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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 federal 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 uncertainties 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


3John G. Kemeny, Report of the Presi- dent’s 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 uncertainties 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 extremely remote because of the industry’s 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.

1970

1973

1975 1977

1978

1979

1980

1987

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

20 LAND USE POLICY January 1988

‘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 preparedness 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 considerations’, 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 session, Part I, 1983, pp 364-379. 13Sheldon A. Schwartz, ‘Emergency preparedness 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 NRC’s 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 reviewing 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).


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 responsibility 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 responsibility 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. ”

Current regulations14

Under the NRC’s 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

LAND USE POLICY January 1988 21


“/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. 2’44 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


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 in July 1985 in the absence of approved plans.‘s

Off-site state and local government plans must designate and extend over the emergency planning zones (EPZs) which are ‘generic area[s] around a commercial nuclear facility used to assist in off-site emergency planning and the development of a significant response base’.” Ordinarily, EPZs of about 10 and 50 miles are delineated for the inhalation and ingestion exposure pathways respectively, but the majority of planning efforts and requirements focus on the lo-mile zone (Figure 1). To gain FEMA approval the plans must comply with the 16 planning standards given in the NRC Emergency Planning Rule. In addition, the state and local governments must conduct a joint exercise successfully demonstrating their ability to implement the plan,20 and there must have been at least one public meeting to discuss the plans.21

As a result of these regulations the typical emergency plans for one reactor may occupy many feet of shelf-space and comprise a bewildering mountain of seemingly unintelligible detail - who does what, who contacts whom, when, where and why, etc. Perhaps the best way to indicate how the current regulations operate is to run through a hypothetical accident.

In the event of an accident, the licensee is required to classify the initiating conditions as one of four emergency action levels (EALs). Appendix 1 of NUREG-0654 defines the four emergency action levels

Ingestion EPZ ------\

(50 mile) Direction of f

plume /

Plume EPZ _ -+ \ travel//

(10 mile)

Example responsti d / area f&r plume exposure

k B


(unusual event, alert, site area emergency and general emergency), and describes the kinds of initiating conditions which would necessitate the declaration of a particular EAL. Appendix 1 also describes the appropriate actions to be taken by the licensees and off-site authorities.

The unusual event and alert categories are intended to provide early warning of minor events that could become more serious. Off-site authorities are to be notified and the emergency organization put on standby, but no public notification is required. If the accident is more serious, or escalates from a minor event, then the licensee may declare a site area emergency. This declaration indicates that significant releases are likely or are occurring but that core melting is not expected. The emergency organization should be fully mobilized by activating the licensee’s on-site Technical Support Center (TSC) and near-site Emergency Operations Facility (EOF), and the state and local government Emergency Operations Centers (EOCs). If sheltering near the site is considered necessary, then the public within at least two miles should be notified, and periodic updates should be provided to the public within at least 10 miles. The general emergency indicates actual or imminent core degradation and potential loss of containment. The public within 10 miles should be notified of the emergency status immediately (that is, within 1.5 minutes). Authorities may advise evacuation if necessary and if it can be completed prior to passage of the plume.

In addition to classifying the accident, the licensee is responsible for the rapid and accurate assessment of the magnitude, nature, timing, duration and dispersion of potential releases. The licensee must have adequate methods and equipment for making meteorological measure- ments, remote radiological monitoring, and real-time dose assessment. Based on this information, the licensee makes recommendations for appropriate protective actions. Off-site authorities are often dependent on licensee assessment, and have a limited independent capability (although some states such as Illinois are developing such a capability). Off-site authorities are not bound by licensee recommendations and may conduct their own evaluation of the situation prior to recommend- ing particular protective actions. The choice of protective actions includes sheltering, evacuation and the prophylactic use of potassium iodide (KI). The state authorities ordinarily decide which protective actions to recommend based on the accident assessments and off-site conditions, such as the time of day, weather conditions and so forth. Protective actions may apply to certain subgroups (eg pregnant women and school children) and certain geographical areas (eg downwind sectors). Unlike in the UK, potassium iodide is not stockpiled for public distribution. In the event of an accident it would be available only to

emergency workers and institutional populations that could not easily and quickly be evacuated.22

In the event of an accident, the licensee must notify all the state and local government authorities as appropriate, within 15 minutes.2’

“NRCIFEMA, Criteria for Preparation and Consequently, since the accident at TMI, many plants have installed Eva’uaGOn of radiological Emergency dedicated phone lines and computerized dialling to improve com- Response Plans and Preparedness in Suppo~ of Nuclear Power P/ants, Nuclear munications. State and local officials decide when to inform the public Regulatory Commission/Federal Emerg- but, in the event of a general emergency, the public within the entire ency Management Agency, NUREG-0654, Washington, DC, USA, 1980, p 63.

lo-mile EPZ must be notified immediately.24 The public is alerted to

?O CFR 50.47 Appendix E (b/)(D)(3). tune to their local emergency broadcast system (EBS) by fixed sirens 24NRC/FEMA, op tit, Ref 22, pp 1-16. (distributed within the EPZ on telegraph poles) or mobile sirens carried



on emergency vehicles (‘route alerting’). The EBS carries predetermined messages notifying the public of the accident status and appropriate protective actions. This system is required by regulations to be capable of providing an alert signal and informational or instructional messages throughout the entire lo-mile EPZ within 15 minutes of the decision to notify the public.25 The licensee is responsible for installing, maintaining and testing the prompt alerting system (ie sirens), whereas the off-site authorities retain responsibility for activating the notification system and for the content of the messages.

In addition to the EBS messages, the utility is required to distribute information to the public annually.*’ The utilities use various means, ranging from informational brochures sent out with electricity bills, to calendars, inserts in telephone books and public notices to disseminate this information. These inform the public about facts such as the nature of radiation, alternative protective measures, what to do when sirens are sounded, where to go in the event of an evacuation and what routes to take.

In the event of an evacuation, the public is given specific instructions over the EBS and told to refer also to the previously distributed materials for further information. The majority of the public is expected to evacuate by private car, although special arrangements are made by the off-site authorities for school children and mobility-impaired and institutionalized populations. Reception centres are designated beyond the lo-mile EPZ for temporary relocation of residents (but see the discussion below). Each licensee is required to submit evacuation time estimates for the lo-mile EPZ under a variety of conditions.27

To ensure that the licensee and off-site officials are familiar with their roles and responsibilities, periodic drills and exercises are required.*’ The licensee must conduct on-site exercises annually, and exercises with off-site authorities biennially.*’ Drills are less elaborate affairs than exercises, the former usually testing smaller portions of the licensee’s on-site capabilities. The public is not directly involved in either exercises or drills, although some exercises have involved activating the prompt alert and notification system, and relocation centres.

The geography of emergency planning zones

The size and shape of the area within which planning is conducted depends on the nature and magnitude of the accident for which one is planning. Prior to 1979, emergency planning was concerned with only Design Basis Accidents (DBAs). (DBAs are accidents which the plant is technically built to withstand, without major off-site releases.) Worst- case accidents were considered to be so unlikely as to be incredible. As stated in the first planning guidelines:

The AEC considers that it is reasonable, for purposes of emergency planning relative to nuclear facilities, to prepare for the potential consequences of accidents of severity up to and including the most serious design basis

'"/bid, 3-3; 10 CFR 50.47 Appendix E accident analyzed for siting purposes

W)(D)(3). The AEC recognizes that accidents with more severe potential consequences *?O CFR 50.47 Appendix E (W)(D)(2). 27NRC/FEMA, op tit, Ref 17, Appendix 4.

than design basis accidents can be hypothesized. However, the probability of

**lo CFR 50.47(6)(14). such accidents is exceedingly low. Emergency plans designed to cope with

?O CFR 50.47 Appendix E (W)(F)(2) and design basis accidents would also provide significant protection against more

(3). severe accidents, since such plans provide for all the major elements and

30NRC, op n’t, Ref 6, p 4. functions of emergency preparedness.“”

LAND USE POLICY January 1988

3’Roger J. Keyes and Peter J. Taylor, A Critical Review of Emergency Planning for Reactor Accidents and Spent Fuel Trans- port in the United Kingdom, Political Ecolo- gy Research Group, Oxford, UK, 1984, p 28. 32Collins et al, op tit, Ref 9. 33Kemeny, op tit, Ref 3, p 17. 34Collins et a/, op tit, Ref 9, l-9, italics added. 35tbid, p 5. 36NRC/FEMA, op tit, Ref 22, p 6. 37Collins et al, op cit. Ref 9, p 3. 38Keyes and Taylor, op cit. Ref 31, p 31. 39EPA, Manual of Protective Action Guides and Protective Actions for Nuclear Inci- dents, Environmental Protection Agency, Washington, DC, USA, 1980.


Consequently, emergency planning was given a low priority, minimal planning was undertaken and the rudimentary plans that did exist were

confined to the small area of the low population zone (LPZ). The LPZ concept was used originally in siting decisions but gradually

became adopted as the basis for emergency planning. The size of the LPZ varied according to local conditions and reactor designs, from two to six miles. The boundary of the LPZ was defined as ‘the distance from the reactor which an individual who took no protective actions would have to be situated to limit his radiation dosage, during the entire time it took for the radioactive cloud to pass overhead, to 250 rems to the whole body and 300 rems to the thyroid’.”

In 1978, the joint NRC/EPA task force rejected the LPZ concept for planning, and recommended instead two Emergency Planning Zones (EPZs) of 10 and 50 miles.32 Similarly, the Kemeny Commission pointed out that, while the LPZ was a central concept in siting policy, it had serious shortcomings. Because of the excessively high doses used to calculate the boundary, most LPZs were exceedingly small; so small indeed that they were irrelevant to public protection. Should a severe accident occur, people beyond the LPZ might receive massive and unacceptable doses. The Commission found the entire concept flawed, and recommended that it be abandoned in siting and emergency planning decisions.33

In rejecting the concept of the LPZ, the NRC/EPA task force concluded that planning must address the consequences of a variety of accidents including those more severe than DBAs. Even so, the task force was cautious about seeming to recommend planning for extremely unlikely worst-case accidents, and concluded that:

Both the design basis accidents and less severe core-melt accidents should be considered when selecting a basis for planning predetermined protective actions and that certain features of the more severe core-melt accident should be considered in planning to assure that some capability exists to reduce the consequences of even the most severe accidents.“4

Consequently, ‘the objective of emergency response plans should be to provide dose savings for a spectrum of accidents that could produce off-site doses in excess of the PAGs [Protective Action Guides]‘.“’ Given the circumspection about planning for worst-case accidents and the need for consistency between the objectives and their rationale, the later guidelines contain a modified version of these objectives that emergency plans should ‘provide dose savings (and in some cases immediate life saving) for a spectrum of accidents’.“6 In other words, dose saving is irrelevant in worst-case accidents where the goal is to avoid prompt fatalities.

Protective Action Guides ‘represent trigger or initiation levels, which warrant pre-selected protective actions for the public if the projected [future] dose received by an individual in the absence of a protective action exceeds the PAG’.37 PAGs are therefore comparable with the UK concept of Emergency Reference Levels (ERLs).‘s The present PAGs were laid down in a manual published by the EPA in 1975 and revised in 1980.39 The manual was never completed and currently PAGs exist only for exposure to airborne radioactive materials, with levels being specified for the whole body (l-5 rems) and the thyroid (5-25 rems).

In the event of an accident the licensee would conduct an accident



assessment and make dose projections. If these indicated, for example, that doses might exceed the PAGs within two miles and five miles downwind, then the utility would recommend protective actions, such as sheltering or evacuation, within that distance. This is the keyhole concept illustrated in Figure 1. The task force, however, was at pains to point out that the PAGs represent only ‘trigger levels’ and are not intended to indicate ‘acceptable doses’.4”

Based on a review of accident types and characteristics4’ and a consideration of the PAGs, the task force recommended a plume exposure pathway EPZ of 10 miles and an ingestion exposure pathway EPZ of 50 miles.

EPZs are defined as ‘the areas for which planning is needed to assure that prompt and effective actions can be taken to protect the public in the event of an accident’.42 The plume exposure pathway ‘refers to whole body external exposure to gamma radiation from the plume and from deposited materials and inhalation exposure from the passing radioactive plume’.43 Protective actions within the plume exposure EPZ might include sheltering, evacuation and iodide prophylaxis. The ingestion exposure pathway ‘refers to exposure primarily from ingestion of water or foods such as milk and fresh vegetables that have been contaminated with radiation’.44 Protective actions include the use of alternative food supplies, the destruction of contaminated produce and moving cattle inside and onto stored foods. Such protective actions could apply over the entire 50-mile EPZ, including the lo-mile zone, or might be confined to smaller areas.

The rationale for the size of EPZs was given in Appendix 1 to the task force report and summarized in the planning guidelines.45 Accordingly, the size of the plume exposure EPZ was based primarily on the following considerations:46

0 projected doses from the traditional design basis accidents would not exceed Protective Action Guide levels outside the zone;

0 projected doses for most core melt sequences would not exceed Protective Action Guide levels outside the zone;

0 for the worst core melt sequences, immediate life-threatening doses would generally not occur outside the zone;

0 detailed planning within lo-miles would provide a substantial base for expansion of response efforts in the event that this proved necessary.

4oCollins, et al, op tit, Ref 9, p 4. 4’lbid. Armendix 1. 42NRk/tkMA, op tit, Ref 22, p 10. 4344 CFR 350.2(h). 4444 CFR 350.2(i). 45Collins et al, op tit, Ref 9; NRUFEMA, op tit, Ref 22. -NRC/FEMA, op tit, Ref 22, p 12. 47Collins et al, op cif, Ref 9, l-37. 48/bid, l-4 to l-43.

Ten miles was chosen for the plume exposure EPZ because ‘the probability of large doses drops off substantially at about lo-miles from the reactor’ (Figure 2) and because, given a core melt accident, there is about a 30% chance that PAGs will be exceeded at this distance.47 Hence, it was assumed that doses from DBAs and less-severe core melt accidents would not exceed PAGs beyond lo-miles and protective actions would be unnecessary. Within lo-miles projected doses might exceed PAGs, and protective actions would provide dose savings, in line with the stated objectives. In more severe core melt accidents life-threatening doses might occur within lo-miles and the objective is therefore immediate life savings rather than dose reductions. Beyond lo-miles life-threatening doses are unlikely and protective actions could be extended to provide dose savings.

The rationale given by the task force for the choice of a 50-mile ingestion pathway EPZ is much less well developed.48 This lack of



200 REM

Figure 2. Dose v distance.

Notes: Conditional probability of exceeding whole body dose v distance. Probabilities are conditional on a core melt accident (5 x 10”). Whole body dose calculated includes: external dose to the whole body due to the passing cloud, exposure to radionuclides on ground, and the dose to the whole body from inhaled radionuclides. Dose calculations assumed no protective actions taken, and straight line plume trajectory.

Source: Collins et al, see text, op cif, Ref 9, l-38.

4sNRC/FEMA, op tit, Ref 22, p 13. ;‘;dCFR 50.47(c)(2).

Distance (miles)

attention to ingestion pathway exposures is a generic problem in current planning efforts. Nonetheless, NUREG-0654 asserts that chemical conversion of atmospheric iodine, wind dispersion and the deposition of particulate matter from the plume would be sufficient to prevent doses in excess of the PAGs beyond 50 miles.49

The final planning regulations allow some variance from these limits. They require that ‘generally’ the EPZs should comprise areas ‘about’ lo-miles and 50 miles.50 ‘ The exact size and configuration of the EPZs [however] . . . shall be determined in relation to local emergency response needs and capabilities as they are affected by such conditions as demography, topography, land characteristics, access routes, and jurisdictional boundaries.‘5’ Ostensibly, this allows state and local governments to adopt different-sized EPZs. Invariably, however, the minimum lo-mile zone is adopted with little modification for local conditions, except jurisdictional boundaries. As will be shown below, local government attempts to diverge from this narrow path are strongly resisted by the utilities, although there are examples to the contrary, such as Diablo Canyon in California, with a 30-mile plume exposure EPZ, and the recent legislation in Maine that creates an additional lo-mile EPZ.

The hostage plant problem

Universal enthusiasm did not greet the expanded planning regulations that came into effect in 1980. Many industry representatives and proponents felt the requirements were unnecessarily conservative and overly burdensome. Since then, state and local governments have refused to participate in off-site planning at three plants (Indian Point,



52Nuclear News, ‘Emergency plan better, but still lacking - FEMA’, Nuclear News, Vol 26, No 2, i983, p 41. 53Nuclear News. ‘NRC sets June 9 shut- down if plan not improved’, Nuclear News, Vol 26, No 8, 1983, pp 47-48. “‘Nuclear News, ‘NRC permits continued operation; new test set’, Nuclear News, Vol 26, No 9, 1983, p 31. 55Nuclear News, ‘NRC accepts FEMA ok of emergency plans’, Nuclear News, Vol 26, No 14, 1983, p 67. 56Nuclear News, op tit, Ref 18. “Nuclear News, ‘Suffolk County voted to block the startup of Shoreham’, Nuclear News, Vol 26, No 3, 1983, pp 2526. “Nuclear News, ‘FEMA not content with Lilco plan’, Nuclear News, Vol 26, No 10, 1983, p 51; Nuclear News, ‘Lilco chair resigns: heir seeks cost controls’, Nuclear News, Vol 27, No 3, 1984, p 51; Nuclear News, ‘One step forward: two steps back’, Nuclear News, Vol 28, No 5, 1984, p 41; and Nuclear Safety, ‘Shoreham gets, then loses, 5% power permission’, Nuclear Safetv, Vol 26. No 3. 1985, II 388. 5gLeonard Buder, ‘Lilco lacks power to carry out Shoreham evacuation, court says’, NY Times, 10 February 1987, Al. “Nuclear Safety, ‘Technical and political factors cloud Seabrook licensing sche- dule’, Nuclear Safety, Vol 28, No 1, 1987, pp 138-142.

Shoreham and Seabrook). Such actions have blocked the NRC from granting operating licences and have been heavily criticized for holding plants ‘hostage’. The situation remains unresolved at Shoreham and Seabrook. TO break the impasse, the industry and the NRC have adopted two approaches. The first involves the results emerging from the re-evaluation of source term estimates following the TM1 accident. (The ‘source term’ is the amount of various isotopes released to the environment following an accident.) Lower estimates could be used as the technical basis for shrinking the EPZs. The second involves redrafting the current regulations to limit state and local government participation and to eliminate their de facto veto of plant licensing.

The Indian Point power plant, on the banks of the Hudson River in New York, was the first plant to be ‘held hostage’ by local government under the emergency planning regulations. In May 1982 the Rockland County legislature voted to pull out of the intercounty planning effort, after being informed by the local emergency services that the state plan was inadequate.s2 Nonetheless, the NRC allowed the plant to continue to operate in the absence of an approved plan until May 1983, when the Commission voted to close the plant unless local participation or a satisfactory alternative could be demonstrated by 9 June.s” In June, however, the NRC voted in favour of continued operation because significant improvements in planning had been made and Rockland County was soon expected to submit its own plan.s4 By August no plans were forthcoming so the state stepped in to substitute for Rockland County emergency personnel, and the NRC formally approved the plans in October.”

At Shoreham (on Long Island, New York) the situation was somewhat different since the plant had never operated. Two problems dogged the licensing process: inadequate back-up generators blocked the issue of even a loading and low-power license until July 19X5s6 and inadequate off-site planning continues to block the granting of a full-power licence.

In February 1983 Suffolk County legislature voted 15-1 not to submit emergency plans or participate in exercises. The legislature argued that it was impossible to set up and implement effective plans, especially plans for evacuation, given the proximity of New York City, the population densities and the limitations of the road network. At the same time, New York Governor Mario Cuomo announced that the state would not intervene without county support.” In an attempt to get around this problem, the utility - Long Island Lighting Company (LILCO) - submitted its own off-site plan in 1985. In the subsequent four years, FEMA, New York State and the New York Supreme Court found the plan inadequate since the utility lacked the legal authority to carry out the functions of county emergency workers, such as traffic control, and so forth.“’ Most recently, in February 1987, the New York

State appeals court ruled that LILCO has no such authority.‘Y Hence the current impasse: Shoreham has been able to operate at 5% power since July 1985, but cannot be granted a full-power licence without

approved emergency plans. The Seabrook nuclear power plant is located in New Hampshire just

two miles from the Massachusetts border, with several large popular beaches and resort communities within the lo-mile zone. On 20 September 1985 Governor Michael Dukakis announced that his office would not submit emergency plans for Massachusetts.“’ Dukakis,


6’Nuclear News, ‘Seabrook, though finished, may have to wait’, Nuclear News, Vol 29, No 8, 1986, pp 26, 155. 62Nuclear News, ‘NHY submits own offsite elan for Massachusetts’, Nuclear News, Vol 30, No 7, 1987, p 24. 63N.J. Palladino. ‘Gettina to the source’. in Source Term Evaluation for Accident Con- ditions, International Atomic Energy Agen- cy, Vienna, Austria, 1986. @‘Matthew L. Wald, ‘The NRC struggles to fill a new role in a changed world’, NY Times, 12 July 1986. 65Nuclear News, ‘ANS Special Committee reports to NRC’, Nuclear News, Vol27, No 15, 1984, pp 37-39. 66Nuclear News, ‘BG & E to ask NRC for 3.2 km EPZ radius’, Nuclear News, Vol 28. No 15, 1985, pp 2526. 67APS (American Physical Society), ‘Re- port to the American Physical Society of the Study Group on Radionuclide Release from Severe Accidents at Nuclear Power Plants’, Reviews of Modem Physics, Vol 57, No 3, 1985, Part II; Nuclear News, ibid. 68Nuclear News, ‘NHY seeks to shrink EPZ to l-mile radius, Nuclear News, Vol 30, No 2, 1987, p 28; US Congress, House, op tit, Ref 1, pp l-33. 69NRC, ‘Licensing of nuclear power plants where state and/or local government decline to cooperate in offsite emergency planning’, proposed rule, FederalRegiste;, Vol 52. No 44. 1987. DD 6980-6987. ?bid;.Gary Hart, Letters, NY Times, 24 February 1987; and Nuclear News, op tit, Ref 53. 7’John Graham, ‘Governors upbraid NRC over proposed revision’, Nuclear News, Vol 30, No 4, 1987, pp 27-30. 72NRC, op tit, Ref 69, p 6981. 73P.M. Boffey, ‘New plan on nuclear plants is laid to frustration’, NY Times, 6 February 1987; Ellyn Weiss, ‘Proposed NRC rule would compromise nuclear emergency planning’, Nucleus, Vol 9, No 1, pp 3 and 7; and Ben A. Franklin, ‘Officials deride proposal on nuclear evacuations’, NY Times, 24 February 1987. 74NRC, op tit, Ref 69, pp 6984-6986.


sceptical of the ability to evacuate the beaches, suggested that the plant be closed in the summers of 1987 and 1988 until the road system could

be improved.61 Recently, the utility submitted its own off-site plan for

the Massachusetts communities affected.62 As at Shoreham, this attempt has so far failed to move along the licencing process.

Apart from attempts by utilities to substitute for local government, there have been two attempts to by-pass the ‘hostage plant’ impasse. The first involves reducing the size of the EPZ to make planning less burdensome and to exclude ‘problem’ states from the process. The second involves redrafting the regulations to limit state and local government participation and to remove their de facto veto.

Following the accident at TMI, the industry and the NRC began a re-evaluation of the source term issue.6” The rationale for such a re-evaluation was that previous estimates were considered to be too high, and that lower estimates could provide the basis for a reduction in the EPZs and planning requirements.64 As early as 1983 there was a private proposal circulating at the NRC which suggested a two-mile EPZ. Similarly, in 1984, the American Nuclear Society (ANS) released its report which gave no specific new zone size, although most of the discussion centred on a zone of two miles or less6’

In 1985, based on this research, Baltimore Gas and Electric (BG & E) Company formally requested a reduction in the Calvert Cliffs EPZ from 10 to two miles.” The NRC later suggested that BG & E withdraw their request. By this time the source term research was beginning to run into problems, with questions being asked about the theoretical assumptions for such reductions.67 Consequently, the NRC ‘coached’ NHY in its application for EPZ reductions at Seabrook in December 1986. Originally, NHY had stressed the significance of reduced source term estimates, but at the NRC’s urging greater emphasis was placed on the unique safety and containment features at Seabrook.“’

As research on source terms became bogged down and failed to provide the justification for reduced planning zones, the NRC changed direction. In March 1987 it published a proposed rule entitled ‘Licensing of nuclear power plants where state and/or local governments decline to cooperate in off-site emergency planning’.“” The NRC argued that the current rules were premised on the assumption that state and local governments would cooperate and were never intended to provide a local veto on plant licensing.7”

Without state and local government participation, it is difficult to demonstrate that adequate protective measures will be taken,” Under the proposed rules, the NRC could approve plans and issue licences if the utility can demonstrate that adequate protective measures caiz be taken. The applicant needs to show only a ‘good faith and sustained effort’ to obtain off-site cooperation, and the plan must incorporate effective measures to compensate for the lack of participation.72

The proposal has been criticized roundly from diverse quarters.” Particularly germane are NRC Commissioner Asseltine’s dissenting remarks that the two cases of non-cooperation and the economic hardship faced by the utilities were insufficient justifications for the proposal. 74 Following Chernobyl, the NRC, in his opinion, should be strengthening, not weakening, emergency planning. He considered it ‘wishful thinking’ on the part of the NRC to assume that local governments would act in an actual emergency, in spite of previous refusals to participate, and besides even if they did ‘an ad hoc response



“Ibid, p 6986. =/bid p 6986. “Inside NRC, 6 July 1987. “F. von Hippel and T. Cochran, ‘Estimat- ing long-term health effects of Chernobyl’, Bulletin of the Atomic Scientists, Vol 43, No 1, 1986, pp 18-25. 79C. Hohenemser, M. Deicher, A. Ernst, H. Hofsass, G. Lindner and E. Recknagel, ‘Chernobyl: an early report’, Environment, Vol28 No 5,1986, pp 6-13.30-43.

Figure 3. Radiation levels in Europe following the Chernobyl accident.

Source: After von Hippel and Cochran, see text, op tit, Ref 78, p 21.

30

by the responsible government officials is simply inconsistent with the fundamental precepts of emergency planning’.75 In sum, for Asseltine, ‘the “new” emergency planning philosophy is nothing more than the Commission’s pre-1980 philosophy in new trappings’.76

In contrast with attempts to shrink the EPZ and exclude local government, proposals to expand current planning requirements have also appeared. Several bills are pending in the Massachusetts legislature suggesting a variety of expanded EPZs, and new legislation in Maine establishes a second emergency planning zone extending approximately 10 miles beyond the current IO-mile EPZ.77 Much of the impetus for these developments derives from the accident at Chernobyl.

Notwithstanding the difference between Soviet and US reactors, it is clear (Figure 3) that radiation levels around the crippled reactor at Chernobyl exceeded PAGs far beyond 10 miles, and the fallout was also not concentrically distributed. 78 People up to 18 miles away were evacuated, and controls on the handling, distribution and consumption of foodstuffs were imposed beyond 1000 miles. Chernobyl also demonstrated one currently unanticipated problem for emergency planning, namely the identification and handling of radiation ‘hot spots’ associated with local rainfall.79

These examples underscore the critical need for flexibility in the structure of emergency preparedness. Emergency planners must be prepared to implement a variety of protective measures at varying distances and directions according to particular accident characteristics, local topography and demography, and site specific meteorological conditions. Ostensibly, current plans account for such variables but, in reality, these factors are not adequately reflected in the geographical organization of emergency planning. Rather than rigid adherence to

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8oUS National Research Council, Social and Economic Aspects of Radioactive Waste Disposal, National Academv Press, Washington, DC, USA, 1984, p 2i. 8’Phili~ D. Pahner. A Psvcholouica/ fers- pective of the ke& En&y Con- troversy, RM-76-67, International Institute for Applied Systems Analysis, Laxenburg, Austria, 1976. “US Council on Environmental Quality, Public Opinion on Environmental Issues: Results of a National Opinion Survey, USGPO, Washington, DC, USA, 1980, p 21. 83Paul Slavic, Sarah Lichtenstein and Baruch Fischhoff, ‘Images of disaster: perception and acceptance of risks from nuclear power’, in Gordon Goodman and William Rowe, eds, Energy Risk Manage- ment, Academic Press, London, UK, 1979.

Figure 4. Public attitudes to nuclear

power in the US.

Note: ‘Don’t knows’ are unsolicited responses as this category is not given as a response option.

Source: Unpublished data provided by Cambridge Reports.


lo-mile and 50-mile zones, a graded response at various distances appears to be a much more appropriate structure for emergency response. In the wake of Chernobyl, emergency planners will also need to address the potential for adverse consequences beyond the existing 50-mile limits.

Public response Technical considerations of nuclear plant accidents have driven the design of nuclear emergency plans and the development of emergency decision structures. Much less use has been made of the existing knowledge of public reactions to nuclear power and how such reactions might contribute to human behaviour during an accident. Obviously, the nature of public response has the potential for confounding even the best developed plans, and for determining the ultimate success of the warning system adopted and the radiation protection strategy chosen.

It is widely recognized that the public is greatly concerned about nuclear power. This has not always been the case, for nuclear power expanded through the late 1950s and 1960s with little evidence of public concern. Since the resurgence of the environmental movement in the late 1960s the debate over reactor safety in the early 1970s and the growing recognition of waste disposal problems over the past 15 years, public support for nuclear power has declined (Figure 4). Since 1978 Louis Harris polls have found respondents opposed by nearly 2-l majorities to nuclear plants being built within five miles of their homes.” After an initial period of adjustment of public attitudes to the Three Mile Island accident in 1979, public opposition to nuclear power has moved steadily into a majority position. Although the long-term effects of the Chernobyl accident are not yet clear, it is apparent that it was a traumatic event in much of Western Europe and has put both reactor accidents and emergency planning back on the policy agenda.

The roots of the public concern with nuclear power are now at least reasonably well understood. Strong fears over nuclear power have undoubtedly contributed to anxiety over civilian uses of nuclear energy. Some psychologists have argued that a substantial part of the public concern over nuclear power represents anxiety ‘displaced’ from the fear of nuclear weapons. s1 The common public perception that nuclear plants can explode and ‘cause a mushroom-shaped cloud like the one at Hiroshima’ may well grow out of this 1inkage.s’ So, in turn, may perceptions of the nature of nuclear plant hazards. Studies at Decision Research Inc have convincingly shown that nuclear power scores high (often extremely so) on a number of characteristics of hazards - involuntary risk, newness, catastrophic nature, severity of consequences - that are of particular concern to the pub1ic.s” Long before Chernobyl, when asked to write scenarios of the maximum credible disaster that

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@‘Ibid. 85John H. Sorensen, ‘Evaluating the effectiveness of warning systems for nuclear power plant emergencies: criteria and ap- plications’ in M. Pasqualetti and D. Pijaw- ka, eds, Nuclear Power: Assessing and Managing Hazardous Technologies, West- view Press, Boulder, CO, USA, 1984, pp 259-277. *%. Maxwell, ‘Hospital organizational response to the nuclear accident at Three Mile Island: implications for future oriented disaster planning’, American Journal of Public Health, Vol 72, 1982. pp 275279. “Cynthia 8. Flynn, Three’ ‘Mile Island Telephone Survey: a Preliminary Report, NRC, Washington, DC, USA, 1979.

might be produced in their lifetime by a nuclear power plant, respondents in psychometric experiments conjured up accidents resulting in vast, and sometimes worldwide, scales of death and destruction.x4 Finally, it is apparent that these basic concerns over hazards are exacerbated by a pervasive distrust in the industry and governmental agencies that manage the technology. The continuing scientific debate over nuclear power hazards, and the evident cases of mismanagement and neglect (eg nuclear wastes), have contributed to this distrust. While an erosion of social trust extends to other industries and to a broad range of social institutions, special problems arise for technologies which are also feared for their hazards.

This deep-seated public concern has at least three far-reaching implications for emergency planning for nuclear power plants. First, it complicates the design of an effective warning system. If the warning message is not carefully prepared or if it is given too early in the accident process, it could well lead to overresponse (such as widespread evacuation) where vigilance is the desired reaction. The pluralistic nature of public perceptions may also be expected to result in varied responses. A counter-tendency may arise from public distrust since the credibility of the warning source is an important ingredient in securing timely and effective resp0nse.s’ Distrust of official sources, such as the utility or a state emergency management agency, could lead local residents to seek unofficial, and less reliable, confirmation sources. Overcoming this problem may require careful warning system design to include more credible sources and yet high consistency and clarity in the multiple messages. As yet, most warning systems have not given these issues the degree of attention they merit so that considerable uncertainty in the performance of the existing systems remains.

The second problem of high public concern relates to the performance of emergency workers. While role abandonment during disasters tends to be uncommon, the high degree of fear over nuclear power accidents and radiation exposure is a complicating factor in ensuring commitment to emergency work. During the Three Mile Island accident, for example, hospitals did experience problems in keeping a full complement of medical personnel. X6 Since nuclear emergency plans rely on existing public services to take on emergency response functions, it is important that the understanding of nuclear hazards be as accurate as possible. Potential problems with role abandonment could occur, given a feared hazard, if other members of the family (such as school children) are viewed as greatly endangered. Training of emergency workers needs to include efforts to provide at least a basic understanding of radiation hazards.

The third, and perhaps most important, uncertainty is whether emergency organizations can implement certain protection strategies in the face of high public concern. Many emergency plans call for limited evacuations (often sectoral) within the designated emergency planning zone. Although the Three Mile Island accident, with its widespread confusion, is certainly not a test of what is possible or what might occur in a future nuclear accident, it is noteworthy that the Governor’s recommendation that 2500 preschool children and pregnant women within a five-mile radius evacuate stimulated the evacuation of 144 000

people within a 15mile radius. 87 A large-scale out-migration when a

limited, targeted evacuation is desired may greatly complicate mounting a successful emergency response. Spontaneous evacuation beyond the



designated area, as discussed below, will increase the density of

evacuation routes, lengthen the queuing time and generate additional cross-traffic. The more disorganized evacuation also carries a greater potential of evacuees mistakenly moving in the direction of the plume.

Even more difficult is the issue of sheltering. While evacuation may be the preferred response to most serious nuclear accidents, some accident situations (eg an unexpected early release or a heavy snowfall) may not allow for evacuation. Also, in the case of certain releases - such as those where projected doses are in the millirem or tens of millirem range - the risks of evacuation may exceed radiation risks.88 In such situations sheltering may be the only, or the preferred, response. And sheltering, depending upon type of housing and the effectiveness of response, can substantially reduce radiation exposure. But what will be the response of the public to a recommendation from the Governor to shelter? Will even a well-conceived and executed warning overcome the public propensity to evacuate? The answer to this question is not known - and may not be known until experience gives the answer. Loss of this emergency protection action would have serious implications for the ability to reduce exposure to some accident situations. A better understanding is needed of the viability of this option and means for increasing its effectiveness.

Evacuation Warnings of natural and technological risk events happen at least once a day in the USA and there are numerous evacuations each year. Very little of this experience involves radiological releases, however, and almost none relates to nuclear plant accidents. As a result, the likely evacuation behaviour of a population during an actual nuclear accident is uncertain - and the subject of controversy. Accurate prediction of this behaviour is essential, however, for if the wrong off-site protective action is recommended, or the recommendation delayed, the surround- ing population may be exposed needlessly to high levels of radiation.

There are reasons for both optimism and pessimism. The substantial experience with evacuation in a range of natural and technological disasters indicates that it is possible to warn and evacuate sizeable populations even when prior emergency planning has been minimal or non-existent. Perhaps the most dramatic example of this occurred during the 1975 earthquake in Haicheng, China, when a simple warning resulted in a near universal evacuation in freezing winter temperatures and greatly reduced the consequences of the earthquake that happened five hours later. 89 The ad hoc evacuation from a chemical release

=W.F. Witzig, J.K. Shillenn, F. Clemente, following the train wreck at Mississauga, Ontario, is often cited as

CC. Rusnak, S.D. Weerakkody and CR evidence of the ability to carry out evacuations effectively and without

Wilusz. ‘Evaluation of orotective action panic (although good luck was also involved).N Then, too, the risks’, 2 vols, NUREGbl-4726, Draft, US numerous exercises of emergency plans at nuclear plants, despite a lack Nuclear Regulatory Commission, Wash- ington, DC, USA, 1986.

of realism, indicate that large populations can be alerted quickly.

BgDennis S. Mileti, Janice Ft. Hutton and But there are grounds for pessimism as well. At Three Mile Island, John H. Sorensen, Earthquake Prediction almost everything that could go wrong did. The emergency information Response and Options for Public Policy, Institute of Behavioral Science, University

provided to the public was a welter of confusion concerning the facts

of Colorado, Boulder, CO, USA, 1981, pp and contradictory recommendations for personal protection. In such a 3-6. context. it is not surmising that the evacuation that did occur was ouite wlan Burton, The Mississauga Evacua-

_ - 1

tion, Final Report, Institute for Environ- spontaneous, disorganized and uneven. Although it is quite clear that

mental Studies, University of Toronto, this experience is not a model for future nuclear accidents, generic Toronto, Canada, 1981. problems exist. A complex system of interinstitutional cooperation is



involved, opportunities for misinformation and failure are numerous, reactor accidents are difficult to evaluate, personal experience with such events is usually absent and, as noted, the hazards are greatly feared.

The decision to evacuate carries several important policy considerations. Should the goal of evacuation be to reduce exposure and potential fatalities when an accident is imminent, or should it strive to prevent exposure by early, precautionary evacuations? This is a choice that is both difficult and carries far-reaching implications. By the time a release is imminent, too little time may be available to evacuate the population, and the time necessary for evacuation, as noted above, is also uncertain. On the other hand, a precautionary evacuation involves accident and health risks as well as substantial economic loss. Who will bear the expenses and the liability for a ‘false’ evacuation? If precautionary evacuation is desired, what error rate is tolerable? And what will be the impact of several ‘false’ warnings on the response of the public and emergency workers? Then, too, different perspectives on these questions exist. Utilities tend to be very cautious about ‘premature’ evacuation, whereas regulators and state officials clearly want to err on the side of safety. These are vexing issues. Practice in the USA appears to be giving greater emphasis to precautionary evacuation, but regulatory guidance remains unchanged in its basic orientation.

Because nuclear accidents are rare and exercises do not involve evacuation, emergency plans necessarily rest upon a series of untested assumptions concerning warning response and evacuation behaviour. The first issue is spontaneous evacuation, or what has been termed ‘hypervigilant behaviour’.“’ In the event of a nuclear plant accident, large numbers of persons may take actions earlier and select more drastic options than advisaries recommend or that the situation warrants.92 If correct, there are several implications. The public may well run ahead of the sequence of actions recommended in emergency warnings, spontaneously fashioning their own protective actions and behaviour rather than following planned procedures. Larger populations, including those at greater distances from the plant, will evacuate, thereby confounding the assumptions upon which emergency planning zones are delimited and transportation routes and means selected. Since families tend to evacuate as units, parents are likely to arrive at schools to pick up their children, rather than delaying for the official evacuation order and observing the instruction in plans to allow children to leave as a group in school buses. This convergent behaviour could well make schools difficult to evacuate, and may encourage school children with cars to conduct their own evacuations.

“Johnson. oo cit. Ref 8. ‘*J. Johnso; and D. Zeigler, ‘Distin- guishing human responses to radiological emergencies’. Economic Geoaraohv. Vol 59, 1984, pp j86-402.

A second issue is the choice of routes and destinations by evacuees. Emergency plans currently specify the routes and destinations (receiv- ing centres) to be chosen by resident populations. But it is clear, from experience at Three Mile Island as well as other disasters, that evacuees tend to select their own destinations, based upon the location of friends and relatives, as well as perceptions of danger. Although this behavioural propensity is widely recognized and well documented, it is ignored by existing plans which assume that recommended routes and destinations will be used. The impact of this reality upon the workability of existing clans is unknown. but it is clear that the next generation of plans lhbuld be built bottom-up from what is known “about actual behaviour rather than trying to ‘fit’ behaviour into rational, engineered

_ , I, notions of evacuation.


93For example, A.G. Hobeika and B. Jamei, ‘MASSVAC: a model calculating evacuation times under natural disasters’, in Computer Simulation in Emergency Planning, Society for Computer Simula- tion, San Diego, CA, USA, 1985; KLD Associates, Inc, Formulation of the DYNEV and I-DYNEV Traffic Simulation Models used in ESF, prepared for the Federal Emergency Management Agency, 1984; V. Sheffi, H. Mahmassani and W.B. Powell, ‘A transport network evacuation model’, Transportation Research, 4A, 1982, pp 209-218; and Frank Southworth and Shih-Miao Chin, ‘Network evacuation modelling for dam failure related flooding’, report prepared for the US Department of Energy by the Transportation Group of Oak Ridge National Laboratory, 1987. “Southworth and Chin, ibid.


Special populations, particularly the relatively immobile populations at hospitals, nursing homes and prisons as well as transients (eg travellers) who may be in the area, raise particular problems for

evacuation. Also involved, but rarely recognized, are social groups, such as street people, the very poor (who lack telephones and private vehicles), or cultural groups (native tribes, the Amish) who are outside the mainstream. Emergency plans are typically weak on provisions for evacuating such populations. Evacuating the mobility-impaired, such as the old and infirm, complicates matters since such movement may place them at increased risk. Precautionary evacuation of such groups is particularly problematic because the potential benefits are less certain.

These problems call into question the adequacy of existing evacuation time-estimate models, upon which recommendations for off-site protective actions may rest. These models are essentially traffic engineering models, which treat the cumulative loading of an evacuating population onto a highway network, the assumed choice of destinations and routes, traffic flow capacity along routes, the on-the-road behaviour of evacuees and the resulting clearance times. In recent years, elaborate network simulation models have emerged that include more complex assumptions affecting network loading and traffic behaviour.“” But, as the more advanced modellers recognize, few of the reliable data required for model validation still exist. 94 Such critical variables as the timing of evacuee departures, the choice of destinations, the geographical scope of evacuation, family behaviour, and behaviour during the commute are all still relativily poorly understood. Emergency decision makers that we have interviewed over the past year express little confidence in such time estimates, using them only as very general benchmarks and relying upon other less analytic sources.

Evacuation during nuclear plant accidents, it is clear, remains a very uncertain business. Considerable further research and experience is needed before greater confidence in predicting evacuation results, or defining evacuation strategies, will exist.

Conclusions

A substantial societal effort to improve emergency planning and preparedness for nuclear power plants has occurred since 1979. Improvements are apparent in a wide number of areas, particularly overall regulatory guidance, communications systems, and a regime of exercises and drills. Nonetheless, uncertainty still remains as to whether performance during the next accident will overcome the obstacles so apparent during the Three Mile Island accident.

Notable problems remain. Flexibility is a major problem with the planning regulations and resulting plans. Organizational roles and responsibilities are often sharply divided, and coordinated by a military model of decision making. This encourages a checklist mentality, in which the primary goal is compliance. Given the virtual monopoly on technical information often held by the utilities, conflicts of interest and the delays in provision of information to off-site authorities are apparent. This points to a need for greater independent technical assessment capability for public authorities.

The optimal geographical arrangement of emergency planning is also a problem. Controversy will always arise in the drawing of zonal boundaries, and nuclear opponents are quick to point out that there is



no impenetrable wall at IO miles, nor did the fallout from Chernobyl respect political borders. There is ample reason to believe that a graded emergency response at a variety of distances would improve the capability to cope with a spectrum of accidents. In areas such as Europe and the eastern USA it may also be prudent to consider planning on a regional basis, given the high population density around nuclear plants.

Finally, there is the issue of protective actions. All too often emergency plans are conceived as evacuation plans - plans that apply to only the lo-mile EPZ. Given the range of possible accidents and local conditions and constraints, other protective actions (eg sheltering) may be necessary at a variety of distances. Downwind evacuation to 1.5 miles and sheltering out to 2.5 miles could prove necessary, with localized controls on milk consumption wherever radiation ‘hot spots’ occur.

A more troublesome, if elusive, problem is the apparent mindset we have encountered that worst-case accidents are so unlikely as to be incredible. This mindset was pervasive before TMI, and appears to be deep-seated among staunch proponents of nuclear power. As the memory of the TM1 accident fades, it is likely that the mindset will return. Indeed, we see it already in those that dismiss the significance of Chernobyl for planning in the West. Several problems stem from this. First there is a tendency to be blase about planning and preparedness. Second is the failure to plan for large accidents. (For example, medical planning is still hopelessly inadequate to deal with the nature and magnitude of health effects that can be expected in a worst-case accident, and plans for ingestion exposure controls are rudimentary or non-existent.) Third, recent attempts to reduce the size of EPZs and to exclude state and local government also reflect this mindset. Clearly, excluding local participation erodes the potential effectiveness of planning and preparedness efforts. Notwithstanding the differences between Soviet and US reactors, reducing the size of the EPZ is in direct contradiction to the scale implications of the Chernobyl accident.

A final generic problem is the systematic failure of emergency planners to take account of behavioural factors. Existing plans take little cognizance of the extensive research on human behaviour during accidents and disasters over the past eight years, and on public perception of the risks of nuclear power, despite the intent of the Kemeny Commission. . ” Public aversion to nuclear power raises significant uncertainties about the nature of public response during an emergency. Emergency planning and preparedness efforts must take more adequate account of this fact in the design of educational programmes and warning systems, and in the implementation of alternative protective actions. Evacuation is often the preferred method of protection, and planners must be aware of the findings from behavioural research in shaping viable strategies.

g5Sorensen, op tit, Ref 85, p 274.

Where does this leave us for the next major nuclear plant accident? Unfortunately, we are left with an abiding sense of uncertainty. Significant improvements have been made, but the efficacy of these improvements remains in doubt. Only with another accident will the extensive system of emergency preparedness receive its first real test, only then since the drill and exercise procedures do not accomplish that purpose. An important part of that test will involve validation, or invalidation, of the underlying assumptions, the resiliency of the institutional structures which have evolved and clarification of the types and magnitudes of remaining uncertainties.
