ML20052H187

Draft Limited Appearance Statement for ASLB 820414 Hearings, Supporting Facility Licensing.Nrc Current Requirements for Emergency Planning & Public Perception of Nuclear Accident Consequences Are Excessive

ML20052H187
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/14/1982
From:	Amy Hull AFFILIATION NOT ASSIGNED
To:
References
NUDOCS 8205200045
Download: ML20052H187 (11)

Text

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S o -3 z' Andrew P. Hull, M.S.

Supervisor Environmental Monitoring Safety & Environmental Protection Division Brookhaven National Laboratory Upton, New York 11973 Residence: 2 Harvard Road Shoreham, New York Member: Energy Education Exponents At the outset. I want to make it clear that I speak as an individual who has been professionally trained and employed in radiation protection for the past twenty-five years. I am a member of Energy Education Exponents (E ) in order to pro =ote the availability of factually accurate information about energy to the public, which I believe is essential to the for acion of sensible public policy in this area. Coc: mon sense suggests to me that on Long Island we should aim toward a mix of fuels for the generation of electricity, rather than being virtually 100% dependent on oil, and that nuclear power can and should play a central role in achieving this deversification. I start trom this position in my advocacy of the granting of a license to LILCO to operate the Shoreham Nuclear Power Station. -

My particular expertise has to do with the health risks of radiation, including that associated with nuclear power stations. In recent years, there have been a number of studies of the health risks of the alternative means of generating electricity ( ). Uniformly, they have concluded that the health risks of the nuclear fuel cycle are as low or lowest than those of the practicable alternatives. Whatever criteria are employed for deciding for or against any of the available choices in my view 3 neither the overall

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health risks nor their relative tM 5 are sufficient to warrant selecting or rejecting one solely on a basis of health and safety.

Following the accident three years ago in March 1979 at the Three Mile Island Nuclear Power Station, emergency planning seems to be an aspect which 8205200045 820414 Mf d PDR ADOCK 05000322 T PDR I 9p J j

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has greatly preoccuppied the NRC and which has greatly worried the public.

As part of my duties, I am a team captain in the Department of Energy's Radiological Assistance Plan for Region I (covering the northeastern U.S.).

I was at Harrisburg within a few hours of the accident and shortly thereaf ter became responsible for the interpretation of the extensive environ = ental monitoring data that was obtained during the following several weeks. From this experience I became curious as to why the environmental releases of radioactivity in addition to the noble gasses, were so much smaller that had been anticipated.

Subsequently, I have presented several technical papers on emergency planning at meetings of the American Public Health Association, the American

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Nuclear Society, the Health Physics Society and a symposium of the International Atomic Energy Agency. These have been based on my direct involvement at TMI and on a careful reading of many of the related authoritative analyses (such as the main report of the President's Commission and the technical background appendices). thymost recent, " Emergency Planning for What?", was published in Nuclear News a year ago. I intend to submit it as a backup to the written version of this statement.

The essential argument of this article is that both NRC's current require-ments for emergency planning and the public perception of the consequences of Se sm ih41 nuclear accident are excessive and lacking a technical basis ' 2 rd en actual experience.

Prior to the TMI-2 accident) detailed emergency planning was essentially confined to the Low Population Zone (LPZ), typically a radius of three to so miles from a power reactor. Nothing happened at TMI to warrent the enlarge-ment of this zone. On that occasion, only the radiegasses were released in large quantities. The maximum dose to the most nearby persons was about 100 rt.-a millicuster (equivalent to the background radiation they might have

received by moving to Denver for a year). The average to the population within 50 miles was about 1/100 of this and within the variability of local background throughout the U.S.

Even if all of the available radiogasses were released at one time from compared to the a large power reactor such as Shoreham (a.=ost unlikely event, possibility of a gradual release), the anticipated radiation dose to persons downwind would be insufficient to warrant protective actions beyond the LPZ.

Since the accident at IMI, several scientists have made careful examina-

!MI and of a number of previous smaller tions of the release mechanisms at intentional and unintentional incidents. All of the evidence from experience suggests that the probability of the release of radioiodines or solids s' is during a vater-cceled power reactor accident is appreciably 1:ver than had been assumed heretofor.

In the absen:e of such releases, there is simply no reason (aside from the current parancia exposure to radiation, no matter how in fe n.f.'b >-ci ) for an e=ergency response beyond the LPZ. There is even less warrant for evacua-tion, which in my view is being over-emohasized. If there is a serious mal-function at Shoreham or any other power reactor in the northerly f-d ; of the U.S. where almost all homes have cellars, the first response should be sheltering, which would avert a life-threatening dose from the largest imaginable release of radiogasses.

The current thinking about evacuation with regard to reactor malfunctions seems to me akin to contemplating it to escape from the projected path of a hurricane which it is still hundreds of miles at sea and many hours away, or to escape the possible path of a forest fire which is still many miles dis-cant. In neither case does it seem vise or prudent to adapt a protective strategy which could result in large numbers of persons being on the road at

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the time the hurricane or fire actually arrives and possibly in its actual in their path with less protection chan they would have had by staying put homes, places of business, or schools. The sad experience of persons killed while trying to drive out of the path of tornados should be a lesson in this regard.

In my judg:ent, there would be little if any technical justification for calling for evacuation until experts in making environmental measurements have made field surveys to ascertain if any deposition of radiciodines or solids have actually occurred. In this extremelv unlikely possibility that they are present in sufficient amounts to result in large dese-rates, there

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would be time to accomplish an orderiv removal of those significant risk.

I==ediate sheltering of those close in (within a few miles of a power reactor) en the sounding of an alarm and relocation only af ter radiation surveys (if at all) is the adopted protective strategy of almost every country, with light water power reactor programs. (such as France, Germany, Switzerland and Japan).

In this instance, our U.S. penchant for " bigger" is not better, but in fact could put large numbers of persons at unnecessary risk.

Emergency preparedness for what?

(Implications of the TMI-2 accident) by Andrew P. Hull ne possibility of a major accident at a large nuclear TABLE I power plant was recognized at the outset of the commercial PoTENTtAt. OrtstTE Doses Dire To DEstcN Basts tmplementation of nuclear power m the United States m AcctDENTs (CONSERVATIVE CASE)3 <

1 1957. A study of the theoretical possibilities of such an accident and of the consequences of various accident cases, Two-Houa Dunarson or AcetDENT with or without large uncontrolled releases of fission prod- ExettisioN Bousonav 1.ow Perc6anow Zone (3200 riet) (4 Massi ucts to the environment, was initiated by the U.S. Atomic Energy Commission at that time.$ For the worst postulated Aceroast Thyroid whole Body nyroid whole Body

@m) (Rm) (Rm) (Rern) case-the release to the atmosphere, under the most adverse _

meteorological conditions, of 50 percent of the core inven- Loss of Coolant 155 3 81 3 ControlRod Eicction <1 <1 <1 <1 tory of fission products-the study envisaged the necessity of the evwation of as many as 460 000 persons from an [j' {d ak I area of 760.quare miles. 10CFR100 Dose Pnor to the accident at Unit 2 of the Three Stile Island Guideline 300 25 300 25 station on 51 arch 28,1979, however, formal planning for protective actions (including evacuation) was generally not Radiation Control Program Directors passed a resolution required beyond the low population zone (LPZ). The LPZ

'a the area beyond the site boundary within which, during in 1976 uking the NRC to make a determination of the most severe accident basis for which radiological re:ponse the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> following the onset of a design-basis acci.

dent, an individual would not receive a whole-body radia. plans should be developed by offsite agencies.' A task force consisting of NRC and Environmental Protection Agency tion dose of more than 25 rem or not more than 300 rem to the thyroid due to exposure to or inhalation of constit. representatives was convened to address this request and uents of the radioactive plume.3 Some potential otYsite related issues. It prepared a report, published in 1978,' on doses due to several postulated incidents, including the the planning basis for the development of state and loc-I maximum design-basis accident, are shown in Table L ney are based on leakage from the containment at the peak ,

pressure.3 The LPZ is further defined as an area containing

" residents, the total number and density of which are such that there is a reasonable probability that appropriate pro- '

tective measures can be taken on their behalf in the event .

of a serious accident."' Prior to the Thil accident, the NRC stad had adopted a position that a distance of 3 miles to the outer boundary of the LPZ was usually adequate.8 .\ **

A more sophisticated assessment of power reactor acci- ,,, _\\ /~ _

dent nsks than that contained in the 1957 study was pub- g lished by the U.S. Nuclear Regulatory Commission in J, \ .

1975.* This assessment adopted an evacuation model for a - \,

series of postulated resctor malfunctions, the area of which h

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included a 360-degree circle out to a radius of 5 miles, and ' \

a 45-degree sector out to 25 miles in the downwind direc- s tion. As shown in Fig.1, even a very slow efective evacua- \ I tion speed of 1.2 mph was expected to materially reduce '~~

)g , i the probability of early fatalities for the most severe pos*u- =* :- .. 7 \- -

la'ed releases kom a pressurized water reactor (PWR). As

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also indicated, more rapid effective speeds were expected i\ l l' 1\ ^

to reduce this probability to near zero.

As a result, at least in part, of concerns raised by this assessment, an ad hoc task force of the Conference of

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Mr. Hull is supervisor of environmental monitorms. Safety and i Eastronmental Prote: tion Division, Brookhaven National Lab- ,

,', ,, ,, , E, , ,,, [ .,

oratory, L'pton N.Y. This article is a revised version of a paper ..

of the same utte presented at the Amencan Nuclear Society's Executive Conference on State / Federal / Nuclear Industry Inter- Ag. 1: Concitionai ::rocacility of earty coath as a function of face. Monterey, Calif., February 4.1981. castance from reseter AD.P8L tW Arm 6 seis

• force and a request for public comment was published in

, ,m the Federal Regirrer on December 15,1978 (42 FR

.:::'jE,,.::,_:rm'~~- - 58658). The indicated deadline for such comments was

• "- ,N 5tarch 30,1979-two days after the T5112 accident.

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Evacuatfort: was it technically justified?

The sequence of events during the first hours, days. and

\ even weeks after the initiating event at T5fl.2 at 4 a.m. )

\  ::::"'.".*. "" Starch 28,1979, has been set forth in detail in several in-

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depth r-views."-82 From their accounts, as well as from the author's first hand involvement. it is evident that the

-\ isgd.  ::".:*:"/,:" -' directly concerned radiation protection agency, the Bureau C"!!*"a* of Radiation Protection of the Commonwealth of Pennsyl-

/' - O \ ~'C F* " vania's Department of Environmental Resources (BRP),

g// , jj [', , ,9 did not initiate any recommendations for evacuation at any time during the incident.

The legal authority for the proclamation of a state of

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g';f [' b' e - l I

• =7.::1. emergency and for ordering an evacuation belonged to the

/ governor of Pennsylvania. Supposedly, his decision to exer-

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.,,,,,,, , cise this authority would have been based on information about the extent of a nuclear accident as supplied by the

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involved facility. an assessment of its offsite potential by Fig. 2: Concept of emergency planning zones the BRP. and the recommendation of the Pennsylvania secretary of health." As is well known, however, the situ-government emergency response plans. In it the task force ation of the reactor was not clearly established for several concluded that -[t]he objective of emergency response plans days, and communications were difficult. The BRP, how-should be to provide dose savings for a spectrum of acci- ever, was in continuous contact with the reactor emergency dents that could produce off-site doses in excess of the operations center. as well as with the U.S. Department of Protective Action Guides." Th se guides were 5 rem whole- Energy's otTsite environmental surveillance center. At no body dose and 10 rem thyroid.' time did the information supplied directly to the BRP by The NRC-EPA task force recommended that emergency these two centers support the implementation of emergency planning zones (EPZs) be defined arcund each nuclear protective actions."

reactor, both for the short. term " plume exposure pathway" Starting on Thursday aftemoon (March 29), however, and for the longer term " ingestion exposure pathway." As remotely located federal agencies began making such rec-shown in Fig. 2. these had. respectively. radii of 10 and 50 ommendations. either directly to Gov. Richard Thornburgh, m4es. The task force suggested that within the plume expo- or through his secretary of health. The first call to the sec-sure EPZ, shelter and/or evacuation would likely be the retary came from the director or the National Institute of immediate protective actions recommended for the general Occupational Safety and Health, who suggested that a pre-public." cautionary evacuation was advisable since it was "not Reference was made to studies" that indicated that if known how to shut down the reactor.""

such actions were taken within about 10 miles of a nuclear On the basis of a misinterpretation of the location of a power reactor. there could be significant savings of early helicopter, when a measurement of a radiation level of injuries and deaths following even the most severe atmos- 1200 mR/h was made in the plume during intentional pheric releases. From these studies, the task force concluded venting, the NRC Operations Center recommended in mid-that evacuation appeared to be more etYective than shelter- morning on Friday. March 30. an evacuation out to 10 ing in reducing the number of early health etYects within miles. This recommendation was headed orY at the Gover-5 miles of a reactor, as long as the delay time and the nor's otfice by the BRP. which had more accurate and more nonparticipating segment of the population were kept sutH- current information." I.ater on in the day, the NRC be-ciently small. Between 5 and 10 miles. this distinction was came concerned about the esplosive potential of the "hy.

not so apparent, especially for an " atmospheric" (core melt drogen bubble" and recommended an evacuation out to 10 followed by catastrophic failure of containment) incident. miles, which the Governor reduced to an advisory that For areas beyond 10 miles. there was little apparent distinc- pregnant women and young children leave the area. Ac-tion between the benetits of sheltering and evacuation in cording to a study, 21000 persons within a 5-mile radius terms of projected early fatalities or injuries. and 114 000 persons within 25 miles did evacuate, many It is interesung to note, in the current post TMI emer- prior to the Governor's advisory. The costs of this evacua-gency planning climate, that in its report the NRC-EPA tion have been estimated at 59.3 million.28 In the months task force also stated: "The EPZ guidance does not change that followed the accident, a review by the Emergency the requirements for emergency planning, it only sets Preparedness and Response Task Force to the Presidect's bounds on the planning problem. The Task Force does not Commission on the Accident at Three Mile Island indicated recommend that massive emergency preparedness pre; rams that federal ottictals in several Ley bureaus and at the White be established around all nuclear power stations." House remained preoccupied for the next few days with The task force noted in this connection that some capa- evacuation and particularly -ith the appropriate radius, bilities already existed under the general emergency plans with proporients arguing variously for 5,10, and even 20

. of federal and state agencies. mdes."

! A notice of the avadability of the report of the task Almost from the onset, it was established that the radio-62 NtJCLEAA NEWS / APAIL 1981

activity that was being released to the atmosphere as a re-suit of the accident did not come directly from the contain- so co co so 2s e ment building, but rather indirectly from leakage from the coolant letdown system and gaseous waste treatment sys- k tems in the auxiliary building.88-88 From the results of the \ '

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first post-accident sampling of the primary coolant water on March 29 and of the containment atmosphere on 5f arch as 31, it appeared that 5.0 X 10' Ci of xenon-133 (5.3 days ,

half life), or 41 percent of the core inventory, was present in the containment atmosphere. The total release of Xe 133

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se, from the auxiliary building was estimated by the President's ,3 Commission as between 2.4 X 108 Ci and 13 X 108 Ci, er 80 2-10 percent of the core inventory. Other evidence, how-N #

ever, suggests that the actua! amount released was closer to the lower estimate.'* 88 The early sampling indicated that ,

4.4 X 10* Ci of iodine 131, or 7 percent of the core inven- g tory, was contained in the primary system. A more com- ,,,

plete inventory of I 131, as of April 1, was indicated in

• the report of the President's Commission as follows: pri-mary loop. 7.5 X 10* Ci; containment building water,10.6 s n X 10' Ci auxiliary building tanks, 4.0 X 10' CL The / \g total,22 X 10' Cl, was 34 percent of the equilibrium core , I g ,,,, \

"# c atly sampling also indicated that 4.3 X 108 Ci, or ] [,

0.007 percent of the core inventory of I-131 was airborne in the containment atmosphere. The President's Commis- Fig. 3: Estimated dose in vicimty of TMi-2 sion indicated that 3.6 X 10' Ci, or 0.06 percent of the core inventory, was airborne, but this appears to have been mrem. A child located close to the TMI boundary would a typographical error?' The early estimates of the amount have received an estimated inhalation dose to the thyroid of I 131 indirectly released to the atmosphere ranged from of 2-3 mrem resulting from the releases of the 8-13 Ci 8 to 13 Cl. The President's Commission indicated that 13- og g,3 3 3

• 17 Ci were released to the atmosphere through the next month. What if?

"Ihe integrated external dose from the released radiogases The initial sampling showed that a large fraction of the to the population within 50 miles has been estimated vari- core inventory of radiogases had been released from the ously from 50 to 5000 person-rem with a most probable fuel and had become airborne in the containment, and that value of about 2000 person-rem."" Ground-level isodose a somewhat smaller fraction of the radiciodmes appeared contours, which were derived from DOE helicopter-based to have been released into the primary coolant. and only a measurements of dose rates in the plume centerline, are small amount of this release was airborne in the contain-shown in Fig. 3. For purposes of comparison, the total ment. A tabulat.on showing the amounts of some of the doses for the same period, as measured by the uti'ity's principal nuchdes of radiological concern that escaped from thermoluminescent dosimeters (TLD) at several locations the fuel to the primary coolant and that subsequently established long before the accident, are also shown. The migrated to the containment and to the auxiliary building is maximum estimated dose to the most nearby individuals, shown in Table II. The estimated amounts released to the located about 0.5 miles east of TMI-2 was less than 100 atmosphere during the incident, normalized to March 29 TABLE II DisTatBUTION oF XE 131, X 137.1-131, Cs 137. Ano Sa-90 AT TMI-2 (NonM Attzto To 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br />. M ARCH 29,1979 ExcEPT FoR I-131 To Aran. 4,1979)

Cosa Penwaar CowTaus arvo CowTautwann Au9nLIAav SUILDIMo (Q) Rz r.

Invuwrosv Srsnw wans Azm

, (Cl) (C) (C) (Ci) wann Ara Xe-131 4.1 x 108  ?  ? 2.5 x los  ? 3.4 x lo* 21 Xe 133 1.45 x 10*  ?  ? 8.73 x 10'  ? 1.19 x 10?* 21 1 131 6.38 x 10' O.75 x 10? 1.06 x 10' 4.3 x 10' O.4 x 10: 140 " 12 Cs-137 8.45 x 105 1.31 x 108 3.65 x 10$ - 0.11 x 10' - 21 Sr.90 7.8 x los < l.4 x 10' <4.2 x 108 - < 0.1 x 102 - 21

• Events. ally released as 8.3 x 10* C1 (Raf. 21) Lower estunates of Xe 131 retened include 14

• 104 Ci t Ref. IS) and 19 x 10* C tref 19).

"factudes aanmanad 125 C reuuned on alter and 15 C released from stack. ,

NUCLEAR NEWS / APRIL 1981 63 l

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I

. . l was released during the a'st 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> after the accident,88 ame.se m as.cm swume and that a potential boundary dose of some 500 mrem, as "Y.amme come ama.as m ac. measured on an essentially unoccupied island 0.6 mile to M %"n' ., ,,,,, O .ama

. *** maumu.-suume the northwest of TMI-2 (see Fig. 3) was delivered during o au. == camaa  %* ,a this same period. With the use of these data, a boundary

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• • • , dose at that location of about 25 rem can be projected if

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,,,,,,,, the entire 8.7 X 10' Ci of Xe-133 that was airborne in ,

=' m 'co== the containment had been released during this same period. l

\ This estimate may neglect some portion of the shorter lived

^ noble gases, such as Xe 19 (9.1 hr) and Kr-88 (2.8 br),

N which could have been signi8 cant contributors to environ-mental dose within the nrst day after the accident. Con-sidering these and supposing that the containment failed during the afternoon of March 28. one could arrive at a g aumu.= - projected boundary dose as much as Sve times greater than j that projected solely on the basis of Xe 133.

m In any event, this suggests that only for an accident that

,,"."*8g resulted in a prompt release of a large fraction of the core inventory of radiogases into the containment, followed very Fig. a: Reteese fractions at Tw-2 shortly thereafter by its catastrophic failure, would evacu.

ation have been warranted in terms of the potential for 1979, are also indicated. The principal source of these data exceeding the LPZ external dose limit of 25 rem at the site is Bishop er al.8' except for I 131, which is from the report boundary or close to it. Furthermore, if one assumes that of the President's Commission." By comparison of the rela. the dose decreased with distance as (r/ro)-'8. the warrant tive amounts of I 131 and cesium-137 in the primary cool- for evacuation under this external dose criterion would ant and the fraction of the latter that was released from the probably have been conaned to the LPZ. Even for this fuel. Bishop er al estimated that about 60 percent of the most extreme case. it does not appear that the upper limit radioiodines were also released from the fuel. Stuch of the of 5 rem gamma dose for whole-body exposure, as set remainder, above that accounted for in the primary coolant forth in the currently applicable Protective Action Guide and leakage. is believed to have settled into the contain- (PAG).8* could have been exceeded beyond 10 miles from ment building sump.88 The fractions of the core inventory the point of release.

of these nuclides that were released to the reactor coolant If the previously indicated inhalation dose to the thyroid system, to the reactor building to the auxiliary building. of a child from the elevated release of 15 Ci of I 131 is uid to the environment are depicted in Fig. 4. scaled up to the total 4300 Ci that was apparently airborne As is apparent, in terms of the amounts and kinds of in the containment on March 28. its release would have radioactivity actually released to the atmosphere and the produced a boundary inhalation dose of approximately 1 resultant radiation dose to the nearby population, the TMI 2 rem to this child's thyroid. This does not call for evacua-accident was a relatively inconsequential event. However, tion under the LPZ design limit of 300 r m or even the there was a widespread concern about public safety espe- current upper PAG level of 25 rem. A ground level release cially in connection with the " hydrogen bubble" scare, of this amount of I-131, (with the conservative assumption which was based not so much on the actual amounts of of an X/Q of 10-* sec/m'). could have produced an inhala-activity released as on the perceived potential for much tion dose of about 100 rem to the thyroid of a nearby larger aittorne releases in the event of a breach of the child and could have exceeded the PAG out to about 3 containment. miles.

An elementary evaluation of the potential dose from the These simple considerations suggest that the extreme release of airborne activity due to the failure of the contain- "what if" scenarios that were imagined by the public, by ment may be made simply by scaling from what did take the media. and even by many of the " absentee" TMI crisis place. If the release of 9 percent of the core inventory of managers were bued more on imagination than on realism.

Xe 133 produced a dose of approximately 100 mrem at If there were a priorf grounds for considering evacuation, the nearest occupied location offsite (about 0.5 mile east they were more on the anticipation of the possibility of a of TMI-2-see Fig. 3), then the release of the 60 percent large release of radioiodines than on the potential exposare that was airborne in the containment (see Fig. 4) would due to radiogases. Once the small amount of iodine that have resulted in a dose of about 700 mtem. This projection was actually airborne in the containment had been estab-is based on the estimates by Bishop er al that the equivalent lished and the absence of an explosive potential of the of 11.9 X 10* Ci of Xe 133 f adjusted for decay) was hydrogen bubble was realized-which appears to have come actually released. If a lower release estimate of 2.5 X 10* about on Saturday. March 31. or on Sunday. Apri! 1, at ,

Ci is used, then the projected boundary dose would be the latest--it seems reasonable to have expectec that con. i about ave times greater. sideration of evacuation would have terminated. The NRC The above estimate implicarly assumes that the average however. never did straightforwardly disavow the threat  ;

meteorological dispersion during a week or so after the from the hydrogen bubble. and so the " emergency" psy.

accadent would have been applicable to a shorter time chology it created was slow to dissipate. The Governor's l

period. A more comervative estimate may be made by advisory to pregnant women and preschool children was I taking into account that about 70 percent of the total, or not formally lifted until April 9. two weeks after the about 1.75 X 10* Ci of Xe 133 (using the lower estimate), incident."

e4 que.,gaa NEWS aoot .ns-l L __ _____-

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The current situation: good news and cad news Island supports the NRC's judgment of the need for addi.

tional attention to emergency response planning, it is open Good News. The President's Commission found that the NRC had erred with regard to the explosive potential of to question that the incident " clearly" demonstrated the need the hydrogen bubble.58 It also found that had a mettdown for the degree and extent of the protective measures being occurred, there was "a high probability that the containment ca!!cd for by the Commission. Also, while it clearly dem-onstrated that the perception of on-site conditions by vari-building and the hard rock on which it is built would have ous state and local entities adected the way they reacted, been able to prevent the escape of a large amount of radio-this is of questionable relevance for a future simdar occa-activity." This finding appears to have been based on the sion. Should one occur, it is to be hoped that the concerned report of the President's Commission's Technical Stad on Alternative Event Sequences.

utility, the NRC, the state radiological and health bureaus.

and the Federal Emergency Management Agency have a De technical staff also stated that the high retention of better coordinated mponse, m which case the confusion iodine in the primary water was attributable to "the chemi.

th*: reigned durms the mcident should not be replicated.

cal reducing conditidas existing in the water near the fuel This confusion was a signincant contributory factor to the at the time of the releases of the iodine, to the high pH of reaction of the state and local agencies to what were largely the water, to the high chemical activity of iodine and possibly imagmed dangers. Had these agencies responded to the situ-to the presence of silver in the reactor vessel" They also in- ation in a more c rdinated way. the Public perception of dicated that if all of the zirconium cladding of the fuel had

• *** N reacted with water and the hydrogett gas so generated had been much "*"'N dimmished. In the author.s judgment, this should burned or detonated, the containment building would have remained intact. They also concluded that a steam explosion be m of th mm knpnant anchons hm me mch leading to a failure of the containment would have been but it does not yet seem to have been given appropriate emphasis m the "fessons learned.

unlikely. A recent study in Sweden has come to the same One of the principal features of the emergency planning conclusion with regard to steam explosions in LWRs.8' This mie is the adopuon of the NRC EPA task force recom-is the type of accident that was postulated in the Reactor mendation that enlarges the zone for which detailed emer.

Se/ary Study to lead to the !argest atmospheric releases of radioactivity of short duration with minimal warning time. SenCY planning is to be provided. As already indicated, its radius is about 10 miles for the plume-exposed pathway and Bad News. The bad news is that these findings of the abat M mile for the ingesuon pathway. In light of the President's Commission and its technical staff seem to have improbability of immediate life threatening exposures be-gone almost entirely unnoticed by the public, by the media, and even by the regulators. Judging by their extent the yond the existing LPZ. the extent of th,si plume exposure requirements being called for by the NRC on the basis of EPZ appears excessive. In efect, it applies the same rigor t the desirab/c objective of the minimization of population

" lessons teamed from the TMI 2 accident seem to call for the erection of a stout fence against the escape of a horse dose and the possibility of hypothetical lats efects as it that might slip its tether, but has little likelihood of getting applies to an bviously urgent objective the prevention of out of its stall and much less than previously surmised of eady fatal edun w dnen m nea@ pene.

escaping from the barn.

With regard to most other planning for natural or tech-n I gical catastrophes, the emphasis appears to be on the An example is to be found in the NRC's rule on emer, gency planning.a which calls for its considerable augmen. Pmvmion of imenm fatal eduts w imunes. Subtle and/

tation both on- and odsite. Although the rule is intended or long-term hypothetical efects (similar to those associated with up to a few rems exposure to radiation) do not appear to assure that " adequate protective measures" can and will be taken in (Se event of a radiological emergency, evacua-

• ***"I * *II " 'Y 7 " "'F"" ' '

emergency planning rule appears to make dose minimiza-tion is the only measure that is specifically mentioned. Not tion mandatory in all cases, without allowing for considera-only is it thus given prominence but much of the other ti n f the cost-benefit trade-otYs generally applied to low-required offsite plannmg appears to be closely related to dose radiation in other situations. In a recent study m, which evacuation-i.e., notification, dissemination of instructions, the costs of remedial actions were compared to the mone-

' communications systems, etc.

tary value f health efects averted, it was found that even In the supplementary information to the rule, both as initially proposed and in the final version, the NRC stated r a release of 10? Ci of I 131 and associated fission that in the aftermath of the accident at Three Mile Island, pmduen. namah wM not k cMW d meM

"[ slate siting and engineered features alone do not optimize to nelude pene exped m < W rd Based on the protection of the public health and safety."It further stated

. - me eIPenence, the m of tMs enMon wald have restncted remedial actions to within the previously that "{t]he accident showed clearly that the protection pro-vided by siting and engineered safety features must be accepted N bolstered by the protective measures during the course of Evacuation: the wrong emphasis?

an accident" and also that it "showed clearly that on-site Of the several modes of potential dose minimization, the

conditions. even if they do not cause significant otY-site new rule appears to give undue emphasis to evacuation.

radiological consequences will adect the way the various Both the report of the NRC-EPA task force on emergency

• l state and local entities react to protect the public from planmng and a related IAEA report" suggest that, whereas dangers, real or imagined, associated with the accident." In evacuation may be in many circumstances the most edective the light of this the Commission concluded that "the public close-in mode of protection action. at greater distances from a can Le protected within the framework of the Atomic reactor site it may be less efective than sheltering. The Energy Act only if additional attention is given to emer- minimization of dose by alternative measures such as the gency response planning " control of ventdatsn. respiratory protection, or iodine While the confusion followin: the accident at Three Mile prophylaxis is also considered in these two reports. As both ,

i NUCLEAR MWS / APRIL 1981 86 f

observe, a malfunction could occur during weather condi. to feel that they are being adequately protected against tions when evacuation might be dificult or even impossible. possible natural disasters. let alone with comparable infor.

Thus, it seems unwise to condition emergency authorities and marion about the toxicity of specific chemicals that might the public to think almost exclusively in terms of evacuation get abroad in large quantities because of technological as the only available effective or most desirable protective failures.

measure in the event of a large airborne release from a In comparison with emergency planning requirements of power reactor. other countries. some with larger populations close to power in the author's view, reasonable emergency action plans reactors than are found in the United States, the new rule should include a set of preestablished responses, graded seems excessive and unduly preoccupied with evacuation. In according to the probability of the risk, as well as to the West Germany, Switzerland, and Japan, for example, the severity of the effects that might be incurred. The rule does recommended initial protective action is sheltering."" As not do so; rather, it seems to call for the same degree of shown, in Fig. 5, in West Germany evacuation 4 contem-protective planning for severe events with anticipated likeli. plated only after some hours subsequent to the passage of hoods of 1/20 000-i/100 000 per year

• as it does for smal- the cloud of radioactive material released during an acci-ler ones that might be expected to happen much more fre- dent. and then only for persons who might be exposed to quently. In the case of flood plains, earthquake severity more than 25 rem if they remain sheltered. Emergency zones, prospective tornado impact areas, and the like likeli- response, prior to actual measurements of radiation levels, hood of recurrence generally seems to be considered in such is contemplated only within a radius of 5-8 km (3-5 miles).

planning. In order to achieve a sensible allocation of effort Beyond this radius. their pas call for a graded response and resources, this factor ought to be considered in the case based on actual measurrwents and only if, without counter-of emergency planning for nuclear reactor malfunctions. measures, the projecod dose would exceed the 25-rem it is almost self-evident that events with small conse. " emergency reference levels." The Swiss and Japanese emer.

quences are more likely than are those with large ones. gency plans are similar in principle.

This raises a serious question about the desirability and/or As is the case in the United States. these plans are based need for providing the detailed information called for in on release estimates that correspond closely to those in the the rule to the public throughout a 10-mile EPZ on a yearly Reactor Safety Study (WASH 1400). That these estimates frequency. The net result may well be to exacerbate the are unduly conservative is suggested not only by the Th!I-2 prevailing excessive fear of radiation." and thus to be con- experience, but by recent reviews of past evidence from ducive to precipitate action if and when these minor events experiments and incidents by Levenson and Rahn" and by do occur. The author believes a more prudent approach Storowitz. A study of the ulution chemistry of iodine in would be to assure the public that in the event of an acci- containment structures, which also supports this contention, dent they will have information and instruction from an has recently been provided by R. Lemire et al.ss, authoritative and informed source, as is the practice with regard to most other potential hazard situations. In this Conclusion same vein, it may be observed that it is not deemed neces- It appears to be generally recognized that almost all of sary to provide the public with d: tailed advance information the radioactivity that was released from the fuel during the about meteorology, hydrology, seismology, etc., to lead them Thti-2 accident was successfully retained within the con.

+s ~~

~

2.t. km \

B jB 2 3

C D3 \ D2 am  ; \

g a D$(7d)s100 rad DLa00c)s250 rod Oya (30c) e25 red

/

s' 250 red s des (30cl a25 rad O$(7d)= 7dcy cutdecr bene mcrrow dose due to externel expcsure from ground 0$(3 Col = 30yect outdoor whole body dose due to externet exposure frcm grcund Ag. 5: Senemanc of protective actior's mocol. A: Snettering two nours after coerator knows release will occur (t=2h): evacuaticn at t=6h; travel time,15h. 8,: Sheitenng at t= M: fast relocation tames atace eitner two mours after clouc =assage or t=t4n. i wnicnewsr is larger: travel time cocendent on population. S.: Normat actmties: fast redocation as in Area 8,. C. Normal actm-ties; retocation begins t=30c. D,: Normal actmties: cecontamination to recuce O*' (304) to 25 rad. D : Normal actmties.

Core 5fr/t. Massachuscits institute of Teshnology. Departmens tainment building and that no more than 10 percent of the of Nuc! car Ensmeering (1978L fission gases escaped. via the auxiliary building. 11. USNRC. Investitarum mro the March Je. leio Three Mole I..

It seems to be insuSciently recognized that, except for land Accident be the m?>ce of Inspecswr and Entvecement.

the fission gases, almost all of the other radioactivtty that NUREG.06m (July 1979).

escaped from the fuel was retained in the coolant system 11 J. G. Kemeny er al. Arport of the Presulent's Commmion mr or in the water that leaked from it by essentially panive 'he Ace' den' 8' Th're Vde l'tand. U.S. Prit Office (October mechanisms. Some of these were suggested by the Technical 37 ,,,,, ,, g, 7,,,,, ug, Island. A Arport to the cum.

Stad on Alternative Event Sequences. Additional passive og,,,,,,, ,,g ,, ,3, p,3f,c. U.S. Prts. OfRce (January 19An n.

retention mechanisms for the retention of radiciodines and 14. ne author was a member of the initial re ponse team tat arookhaven National Laboratory) from the Department of aerosols have recently been indicated in the recent reviews Energy Radiolosical Assistance Program (RAP) Region I. which of release data from a number of fuel melt esperiments. arrived at Ha fisburg at 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> on March 28. The teami oeliberate tests. and unplanned incidents at operating re. subeewn participation in DOE's larger response has been act actors, with and without containment. These data indicate forth by P. L contelon and R. C. wittiams. Crisis Contamed.

that except for the radioactive noble gases, the current esti. DOE'EV ~10278.T1 (1980L 8' port of the Coternor r Commnsum

!! W ** 88""- " 8'-

mates by the NRC of potential releases of assion products ' " " " "" ' "'"

to the environment from power reactor malfunctions are *[g*p'e 19 unrealistically conservative, possibly by several orciers of 16. W. P. Dornsife. "The TMI Accident. As It Really Happened."

magnitude. paper presented June 10. 1980, at the Annual Meeting of the American Nuclear society. Las vesas. Nev.

This is not to suggest that the TMI 2 accident does not " 'h' ^d'"' ** D "' MII' I"*"d' 87 P"'id'" C'***'*"

support the desirability of some improvements in emer.

Report 09 the Emererner Preperedness and Respome Tea Ton e, gency response, especially .tn tts planning and organization. U.S. Pris. Omee (1980 L But neither TMI nor any other relevant experience appears 18 A. P. Hull. A Cntreue of Source Term and Emironmenial Mca.

to support the notion that the potential for sirborne re. surements of Three MJe Island. BNI *69*0 6197H.

19 President's Commission. Aerorr of ihr Tad Group on Nealth leases from a power reactor malfunction is suscient to # " ""

warrant the kind and extent of emergency planning that is ,0.D$ Cam t. i c m" u I 29. 1980 currently being called for. Rather, it seems t.n example of 21. W. N. Bishop et al "Fissaon Product Release from the Fuel s regulatory caution that does not necessarily constitute wis- Followins the TMI.: Incident." presented Apnl A 198to. at 198n ANS ENS Topical Meeting on Thermal Reactor Safety. Knos-dom and that could be potentially counterproductne to the optimum protection of the public as well as of questionable cost. effectiveness tn most realistically imaginable snuations.

I"{C Techwal Sid Mins bit = Al-ternetise Eient Scenences. U.S Prts. Omce (1980).

In its review of the TMI 2 accident, the Congressional 23. L 8ettist and M. J. Peterson, Jr " Radiological Conicquence-Subcommittee on Energy Research and Development con. of the Dree Mile Idand Incident." in Aadiar on Prorection.

Procudings of fth International Congreu of the International cluded that the NRC had devoted too much attention to Au ciati n (Elmsford. N.Y. : Pergsmon pipe break accicients leading to sudden large loss of coolant *'hProtection and that safety research had focused on the ability of the 24. Table V of Reference 9.

emergency coolant system to replace these losses." The sub- 25. K. M. Becker. Steam Explosions in light Water Aractors. KTH.

committee concluded that there is a need for the study of NEL 27 (1990).

i :6. USNRC. "Emersency P!annins" IOCFR50 and 70. Final rule.

scenarios that develop much more slowly, it also called for FR 45:162, pp. ??40215 ( August 19.1980).

additional research in more important areas of small pipe 27. L Fritelli and A. Tamburrano. " Emergency Planning: Can the breaks. combinations of circumstances, and human factors. Remediat Actions Costs se compared to the Monetary value of By analogy, the TMI 2 experience strongly suggests the the Health EReets They Sase". IAEA.CN 19. Paper No. 50 f m publication).

desirability of graded planning for emergencies, with the E Intunations! Atomic Ennsy Asency, Planning For 0#4ne Ao emphasis on the more probable rather than the most ex- sponse to Radiarson Accidente at Nuclear Facsintrer. lAEA.

treme cases. TECDOC.*:S (19*9).

'9 R. Dupont. Nuclear Phobia- Phobie Thmkmr Abour Nuclear Power. De Media Instttute. 3107 M Street. N W Wa<.hington.

Reforences D C. :enot <19e0).

1. U.S Atoauc Energy Commission, Theoretwel Poss46 dines amt 30. A K. Burkhardt. "Modelins of Protective Actions in the Ger.

Conseguences or Maror Accedenis m Large Nucleer fomer tfants. man Rhk Sedy." IAEA-CN-39 Paper 35 fin publication).

4 WASH.740 (1957). " *#'* " " *

• 8*" th' '

2. , The Sarery of Nuclear Aeactors. WASH.t:50 s1973). Comquenen d Senn Acadents an Nuclear Power Plants."

3. U.S. Nuclear Regulatory Commmeon. Emerrency Plannme fo, IAEMW Pam 1 Un puhtent

! Nucleer Power Plants. Regulatory Guide 1.101. Rev i (1977). 31 Japanm Nuclear Safety Commnsion. OS site Eme'rener Plan-

4. - . " Reactor Site Critena." 10CFR100 f1967).

"*'t *"A !!*d"'" I*' N"'k !** 'I"* 5******" k' 1, 5. M. Garreon. Aerort of the Offnce of Chief Counsel on Emer. m OStiu Emergency Plannins and Preparednns for Nuclear

'

• sency Preparedness (to the President's Commmeon). U.S. Pnnt. Power Plants. Tokyo (1990).

ins Osce (1980). 33. M. Lasenson and F. Rahn. "Realsuc Esumates of the Conse-A R L Rounussen et al., Acactor Satern Sindt WASH.1400 (197!).

quences of Nuclear Accidents." paper presented at 1980 Winter

7. National Conference on Radiation Control. Radiaten sene4rs Muuns of ANS. Washington. D C.

and Aists: Facts. Issues and Ortens. HEW.FDA 77 8021 (1977).

9. H. E. Collins et al.. Pfanamt Sans for the Deielopment of Siare R H. A. Moreutz, "Fisuon Product and Aerosol Schavior Foltos.

and local Generveent Radiolotwal Emereency Response Plans ins Destaded Core Accidents." to be published an Nuclear Tech.

ue Suerert of Laeht Water Nuclear romer !! ants, NUREG.0396 "oloty. l (1979). 31. R. Lemire et al Assessment at lodme Behestor :n Contamment I 9 U.5 Envsronmemal Protection Agencv. Vanrest of Protectn e from a Chemaral Ferrpecris e. AECL 6812 f1981). i Actson Gundes and Protectne Acrens for Nuclear inculenus. EP A 36. U.S Congress. Nuclear Po er ?? ant Satruv Arrer Three Mae i

$20 173 001 (197?). Island. Subcommittee on Energy Research and Producten of

10. D. C. Aldrich. Essamerson of Of Site Aad.oloercal Emereem the Comtruttee on Science and Techno4osy. 96th Congress. Com.

Proverave Messures for Nuclear Acacror Accadents Imoliar mittee Print Serial JJ. U.S. Prts Omce i1990). ,

t NUCLEAR NEWS / AMit.1981 67

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