Comments on an article in the LA TIMES titled: Rethinking Security at San Onofre (Oct. 28th, 2001)
To: Editor, Los Angeles Times firstname.lastname@example.org
From: Russell D. Hoffman, Concerned Citizen
Date: October 28th, 2001
Cc: email@example.com, firstname.lastname@example.org, California Senators
Re: Comments on an article in today's LA TIMES titled: "Rethinking Security at San Onofre"
To The Editor:
Did anyone on your staff try "backing out" the numbers presented in Seema Mehta's chilling and yet understated article on safety at San Onofre in today's LA Times (October 28th, 2001, page B-1, shown below)?
A serious accident was said to have a likelihood of one in one billion. Are those odds long enough? Are they accurate enough? Are they the odds of a "worst case scenario" or actually just the odds of the worst, worst, worst-case scenario, when there are a thousand slightly lesser accidents which are in fact, vastly more likely, and which could kill hundreds of thousands of local residents (as well as people in Kiev, Russia, for example, and everywhere else on the globe)?
The "one in one billion" figure is just the longest odds they could come up with. These numbers are meaningless in today's reality. That comforting figure (at least some people find it comforting) of "one in one billion" was contrived, cocky and unrealistic.
It includes certain conditions, such as having a local severe rainstorm and an onshore breeze. In other words it mathematically eliminates other times. Or in the spin of the article and the study, it "assumes that everything that could go wrong does".
There are about 42 days of "measurable rain" in San Diego County each year (source: NOAA). If we assume about 36 of those contain any significant amount of rainfall, that is 36 out of 365 or about 1 in ten days.
So the odds of "1 in a billion" for accidents which include significant local rainfall become odds of 1 in one hundred million for the same accidents, but regardless of rainfall. And of course, a severe rainstorm usually only occurs over a particular location during part of a day, say, a little over two hours -- so cut the odds by 10 again -- now it's one in ten million for the same accident, but regardless of rainfall.
Rainfall only localizes the deaths from the release. On days where there is no local rainfall, the plume will simply take longer to descend and kill other people who are further downwind -- well beyond any evacuation zone, perhaps, and certainly beyond the ten mile evacuation zone the nuclear industry is supposedly prepared for. The deaths which will occur further away from the nuclear power plant will be among a much greater population, so they will be much hard to identify. This is good for the nuclear industry, but of little use to humanity otherwise.
If we also subtract for the onshore/offshore breeze calculation, we can cut the remaining one in ten million figure approximately in half, assuming that about half the time the breeze flows out to sea, and about half the time it flows back again. So the odds of an accident, regardless of these two simple factors, wind and rain, is, based on the Sandia National Laboratories study, now only 1 in 5 million.
One in five million, then, are the odds against a serious accident with significant releases of radiation, but not necessarily during a severe rainstorm and an onshore breeze.
So where does the estimate of the likelihood of a meltdown actually come from? From all the errors and problems they could think of, and the individual "odds" they believe are valid for those errors and problems, and summing the whole thing mathematically, right? But each guess is just that -- a guess. The value is based on thousands of assumptions, made by people with a vested interest.
But that's not all. First, they ELIMINATED entirely, a vast array of accidents which they simply considered "not credible" and so are not included in the overall estimate!
For example, all asteroid impacts are considered "not credible". No nuclear power plant is designed to withstand an asteroid impact, and indeed, the top of the containment dome is the thinnest part, at just three feet-something. Spent Fuel Pools have hardly any covering at all, and take up acres and acres of space in California.
Airplane strikes were obviously not included either, whether caused by terrorism or some other failure of the system. Terrorism with a truck bomb on the highway apparently WAS included, and a small band of terrorists attacking the perimeter WAS included, but a small band of terrorists clearing the way for a truck bomb driven INTO the plant apparently was NOT included.
It also does not include the odds of a terrorist attacking the Spent Fuel Pool or other vital areas of the plant.
Thus, it is all hokey, and so the "one in 5 million" figure itself probably isn't anything close. And "one in a billion" is downright fanciful -- or deceitful.
The Nuclear Regulatory Commission-funded estimates were done in 1982. Since then, San Onofre has seen a rash of accidents, for example, this year alone, two fires and explosions, and several other near-death experiences. Similar plants around the world have shown significant embrittlement of the alloys used in their construction. San Onofre has yet to be checked for these dangerous "circular cracks".
Terrorism was not figured into the calculations. Embrittlement is belittled, if not ignored entirely.
The local population has grown tremendously since the study was done, while at the same time, only a few new highways and lanes have been added. Rush hour, when only about 1/3 or 1/4 of the cars take to the highways, lasts for hours and hours each workday. One traffic accident in the melee to get out could block I-5 completely, eliminating the primary escape route. What are the odds of that?
It is now well known that the official estimates for the dangers of given dose sizes of so-called Low Level Radiation are suspect. If they are off by half, every Environmental Impact Statement is similarly off, every evacuation plan is similarly too slow and too small, every decision not to pass out "KI" should be reassessed, and every cost-benefit analysis ever done is wrong.
But in fact, being off by "only" half would probably be a blessing -- LLR dose estimates could be inaccurate by an order of magnitude or more, and so, LLR might be 10 times worse than the NRC and the nuclear industry tells the public, maybe 100 times worse -- maybe even 1000 times worse (source: Toxics A to Z, Univ. of Calif. Press, 1991). No one knows precisely, because no valid studies have been done (who wants to give plutonium to babies, for instance, to find out their dose level? And how many participants would it take to see what dose will kill 1 in 10,000 people who receive it?) Problems with the current assumptions range from improper or inaccurate dose estimations, to bias in removing or not including victims from the study group.
Here is a URL where numerous vulnerabilities of San Onofre, to terrorism and other problems, are discussed in detail, including a list of "25 simple ways San Onofre can be attacked by terrorists, causing a meltdown and major release of radiation to the environment":
October 28, 2001
RESPONSE TO TERROR
Rethinking Security at San Onofre
Planning: Some of the anti-terror measures at other nuclear plants aren't in effect there. Edison says steps are sufficient; others say more should be done.
By SEEMA MEHTA, TIMES STAFF WRITER
The San Onofre nuclear power plant is one of the most visible--and potentially deadly--targets in Southern California, yet government officials haven't added some of the extra protections put in place at the nation's other nuclear facilities since the Sept. 11 terrorist attacks.
Southern California Edison has stepped up security at its plant south of San Clemente by adding more private, armed security guards. The California Highway Patrol and Coast Guard have beefed up patrols as well, and the plant is at its highest stage of alert.
But measures taken by government agencies don't go as far there as some taken at nuclear plants in the northeastern United States and in Central California. In the Northeast, governors of New York, New Jersey and Massachusetts have called out the National Guard to protect nuclear power facilities in their states. Gov. Gray Davis has taken no similar steps at San Onofre or Diablo Canyon, which sits on California's Central Coast near San Luis Obispo.
After Sept. 11, the local Coast Guard office barred boats from coming within a mile of Diablo Canyon--the state's only other operational nuclear plant. And CHP officers now guard that facility's entrance, where additional vehicle barriers have been erected.
San Onofre, located just south of San Clemente, also sits at the edge of the Pacific Ocean, but Coast Guard officials said there was no need to restrict vessels, which can still come right to shore. Beachgoers still can walk the few hundred yards of sand strip between the plant and San Onofre State Beach, a popular surfing spot.
Edison officials say their increased security is sufficient at San Onofre, which has two working 1,120-megawatt reactors. Moreover, industry officials say the chances of an attack on such a concrete- and steel-reinforced "hardened target" as a nuclear plant are slim. But they concede that the plants weren't built with attacks like those on the Pentagon and the World Trade Center in mind.
"The plant was never designed for the impact from a commercial airplane," said Ray Golden, Edison's spokesman for San Onofre, which is majority-owned and wholly operated by the private utility. "That does not mean we wouldn't withstand it."
A threat earlier this month against the Three Mile Island plant near Harrisburg, Pa., has drawn even more attention to nuclear plant security. While the threat eventually was deemed "noncredible," it caused two nearby airports to temporarily shut down and military aircraft were ordered to patrol the sky above the plant, said Breck Henderson, spokesman for the U.S. Nuclear Regulatory Commission.
Watchdog Group Sees a New Reason to Worry
Nuclear safety activists in California worry about how safe San Onofre is in today's climate.
"The consequences [would be] immense from an attack," said Daniel Hirsch, director of Committee to Bridge the Gap, a nuclear watchdog group based in Los Angeles. Hirsch also is former director of the Adlai Stevenson program on nuclear policy at UC Santa Cruz.
Edison's Golden, however, said nuclear plants are designed and operated with possible terrorist attacks in mind.
Security measures include extensive background checks on employees, restricted areas, intruder-alert systems and detectors for explosives and metal. Containment domes of steel-reinforced concrete as thick as seven feet and design features to protect against earthquakes also would minimize the risk of radiation release.
The plant was designed to withstand truck bombs set off on the nearby San Diego Freeway or efforts of a small group of terrorists trying to enter the plant. After the nuclear accident at Three Mile Island accident in 1979, older plants were retrofitted and new plants coming online, such as San Onofre's units 2 and 3, were required to meet stricter standards to prevent or contain a meltdown.
The Sept. 11 attacks have prompted the NRC to assess what would happen if an airplane crashed into a reactor, Henderson said. But he did not know when that mathematical computer modeling analysis would be completed.
A different study at San Onofre in 1982--the last time such calculations were made--looked at what could happen in a worst-case disaster scenario. If one of the two working reactors failed, it could result in 27,000 deaths within a year of the accident, 18,000 additional long-term deaths from cancer and $186 billion in property damage. The study, by Sandia National Laboratories in New Mexico, was commissioned by the NRC.
In such a scenario, it is assumed that everything that could go wrong does: The reactor would melt down, releasing a large amount of radiation; prevailing winds would carry that radiation to population centers, and there would be a severe rainstorm.
The chance that these things could happen was believed to be one in a billion. An NRC official said at the time the study was released that there was a greater chance of a jumbo jet crashing into the Super Bowl than of a worst-case-scenario meltdown.
These probability calculations, however, never included a terrorist attack on any nuclear reactor, said Mark Cunningham, chief of the risk analysis branch at the NRC. "We cannot exclude the possibility that we could have a fairly significant radiation release from the impact of a large commercial aircraft," he said.
Jocelyn Mitchell, a senior technical advisor with the NRC, said that if the same calculations were done today, the results would probably be similar. But the death and injury toll could be far lower at San Onofre, according to Dana Powers, a senior scientist with Sandia, based on more recent reports of studies at other plants.
Edison's Golden noted that the 19-year-old study assumed "no emergency planning." In an emergency, he said, residents within 10 miles of the plant would be evacuated, which "would dramatically affect those [casualty] numbers."
Since Sept. 11, San Onofre and the nation's other 102 nuclear power plants have been on the highest stage of alert. That means armed security guards greet plant employees and visitors, public access to sensitive areas has been discontinued and technical information has been taken off the plant's Web site.
Though Golden declined to give details, he said there is an increased security presence inside and outside the plant.
Additionally, CHP officers are patrolling the San Diego Freeway more frequently, and rangers for the state Department of Parks and Recreation are patrolling the state park area. The U.S. Coast Guard has stepped up offshore patrols.
Private security workers hired by Edison watch over the coastal property at the entrance, perimeter and from elevated guard towers. Many of the guards are retired police or military officers, Golden said.
The NRC also stages commando-style drills, using a scenario of a small well-armed band of terrorists trying to sabotage critical plant operations. The last five-day drill at San Onofre, in late 2000, produced mixed results. Though no major problems were identified, the drill uncovered two weaknesses that represented a "credible impact on safety," according to the NRC summary of findings. Details of those findings have not been disclosed, however.
Boats Forbidden Near Diablo Canyon
At Diablo Canyon, the CHP and the Coast Guard have added more patrols. Boats are forbidden within one nautical mile of the plant. (A nautical mile is slightly longer than a standard mile.)
Coast Guard Petty Officer Ted Ford in Morro Bay said his supervisors decided to create the restricted area as a precautionary measure after meeting with local, state and federal officials. That office is a branch of the Los Angeles division of the Coast Guard.
San Onofre is under the jurisdiction of the Coast Guard division based in San Diego.
Coast Guard Lt. j.g. Chris Lee of the San Diego base said that while his agency has stepped up patrols, it opted against putting a security zone in place. "Based on the assessment that we've done, it didn't appear to be necessary," he said, declining to elaborate.
Coast Guard Lt. Ben Benson, also based in San Diego, said San Onofre is one of several sites, including Navy ships in the harbor and bridges and dams on the Colorado River, that are under close scrutiny by his office.
Edison's Golden said San Onofre's private guards constantly monitor the air and the water. The NRC told plant officials that if guards see a suspicious plane, they should look at the tail markings and call the Federal Aviation Administration, which has placed no restrictions on flying above nuclear power plants.
But Steven Dolley, research director of the Nuclear Control Institute, questioned the usefulness of that. "If you can see the number on the tail fin, you have half a second left. . . . That's obviously not sufficient."
His Washington, D.C.-based nonprofit group, which advocates for increased nuclear safety, wants the government to install antiaircraft weaponry at nuclear power plants, including San Onofre.
"No one can predict these attacks," Dolley said. "That's become apparent. If they can't predict them, we need to seriously consider the deployment of antiaircraft forces."
Asked whether the NRC was considering such measures, Henderson said, "We're reconsidering our security issues from top to bottom. That's all I have to say."
Dolley's group also has called on Gov. Davis to deploy the National Guard at both California nuclear power plants, noting the actions of East Coast governors.
A Davis spokesman would say only that the governor has not ordered the National Guard to protect nuclear sites, but would not discuss whether he was considering such measures.
Rep. Darrell E. Issa (R-Vista), whose district includes San Onofre, said deploying the National Guard would be an extreme waste of money, particularly since thousands of Marines are posted at nearby Camp Pendleton.
In fact, the plant is bordered by the U.S. Marine base. Lt. Mamie Ward said the Marines are not involved in day-to-day security issues at the plant, but would be available if called. "They have their own security," she said of the Edison plant.
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