Emergency planning for nuclear power plants has greatly improved since the accident at Three Mile Island in 1979. The nuclear industry is now better prepared than any other to cope with a major accident. Nonetheless, following Chernobyl there have been calls for wider planning zones, and some state and local governments have blocked licensing by refusing to participate in offsite planning. Controversy rages over subsequent attempts by the feder- al government and industry to resolve the current impasse by shrinking the planning zones and restricting local Input in the licensing process. Current regulations are also criticized for failing to take cognizance of the extensive research on human behaviour during emergencies.
The authors are at the Center for Tech- nology, Environment, and Development, Clark University, Worcester, MA 01610, USA.
US Congress, House, A bill to establish an emergency response program within the Nuclear Regulatory Commission, HR 1570, 11 March 1987; US Congress, House, Committee on Energy and Com- merce, Subcommittee on Energy Con- servation and Power, Hearings on Emergency Planning at Seabrook Nuclear Power Plant, 99th Congress, 2nd session, 18 November 1987. Steven Ebbin and Ralph Kasper, Citizen G~OUDS and the Nuclear Power Con- troveisy, MIT Press, Cambridge, MA, USA. 1974: and Donald W. Stever. Sea- brook and the Nuclear Regulatory Com- mission: the Licensing of a Nuclear Power P/ant, University Press of New England, Hanover, NH, USA, 1980.
Emergency planning and nuclear power
Looking to the next accident
Dominic Golding and Roger E. Kasperson
In the wake of the Three Mile Island and Chernobyl accidents, emergency planning for reactor -accidents has become the 1980s battleground for nuclear power. Approval of emergency plans for the Shoreham and Seabrook nuclear plants in the USA has sparked federal-local conflicts over control of this technology and the assurance of safety. Protagonists have called, variously, for enlarging emergency planning zones to 20 miles, shrinking them to two or three miles, allowing plant operators to substitute for state and local participation in off-site emergency responses, or restricting the ability of states and localities to monitor plant conditions. Sometimes these arguments are framed in terms of a technical rationale (eg accident source terms will be smaller than earlier anticipations); other times the rationale is overtly political (the Nuclear Regulatory Commission did not expect states and localities to use plan approval as a de facto means to veto nuclear plant licences).
Why is emergency planning so contentious, the debates increasingly shrill? The overriding issue is that emergency planning is the access point at which nuclear safety policy generally, and the siting of plants specifically, can be challenged. The licensing of plants, including environmental impact assessments, have afforded few opportunities for critics or local officials to raise basic safety questions.2 However, especially in the post-Chernobyl period, substantive issues in emergency preparedness are also involved. After eight years of regulation, large investments in communication systems, studies of transportation needs and estimates of evacuation times, computer models of plume migration and dose distribution, and hundreds of exercises and drills, what have the efforts wrought? When the next serious accident occurs, will the myriad problems so evident at Three Mile Island in 1979 be overcome?
This article assesses the progress in emergency planning over the past two decades, with particular attention to major problems or uncertain- ties that remain unresolved. This analysis, it should be noted, aims to be selective rather than comprehensive in its treatment of potential problems. The objectives are:
0264-8377/88/01019-18$03.00 0 1988 Butterworth & Co (Publishers) Ltd 19
Emergency planning and nuclear power
3John G. Kemeny, Report of the Presi- dents Commission on the Accident at Three Mile /s/and, US Government Print- ing Office, Washington, DC, USA, 1979; and FEMA, Report to the President: Sfate Radiological Planning and Preparedness in Support of Commercial Nuclear Power P/ants, Federal Emergency Management Agency, Washington, DC, USA, 1980, l-2. 4FEMA, op cif, Ref 3, l-4; and AIF (Atomic Industrial Forum), Background Informa- tion, Atomic Industrial Forum, Bethesda, MD, USA, 1986. FEMA, op tit, Ref 3, l-4.
0 to characterize the major developments that have occurred in emergency preparedness for nuclear plants;
0 to identify and evaluate several particularly problematic uncertain- ties that remain in assuring timely and effective response to nuclear plant accidents;
0 to indicate needed developments to fill gaps in scientific knowledge and policy requirements.
To begin with the development of emergency planning and the existing regulatory structure of planning will be briefly reviewed.
The history of emergency planning in the US
Utilities and government have engaged in a substantial effort to upgrade emergency planning around nuclear power reactors (see Table 1). Consequently, preparedness is clearly improved over that existing at the time of the accident at Three Mile Island in 1979, although the extent of the improvement remains unclear. The nuclear industry is, however, far better prepared to cope with a major emergency than most other hazardous industries in the US. Nonetheless, while vast improvements have been made (most notably in communication systems). a number of problems and uncertainties remain.
Prior to 1979 the utilities and government agencies accorded low priority to emergency planning. Severe accidents were deemed extreme- ly remote because of the industrys defence-in-depth strategy of design, involving multiple barriers and redundant safety systems. In the unlikely event of a serious accident, off-site releases would be minimal if no? negligible. Emergency planning and preparedness were rudimentary and confined to a small area around the plant.
In 1970 the Atomic Energy Commission (AEC) issued the first regulations for emergency planning that required licencees to develop only on-site emergency plans. In 1973 the Office of Emergency Preparedness (OEP) directed the AEC to provide planning assistance to state and local governments in developing off-site plans. The AEC, therefore, implemented a non-statutory programme of assistance based on the planning document, Guide and checklist for development and evaluation of state and local government radiological emergency response plans in support of fixed nuclear facilities. An interim version of this document was published in November 1973 (WASH-1293), and a revised version in December 1974 (WASH-1293, Rev 1). The purpose of the Guide and checklist was to provide guidance to state and local
Table 1. Chronology of federal regulations.
AEC issues first rules requiring dlscusslon of on-site emergency plans AEC issues WASH-1293 giving guidance to state and local governments in preparahon of non-mandatory off-site plans for the LPZs NRC reissues WASH-1293 as NUREG 751111 NRC supplements NUREG 751111 with 70 essential elements necessary for NRC concurrence NUREG-0396 concludes it is necessary to plan for a spectrum of accidents beyond DBAs, and recommends abandoning the concept of LPZs in favour of two EPZs with radii of 10 and 50 miles The Kemeny Commisslon recommends that FEMA take lead responsibility for emergency planning, and that licensing be conditional on approved off-site plans President Carter embraces these Commission recommendations Federal regulations (10 CFR 50 and Appendix E) are amended accordingly. NUREG-0654 provides criteria for the development, review and approval of off-site plans NRC proposes relaxing the regulabons for state and local government participation in off-site planning
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NRC, Guide and Checklist for Develop- ment and Evaluation of State and Local Government Radiological Emergency Re- sponse Plans in Support of Fixed Nuclear Facilities, NUREG-75/111, Nuclear Reg- ulatory Commission, Washington, DC, USA, 1975. FEMA, op tit, Ref 3, l-5. Susan L. Cutter, Emergency prepared- ness and planning for nuclear power plant accidents, Applied Geography, Vol 4, No 3, 1984, pp 235-245; FEMA, op tit, Ref 3, l-6; and James H. Johnson, Planning for nuclear power plant accidents: some ne- glected spatial and behavioral considera- tions, in F.J. Carlzonetti and B. Solomon, eds, Geographical Dimensions of Energy, D. Reidel, Dordrecht, the Netherlands, 1986, pp 139-154. H.E. Collins, B.K. Grimes and F. Galpin, Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants, NUREG-0396, Nuclear Regulatory Com- mission, Washington, DC, USA, 1978; FEMA, op tit, Ref 3, l-7. Kemeny, op tit, Ref 3, p 76. /bid, p 16. US Congress, House, Committee on Interior and Insular Affairs, Subcommittee on Oversight and Investigations, Hearings on Emergency Preparedness and the Licensing Process for Commercial Nuclear Power Reactors, 98th Congress, 1st ses- sion, Part I, 1983, pp 364-379. 13Sheldon A. Schwartz, Emergency pre- paredness for nuclear power plants in the USA, in Emergency Planning and Pre- paredness for Nuclear Facilities, Interna- tional Atomic Energy Agency, Vienna, Au- stria, 1986, p 78. The major requirements for emergency planning - on- and off-site - are contained in a brief two pages of the NRCs Emergency Planning Rule (10 CFR Part 50.47), and supplemented by Appendix E. Additional criteria for the development, review and approval of emergency plans are contained in NUREG-0654 (NRC/ FEMA, Criteria for Preparation and Evalu- ation of Radiological Emergency Re- sponse Plans and Preparedness in Sup- port of Nuclear Power Plants, NRCFEMA, Washington, DC, USA, 1980). The policy and procedures used by FEMA in review- ing and approving -state and local emergency plans are given in 44 CFR 350. and supplemented by-the memorandum of understanding (MOU) between the NRC and FEMA (FEMA/NRC, Memorandum of understanding between Federal Emergen- cy Manaqement Agencv and Nuclear Req- uiatory Commission, -Federal Register, Vol 50, No 75, 1980 DD 1548515488. %ode of Federal Regulations, 10 CFR 50,47(a)(l).
Emergency planning and nuclear power
governments in preparing off-site plans, and to the AEC and other
federal agencies in reviewing such plans.6 In 1975 the AEC was abolished and the Nuclear Regulatory
Commission (NRC) was designated as the lead agency for emergency planning. The NRC reissued WASH-1293 as NUREG-75/111, and supplemented this in 1977 with a list of 70 essential elements necessary to achieve NRC concurrence or approval. Off-site emergency plans were still non-mandatory and limited to the small area around the plant known as the Low Population Zone (LPZ). By the time of the accident at Three Mile Island only 11 out of 31 states had NRC-approved emergency plans, and TM1 was not one of them.s
Prior to 1979 questions were already being asked about the adequacy of emergency planning. After two years work a joint NRC/EPA task force published its findings as NUREG-0396 in 1978.9 The task force concluded that it is necessary to plan for the consequences of a spectrum of accidents, including worst-case or Class 9 accidents, and that the concept of the LPZ is meaningless for emergency planning. The task force recommended the abandonment of the LPZ concept and adoption of two emergency planning zones (EPZ) with approximate radii of 10 and 50 miles. The lo-mile EPZ would protect against direct exposure to the radioactive plume by evacuating or sheltering the population. The 50-mile EPZ would protect against the consumption of contaminated water and foodstuffs. Following the accident at Three Mile Island, this document and the task force recommendations became the basis for the revised regulations on emergency planning.
The Kemeny Commission report of 1979 reiterated some of the findings and recommendations of the NRC/EPA task force, and also added some of its own. The Commission recommended that the Federal Emergency Management Agency (FEMA) should have lead responsi- bility for off-site emergency planning and that the granting of operating licences by the NRC should be conditional on review and approval of state and local governments plans. Furthermore, the LPZ concept should be abandoned in siting and emergency planning, and emergency planning should consider a variety of potential accidents and protective actions. Such protective actions may range from evacuation of an area near the plant, to the distribution of potassium iodide to protect the thyroid gland from radioactive iodine, to a simple instruction to people several miles from the plant to stay indoors.
President Carter embraced the criticisms and recommendations of the Kemeny Commission in a statement on 7 December 1979.* He began a significant overhaul of emergency planning by delegating lead responsi- bility to FEMA. On 19 December 1979 the NRC published proposed regulations for comment. The final NRC Emergency Planning Rule was published on 19 August 1980 and came into effect on 3 November.
Under the NRCs Emergency Planning Rule (10 CFR 50) no operating license for a nuclear power reactor will be issued unless a finding is made by the NRC that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. In other words an operating licence will be granted only if adequate emergency plans have been developed.
However, one loophole remains that has allowed many plants to
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Emergency planning and nuclear power
/bid, 50.47(c)(l). j7New York Times, 9 June 1983. Nuclear News, Low-power license issued: five percent power reached, Nuclear News, Vol 28, No 10, 1985, p 45. 44 CFR 350.2(g). 44 CFR 350.9. 244 CFR 350.10.
Figure 1. Emergency Planning Zones.
Note: Not drawn to scale. Source: After NRC/FEMA, see text, op tit, Ref 22, p 16.
e variable boundary
22 LAND USE POLICY January 1988
continue to operate in the absence of approved plans. In spite of failure to meet the applicable standards the applicant will have an opportunity to demonstrate to the satisfaction of the Commission that deficiencies in the plans are not significant for the plant in question, that adequate interim compensating actions have been or will be taken promptly, or that there are other compelling reasons to permit plant operation. Hence, the Indian Point power plant in New York was allowed to remain open in 1983 because sufficient progress had been made although the plans had not been formally approved. Also, approved plans are not required for the issuance of loading and/or low power operating licences. Hence the beleaguered Shoreham plant was given a low power licence...