LTC 148-2011 Letter from Mayor Stoddard MIAM l -
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OFFICE OF THE CITY MANAGER
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NO. L. TC # 1 148 - 2011 - - i LETTER TO CO MMISSIO _
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TO: May r Ma ' Herrera Bower and Members of the - City Commission
FROM: J ge Gonzalez, City nag 'r
DATE: June 14, 2011 }
SUBJECT: Letter From Mayor Stoddard, City Of South Miami, Regarding Turkey
Point Nuclear Power Plant
At the request of -South Miami Mayor Phillip K. Stoddard, PhD, the attached letter is.
transmitted for your perusal
JMG /RE
C: Duncan Ballantyne, Assistant City_ Manager, Hilda Fernandez, Assistant City Manager,
Jorge Assistant City Manager, Dolores Mejia, Special Projects Administrator,
FACLER\CLERTORMS\2011 Mayor Stoddard.Itc.doc.
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C�ty_ofS1
Philip K. Stoddard, PhD 6130 Sunset Drive
Mayor South Miami, FL 33143 -5093
Tel: 305- 668 -2484 Cell': 305- 342 -0161 • Fax:, 305- 663 -6348
Email: mayorstoddard@gmail.com
10 June 2011
To Miami -Dade County Elected Officials:,
We received a letter from Mr. Curtis Somerhoff, Director.of Miami Dade County's"
Department of Emergency Management, dated 9 May 2011, explaining the County's
radiological emergency. plan. I -go through his letter below and explain why his
explanations do not assuage my grave concerns about the County's preparation for
radiological emergencies at Turkey Point.
Mr. Somerhoff wrote:
Federal regulations have established '. two emergency planning zones around
nuclear plants: the plume exposure pathway (with a radius of about 10 miles from
the reactor site) and the ingestion exposure pathway (with a radius l of about 50,
miles from the reactor site)
In the significant radiation releases on record following nuclear accidents, airborne
radiation plumes, at levels considered dangerous, have not stopped 10 miles from the
reactor site, not at Chelyabinsk, Seversk, Chernobyl, Three Mile Island, or Fukushima:
Our government evacuated "American citizens 20 miles out from Three Mile Island and
50 miles out from Fukushima. The Japanese government is now evacuating people from
titate' Village; 25 miles from the Fukushima. ' Transposed to Miami, that would be the '
distance from Turkey Point to Miami International Airport, an area with over a million
A inhabitants. Although the NRC statutes only require local agencies to prepare evacuation
plans for a 10 mile emergency planning zone (EPZ), experience shows this radius is
inadequate.
The ingestion exposure pathway (with a radius of about 50 miles) includes all of
Miami -Dade County, and Parts of Broward, Monroe, and Collier Counties,�as well
as adjacent coastal waters.
Food and water obtained within 50 miles of Turkey Point would be off limits for human
consumption. In other words, the entire Miami -Dade agricultural industry, the Biscayne
Bay and Florida Bay fisheries and seafood industry, and the. Everglades water supply
could be contaminated beyond use. What would we drink, cook with, and wash our
dishes and ourselves in if not the water?
Protective measures range from sheltering and evacuation options for areas
close to the nuclear plant.:.
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According to FPL's evacuation study, the. 10 -mile EPZ around Turkey Point is home to
187,374 residents and 19,055 transients, 206,429 people in all. Miami =Dade. County has
nuclear, emergency shelter capacity for 60,769 evacuees, just under a third of the EPZ
population. What happens to the other 145,660 people, directed to show up at the
Tamiami' Park Emergency Reception Center (ERC), with their pets, seeking direction to
safe radiation; shelters? The ETE study found that 30% of evacuees would bring their
pets a -long, but only two shelters accept pets, and only if they are pre- registered.
And what happens if the plume extends up into the shelter zone, or even to Tamiami Park
contaminating the ERC itself?
Multiple evacuation scenarios are considered so evacuation decision - makers
have detailed time estimates that take into - account such vagaries as shadow
evacuations within and outside the emergency planning zone transient
population behavior and weather impacts._
Let.us consider these "shadow evacuations ", the propensity of people outside an EPZ to
self- evacuate without official instruction to do. so. The County's radiological emergency
evacuations plan is based on an 'Evacuation Time Estimate (ETE). study preparedby
FPL's consultants. The ETE study considered the effects on traffic that 60 % of the .
people in the shadow region evacuated. Unfortunately they defined the shadow region to
only include living outside the 10 -mile EPZ but south of,Coral Reef,Drive (SW
- 152 St), just 1.3 miles from Turkey Point. Based on what evidence do. County emergency
planners believe that people who live north of Coral Reef Drive would not self- evacuate?
Following every nuclear disaster, the suckers who followed official directions and stayed
behind: were told after the fact "Oh sorry the radiation your area received was higher
than we realized at the time. " Everybody knows that now. May I suggest that Cora_ 1
Reef Drive was an arbitrary boundary, selected by the consultants to keep the total
number of evacuees in a logistically manageable range, but with no scientific basis in the
history of nuclear accidents or the published studies of self- evacuation behavior
following radiological releases. ,A more extensive shadow evacuation'than planned.(i.e.,
people north of SW 152 St) totally invalidates the evacuation time estimates.
People who cannot evacuate because of outside conditions (e.g., traffic jams, radiation
clouds, lack of shelter space).will be told to stay inside with the windows closed, a
practice called, "in-place sheltering ". I think it's fair to assume that we'd also be without
power following a. nuclear power plant accident, so no air conditioning, and the tap water
should be considered unfit to drink for 50 miles. This scenario is a formula for
widespread heat shock.as happened in New Orleans after Katrina.
But the County's in -place sheltering plan has other problems. According to the EPA,
masonry houses such as we have in South Florida provide only a 40% reduction in
radiation exposure in a radiological emergency. Spending 24 hours in our houses during
a radiation release would give us the same radiation exposure as standing in our front
yards for 14 hours.
Our experience with hurricane threats demonstrates our ability to manage large-
scale evacuations and sheltering operations.
Prior to hurricane County emergency planners have over a week of warning, and days of
television coverage in which to provide residents with detailed instructions: We get no
warning prior to a radiological emergency, our residents have never practiced a
radiological evacuation, people are truly terrified of invisible threats like radiation, and
even scientists cannot yet agree about the risks of low radiological exposure With the
nuclear plants down and Turkey Point in a haze of radiation, we'll have no power and
probably no television. The sirens'and the odd radio may be the residents' only warning.
of an invisible threat. My point is that experience with hurricanes should not leave us
over - confident of our ability to manage a radiological emergency.
Miami '-Dade maintains a robust radiological emergency training and exercise
program-. Responders tasked in the plan receive recurring radiological response-
training and are evaluated by the Federal Emergency Management Agency
(FEMA) during regular drills and exercises.
Indeed, the Miami -Dade County Radiological Emergency Preparedness Plan stated the .
following` in 2009:
Organizations that operate rotary wing aircraft that could be tasked to support
response or recovery operations in Miami -Dade include but are not limited to:
1. Miami -Dade Fire Rescue Department
2. Miami -Dade Police Department
3. Miami -Dade. Public Works Department
4. US Immigration & Customs Inspections
5. US Coast Guard. .
6.:City of Miami Police Department
But here's what the US Coast Guard wrote to FPL the year before. in 2,008:
This letter provides- current resource and support capabilities for Coast Guard
assets located in the vicinity of the Florida City Turkey Point-Nuclear Plant.
-Please note that any emergency assistance that the Coast Guard may provide
would be limited by the fact that Coast- Guard crews are not equipped or
trained for radiological response, and thus,- cannot be exposed to radiological
contamination. Coast Guard assets will be restricted to activities and geographic
locations that are air monitored for radioactive fallout and are certified to be safe
Without protective clothing or equipment. Consequently, the Coast Guard is
unable to act as the primary responder for nuclear power plant disasters.
One might ask how carefully the County discussed its radiological plan with the US
Coast Guard, or'the other five agencies on that list.
Mr. Somerhoff s statement about delivery of potassium iodide (KI) excuses the state's
policy not to support proactive KI. distribution plans:
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Ample quantities of Potassium Iodide .(KI) are stocks locally and available for
distribution at the Emergency Reception Center. Since KI only protects.one
organ from only one time of radiation, and does not prevent other radiation
. doses, the focus of the plan is.on moving people out of harm's way.
I find both his statement and plan for KI distribution to be irresponsible. While
radioactive cesium, strontium, and xenon are certainly problematic .in a radiological,
release, radioiodines (e.g., I131) are the most abundant radioisotopes released, and are
particularly dangerous for children because .they concentrate in the thyroid and focus
what may be written off as low whole -body dose ( "no more radiation than a few chest X-
rays " ), onto a much smaller target organ. Here I quote from the document World Health
Organization Guidelines for Iodine Prophylaxis Following Nuclear Accidents:
To 'obtain full effectiveness of stable iodine for thyroidal blocking requires that it
be administered shortly before exposure or as soon after as possible:
The County stocks KI for distribution the Tamiami Park ERC. That fact makes it
difficult or impossible to provide KI prophylaxis to children.and pregnant women
downwind of a nuclear accident before they are exposed to airborne radioiodines:
According to the WHO report, taking KI nine hours after initial exposure reduces its
efficacy by 50 %. How long would it take to get KI into circulation in 95% of the
affected population? In North Carolina the public utilities pre - distribute KI to residents
to avoid the obvious distribution problem during and after an emergency.
In none of the local planning documents I have read has anyone convinced me it would
be possible to quickly screen 200,000+ people for radiation exposure at the County's sole
ERC, located at Tamiami Park. Nor is it clear whether emergency managers can
realistically get all the cars through the site- in a timely manner. The Youth Fair at
Tamiami Park gets less than 100,000 attendees at� peak, yet when 'l tried to get my
daughter to the fair one night last spring we found ourselves mired in a 4 square. mile
traffic jam; she got out' and walked the last half mile.
When Mr. Somerhoff wrote that the County has "ample'KI" on hand, I am wondering
how many doses of KI that includes. The disparity in shelter spaces vs. EPZ population
also makes me question whether the County stocks enough doses for the population that
could be exposed (all those under the age of 40), and enough stocks for the next few
weeks or months as proved necessary in neighboring Poland following the Chernobyl
disaster in Ukraine. Likewise I wonder whether the County maintains stocks of KI in
syrup form suitable for children.' Children, as we .know, are critically vulnerable to I131.
exposure because their thyroid glands are small -and their metabolisms are high.
Then Mr. Somerhoff downplayed the human risks from nuclear accidents.
From a risk standpoint, the chance of being seriously injured, permanently
disabled or killed in.an auto accident far exceeds the chance of being injured,
permanently disabled or killed as a result of a nuclear plant accident.
I take it that his point is we should keep things in perspective and not worry too much
about mortality from nuclear accidents. However physicians and scientists recognize that
a nuclear accident entails far broader epidemiological risks than just acute exposure
leading to rapid death. The medical profession has known for over 50 years that genetic
damage from radiological exposure may not appear for years or. even generations
(Powell, 1957, Am J Public Health).
Mr.-Somerhoff'concluded his letter with this confusing statement:
It is my hope the tragic effects in Japan will lead to the discussions necessary to
match the actual threat from nuclear power to the perceived threat.
First he reminds us of Japan where three of Fukushima's nuclear plants experienced
reactor core meltdowns, and loss of cooling at spent fuel pools exposed fuel rods causing
hydrogen explosions, a brief criticality, and massive release of nuclear. contamination.
Then he implies that the actual threat of nuclear power is Jess than the perceived threat.
Scientists believe that the actual threat in South Florida is significantly greater than has
been.broadly perceived. A threat is the product of the probability of an event and the
consequences of an event: on both� counts, .the actual threat, is greater than most people
realize.
First, consider the probability of a radiological accident at Turkey .Point. FPL has
repeatedly stated that Turkey .Point withstood the full impact of Andrew. It did not.
Hurricane Andrew passed to the north of Turkey Point, dealing it the clean side of the
storm and only a 5.5. foot storm surge. Even so, the reactors were down for 5 days,
cooled by diesel generators. Had Hurricane Andrew come ashore South of Turkey Point,
in Card Sound for example, the 17 foot surge it delivered to what is now Cutler Bay .
would have been directed at the Turkey Point reactor site. FPL has repeatedly stated that
TPN 3 & 4 are situated 20 feet above sea level, but UDAR -based elevation maps
provided by Dr. Dean Whitman at FIU show'the on which the two reactors sit is
between l l to 16 feet, with the surface around .the reactor buildings at 15 to 16 feet.
'Reviewing the elevation data, a scientist in this group stated:
There are areas right nearby which are lower including the generators and other
major electrical equipment on the west side which are around 4I feet where the
outlet for cooling water is located. A 16 foot surge with waves on top of that
would inundate 80 -95 percent of the property and damage much of the equipment
located outside.:
These generators and cooling pumps are all- critical for keeping two reactor cores and 2.4
-million, pounds of spent fuel from overheating as happened in Fukushima. NOAA has
recorded lesser storms over that deadly track on two. occasions'. It's just a matter of time.
Second, consider the consequences: I should like you to close your eyes. and remember
what South Dade was, like after Hurricane Andrew. Now, imagine it with oxidizing fuel
rods.
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Our experience with hurricanes has given us incentive to invest in emergency training
and infrastructure. That is the only good news. Local hurricane
preparedness plans are
predicated on our ability to predict storms far before they happen. Nobody has ever
predicted a nuclear accident before it happened. South Florida's emergency planners,
managers, and.responders have no experience coping with actual radiological release,
especially following a monster hurricane, which is when a nuclear is most likely
to occur in South Florida.
When FPL planned the existing reactors at Turkey .Point in the 1960s, Miami was a small
city and South Dade. was a sparsely populated agricultural region. A large . Y P ypo population has
g g� g p
moved in since then, a population too large to evacuate effectively, FPL's ETE study
notwithstanding.. If anything, Mr. Somerhoff s letter details`the inadequacy, of our
emergency preparedness. We have no plan for evacuating large swaths of South
Florida's population from should radiation streak no 50 miles. We have no viable.
mechanism in place to get KI into the mouths of children and pregnant women before
they are exposed to radioiodines. Reliance on a single Emergency Reception Center for
the entire county is ludicrous. People within 10 miles 'of Turkey Point have received
literature but those, I've spoken to have only have limited understanding of the
radiological emergency plans that they've never practiced. The rest of the County's
population seems to have been left out of the planning process altogether.
Last autumn, I protested these inadequacies to the Atomic Safety and Licensing Board of
the NRC. Here's part of their response:
FEMA sent a letter to the NRC indicating that, based on' its "thorough review,"
FPL's emergency evacuation plans are adequate, and there Reasonable
Assurance that the' plans can'.be implemented with no corrections needed.
This would be the same FEMA that approved New Orleans emergency plans prior to
Hurricane Katrina.
Considering the dire circumstances that we have in New Orleans, virtually .
a city that has been destroyed, things are going relatively well.
FEMA Director Michael Brown, Sept. 1, 2005
FEMA has not been very'good at imagining what hurricane driven water can do to levies
or, apparently, to nuclear power plants.
My city, South Miami, is situated 17 miles'' north of Turkey Point, seven miles .outside the
planned evacuation zone. The only consideration we receive in the County's radiological .
emergency plan is that we live in the "ingestion exposure pathway" so in a' radiological
emergency we will "be told not to consume our homegrown fruits, and vegetables:
FEMA's stamp of approval clearly doesn't protect our own families or the residents that
we, were elected or appointed to serve, from the lack of realistic preparation here in
Miami -Dade County. We deserve better consideration.
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Sincerely,
Philip K. Stoddard, Ph.D.
Mayor