were residing within 30 km of Fukushima Daiichi; including 21 reactor stations with more than one million people within 30 km.39 Topping the list is the 125 MWe Karachi Nuclear Power Plant (KANUPP) in Pakistan, which has 8.3 million people within 30 km of the reactor. One U.S. reactor station, Indian Point, has one million people within 30 km. Limerick in Pennsylvania, has just under one million people within 30 km. Figure 2 displays a histogram of populations within 30 kilometers of a reactor, worldwide. Taiwan appears especially vulnerable. The Kuosheng Chin Shan and Lungmen Nuclear Power Stations have 5.5 million, 4.7 million and 1.5 million people within 30 km, respectively. The center of Taipei, the capital of Taiwan, is within 30 km of the Kuosheng and Chin Shan reactor stations each with two operational BWRs, and only 40 km from the Lungmen site where two ABWRs are under construction. A severe nuclear accident at any one of these stations could have devastating consequences for the entire country. There are 104 U.S. operational nuclear power plants at 65 generating stations at 64 sites in 63 counties. (Salem and Hope Creek Generating Stations are treated as a single site.) The NRC’s planning zone for evacuation around a nuclear power plant is 10 miles. The number of people living with 10 miles, 20 km, 30 km and 50 miles of the 64 commercial nuclear sites in the United States are reproduced in Table 3.40 As seen from this table, the number of people living near several U.S. operational nuclear power stations is quite large.

39 Calculations by Declan Butler, Senior Reporter, Nature, France, private communication. 40 Calculations by Matthew G., McKinzie based on U.S. census data projected to 2010. These calculations were made independently of the calculations be Declan Butler presented in Table 2

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There are eight U.S. nuclear power plant sites where the population within 20 km is from 200,000 to 433,000—Indian Point, Three Mile Island, Limerick, Catawba, McGuire, St. Lucie, Turkey Point and Oyster Creek. At 30 of the 64 U.S. nuclear power plant sites the population within 20 km exceeds 69,000 people, i.e., exceeds the population within 20 km of Fukushima Daiichi.

Figure 2: Histogram of populations within 30 km of nuclear power reactors, worldwide.

There are nine U.S. nuclear power plant sites where the population within 30 km ranges from 500,000 to 980,000—Indian Point, Limerick, McGuire, Catawba, Three Mile Island, San Onofre, Turkey Point and Shearon Harris.41 An additional 11 plants have populations between 300,000 and 500,000. At 31 of the 64 U.S. nuclear power plant sites the population within 30 km exceeds 160,000 people, i.e., exceeds the population within 30 km of Fukushima Daiichi. The Indian Point site has a whopping 17 million people within 50 miles, more than 5 percent of the entire U.S. population. In Figure 3, we have super-imposed the Fukushima Daiichi dose rate contours to scale at the location of the Indian Point Nuclear Power Station. There are six U.S. nuclear power stations where the population within 50 miles

41 In Declan Butler’s independent calculation Indian Point has just over one million people within 30 km. See Table 1.

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ranges from 5 million to 8.5 million—San Onofre, Limerick, Dresden, Peach Bottom, Salem/Hope Creek and Braidwood. In Figure 4, we have super-imposed the Fukushima Daiichi dose rate contours to scale at the location of the San Onofre Nuclear Generating Station. An additional 18 plants have populations between 2 million and 10 million. At 25 of the 64 U.S. nuclear power plant sites the population within 50 miles exceeds 2 million, i.e., exceeds the population within 50 miles of Fukushima Daiichi. Clearly, the NRC admonition to Americans in Japan could not be carried out at any of these sites.

Figure 3: NNSA/DOE Fukushima Daiichi dose rate contours superimposed on the location of the Indian Point Nuclear Power Station and drawn to scale. Some of these reactors have recently been granted 20 year license renewals, e.g., the two units at St. Lucie and the two units at Turkey Point. Indian Point Unit-2’s license expires on 28 September 2013, and Unit 3’s license expires on 12 December 2015. Entergy has applied for a 20 year license renewal for the two reactors. One might reasonably find it startling were the NRC to renew these licenses given what we now know. What is more surprising though is that the NRC is already on record saying the events at Fukushima will not affect ongoing license extension reviews! NRC approved evacuation plans are limited to evacuation of people within 10 miles of the plant. Fukushima early-on required evacuation of people residing well beyond 10 miles, including residents of Kawamata and Iitate, which are 46 km (28 mi) and 38 km (24 mi) from the reactors, respectively. The later 2mSv/y dose limit for evacuation impacted people out to about 75 km (46.5 mi).

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Figure 4: NNSA/DOE Fukushima Daiichi dose rate contours superimposed on the location of the San Onofre Nuclear Generating Station and drawn to scale. NRC approved plans assume people beyond 10 miles from the plant do not evacuate early, clog the routes, and thus potentially delay the evacuation of persons within 10 miles. At Indian Point local officials have informed the NRC that they do not believe the population within 10 miles can be evacuated. FEMA assumes the local officials will be successful, so the NRC accepts the FEMA position and not the views of the local officials. Which U.S. reactors should be upgraded or phased out due to the risk of an earthquake, flooding, or tornado that is currently beyond the design basis? The magnitude 9.0 earthquake and resulting tsunami that hit the Fukushima Daiichi reactors was significantly larger than the design basis earthquake and tsunami for these reactors. This was also the case with respect to the Niigataken Chuetsu-oki earthquake that damaged the seven-unit Kashiwazaki Kariwa Nuclear Power Station on July 16, 2007. That quake too significantly exceeded the design basis of the reactors. These events call into question the adequacy of the designs of several U.S. reactors in earthquake prone areas, most notably Diablo Canyon given that the U.S. Geological Survey (USGS) found a previously unknown fault along the central California coast, near the plant. As recently reported in the Los Angeles Times, California state Senator Sam Blakeslee (R-San Luis Obispo, who has a doctoral degree in earthquake science and whose district

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includes Diablo Canyon, claims the fault could be half a mile away, or a few hundred yards, or even under the reactors. The California Energy Commission has recommended a three-dimensional imaging study—a sort of geological CT scan—be conducted to determine the precise location of the Shoreline Fault and learn more about it, and the California Public Utilities Commission has also requested such a study. Because there may be similar surprises at other reactor sites the USGS should be directed to take a comprehensive assessment of the earthquake risk at all reactor sites, beginning with those in areas of known high seismic risk. These studies and assessments should be conducted before further reactor license extensions are granted and the results should be part of any relicensing review by the NRC. A related concern is whether current emergency backup power systems and spent fuel pools can survive a direct hit by a 205 mph Category V tornado? Nuclear plant owners/operators must assume a larger share of the financial risk in the event of a catastrophic nuclear accident. Congress should repeal, or at a minimum significantly revise the Price Anderson Act, which defines the federal government’s assumption of liability and economic burden in the event of catastrophic nuclear accident, to increase the owner/operator share of the financial risk in the event of a catastrophic nuclear accident. The cost of the Fukushima disaster will exceed the current $11 billion cap on the owner/operator share of the liability should a similar accident occur in the United States. Increasing the cap could serve to motivate greater corporate attention paid to the safety of older operating units, and a greater willingness to pay up front for the maximum level of safety to be designed into future units. What are the implications of continued failure of the NRC to fully implement a fire protection rule? The NRC is routinely waiving fire protection rule violations at nearly half of the nation’s 104 operational nuclear power plants, even though fire presents one of the chief hazards at nuclear plants.42 On March 22, 1975, a fire broke out at the Browns Ferry plant where Unites 1 and 2 were operating. Below the plant’s control room, two electricians were trying to seal air leaks in the cable spreading room, where the electrical cables that control the two reactors are separated and routed through different tunnels to the reactor buildings. They were using strips of spongy foam rubber to seal the leaks. They were also using candles to determine whether or not the leaks had been successfully plugged—by observing how the flame was affected by escaping air. The electrical engineer put the candle too close to the foam rubber, and it burst into flame. The resulting fire, which disabled a large number of engineered safety systems at the plant, including the entire emergency core cooling

42 John Sullivan, The Washington Post, May 15, 2011 http://www.washingtonpost.com/politics/nrc-waives-fire-rule-violations-at-nuclear-plants/2011/05/11/AFNa5e3G_story.html.

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system (ECCS) on Unit 1, and almost resulted in a core melt accident, demonstrates the vulnerability of nuclear plants to “single failure” events and human fallibility.43 In May 1980, five years following the Browns Ferry fire, the NRC implemented a fire protection rule, 10 CFR 50 Appendix R. In the late-1990s the NRC discovered, that most of the reactor licensees were in violation of Appendix R in that they were relying on manual operator actions that were not permitted under the rule without expressed approval of the NRC, and these approvals had not been given. Another decade went by with most of the reactors out of compliance, so the NRC staff then offered the licensees an alternative fire protection rule, namely, 10 CFR 50.48(c), which incorporates the National Fire Protection Association’s (NFPA) “Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants, 2001 Edition” (NFPA 805), which the NRC staff helped develop. This alternative performance-based standard was published by NFPA on January 13, 2001. NFPA 805 describes a methodology for existing light-water nuclear power plants to apply performance-based requirements and fundamental fire protection design elements to establish fire protection systems and features for all modes of operation. NRC’s Fire Protection Rule in 10 CFR 50 now allows licensees to voluntarily adopt NFPA 805 and use the fire protection requirements it contains.44 The Commission provided certain enforcement discretion as an incentive for licensees to adopt NFPA 805. As of today, only one reactor, Shearon Harris Unit 1, has adopted and completed NEPA 805. Some 50 reactors, not in compliance with Appendix R, are now pursuing NFPA 805 as a means of complying with the NRC’s fire protection rule. The NRC has proposed staggering its review of NEFA 805 compliance at these 50 reactors over the next decade. Thus, thirty-six years after the Browns Ferry fire 50 out of 104 operational reactors (see Table 4) are not in compliance with either old or the new fire protection rule. On its web page discussing the new rule, the NRC begins with the assertion, “U.S. nuclear power plants are safe; the NRC is making them safer. . . ”45 In effect the NRC is saying that compliance with the fire protection rules is not all that important to the safety of the plants. We believe this is wrong. Additional reliable gauges should be required so that the water level in reactor pressure vessels and spent fuel pools can be monitored during an accident. At Fukushima the status of the water level in the reactors does not appear to have been directly measurable as the cores of Unites 1-3 became uncovered. TEPCo mistakenly

43 David Dinsmore Comey, “The Fire at the Browns Ferry Nuclear Power Station” http://www.ccnr.org/browns_ferry.html#fi originally published in Friends of the Earth, Not Man Apart (California, 1976). 44 The Commission approved the final rule incorporating NFPA 805 into 10 CFR 50 via a staff requirements memorandum (SRM), dated May 11, 2004. The rule was published on June 16, 2004, and became effective July 16, 2004. http://www.nrc.gov/reactors/operating/ops-experience/fire-protection/protection-rule/protection-rule-overview.html 45 U.S. NRC, Alternative Fire Protection Rule (10 CFR 50.48 (c), NFPA 805), updated March 12, 2011. http://www.nrc.gov/reactors/operating/ops-experience/fire-protection/protection-rule.html

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believed the fuel in Unit 1 was only partially uncovered until engineers fixed a gauge that measured the water level some two months after the core was uncovered.46 At Fukushima there are no gauges to permit remote measurement of the water levels in spent fuel pools. This is also thought to be the case with respect to U.S. spent fuel pools at operational reactors. The MACCS2 computer code used to calculate offsite consequences is outdated and should be revised or replaced. MACCS2 is used by the DOE, NRC staff, and NRC licensees to model the doses, health effects, and economic consequences that result from unintended radiological releases into the atmosphere. NRC and its licensees use the MACCS2 code as part of the Severe Accident Mitigation Alternatives (SAMA) analysis. According to David Changin, an architect and developer of the MACCS2 while at Sandia National Laboratories, the code has deficiencies with respect to modeling accidents where recriticality occurs or where the accident lasts more than four day.47 Consequently, MACCS2 underestimates environmental consequences and economic damage associated with a severe accident lasting for weeks. What changes should be implemented regarding radiation monitoring during routine plant operations and following an accident? The radiation monitoring in Japan following the Fukushima accident was less than comprehensive and on at least one occasion was reported erroneously but corrected the next day. Here in the United States there have been criticisms regarding the failure of selected EPA monitors on the West Coast, failure to report readings taken with more sensitive instrumentation and failure to deploy some mobile radiation monitors. We do not have firsthand knowledge of these EPA monitoring issues and will not comment further on them. Rather, we wish to offer two recommendations. First, the Preparatory Commission for the Comprehensive Nuclear-Test-Ban Treaty Organization (CTBTO), the international agency established to monitor for nuclear tests under the Comprehensive Test Ban, currently maintains 60 radionuclide particulate monitoring stations throughout the world. These stations monitor the air continuously, and thus provide extensive data on any radionuclides detected during a nuclear test or accident, including the Fukushima disaster and the data is transmitted daily to its member states, including the United States. The U.S. government should take the necessary steps to promptly release to the public the data it receives from the CTBTO. Second, the EPA and NRC should insure that continuous air monitoring data recorded by air monitors around nuclear power plants and by the national network of EPA stations are available to the public on the internet in real time. Today on the internet and you can check the weather at the beach by logging onto a web-cam, but if you live near a nuclear plant you cannot go on the internet to see what the air monitor is reading. The added cost

46 Chico Harlan, The Washington Post, May 18, 2011. 47 In the Matter of Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application, “Pilgrim Watch Request for Hearing on Post Fukushima SAMA Contention,” Docket # 50-293-LR, May 12, 2011. http://pbadupws.nrc.gov/docs/ML1113/ML111320651.pdf

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of making these data available on the web in real time should be small. Some government officials may be reluctant to provide such data in real time for reasons related to quality control, but this seems a flimsy excuse. After all, the agency could post on the web which monitors it feels are not functioning or calibrated improperly. What are the implications of predicted sea-level rise due to climate change on the safety of nuclear reactors near coasts? In the longer term, the NRC should examine the implications of climate change, including sea-level rise and increased storm wave height. Due to climate change under some scenarios the mean sea-level could rise 1 to1.4 meters by the end of the century.48 What does this imply for the location of new nuclear units with 60-80 year lifetimes along low-lying seacoasts, where cooling water is most abundant and does not compete with existing uses for scarce freshwater resources? What does it imply for the vulnerability of future grid connections to such units, the stranding of the plant in a simultaneous inland flooding scenario, and future evacuation routes in the event of an accident? Principal Conclusions The historical frequency of core melt accidents worldwide does not measure up to the safety objectives of the NRC. On the whole the operational reactors worldwide are not sufficiently safe. Because of differences in the reactor safety cultures and the quality of regulatory oversight the next nuclear power plant disaster is more likely to occur abroad than in the United States. If nuclear power is to have a long term future greater attention should be given to current operational reactors. Older obsolete designs should be phased out rather than having their licenses extended. We should also revisit whether the newer reactor designs currently under construction worldwide and those on the drawing board are safe enough. The administration should appoint a truly independent commission, similar to the Kemeny Commission that investigated the Three Mile Island accident in 1979, that can help to engender public confidence by thoroughly examining nuclear safety issues, including assessing the conclusions and proposed corrective actions arrived at by both the nuclear industry and the NRC in its “90-day safety review.” The 20-year license extensions already granted to 20 U.S. operational BWRs with Mark 1 containments and the 3 extensions granted to BWRs with Mark 2 containments should be revisited and the their license extension periods should be shortened. Similarly no 20 year license extension should be granted to the three BWRs with Mark 1 containments and the five with Mark 2 containments, which have not yet received 20 year license extensions.

48 Declarations of Michael C. MacCracken, Raymond G. Najjar and Shuang-Ye Wu, “Declaration Addendum to (Corrected) Opening Brief of Environmental Petitioners,” filed May 17, 2011, Portland Cement Association v. EPA, et al., No. 10-1358 (and consolidated cases), U.S. Court of Appeals for the District of Columbia Circuit.

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The NRC is overdue in requiring that spent fuel be removed from wet pools to hardened dry casks as soon as the spent fuel has cooled sufficiently to be passively cooled in air. Dry cask storage should be made safer by storing the dry casks in a hardened building such as the Ahaus Spent Fuel Storage Facility in Germany. The Ahaus approach should be adopted at most operational reactor sites and any new off-site interim spent fuel storage facility. In light of an improved scientific understanding of the full range of natural and man-made “beyond design basis” events that could strike 40 + year reactors, the risk of core melt followed by failure of containment should be stringently reevaluated for the two Indian Point units and all other existing reactors located in areas of high population density. The feasibility of an adequately protective evacuation, under these revised conditions and extending beyond the current 10-mile radius for the emergency planning zone, should be explicitly reassessed in the context of the relicensing proceeding. The severity of the resulting radiological and other risks to life, property, and natural resources should inform NRC and state-level decisions regarding which units should be denied license or permit renewals, or have their existing license extensions shortened or revoked. The USGS should be directed to take a comprehensive assessment of the earthquake risk at all reactor sites, beginning with those in areas of known high seismic risk. These studies and assessments should be conducted before further reactor license extensions are granted and the results should be part of any relicensing review by the NRC. Potential radiological accidents caused by earthquake or tsunami should be addressed in emergency response plans for US reactors. Congress should repeal, or at a minimum significantly revise the Price Anderson Act, which defines the federal government’s assumption of liability and economic burden in the event of catastrophic nuclear accident, to increase the owner/operator share of the financial risk in the event of a catastrophic nuclear accident. The U.S. government should take the necessary steps to promptly release to the public the data it receives from the CTBTO. The EPA and NRC should insure that continuous air monitoring data recorded by air monitors around nuclear power plants and by the national network of EPA stations are available to the public on the internet in real time.

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Table 1: List of Nuclear Power Reactors that have Experienced Fuel Melt or Other Failures Leading to Reactor Shut-Down. 1. Sodium Reactor Experiment (SER) Location: Santa Susana Field Laboratory, California, USA Reactor type: sodium-cooled graphite-moderated thermal power reactor Power: 20 MWt; 6.5 MWe History: initial criticality: April 25, 1957; first produced electricity July 1957; operated 2

years, partial core melt accident between 12 and 26 July 1959, resulting in melting of as much as one-third of the fuel; shutdown 26 July 1959 (It appears to have been operated for several days with its core partially melted.); converted to HEU-Th fuel; second core operations began September 1960; permanently shutdown February 1964.

2. Stationary Low-Power Reactor No. 1 (SL-1) Location: National Reactor Testing Station (now Idaho National Laboratory) Reactor type: experimental, gas-cooled, water-moderated Power: 3.3 MWt; 300 kWe History: initial criticality March 1961; prompt criticality accident 3 January 1961; shut

down May 1964 3. Enrico Fermi Unit 1 Reactor Location: Newport, Lagoona Beach, Frenchtown Township, Monroe County, Michigan,

USA Reactor Type: Liquid Metal Fast Breeder Reactor ( LMFBR) Power: 200 MWt; 65 MWe (gross); 61 MWe (net) History: initial criticality 23 August 1963; commercial operations began August 1966;

partial fuel melt accident 5 October 1966, two of the 105 fuel assemblies melted, but no contamination was recorded outside the containment vessel; closed November 1972

4. Chapelcross Unit 2 Nuclear Power Plant Location: Annan, Dumfreshire, Scotland, United Kingdom Reactor Type: gas-cooled, graphite moderated; Magnox Power: originally 180 MWt, up-rated progressively to 265 MWt, originally 23 MWe

(gross) progressively up-rated to 60 MWe (gross); 50 MWe (net) History: startup May 1959; while under evaluation for the commercial reactor program

experienced a partial blockage in a single fuel channel May 1967, contamination was limited to one region of the core; shut down 29 June 2004

5. Saint-Laurent A-1 Nuclear Power Plant Location: St. Laurent-Nouan, Loir-et-Cher, Centre, France Reactor Type: gas-cooled, graphite moderated Power: 1570 MWt; 405 MWe (gross), 390 MWe (net) History: grid connection 14 March 1969; commercial operation June 1969; 50 kg of

uranium began to melt 17 October 1969; permanently shut down 27 May 1992 6. Saint-Laurent A-2 Nuclear Power Plant Location: St. Laurent-Nouan, Loir-et-Cher, Centre, France Reactor Type: gas-cooled, graphite moderated Power: 1690 MWt; 465 MWe (gross) (uprated to 530 MWe (gross)), 450 MWe (net)

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History: started November 1970; grid connection 9 August 1971; commercial operation November 1971; heat excursion causing some fuel melting 13 March 1980; permanently shut down 27 May 1992

7. Three Mile Island Unit 2 Nuclear Power Plant Location: Londonderry Township; Dauphine County, Pennsylvania, USA Reactor Type: Pressurized Water Reactor (PWR) Power: 2,568 MWt, 808 MWe (gross); 776 MWe (net) History: initial criticality December 1978; partial core melt accident March 1979;

decommissioned 1979 8. Chernobyl Unit 4 Nuclear Power Plant Location: Pripyat, Ukraine SSR (now Ukraine) Reactor Type: RBMK-1000 (graphite-moderated water-cooled) Power: 3,200 MWt; 1,000 MWe (gross); 925 MWe (net) History: destroyed in full-core melt accident 26 April 1986 9. Greifswald Unit 5 (KGR-5) Nuclear Power Plant Location: Lubmin, GDR (now Germany) Reactor Type: VVER-440, Model V-230, Pressurized Water Reactor (PWR) Power: 1,375 MWt; 440 MWe (gross); 408 MWe (net) History: grid connection 24 April 1989; commercial operation 1 November 1989; near

core melt with 10 fuel elements damaged 7 December 12975; permanent shutdown 24 November 1989

10. Fukushima Daiichi Unit 1 Nuclear Power Plant Location: Ohkuma, Fukushima Prefecture, Japan Reactor Type: Boiling Water Reactor (BWR), GE BWR/2, Mark 1 Containment Power: 1,380 MWt; 450 MWe (gross); 439 MWe (net) History: initial criticality 10 October 1970; grid connection 17 November 1970;

commercial operation 26 March 1971; partial core meltdown following earthquake on 11 March 2011

11. Fukushima Daiichi Unit 2 Nuclear Power Plant Location: Ohkuma, Fukushima Prefecture, Japan Reactor Type: Boiling Water Reactor (BWR), TOS1 (GE BWR/4), Mark 1 Containment Power: 2,381 MWt; 794 MWe (gross); 760 MWe (net) History: initial criticality 10 May 1973; grid connection 24 December 1973; commercial

operation 18 July 1974; partial core meltdown following earthquake on 11 March 2011 12. Fukushima Daiichi Unit 3 Nuclear Power Plant Location: Ohkuma, Fukushima Prefecture, Japan Reactor Type: Boiling Water Reactor (BWR), TOS1 (GE BWR/4), Mark 1 Containment Power: 2,381 MWt; 794 MWe (gross); 760 MWe (net) History: initial criticality 28 January 1978; grid connection 24 February 1978;

commercial operation 12 October 1978; partial core meltdown following earthquake on 11 March 2011

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Table 2: Population within 30 km (18.6 mi) and 75 km (46.6 mi.) of nuclear power stations worldwide. Source: Declan Butler, Senior Reporter, Nature, France, private communication.

Country Site Name Reactors MWe Population within 30 km …within 75 km Location PAKISTAN KANUPP 1 125 8,346,926 14,470,519 Seacoast TAIWAN, CHINA KUOSHENG 2 1,933 5,454,287 9,882,167 Seacoast TAIWAN, CHINA CHIN SHAN 2 1,208 4,687,065 9,833,555 Seacoast KOREA, REPUBLIC OF KORI 8 3,227 3,410,020 7,052,596 Seacoast CHINA GUANGDONG 2 1,888 3,247,486 27,821,860 Seacoast CHINA LINGAO 4 3,876 3,106,385 27,537,030 Seacoast INDIA NARORA 2 404 2,243,522 15,929,296 Inland near a river CANADA PICKERING 8 3,094 2,197,681 5,832,548 Inland near a lake GERMANY PHILIPPSBURG 2 2,292 1,743,695 6,373,483 Inland near a river GERMANY NECKARWESTHEIM 2 2,095 1,619,944 7,073,310 Inland near a river BELGIUM DOEL 4 2,910 1,511,575 9,034,387 Seacoast GERMANY BIBLIS 2 2,407 1,510,809 7,253,269 Inland near a river TAIWAN, CHINA LUNGMEN 2 2,600 1,498,212 9,144,323 Seacoast KOREA, REPUBLIC OF WOLSONG 4 2,722 1,300,745 5,378,972 Seacoast CHINA QINSHAN 9 6,038 1,299,506 12,772,648 Seacoast GERMANY KRUEMMEL (KKK) 1 1,346 1,177,741 4,173,068 Inland near a river USA INDIAN POINT 2 2,065 1,075,040 17,343,606 Inland near a river UNITED KINGDOM HARTLEPOOL 2 1,190 1,062,217 3,012,729 Seacoast UNITED KINGDOM OLDBURY 2 434 1,042,295 4,477,473 Inland near a river SWITZERLAND BEZNAU 2 730 1,027,780 5,866,058 Inland near a river CHINA TIANWAN 2 1,866 1,010,056 6,875,833 Seacoast USA LIMERICK 2 2,264 982,549 8,156,849 Inland near a river CHINA FUQING 3 3,000 980,280 6,934,209 Seacoast INDIA KAKRAPAR 4 1,664 963,906 8,192,016 Inland near a river SWITZERLAND GOESGEN 1 970 959,787 5,638,222 Inland near a river FRANCE FESSENHEIM 2 1,760 931,516 4,185,876 Inland near a river JAPAN TOKAI 1 1,060 919,437 4,059,660 Seacoast

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Country Site Name Reactors MWe Population within 30km …within 75km Location SWITZERLAND MUEHLEBERG 1 373 892,419 3,432,574 Inland near a river USA THREE MILE ISLAND 1 786 836,919 2,484,072 Inland near a river BELGIUM TIHANGE 3 3,016 836,375 5,756,062 Inland near a river SWITZERLAND LEIBSTADT 1 1,190 817,983 5,829,898 Inland near a river FRANCE CATTENOM 4 5,200 801,518 3,226,819 Inland near a lake ARMENIA ARMENIA 1 375 768,816 2,474,639 Inland near a river USA MCGUIRE 2 2,200 758,773 2,432,640 Inland near a lake INDIA KUDANKULAM 2 1,834 751,613 4,772,980 Seacoast KOREA, REPUBLIC OF SHIN-WOLSONG 2 1,920 748,525 6,471,427 Seacoast USA CATAWBA 2 2,258 717,868 2,127,615 Inland near a lake PAKISTAN CHASNUPP 2 600 712,171 3,926,531 Inland near a river FRANCE BUGEY 4 3,580 698,393 3,710,199 Inland near a river CHINA HAIYANG 2 2,000 690,825 3,360,693 Seacoast UNITED KINGDOM HEYSHAM 4 2,400 657,237 5,118,870 Seacoast CHINA SANMEN 2 2,000 631,742 5,108,107 Inland near a river FRANCE ST. ALBAN 2 2,670 615,386 3,603,767 Inland near a river USA SAN ONOFRE 2 2,150 606,973 6,866,677 Seacoast JAPAN HAMAOKA 3 3,360 591,946 2,914,603 Seacoast USA TURKEY POINT 2 1,386 584,744 3,238,967 Seacoast GERMANY UNTERWESER (KKU) 1 1,345 568,175 2,726,963 Inland near a river INDIA TARAPUR 4 1,280 563,932 9,010,254 Seacoast USA R.E. GINNA 1 580 506,446 1,327,140 Inland near a lake GERMANY GRAFENRHEINFELD (KKG) 1 1,275 503,848 2,513,299 Inland near a river INDIA MADRAS 1 880 503,580 11,992,825 Seacoast UNITED KINGDOM HINKLEY POINT B 2 840 503,419 4,039,886 Seacoast GERMANY GROHNDE (KWG) 1 1,360 489,228 4,718,994 Inland near a river CHINA TAISHAN 2 3,400 487,558 6,860,794 Seacoast GERMANY EMSLAND (KKE) 1 1,329 463,105 3,520,043 Inland near a river INDIA RAJASTHAN 6 1,085 461,484 4,059,303 Inland near a river FRANCE GRAVELINES 6 5,460 457,739 2,493,458 Seacoast CHINA NINGDE 4 4,000 455,546 3,872,299 Seacoast

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Country Site Name Reactors MWe Population within 30km …within 75km Location USA BEAVER VALLEY 2 1,738 444,404 3,415,272 Inland near a river USA SEQUOYAH 2 2,274 440,276 1,006,876 Inland near a river NETHERLANDS BORSSELE 1 487 437,946 5,647,252 Seacoast CANADA DARLINGTON 4 3,512 435,704 4,349,774 Inland near a lake USA HOPE CREEK 1 1,161 432,104 5,162,087 Inland near a river JAPAN SHIMANE 3 2,553 424,077 944,633 Seacoast USA SURRY 2 1,598 422,873 2,156,287 Seacoast GERMANY GUNDREMMINGEN 2 2,572 420,112 3,372,727 Inland near a river JAPAN KASHIWAZAKI KARIWA 7 7,965 418,769 2,111,422 Seacoast USA SEABROOK 1 1,245 416,677 4,336,769 Seacoast UNITED KINGDOM HUNTERSTON B 2 860 404,437 2,431,055 Seacoast USA SHEARON HARRIS 1 900 403,309 2,143,401 Inland near a lake USA OYSTER CREEK 1 614 401,413 3,683,604 Seacoast USA SALEM 2 2,332 388,084 5,030,681 Inland near a river SLOVAK REPUBLIC BOHUNICE V2 2 944 384,288 2,577,490 Inland near a river USA ENRICO FERMI 1 1,122 381,964 5,663,043 Inland near a lake USA WATERFORD 1 1,176 381,273 2,076,040 Inland near a river USA PEACH BOTTOM 2 2,224 360,539 4,986,475 Inland near a river UKRAINE KHMELNITSKI 4 3,800 344,228 1,112,792 Inland near a lake USA ST. LUCIE 2 1,678 342,226 960,085 Seacoast GERMANY BROKDORF (KBR) 1 1,410 338,296 4,192,615 Inland near a river SLOVENIA KRSKO 1 666 332,937 2,404,606 Inland near a river USA DRESDEN 2 1,734 332,170 6,776,346 Inland near a river INDIA KAIGA 4 808 324,436 2,573,287 Inland near a river CHINA FANGCHENGGANG 1 1,000 324,142 1,867,423 Seacoast RUSSIA BELOYARSKY 2 1,364 323,105 2,323,348 Inland near a lake UKRAINE ZAPOROZHE 6 5,700 319,467 1,535,072 Inland near a river GERMANY ISAR 2 2,288 315,142 3,223,271 Inland near a river USA SUSQUEHANNA 2 2,325 312,497 1,515,513 Inland near a river FRANCE TRICASTIN 4 3,660 308,661 1,712,197 Inland near a river USA MILLSTONE 2 2,014 308,069 2,612,274 Seacoast

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Country Site Name Reactors MWe Population within 30km …within 75km Location SLOVAK REPUBLIC MOCHOVCE 4 1,654 301,510 2,036,249 Inland near a river USA FORT CALHOUN 1 482 299,423 944,172 Inland near a river CZECH REPUBLIC DUKOVANY 4 1,796 295,717 1,771,525 Inland near a river FRANCE ST. LAURENT 2 1,830 288,299 1,234,591 Inland near a river UNITED KINGDOM DUNGENESS B 2 1,040 280,216 2,858,182 Seacoast USA PILGRIM 1 684 274,758 4,663,188 Seacoast JAPAN TSURUGA 2 1,448 274,591 2,603,323 Seacoast USA PERRY 1 1,245 270,809 2,354,526 Inland near a lake CZECH REPUBLIC TEMELIN 2 1,926 270,671 1,105,062 Inland near a river JAPAN GENKAI 4 3,312 257,100 4,311,118 Seacoast FRANCE CRUAS 4 3,660 246,355 1,276,632 Inland near a river USA BYRON 2 2,300 238,664 989,177 Inland near a river JAPAN MONJU 1 10 235,566 2,544,702 Seacoast USA QUAD CITIES 2 1,734 232,716 697,446 Inland near a river USA DUANE ARNOLD 1 579 230,003 669,089 Inland near a river JAPAN ONAGAWA 3 2,090 229,211 2,140,841 Seacoast JAPAN SENDAI 2 1,692 223,259 1,681,383 Seacoast GERMANY BRUNSBUETTEL (KKB) 1 771 222,210 3,560,936 Inland near a river SOUTH AFRICA KOEBERG 2 1,800 221,647 3,482,235 Seacoast SPAIN VANDELLOS 1 1,045 219,310 904,569 Seacoast IRAN BUSHEHR 1 915 213,129 510,301 Seacoast CHINA HONGYANHE 4 4,000 208,820 1,990,712 Seacoast FRANCE CIVAUX 2 2,990 205,203 779,624 Inland near a river JAPAN MIHAMA 3 1,720 204,512 2,831,598 Seacoast JAPAN FUKUSHIMA-DAINI 4 4,268 204,250 1,585,740 Seacoast CHINA YANGJIANG 3 3,000 202,429 2,784,768 Inland near a river FRANCE CHOOZ 2 3,000 199,917 2,556,268 Inland near a river JAPAN SHIKA 2 1,613 198,118 1,981,451 Seacoast UNITED KINGDOM SIZEWELL B 1 1,188 197,616 1,595,501 Seacoast JAPAN TAKAHAMA 4 3,220 191,859 4,799,666 Seacoast BULGARIA BELENE 2 1,906 191,696 1,306,180 Inland near a river

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Country Site Name Reactors MWe Population within 30km …within 75km Location CHINA CHANG JIANG 2 1,220 188,966 1,149,778 Seacoast USA OCONEE 3 2,538 188,819 1,236,188 Inland near a lake CANADA GENTILLY 1 635 184,452 653,781 Inland near a river HUNGARY PAKS 4 1,889 184,137 1,298,735 Inland near a river FRANCE GOLFECH 2 2,620 183,965 1,456,457 Inland near a river FRANCE PENLY 2 2,660 180,496 1,368,777 Seacoast ARGENTINA ATUCHA 2 1,027 180,152 2,398,222 Inland near a river FRANCE CHINON 4 3,620 176,411 1,644,162 Inland near a river RUSSIA KURSK 5 3,700 175,964 882,159 Inland near a lake JAPAN FUKUSHIMA-DAIICHI 6 4,546 171,563 1,727,898 Seacoast USA BROWNS FERRY 3 3,272 171,133 951,815 Inland near a river KOREA, REPUBLIC OF YONGGWANG 6 5,875 171,111 3,294,647 Seacoast USA MONTICELLO 1 572 164,742 2,729,560 Inland near a river RUSSIA VOLGODONSK 4 3,922 162,717 392,011 Inland near a river

FRANCE FLAMANVILLE 3 2,660 162,681 488,730 Seacoast JAPAN OHI 4 4,494 158,938 4,780,771 Seacoast USA DIABLO CANYON 2 2,240 157,658 474,224 Seacoast RUSSIA BALAKOVO 4 3,800 157,149 479,672 Inland near a river RUSSIA NOVOVORONEZH 3 3,948 154,200 1,580,101 Inland near a river USA CALVERT CLIFFS 2 1,735 153,632 2,494,168 Seacoast USA DONALD COOK 2 2,069 150,775 1,150,068 Inland near a lake BRAZIL ANGRA 3 3,129 149,617 1,351,735 Seacoast USA VERMONT YANKEE 1 620 146,511 1,263,056 Inland near a river JAPAN IKATA 3 1,922 144,640 1,852,353 Seacoast FRANCE PALUEL 4 5,320 140,255 1,513,559 Seacoast BULGARIA KOZLODUY 2 1,906 138,341 1,356,716 Inland near a river FRANCE BLAYAIS 4 3,640 136,558 1,630,953 Seacoast ROMANIA CERNAVODA 2 1,300 130,794 1,150,730 Inland near a river RUSSIA NOVOVORONEZH-2 2 3,948 130,131 1,580,219 Inland near a river USA VIRGIL C. SUMMER 1 966 129,769 1,005,311 Inland near a lake UKRAINE SOUTH UKRAINE 3 1,900 127,585 534,511 Inland near a lake

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Country Site Name Reactors MWe Population within 30km …within 75km Location FRANCE NOGENT 2 2,620 124,445 1,755,869 Inland near a river FRANCE DAMPIERRE 4 3,560 123,675 1,193,163 Inland near a river USA PALISADES 1 778 120,508 1,155,209 Inland near a lake USA BRAIDWOOD 2 2,330 118,688 3,850,666 Inland near a lake USA BRUNSWICK 2 1,858 118,581 375,497 Inland near a river USA RIVER BEND 1 978 115,926 851,030 Inland near a river UKRAINE ROVNO 4 2,657 115,190 757,532 Inland near a river USA FITZPATRICK 1 854 105,411 909,286 Inland near a lake USA PRAIRIE ISLAND 2 1,096 105,033 2,717,954 Inland near a river USA NINE MILE POINT 2 1,763 102,501 906,884 Inland near a lake USA LASALLE 2 2,238 100,965 1,330,267 Inland near a lake FRANCE BELLEVILLE 2 2,620 100,727 919,124 Inland near a river USA DAVIS BESSE 1 879 100,321 1,836,697 Inland near a lake MEXICO LAGUNA VERDE 2 1,300 100,291 1,972,320 Seacoast SWEDEN RINGHALS 4 3,649 99,679 1,036,661 Seacoast USA COLUMBIA 1 1,131 99,370 369,135 Inland near a river USA CRYSTAL RIVER 1 860 94,403 780,950 Seacoast USA NORTH ANNA 2 1,806 94,397 1,540,924 Inland near a lake USA WATTS BAR 2 2,288 93,378 938,600 Inland near a river USA FARLEY 2 1,711 93,183 406,403 Inland near a river USA H.B. ROBINSON 1 710 88,672 784,459 Inland near a lake USA POINT BEACH 2 1,026 86,898 758,409 Inland near a lake ARGENTINA EMBALSE 1 600 86,854 331,303 Inland near a lake RUSSIA SMOLENSK 3 2,775 85,944 313,388 Inland near a river USA ARKANSAS ONE 2 1,839 85,619 271,014 Inland near a river KOREA, REPUBLIC OF ULCHIN 6 5,873 81,559 613,281 Seacoast JAPAN TOMARI 3 1,966 77,272 1,973,708 Seacoast RUSSIA LENINGRAD-2 2 5,750 76,581 3,711,222 Seacoast RUSSIA LENINGRAD 4 5,750 76,060 3,638,403 Seacoast JAPAN HIGASHI DORI 1 1,067 74,970 671,750 Seacoast FINLAND OLKILUOTO 3 3,340 73,829 265,398 Seacoast

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Country Site Name Reactors MWe Population within 30km …within 75km Location USA KEWAUNEE 1 556 71,263 743,914 Inland near a lake SPAIN SANTA MARIA DE GARONA 1 446 69,438 2,121,476 Inland near a river JAPAN OHMA 1 1,325 66,520 677,215 Seacoast UNITED KINGDOM WYLFA 2 980 66,112 328,046 Seacoast SPAIN ASCO 2 1,992 59,485 996,220 Inland near a river USA COMANCHE PEAK 2 2,367 59,370 1,311,105 Inland near a lake USA HATCH 2 1,759 56,721 358,913 Inland near a river UNITED KINGDOM TORNESS 2 1,205 56,458 1,505,052 Seacoast SPAIN ALMARAZ 2 1,964 54,384 427,834 Inland near a lake USA CLINTON 1 1,043 53,770 718,287 Inland near a lake RUSSIA KALININ 4 3,800 44,176 253,245 Inland near a lake

USA CALLAWAY 1 1,190 41,780 470,839 Inland near a river SPAIN COFRENTES 1 1,064 41,015 2,545,941 Inland near a river RUSSIA KOLA 4 1,644 39,213 219,995 Seacoast USA SOUTH TEXAS 2 2,560 38,539 258,482 Inland near a river USA VOGTLE 2 2,302 37,899 688,888 Inland near a river CANADA BRUCE 8 4,693 33,900 174,682 Inland near a lake FINLAND LOVIISA 2 976 30,688 727,010 Seacoast SWEDEN OSKARSHAMN 3 2,511 27,739 152,138 Seacoast USA GRAND GULF 1 1,259 25,980 294,789 Inland near a river TAIWAN, CHINA MAANSHAN 2 1,841 25,781 479,359 Seacoast SWEDEN FORSMARK 3 3,138 22,043 343,174 Seacoast CANADA POINT LEPREAU 1 635 20,726 191,365 Seacoast USA COOPER 1 769 18,838 147,299 Inland near a river USA PALO VERDE 3 3,942 16,928 1,405,403 Inland near a lake SPAIN TRILLO 1 1,003 16,175 501,965 Inland near a river USA WOLF CREEK 1 1,160 13,185 172,300 Inland near a lake RUSSIA BILIBINO 4 44 276 2,253 Inland near a river

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Table 3: Population within 50 miles, 30 kilometers (km - 18.6 miles), 20 kilometers (12.4 miles), and 10 miles of U.S. nuclear power stations, and the Fukushima Daiichi Nuclear Power Station in Japan.

Population

Nuclear Reactor Site within 50 miles

within 30 km

within 20 km

within 10 miles

Arkansas Nuclear One 300,875 85,118 56,562 46,665Beaver Valley Power Station 3,136,087 386,818 195,304 115,185Braidwood Generating Station 5,058,878 139,413 48,994 37,419Browns Ferry Nuclear Plant 964,440 166,229 91,396 35,574Brunswick Steam Electric Plant 447,204 125,455 41,134 28,098Byron Generating Station 1,263,788 209,381 37,583 27,967Callaway Nuclear Power Station 533,393 38,769 21,431 9,380Calvert Cliffs Nuclear Power Station 3,265,942 133,018 66,815 35,732Catawba Nuclear Station 2,583,890 842,304 336,079 216,684Clinton Power Station 796,220 47,672 19,264 12,807Columbia Nuclear Generating Station 440,870 122,151 24,473 4,212Comanche Peak Steam Electric Station 1,763,739 68,039 46,026 33,584Cook (Donald C.) Nuclear Power Station 1,229,031 129,972 83,371 52,335Cooper Nuclear Station 158,357 15,900 7,930 3,688Crystal River Nuclear Power Station 1,068,039 98,249 33,238 20,328Davis-Besse Nuclear Power Station 1,765,945 77,506 22,855 15,540Diablo Canyon Nuclear Power Plant 441,494 134,743 68,045 22,837Dresden Generating Station 5,968,730 278,110 88,993 60,561Duane Arnold Energy Center 663,337 222,916 186,729 112,515Enrico Fermi Atomic Power Plant 4,921,862 318,112 137,964 90,230Fort Calhoun Station 939,025 284,348 28,936 19,382Grand Gulf Nuclear Station 323,731 21,270 11,734 8,412H.B. Robinson Nuclear Power Station 892,571 82,207 39,719 32,483Hatch (Edwin I.) Nuclear Power Station 419,726 50,951 19,186 10,129Indian Point Nuclear Power Station 17,310,391 978,945 433,603 252,828James A. FitzPatrick Nuclear Power Plant 884,703 89,086 42,727 31,722Joseph M. Farley Nuclear Plant 422,000 83,846 18,344 11,357Kewaunee Nuclear Power Station 766,265 70,032 21,655 10,025La Salle County Generating Station 1,941,089 90,859 47,514 16,337Limerick Generating Station 7,907,943 944,872 352,527 245,899McGuire (W.B.) Nuclear Station 2,887,444 874,252 329,848 189,378Millstone Nuclear Power Station 2,890,682 250,354 133,056 100,780Monticello Nuclear Generating Plant 3,026,547 210,588 101,362 59,159Nine Mile Point Nuclear Station 882,346 88,009 42,717 31,876North Anna Nuclear Power Station 1,879,826 121,567 38,086 23,228

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Population Nuclear Reactor Site within

50 miles within 30 km

within 20 km

within 10 miles

Oconee Nuclear Power Station 1,402,463 181,908 104,956 74,546Oyster Creek Generating Station 4,346,015 369,541 204,833 122,628Palisades Nuclear Power Station 1,344,455 102,087 44,726 31,298Palo Verde Nuclear Power Station 2,127,628 40,433 6,058 3,798Peach Bottom Atomic Power Station 5,406,288 350,043 81,614 46,202Perry Nuclear Power Plant 2,270,346 248,902 125,073 82,525Pilgrim Nuclear Station 4,536,218 237,115 104,292 65,881Point Beach Nuclear Power Station 772,560 77,493 29,808 20,446Prairie Island Nuclear Generating Plant 2,998,068 108,151 46,013 29,545Quad Cities Generating Station 654,537 219,947 56,458 31,692River Bend Station 950,101 103,067 39,648 23,979Robert E. Ginna Nuclear Power Station 1,247,344 496,302 101,764 61,697Salem and Hope Creek Generating Stations 5,348,293 392,762 79,003 42,125San Onofre Nuclear Generating Station 8,509,157 600,809 159,101 85,877Seabrook Nuclear Station 4,208,014 373,439 158,386 117,522Sequoyah Nuclear Power Station 1,080,727 427,297 161,789 95,419Shearon Harris Nuclear Power Plant 2,588,936 501,496 186,579 91,925South Texas Project Electric Generating Station

265,091 31,633 11,854 2,224

St. Lucie Nuclear Power Station 1,194,373 376,216 265,315 182,511Surry Nuclear Power Station 2,188,711 370,414 176,842 116,947Susquehanna Steam Electric Station 1,744,486 277,445 100,719 53,197Three Mile Island Generating Station 2,818,044 813,589 403,845 183,680Turkey Point Power Station 3,426,334 579,857 251,892 156,705Vermont Yankee Generating Station 1,418,842 126,257 46,010 34,447Virgil C. Summer Nuclear Power Station 1,179,156 132,963 30,076 12,360Vogtle (Alvin W.) Nuclear Power Station 721,893 36,853 10,158 5,171Waterford Generating Station 2,005,593 332,637 113,956 87,231Watts Bar Nuclear Power Station 1,173,601 92,982 29,569 19,971Wolf Creek Generating Station 177,920 11,515 6,603 4,992Fukushima Daiichi Nuclear Power Station 1,964,725 159,859 69,162 51,925

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Table 4: NFPA 805 Fire Protection Transitioning Plants Site Utility ADAMS

Accession Arkansas Nuclear One 1 & 2 Entergy Operations ML053140128 Beaver Valley 1 & 2 FirstEnergy Nuclear Operating Co. ML060040259 Browns Ferry 1, 2, & 3 Tennessee Valley Authority ML090650597 Brunswick 1 & 2 Progress Energy ML083030138 Callaway AmerenUE ML053420340 Calvert Cliffs 1 & 2 Constellation Generation Group ML061150257 Catawba 1 & 2 Duke Energy ML072260422 Cooper Nebraska Public Power District ML053640280 Crystal River 3 Progress Energy ML070610088 D.C. Cook 1 & 2 Indiana Michigan Power Co. ML060090370 Davis-Besse FirstEnergy Nuclear Operating Co. ML060040259 Diablo Canyon 1 & 2 Pacific Gas and Electric Co. ML060100480 Duane Arnold FPL Energy ML062500229 Farley 1 & 2 Southern Nuclear Operating Co. ML080450434 Fort Calhoun Omaha Public Power District ML081620232 Ginna Constellation Generation Group ML053620035 H. B. Robinson 2 Progress Energy ML072420196 Kewaunee Dominion Energy Kewaunee ML082040111 McGuire 1 & 2 Duke Energy ML061150375 Monticello Nuclear Management Co. ML060730265 Nine Mile Point 1 & 2 Constellation Generation Group ML061150257 Oconee 1, 2, & 3 (Pilot) Duke Energy ML050670305 Palisades Entergy Operations ML082540402 Perry 1 FirstEnergy Nuclear Operating Co. ML060040259 Point Beach 1 & 2 Florida Power & Light Co. ML082600482 Prairie Island 1 & 2 Nuclear Management Co. ML060730265 Prairie San Onofre 2 & 3 Southern California Edison ML080920132 Shearon Harris 1 (Pilot) Progress Energy ML051720404 St. Lucie 1 & 2 Florida Power & Light Co. ML053640283 Turkey Point 3 & 4 Florida Power & Light Co. ML053290175 VC Summer SCE & G ML062990453 Waterford 3 Entergy Operations ML060030453

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Appendix A: An Estimate of the Collective Effective Dose Resulting from Radiation Emitted During the First Months of the Fukushima Daiichi Nuclear Accident The Magnitude 9.0 earthquake off Japan’s Pacific Coast, which was the initiating event for accidents at four of the six reactors at the Fukushima Daiichi nuclear power plant, occurred at 14:46 local time on March 11th. At 15:41 a tsunami hit the plant and a station blackout ensued. A reconstruction of the accident progression by Areva49 posited that the final option for cooling the reactors – the reactor core isolation pumps – failed just hours later in Unit 1 (at 16:36), failed in the early morning of March 13th in Unit 3 (at 02:44), and failed early in the afternoon of March 14th in Unit 2 (at 13:25). Radiological releases spiked beginning on March 15th and in the Areva analysis are attributed to the venting of the reactor pressure vessels, explosion in Unit 2, and – significantly – explosion and fire in Unit 4. Fuel had been discharged from the Unit 4 reactor core to the adjacent spent fuel pool on November 30, 2010, raising the possibility of a core melt “on fresh air.” The Japanese Ministry of Education, Culture, Sports, Science and Technology (MEXT) has posted hourly dose rates by prefecture50 on its website. We do not currently know the geographic coordinates of these radiation monitoring sites. The English language versions of the hourly dose rate measurements by prefecture begin in table form at 17:00 on March 16th, and hourly dose rates are provided as charts51 beginning at 00:00 on March 14th. We first extracted the early data for selected prefectures from these charts point by point using image processing software, and these extracted points were subsequently normalized to tabular data beginning at 17:00 on March 15th from the MEXT Japanese language website provided to us by Professor Tadahiro Katsuta of Tokyo’s Meiji University. Hourly dose rates were not provided by MEXT for Miyagi Prefecture to the north of the Fukushima Daiichi until after 17:00 on March 15th, and importantly not for Fukushima Prefecture until April 5th. We used these available hourly dose rate measurements by prefecture to calculate a collective effective dose for prefectures near the damaged Fukushima Daiichi plant, including Tokyo. In radiation protection, the effective dose takes into account any non-uniformity of exposure and can be used to calculate the risks of cancer. The collective effective dose is the effective dose summed over the exposed population. Units of measure for collective effective dose are person-sieverts, or in the older units, person-rems (1 person-rem is equal to 0.01 person-sieverts. The cancer and genetic risks for a given radiation exposure may be very small for an individual if the radiation exposure is small, but when a small exposure occurs over a large population, health effects can be expected on a statistical basis.

49 Alan Hanson, Stanford University Center for International Security and Cooperation (CISAC) Visiting Scholar, and Executive Vice President, Technologies and Used Fuel Management of AREVA NC Inc., March 21, 2011 CISAC Seminar: “The Nuclear Crisis in Japan,” http://iis-db.stanford.edu/evnts/6615/March21_JapanSeminar.pdf. 50 http://www.mext.go.jp/english/radioactivity_level/detail/1304080.htm. 51 http://www.mext.go.jp/english/radioactivity_level/detail/1303986.htm.

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In Figure A1, the dose rates for Ibaraki and Tokyo prefectures are plotted by hour for a three-week time interval. Ibaraki Prefecture borders Fukuhima Prefecture, and the center of Ibaraki Prefecture is located about 130 kilometers (81 miles) southwest of the reactor accident site. Tokyo is located about 250 kilometers (155 miles) also southwest of Fukushima Daiichi. The fact that these two prefectures are in the same direction from Fukushima Daiichi, with Tokyo more distant, makes it likely that the radiation readings in Tokyo should be similar but smaller than for Ibaraki Prefecture as can be seen in Figure 1.

Figure A1: Hourly dose rates for Ibaraki and Tokyo Prefectures, data from MEXT. Radiation dose rates in the impacted prefectures does not just depend on proximity to the Fukushima Daiichi plant, but also depends on the prevailing winds and weather events over the course of the accident progression. Figure A2 charts the hourly dose rate in Tochigi Prefecture and Yamagata Prefecture, which both border Fukushima Prefecture. Not only is the dose rate in Yamagata lower overall than in Tochigi, but the radiation from the first prominent spikes on March 15th did not register in Yamagata Prefecture until almost a day later than it did in Ibaraki, Tochigi or Tokyo Prefectures. This disparity in dose rate depending on the direction of a prefecture from Fukushima is even more evident in Figure A3, where dose rates in Niigata Prefecture which borders Fukushima Prefecture to the west don’t appear to rise above background levels, but dose rates are higher in Kanagawa Prefecture south of Tokyo, and the radiation spikes are apparent. Figures A4 and A5 contrast the dose rates in Saitama and Chiba Prefectures, and Gumma and Nagano Prefectures, respectively.

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Figure A2: Hourly dose rates for Tochigi and Yamagata Prefectures, data from MEXT.

Figure A3: Hourly dose rates for Kanagawa and Niigata Prefectures, data from MEXT.

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Figure A4: Hourly dose rates for Saitama and Chiba Prefectures, data from MEXT.

Figure A5: Hourly dose rates for Gumma and Nagano Prefectures, data from MEXT.

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In order to calculate the excess collective effective dose caused by the accident, it is necessary to subtract a background radiation signal to measure health effects from the excess radiation produced by the events at Fukushima Daiichi. Ranges for background radiation levels were published by MEXT for each prefecture along with the hourly dose data, described as the “Usual Value Band.” Figure A6 shows the average dose rates across eleven prefectures for March 14th and March 15th, and contrasts these dose rates with the background range provided by the Japanese government. For this analysis, we have subtracted low, high and average background dose rates in order to calculate a range and mid-value for the collective effective dose from radiation emitted during the accident, as shown in Table A1.

Figure A6: A chart of the average dose rate on March 14th (blue) and for March 15th (red), and the typical background ranges (black bars) for eleven Japanese prefectures near Fukushima Daiichi: all units are micro-sieverts per hour.

We obtained population data for Japan prefectures from the Japan Ministry of Internal Affairs and Communications, Statistics Bureau52 for the year 2010. These populations were multiplied by total doses less background to calculate the collective effective dose by prefecture, as shown below in Table A2. The BIER VII Phase 253 best estimates were used to estimate expected excess cancers and excess cancer deaths as a function of 52 http://www.stat.go.jp/english/data/chiri/map/index.htm. 53 http://www.nap.edu/openbook.php?isbn=030909156X.

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exposure to the radiation released from Fukushima Daiichi. These excess cases are compared with expected incidence of cancer and cancer deaths absent this exposure. The BEIR VII risk estimates are for a U.S. population of all ages. We do not have comparable risk estimates for a Japanese population, but the differences would be insignificant compared to other uncertainties. Figure A7 maps the prefectures color-coded by the calculated mid-value of the collective effective dose. Table A1: Hourly dose rates by prefecture were integrated over 16,020 hours of data: from March 14, 2011 until May 23, 2011, for hours were data was available. Background dose rates for each prefecture were taken as the average of low and high reported background values.

Japanese Prefecture 

Hours of Data 

Summed Dose (rem) 

Average Background Dose (rem) 

Excess Dose above Average Background 

(rem) Chiba‐ken  1689  0.009344 0.005574 0.003771Fukushima‐ken  1146  0.208840 0.006188 0.202652Gumma‐ken  1685  0.008350 0.005224 0.003127Ibaraki‐ken  1689  0.026319 0.007769 0.018550Kanagawa‐ken  1687  0.010139 0.008772 0.001367Miyagi‐ken  1380  0.011062 0.004754 0.006308Saitama‐ken  1677  0.011521 0.007630 0.003891Tochigi‐ken  1689  0.014826 0.008192 0.006635Tokyo‐to  1689  0.013245 0.009036 0.004208Yamagata‐ken  1689  0.009273 0.009036 0.000237

Table A2: Census population figures, collective dose and statistical cancers and cancer deaths calculated for radiation exposure above background.

Japanese Prefecture 

2010 Population 

Collective Effective Dose 

(person‐rem)Excess Cancers 

Excess Cancer Deaths 

Cancers Absent Exposure 

Cancer Deaths Absent Exposure 

Chiba‐ken  6,217,119  23,442.8 26.6 13.4 2,605,595  1,269,536Fukushima‐ken  2,028,752  411,129.8 466.6 234.3 850,250  414,271Gumma‐ken  2,008,170  6,279.3 7.1 3.6 841,624  410,068Ibaraki‐ken  2,968,865  55,071.1 62.5 31.4 1,244,251  606,242Kanagawa‐ken  9,049,500  12,366.7 14 7 3,792,645  1,847,908Miyagi‐ken  2,347,975  14,810.5 16.8 8.4 984,036  479,457Saitama‐ken  7,194,957  27,996.2 31.8 16 3,015,407  1,469,210Tochigi‐ken  2,007,014  13,316.2 15.1 7.6 841,140  409,832Tokyo‐to  13,161,751  55,389.9 62.9 31.6 5,516,090  2,687,630Yamagata‐ken  1,168,789  276.5 0.3 0.2 489,839  238,667Total  48,152,892  620,079.0 703.7 353.5 20,180,877  9,832,821

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Figure A7: Hourly dose rates from MEXT were used to calculate an effective collective dose over the population for radiation exposure during the first weeks of the accident. Japan prefecture (Ken and To) boundary polygon data were obtained from Harvard University.54 There are several factors that make our current estimate of collective effective dose from the Fukushima accident highly uncertain. First, we did not include a sheltering factor. Staying indoors will significantly reduce a person’s dose from ionizing radiation in the environment, which is the principal of the Cold War fallout shelter. Some measurements published by the Japanese government illustrate this fact. On March 16th at 8:16 AM

54 http://www.fas.harvard.edu/~chgis/japan/datasets.html: citation for original data given as the United Nations Environment Programme (UNEP).

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local time, at a point 60 kilometers northwest of the Fukushima Daiichi plant, radiation readings were recorded as 18.0 micro-sieverts per hour outdoors and 1.5 micro-sieverts per hour indoors.55 Secondly, media reports indicate that people have been voluntarily leaving Tokyo, and the earthquake and tsunami have resulted in displaced persons in some of these prefectures. The 2010 Japanese census data does not likely represent the actual populations in these prefectures during the radiation exposures. Factors that could contribute to an increase in the collective effective dose over what we have calculated are the contributions of other radiation exposure pathways – ingestion of contaminated water and food, and inhalation of radioactive particles. And as noted above, the analysis does not include complete information for Fukushima and Miyagi Prefectures due to lack of continuous radiation monitoring data available to us at this time. Importantly the accident is still ongoing, so there will be a contribution to the collective effective dose from exposures after May 23, 2011. Finally, these calculations are for a single value of dose rate across an entire prefecture – weather, topography and other factors will likely have produced areas with greater or lesser dose rates than MEXT reported for the entire prefectures. In the aftermath of the accident at Fukushima Daiichi, extensive dose reconstructions will certainly be undertaken that will include better data on radiation levels, weather, other exposure pathways, and population distribution, as was done for Three-Mile Island and continues today for Chernobyl.

55 MEXT, “Readings at Monitoring Post out of 20 Km Zone of Fukushima Dai-ichi NPP, As of 20:00 March 16, 2011,” at: http://www.mext.go.jp/component/english/__icsFiles/afieldfile/2011/03/20/1303972_1620.pdf.

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Appendix B: NRC’s Post-Fukushima Efforts: Scope Limitations and Secrecy Concerns (Reproduced from the report prepared by the staff of Congressman Edward J. Markey, “Fukushima Fallout, Regulatory Loopholes at U.S. Nuclear Plants,” May 12, 2011, pp. 22-23.)56 On March 23, the NRC voted to require a multi-phase review87 of U.S. nuclear reactor safety in the wake of the Japanese meltdown. The near-term review portion of these efforts called for the establishment of a task force to:

“Evaluate currently available technical and operational information from the events that have occurred at the Fukushima Daiichi nuclear complex in Japan to identify potential or preliminary near term/immediate operational or regulatory issues affecting domestic operating reactors of all designs, including their spent fuel pools, in areas such as protection against earthquake, tsunami, flooding, hurricanes; station blackout and a degraded ability to restore power; severe accident mitigation; emergency preparedness; and combustible gas control.”

The task force was additionally directed to develop near-term recommendations for regulatory and other changes, and is also required to inform its efforts using stakeholder input. The longer (90 day) review is supposed to include more extensive stakeholder input, and the task force was directed in this phase to “evaluate all technical and policy issues related to the event to identify potential research, generic issues, changes to the reactor oversight process, rulemakings, and adjustments to the regulatory framework that should be conducted by NRC.” All of the results of these efforts were supposed to be made public. The NRC recently initiated inspections at each nuclear power plant in order to assess the operational or regulatory issues that may have arisen as a result of the Fukushima meltdown, and that the reports associated with these inspections are supposed to be submitted by May 13. According to reports received by Rep. Markey88, the NRC may be artificially constraining the scope of these investigations and may keep the results of most of these investigations secret. These constraints and limitations include the following:

• The NRC only allowed89 its inspectors 40 hours in which to perform each inspection for nuclear power plants that contain one nuclear reactor. For nuclear power plants with more than one unit, inspectors are being provided with only 50-60 hours total in which to complete their work. By contrast, the Institute of Nuclear Power Operations (INPO) reportedly spent hundreds of hours performing their inspections. • The NRC inspectors were initially told to limit their inspections to the adequacy of safety measures needed to respond to Design Basis Events. This meant that inspectors would be assessing licensees’ ability to withstand and respond only to

56 http://markey.house.gov/docs/05-12-11reportfinalsmall.pdf

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events that have already been contemplated and analyzed by the NRC and for which regulatory requirements have been implemented, but not events such as the ones that occurred in Japan, which were previously believed to be impossible. • After several NRC inspectors complained that it made no sense to limit the scope of the inspections to Design Basis Events, the guidance was changed to enable inspectors to look beyond them, and explicitly includes an examination of the measures that were implemented following the terrorist attacks of September 11, 2011 (some of which could help mitigate against some of the problems that occurred in Japan); however, they were also explicitly told not to record any of their beyond Design Basis observations or findings in documents that would be made public as part of the Commission’s review or public report(s). Instead, these findings would be entered into a private NRC database and kept secret. • Inspectors were also told not to include matters in their reports that licensees had already identified. Since the INPO inspections were concluded before the NRC inspections began, none of the reportedly dozens of issues that were identified by INPO inspectors and reported to licensees will be included in the NRC inspection reports.

Although four of five NRC Commissioners, in response to questions from Congressman Markey, committed to a full investigation of all vulnerabilities and the public release of all non-security-sensitive findings at a May 4, 2011 hearing of the Energy and Commerce Committee90, the limitations imposed on NRC’s inspectors appear to ensure that the full range of vulnerabilities of U.S. nuclear reactors to events that occurred in Japan will not be performed, or reported to the NRC or the public. The NRC needs to ensure that there is a full investigation of such vulnerabilities, and that all non-security sensitive findings and recommendations are made public. __________________ 87 Tasking Memorandum – COMBJ-11-0002 – NRC Actions Following The Events In Japan. 88 Private correspondence from an individual working inside an operating nuclear power plant obtained by Rep. Markey’s staff 89 See NRC Temporary Instruction 2515/183 Followup To The Fukushima Daiichi Nuclear Station Fuel Damage Event. 90 Private communications from an individual working inside an operating nuclear power plant obtained after the May 4 hearing do not indicate that any changes to these inspections have occurred.

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Appendix C: Need for an Objective Independent Technical Review of the Lessons from Fukushima. Since it was created out of the old Atomic Energy Commission (AEC) in 1974, the NRC staff, like the previous AEC staff, has been prone to capture by the industry it regulates. It is also equally true that the NRC staff is largely comprised of highly professional dedicated public servants. Moreover, no President has been willing to appoint, and no Senate willing to confirm, NRC commissioners without ensuring that the majority of commissioners are strongly supportive of continued use of nuclear power on terms that are financially agreeable to the licencees. These two factors and pressure from Congress have resulted in the NRC taking actions that have placed the economic interest of the industry ahead of safety, and have over the years stripped public participants in the licensing process of adjudicatory rights they were previously afforded. Former NRC Commissioner Peter A. Bradford has recited a litany of examples of why the NRC and its staff cannot be trusted to conduct an objective review of the lessons from Fukushima:

Immediately after the Sept. 11 attacks, the NRC rushed out a claim that nuclear power plants were designed to withstand such plane crashes. This claim, which had no basis, was later withdrawn. Not withdrawn was a claim made by NRC attorneys a day after the catastrophe, while the ruins of the World Trade Center towers still smoldered, that acts of terrorism against nuclear facilities were too unlikely to require NRC review. In 2002, NRC senior management overrode a staff recommendation that the Davis-Besse plant—located halfway between Detroit and Toledo, Ohio—shut down promptly to check the integrity of its reactor vessel, a feature critical to the safety of the plant. When the plant eventually did shut down, a rust hole as big as a football was discovered in the reactor vessel. The essential cooling water was contained by a thin stainless steel liner that was never designed for that crucial purpose. The NRC’s inspector general concluded that the agency had placed the economic interest of the licensee ahead of its responsibility to protect the public. In 2003, the NRC nominated the official who had overseen the Davis-Besse shutdown delay for the highest possible civil service financial award, a 35 percent salary bonus — or about $40,000. The NRC inspector general concluded that the same official had, during the time covered by the salary award, knowingly inserted a false statement into a letter sent by the NRC chair to the Union of Concerned Scientists. When President George W. Bush appointed Gregory Jaczko to the NRC in 2004, he and Congress insisted that Jaczko not participate for a substantial period in matters related to the potential Yucca Mountain waste repository since Jaczko’s previous employer, Sen. Harry Reid of Nevada, opposed the project. When President Bush subsequently named Dale Klein to chair

50

the agency, no similar requirement was imposed despite the fact that Klein had been paid to appear in an industry advertising campaign attesting to the suitability of Yucca Mountain to house the nation’s nuclear wastes. (Obama recently transferred the chairmanship from Klein to Jaczko). On a 2004 trip to China to support the sale of Westinghouse reactors, NRC chair Nils Diaz publicly assured the Chinese that the Westinghouse design would soon be approved by his agency. Diaz was supposed to be keeping an open mind about the Westinghouse design pending the staff review. Such a statement by the head of the NRC can only have discouraged any staff reviewer who might have been considering raising a safety concern. Former Sen. Pete Domenici of New Mexico, then chair of the subcommittee with jurisdiction over the NRC, claimed in his 2004 book, “A Brighter Tomorrow: Fulfilling the Promise of Nuclear Energy,” that he had compelled the NRC to reverse its “adversarial attitude” toward the nuclear industry by threatening to cut its budget by one-third during a 1998 meeting with the chair. This sad story of congressional bullying and subsequent regulatory acquiescence reflects badly on overseer and regulator alike. In recent years, the NRC has eviscerated the structure for resolving public safety concerns the agency previously had observed for 40 years. To give one of many examples, lawyers can no longer cross-examine witnesses but must submit their questions to the licensing board chair, who decides whether to ask them. Since these public hearings have never been a major source of licensing cost or delay (and have uncovered serious safety concerns), such measures can only be intended to spare the industry and the NRC from the embarrassment and inconvenience that can come from active public involvement. Other examples abound. They are not offset by any episodes of overreaching on behalf of the general public. 57

57 Peter A. Bradford, “Nuclear agency needs independent appointees,” Atlanta Journal Constitution, Opinion, September 7, 2009: http://www.beyondnuclear.org/storage/documents/Bradford_NRC_AJC_Sep1709.pdf; See also, Bradford, Federal of America Scientists (FAS) website, accessed May 18, 2011. http://www.fas.org/pubs/pir/oped/dem_nuclear_energy_policy.html

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Appendix D: NRDC’s Letter to President Obama on the Fukushima Daiichi Nuclear Accident Calling for an Independent Review.

52

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