Re: Emergency Planning Exercises -Reply

[RONALD GOODWIN <RONALD_GOODWIN@health.ohio.gov>]

     Jim and Sandy are exactly right.  I was fortunate enough to have 
     worked at Three Mile Island, with George Giangi and some excellent 
     contractors from Energy Incorporated (Idaho Falls, ID) developing the 
     very first emergency plan and implementing procedures based on NUREG 
     0654/FEMA REP -1.  When we finished writing the plan, and about 60 
     procedures, we exercised them.  I wish we had exorcised them.  We 
     found that to make anything work, to meet the offsite objectives, to 
     get the release limits up to the point that offsite monitoring teams 
     had anything to do, except pick their noses and b###@ we had to make 
     some of the most outlandish "failures" that could ever be seen.  Since 
     then, I have written and carried out exercise scenarios at Southern 
     California Edison (SONGS), Louisiana Power & Light (Waterford III), 
     Northern States Power (Monti and Prairie Island), South Texas Project 
     (STPEGS), Grand Gulf, and a few others I can not even remember.  To 
     reach these releases, we have failed containment air locks, failed 
     open target rock valves and supplemental closure valves, blown 
     containment reliefs due to stuck PORVS, and every other STUPID MEANS 
     POSSIBLE sometimes exceeding even the imagination of some game writer 
     for NINTENDO, JUST TO MEET THE EXERCISE SCENARIOS.  Realism be damned. 
      We have failed valves that could be closed by hand in minutes and had 
     the poor maintenance people stymied on why they could not close a 
     valve that they tested or stroked every month or so.  However, in all 
     this, the media, just as they did today when Palo Verde finally got 
     that fuel bundle unstuck reported "No radioactivity was released from 
     the plant".  If we, the hp society do not begin to stand up, and tell 
     the media, and the feds, and the locals that the scenarios we paint, 
     CAN NOT happen under normal operations (remember everyone, Chernobyl 
     is in Mother Russia, not Wisconsin (sorry about that Wisconsin, but I 
     love the name of your state)) we will continue to be guilty of 
     harboring and even enhancing the dangerous state of nuclear power.  
     AND WE WILL NEVER GET A LICENSE TO BUILD ANOTHER POWER PLANT IN THIS 
     OR ANY OTHER CENTURY!
     
     Sorry, did not mean to preach to the choir, but after 16 years (yes we 
     wrote the first scenario in 1980) of writing scenarios and trying to 
     get the regulators to understand realism, I am about to give up and 
     move to a shack in Montana (I understand there may be one for lease 
     real soon!)  (Ultimately big grin ! ! !)  Thanks for providing this 
     method of speaking out.  I hope that just one radsafer that reads this 
     (beside Jim and Sandy) knows where I am coming from, and maybe have 
     the ear of a regulator that can make the appropriate changes.
     
     To all who took the time to read all of this, best regards, and I bid 
     you peace!
     
     Ron Goodwin
     Senior Health Physicist
     Ohio Department of Health
     Bureau of Radiation Protection


______________________________ Reply Separator _________________________________
Subject: Emergency Planning Exercises  -Reply
Author:  radsafe@romulus.ehs.uiuc.edu at Internet
Date:    4/8/96 11:02 AM


Sandy --
     
As a representative of one of those "governmental agencies" 
that you spoke of, I couldn't agree with you more. Several 
years ago, when FEMA first proposed that all radiological 
exercises had to result in off-site doses of 1 rem whole body
/ 5 rem thyroid or greater in order to drive offsite protective 
actions, we -- along with several of our colleagues, raised 
holy hell. We pointed out that this requirement, along with 
other "guidance" provided by FEMA, reinforces in the minds
of many otherwise reasonable people that every time 
something abnormal occurs at a nuclear plant (which may or
may not result in the declaration of a Notification of Unusual 
Event) that the event will escalate, eventually resulting in 
massive releases of radioactive material and requiring 
protective actions for the general public. Empirical evidence, 
however, is contrary to the above.
     
I have long personally been an advocate of a concept known 
as "exercise realism" -- in which the event may or may not 
progress through all the emergency classes -- which may or 
may not result in core damage -- which may or may not
result in releases of radioactive materials to the environment 
-- and which may or may not require offsite protective 
actions. We are working with one of our utilities now to set 
up such a "realistic" exercise for the NRC/FEMA "off year" -- 
and the biggest concern is how to adequately demonstrate 
certain portions of the emergency plan -- both onsite and 
offsite.
     
Jim Hardeman, Manager
Environmental Radiation Program
Environmental Protection Division
Georgia Department of Natural Resources 
4244 International Parkway, Suite 114 
Atlanta, GA 30354
(404) 362-2675   fax: (404) 362-2653 
Jim_Hardeman@mail.dnr.state.ga.us
     
>>> <sandy_perle@email.fpl.com> 04/08/96 08:37 >>>
     
I'd also like to emphasize a very important point that Regis 
Greenwood made, that to exercise the governmental
agencies we ultimately release more radioactivity from the
plant that is feasibly or realistically possible. This gives the 
false conclusion to the governmental agencies that this is a 
real possibility, which it is not. Worse than that, we have to 
play the game when dealing with the real media,
newspapers, TV and radio individuals that are in the 
Emergency news Center, and they go away believing that the
scenario and results of radioactivity releases is in fact real. 
THAT is the worse problem with emergency exercises. It is
an educational issue that needs to be continually stressed
with the media prior to and following a drill. Unfortunately, the 
media is constantly changing, therefore the educational
needs must be met on a continual basis.