ML20052H197

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

ML20052H197
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/14/1982
From:	Amy Hull AFFILIATION NOT ASSIGNED
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, . Limitcd Appsarrnca Statemint of Andrew P. Hull bafora Atomic Safety and Licansing

. . B ard of th2 U.S. Nuclear Rsgulatory Commission - In ths MStter of

• Long Island Lighting Comptny (Shorchtm Nuclear Powar Statien -

Unit 1) Docket No. 50-322-OL, April 14, 1982 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 promote the availability of factually accurate information about energy to the public, which I believe is essential to the formation of sensible public policy in this area. Common 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 diversification. I start from 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 (1 - 6). Uniformly, they have concluded that those of the nuclear fuel cycle are as low or lower than any of the other p r acti cabl e alte rnatives. Whatever criteria are employed for deciding for or against any of the available choices, in my view neither the overall health risks nor their relative risks are sdfficient to warrant selecting or rejecting one fuel cycle 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 820520<H153 820430  !

PDR ADOCK 05000322 i T PLWt

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l has gcently 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 thereafter became responsible for the interpretation of the extensive environmental 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 than had been anticipated.

Subsequently, I have presented several technical papers on emergency planning at meetings of the American Public Health Association, the American 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 its technical background appendices). My most recent article, " 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. My essential argument in this article is that both NRC's current requirements for emergency planning and the public perception of the consequences of a nuclear accident are excessive and lacking a technical basis from 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. No. thing hapoened at TMI to warrant the enlarge-ment of this zone. On that occasion, only the radiogasses were released in large quantities. The maximum dose to the most nearby persons was about 100 milli rem s (equivalent to the extra background radiation they might have

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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 a large power reactor such as Shoreham (a most unlikely event, compared to the 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 TMI, several scientists have made careful examinations of the release mechanisms at TMI and of a number of previous smaller inten-tional and unintentional incidents. All of the evidence from experience suggests that the probability of the release of radioiodines or solids is during a water-cooled power reactor accident is appreciably lower than had been assumed heretofor.

In the absence of such releases, there is simply no reason (aside from the current paranoia exposure to radiation, no matter how infinitesimal) for an emergency response beyond the LPZ. There is even less warrant'for evacua-tion, which in my view is being over-emphasized. If there is a serious mal-function at Shoreham or any other power reactor in the-northerly portions of the'U.'S. wnere almost all homes have cellars, the first response should be

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shel_tering, which would avert a life-threatening dose from the largest imaginable release of radiogasses. ~

r l The current think'ing about evacuation with regard to reactor malfunctions

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l seems to me akin to contemplating it to ' escape from the projected path of a

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hurricane which it is still hundreds'of miles at sea and many hours away, or l

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l to escape the possible path of a forest fire which is still many miles dis-l tant. In neither case does it seem wise or prudent to adapt a protective strategy which could result in large numbers of persons being on the road at w

, i il the time the hurricane or fire actua'l ly arrives and possibly in its actual path with less protection than they would have had by staying put in their 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 judgment, 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 has actually occurred. In this extremely unlikely possibility that they are present in sufficient amounts to result in large dose-rates, there would be time to accomplish an orderly removal of those significant risk.

Immediate sheltering of those close in (within a few miles of a power reactor) on 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 p , ' rams, (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 a versons at unnecessary risk. ,

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REFERL FS l

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1. USAEC, Comparative Risk-Cost-Benefit Study of Alternative Sources of Electrical Energy, WASH-1224 (1974).

2. C. L. Comar and L. A. Sagan, " Health Effects of Energy Production and Conversion", Annual Review of Energy, J. M. Hollander, Ed., Vol. 1, (1976).

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3. H. Inhaber, " Risk of Energy Production", AECB-1119, (1978) .

4. WHO, " Health Implications of Nuclear Power Production", World Uealth Organization (1978).

5. NAS-NRC, Energy in Transition to the Year 2010, Report of the Committee on Nuclear and Alternative Energy Systems, National Academy of Sciences-National Research Council, (1979).

6. L. D. Hamilton " Comparative Risks from Different Energy Systems:

Evaluation of the Methodology of Studies", International Atomic Energy Agency Bulletin, 22:5/6, p. 35-71, (1981).

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Emergency preparedness for what?

(Implications of the TMI-2 accident) by Andrew P. Hull The possibility of a major accident at a large nuclear TABLE I power plant was recognized at the outset of the commercial PotsNTIAs. Orrsrrs doses DtrE To DESIGN-Basts implementation of nuclear power in the United States in AccmENTs (CossEnv4T!vs Crss)*

1957. A study of the theoretical possibilities of such an accident and of the consequences of various accident cases. Two. Hohn DURAT1oM OF ACCIDENT with or without large uncontrolled releases of fission prod. ExcLustoM BocNoaar t.ow Porctanow ZONE ucts to the environment, was initiated by the U.S. Atomic #3200 '*) I' M"**'

Energy Commission at that time.2 For the worst postulated Acetoext Thyroid Whole Body Thyroid Whole Body I"") ' "") I "" ' ' "" )

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 tory of fission products-the study envisaged the necessity Controt Rod Ejection <1 <1 <1 <!

of the evacuation of as many as 460 000 persons from an [',' $dI, Q ak 1 I area of 760 square miles. 10CFR100 Dose Prior to the accident at Unit 2 of the Three 5 file Island Guideline 300 25 300 25 station on 5farch 28,1979, however, formal planning for protective actions (including evacuation) was generally not required beyond the low-population zone (LPZ). The LPZ Radiation Control Program Directors passed a resolution is the area beyond the site boundary within which. during in 1976 asking the NRC to make a determination of the most severe accident basis for which radiological response 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 otYsite agencies." A task force tion dose of more than 25 rem or not more than 300 rem consisting of NRC and Environmental Protection Agency to the thyroid due to exposure to or inhalation of constit. representatives was convened to address this request and uents of the radioactive plume.2 Some potential otisite related issues. It y. epared a report, published in 1978,8 on doses due to several postulated incidents, including the the planning basis for the development of state and local ,

maximum design-basis accident, are shown in Table L They are based on !rakage from the containment at the peak '

pressure.8 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 T51I accident, the NRC F stati had adopted a position that a distance of 3 miles to the outer boundary of the LPZ was usually adequate.8 }N ~~"'*""'**

A more sophisticated assessment of power reactor a'ci- /

dent risks than that contaiced in the 1957 study was pub- g

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lished by the U.S. Nuclear Regulatory Commission in , N ,

1975.' This assessment adopted an evacuation model for a j \.

l serie s of postulated reactor malfunctions, the area of which h'\

1 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- ,

g tion. As shown in Fig.1, even a very slow effective evacua- - \ T tion speed of 1.2 mph was expected to materially reduce the probability of early fatalities for the most severe postu-e  :-

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lated releases from a pressurized water reactor (PWR). As -

k\ e also indicated. more rapid etYective speeds were expected '

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to reduce this probability to near zero.

As a result, at least in part, of concerns raised by this Y  : ,

assessment, an ad hoc task force of the Conference of 1 l l

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Sir. Hull is supervisor of environmental monitoring. Safety and j' Environmental Protection Division, Brookhaven National Lab- .,*, ,', ,, ,, ,, ,,,  ; ,, ' , ',

oratory, Upton. N.Y. This article is a revised version of a paper .

of the same title presented at the American Nuclear Society's Executive Conference on State / Federal / Nuclear Industry later. Fig. 1: Concitional prooability of early death as a function of face. Sfonterey, Calif., February 4.1981. distance from reactor

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eNCt.imt ty. 1; 4rm sep

• farce and a request f:r public comment was pubhshed in the Federal Register on December 15,1978 (42 'FR 58658). The indicated deadline for such comments was i

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T"- -N March 30,1979--two days after the T51I 2 accident.

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h Evacuation: was it technically justified?

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

\ even weeks after the initiating event at T51I-2 at 4 a.m.

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

1. g,7f.,::.""-- ,,,, '

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CT*'"" depth reviews.u-u From their accounts, as well as from

\ - a- - the author's first. hand involvement." it is evident that the

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\ E5:"" directly concerned radiation protection agency, the Bureau

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of Radiation Protection of the Commonwealth of Pennsyl-vania's Department of Environmental Resources (BRP),

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did not initiate any recommendations for evacuation at any time during the incident.

a The legal authority for the proclamation of a state of f " 4""" ::L'.*%

.. emergency and for ordering an evacuation belonged to the f l

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

/ cise this authority would have been based ott information

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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 communicatiom were ditlicult. 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." These guides were 5 rem whole- Energy's offsite 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 around each nuclear protective actions."

reactor, both for the short-term " plume exposure pathway" Starting on Thursday afternoon (Starch 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, miles. 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 of 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.

1 that evacuation appeared to be more effective than shelter- morning on Friday. NIarch 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 otlice by the BRP. which had more accurate and more nonparticipating segment of the population were kept sufft- current information." 1.ater on in the day, the NRC be-ciently small. Between 5 and 10 miles. this distinction was came concerned about the explosive 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-l tion between the benefits of sheltering and evacuation in cording to a study, 21000 persons within a 5-mile radius terms of projected early fatalities or injuries. and 144 000 persons within 75 miles did evacuate, many It is interesting 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 $9.8 million.n In the months I 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 Aesponse Task Force to the President's bounds on the planning problem. The Task Force does not Commission on the Accident at Three Slile Island indicated recommend that massive emergency preparedness programs that federal otficials in several key 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 with the appropriate radius, bilities already e.wted under the general emergency plans with proponents arguing variously for 5.10. and even 20

.of federal and state agencies. miles."

'A notice of the availability of the report of the task Almost from the onset, it was established that the radio.

I 62 NUCLEAR NEWS / APAll 1981  ;

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activity th:t w*s being retrased to the atmosphera as a re-suit of the accident did not come directly from the contain- so too co so as e ment building, but rather indirectly from leakage from the coolant letdown system and gaseous waste treatment sys-tems in the auxiliary building.22-" From the results of the first post accident sampling of the primary coolant water on Alarch 29 and of the containment atmosphere on Afarch i as e 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 "

so the containment atmosphere. The total release of Xe-133 from the auxiliary building was estimated by the President's 73 Commission as between 2.4 X 10' Ci and 13 X 108 Ci, er 'o 2-10 percent of the core inventory. Other evidence, how-ever, suggests that the actual amount released was closer to ,n ,

the lower estimate.2' t' The early sampling indicated that g 4.4 X 10' Ci of iodine-131, or 7 percent of the core inven-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 \ c N g X 10' Ci; auxiliary building tanks, 4.0 X 10* Ci. The /

total,22 X 10* Ci. was 34 percent of the equilibrium core 3 / ,3,,,,

inventory. g The early sampling also indicated that 4.3 X 103 Ci, or 0.007 percent of the core inventory of I-131 was airborne O no WI in the containment atmosphere. The President's Commis- Ag. 3: Estimated dose in vicinity 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 T5tl boundary would a typographical error.2" 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 Ci. The President's Commission indicated that 13- of g,g3 g, 17 Ci were released to the atmosphere through the next month. What if7 The 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 radioiodines 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 tabulation showing the amounts of some of the doses for the same period, as measured by the utility's principal nuclides 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 Th112. was less than 100 atmosphere during the incident, normalized to Starch 29, TABLE II DisTutsurtoN or XE-131, XE 137,1 131, Cs-137. AND Sp-90 AT TS11-2 (NonMatizEo To 0400 Hot lRs. STARCH 29,1979 ExcEPT ron I 131 To APRit. 4,1979)

Cons PRIMAny CONT A MW AMD COMrAMINAMD Ag7tgggggy giltLDino (Q) Rar.

luvuxtoav systzM WAnn Aza

. (C) (O) (C) (C) Waran Aza Xe131 4.1 x 10s  ?  ? ,3 x los  ? 3.4 x 104 21 Xe 133 1.45 x 10*  ?  ? 8.73 x 107  ? 1.19 x 10" 21 I-131 6.38 x 10' O.75 x 10- I.06 x 10' 4.3 x 101 0.4 x 10? 140 " 12 Cs137 8.45 x 10' l.31 x 10s 3.65 x 103 -

0.11 x 105 -

21 St.90 7.8 x 10s < l.4 x 10' <4.2 x 102 -

< 0.1 x 102 -

21

• Eventually released as 8.3 x 10e C1 (Ret 21). Lower estimates of Xe.133 released include 2.4 x 10* C tref.18) '

and 2.9 X 108 G (Ret 19).

i "fac!udes asumated 125 Ci retaaned on ft!ter and 15 Ci released from stack. ,

NUCl. EAR NEWS / APRll 1981 63

.- .. - = . _ _ _ - - _-

s ,

l ivas released durirg thz first 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> after 'thi acciaent,88 notease m anacrea emonie and that a potential boundary dose of some 500 mrem, as I

"*E e come 6 ease m ass measured on an essentially unoccupied island 0.6 mile to 10 % e 2 ",,*,",8,*** the northwest of TMI-2 (see Fig. 3), was delivered during ro4=uamsma-o y 'g h .o2=e this same period. With the use of these data, a boundary esses .a ma aan

'** C"" dose at that location of about 25 rem can be projected if

'***" the entire 8.7 X 10' Ci of Xe 133 that was airborne in 8'* " ,,, ,, ,,,

" 8='r** 'co== the containment had been released during this same period.

\ This estimate may neglect some portion of the shorter-li-sd

^ noble gases, such as Xe 135 (9.1 hr) and Kr-88 (2.8 hr),

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\ which could have been significant contributors to environ-mental dose within the first day after the accident. Con-sidering these and supposing that the containment failed during the afternoon of March 28. one could arrive at a y ausmana, sumane projected boundary dose as much as five times greater than g that projected solely on the basis of Xe-133.

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In any event, this suggests that only for an accident that f,', ".","84 resulted in a prompt release of a large fraction of the core inventory of radiogases into the containment, followed very Fid. 4: Release fractions at TMI-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," except for I 131, which is from the report boundary or close to it. Furthermore. if one assumes that of the President's Commission.88 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 criterian would ant and the fraction of the latter that was released from the probably have been confined 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. Much 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)," could have been exceeded beyond 10 miles from ment building sump." 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 bui! ding. to the auxiliary building. of a child from the elevated release of 15 Ci of I 131 is and 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 I 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 rem or even the there was a widespread concern about public safety espe- current upper PAG Ievel of 25 rem. A ground level release cially in connection with the " hydrogen bubble" scais, 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/m2). could have produced an inh =In-activity released as on the perceived potential for much tion dose of about 100 rem to the thyroid of a nearby larger airborne 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 based more on imagination than on realism.

Xe.133 produced a dose of approximately 100 mrem at If there were a priori 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 exposure 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 mrem. This projection was actually airborne in the containment had been estab- .

is based on the estimates by Bishop et al that the equivalent lished and the absence of an explosive potential of the  !

of 11.9 X 10' Ci of Xe.133 (adjusted for decay) was hydrogen bubble was realized-which appears to have come actually released. If a lower release estimate of 2.5 X 108 about on Saturday, March 31. or on Sunday, April 1, at Ci is used, then the projected boundary dose would be the latest-it seems reasonable to have expected that con-about five times greater, sideration of evacuation would have terminated. He NRC The above estimate implicitly 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.

accident would have been applicable to a shorter time chology it created was slow to dissipate. The Governor's period. A more conservative estimate may be made by advisory to pregnant women and preschool children was 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.'8 84 WCtian NEWS aoot 'e*

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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 "ciearly" demonstrated the need the hydrogen bubble." It also found that had a meltdown for the degree and extent of the protective measures being occurred, there was "a high probability that the containment called for by the Commission. Also, while it clearly dem-building and the hard rock on which it is built would have onstrated that the perceptica of on-site conditions by vari-ous state and local entities afected the way they reacted, been able to prevent the escape of a large amot:nt of radio-activity." This finding appears to have been based on the this is of questionable relevance for a future similar occa-sion. Should one occur, it is to be hoped that the concerned .

report of the President's Cornmission's Technical Staff on Alternative Event Seq.ences.u utility. the NRC, the state radiological and health bureaus.

and the Federal Emergency Management Agency have a The technical staff also stated that the high retention of j better coordinated response, in which case the confusion iodine in the primary water was attributable to "the chemi-cal reducing conditions existing in tiie water near the fuel that reigned during the incident should not be replicated.

This confusion was a sigmficant 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 imagined dangers. Had these agencies responded to the situ-to the presence of silver in the reactor vessel." They also in-ati n in a more c rdinated way, the public perception of dicated that if all of the zirconium cladding of the fuel had the seriousness of the TMI accident would very likely have reacted with water and the hydrogen gas so generated had been much diminished. In the author,s judgment, this should burned or detenated, the containment building would have be one of the most important conclusions from the ,ncident.

i remained intaut. They also concluded that a steam explosion leading to a failure of the containment would have been but it does not yet seem to have been given appropriate unlikely. A recent study ir Sweden has come to the same emphasis m the " lessons learned.

One of the principal features of the emergency planning conclusion with regard to steam explosions in LWRs." This is the type of accident that was postulated in the Reactor mle is the adoption of the NRC. EPA task force recom-mendation that enlarges the zone for which detailed emer-

< Safety Study to lead to the largest atmospheric releases of radioactivity of short duration with minimal warning time. gency Pl anning is to be provided. As already indicated, its Bad News. The bad news is that these findings of the radius is about 10 miles for the plume-exposed pathway and President's Commission and its technical staff seem to have about 50 miles for the ingestion pathway. In light of the gone almost entirely unnoticed by the public. by the media, improbability of immediate life. threatening exposures be-and even by the regulators. Judging by their extent, the y nd the existing LPZ. the extent of this plume exposure requirements being called for by the NRC on the basis of EPZ appears excessive. In effect, it applies the same rigor to the desirab/c objective of the minimizz: ion of population

" lessons learned" from the TMI-2 accident seem to call for

. the erection of a stout fence against the escape of a horse d se and the possibility of hypothetical late effects as it I that might slip its tether, but has little likelihood of getting applies to an obviously urgent objective. the prevention of out of its stall and much less than previously surmised of early fatal effects or illness to nearby persons.

escaping from the barn. With regard to most other planning for natural or tech-An example is to be found in the NRC's rule on emer, n I gical catastr phes, the emphasis appears to be on the gency planning," which calls for its considerable augmen. prevention of imminent fatal efects or injuries. Subtle and/

tation both on- and offsite. Although the rule is intended r I ng-term hypothetical efects (simdar to those associated to assure that " adequate protective measures" can and will with up to a few rems exposure to radiation) do not appear be taken in the event of a radiological emergency, evacua- to warrant em"gency "protecti# mponm. The y,Cs ,

tion is the only measure that is specifically mentioned. Not emergency planning rule appears to make dose minimiza-

, only is it thus given prominence, but much of the ottier ti n mandat ry m all cases. without allowing for considera-required offsite planning appears to be closely related to ti n f the cost-benefit trade-ods generally applied to low-evacuation-i.e., notification, dissemination of instructions, dose radiation in other situations. In a recent study m, which communications systems, etc.

the costs of remedial actions were compared to the mone-tary value of 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 for a release of 10 Ci of I 131 and associated fission that, in the aftermath of the accident at Three Sfile Island, products. evacuation would not be cost-edective if extended 4 "[slafe siting and engineered features alone do not optimize to include persons exposed to <10 rem." Based on the protection of the public health and safety"It further stated TS11-2 release experience. the use of this criterion would have restricted 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 acceptedIJZ.

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 off. site new rule appears to give undue emphasis to evacuation.

radiological consequences, will affect the way the various Both the report of the NRC EPA task force on emergency state and local entities react to protect the public from planning and a related IAEA report" suggest that, whereas I j dangers, real or imagined, associated with the accident." In evacuation may be in many circumstances the most effective the light of this, the Commission concluded that "the public close-in mode of protection action, at greater distances from a can be 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 ventilation respiratory protection or iodine While the confusion following the accident at Three Stile prophylaxis is also considered in these two reports. As both ,

NUCLEAR NEWS / APRIL 1981 65

observe, a malfunction could occur during wcnher c ndi- to fIel that they are being adequately prot'ected against tions when evacuation might be difficult or even impossible possible natural disasters let alone with comparable infor-Thus, it seems unwise to condition emergency authorities and mation about the toxicity of specifi: 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 other countries, some with 'arger populations close to power power reactor, in the author's view, reasonable emergency action plans reactors than are found ia 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 .t. pan, for example, the .

severity of the effects that might be incurred. The rule does recommer:ded initial protective action is sheltering.3'-38 As not do so; rather, it seems to call for the same degree of shown in Fig. 5, in West Germany evacuation is contem-protective planning for severe events with anticipated likeli- plated only efter some hours subsequent to the passage of hoods of 1/20 000-1/100 000 per year8 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- respotse. prior to actzal measurements of radiation levels, hood of recurrence generally seems to be considered in such is contemplated oaly within a rad;us of 5-8 km (3-5 miles).

planning. In order to achieve a sensible allocation of effort Beyond this radius, th:ir plans call for a graded response and resources, this factor ought to be considered in the case based or actual measurrenents and only if, without counter-of emergency planning for nuclear reactor malfunctions. measures, the projected 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 bued 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 TMI-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 Rahn28 and by do occur. The author believes a more prudent approach Morowitz." A study of the solution 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.88 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 detailed advance information the radioactivity that was released from the fuel during the about meteorology, hydrology, seismology, etc., to lead them TMI-2 accident was successfully retained within the con-

+s .----~~~N s.

2.t. km

\

8 I 82 3

C D3 \ D2 8km s

" USI7d)2100 rod ojo ace)=2scred ) op,B (30a) 42srcd A  ;

/ 8 250 red s DEo (30c) s25 rod D$ (7d)= 7dcy outdoor bone mcrmw dose due to externct expcsure frem ground O$(30c)= 30yecr outdoor whole body dose due to externct {

exposure from grcund Fig. 5: Senematic of protective actior s model. A: Sheltenng two hours after coerator knows release will occur (t=2h): evacuation at t=8h: travel time.1.Sh. 8,: Sheltering at t=2h: fast retocation takes place either two hours after cloud passage or t=14h.

whicnever is larger; travet time dependent on population. B.: Normal actrvities: fast relocation as in Area 9,. C: Normal activi-ties: relocation begins t=30d. O,: Normat activities: cecontamination to recuce 0% (30a) to 25 rad. 03: Normal activities.

Core Melt. Massachusetts Ittstitute of Tevhnology. Department tainment building and that no more than 10 percent of the fission gases escaped. via the auxiliary building. ,,, f3 ,[,,f,[,7,j ,(,',",'he March t im Threr Afde A.

It seems to be insufliciently recognized that, except for land Accident by the Office of Inspectum and En/arcement.

the Assion gases, almost all of the other radioactivity that NUREG-06no (July 1979).

escaped from the fuel was retained in the coolant system 12. J. G. Kemeny et al. Report of the President's Commanion on or in the water that leaked from it by essentially passive 'he Accide"' o' Th"' Mile Island. U.S. Prts. Office (October mechanisms. Some of these were suggested by the Technical Staff on Alternative Event Sequences. Additional passive n[ cr a Thier Mde island. A R port to the Com-misseners and to the Public. U.S. Prts. Omce (January 1980L retention mechanisms for the retention of radioiodines and 14. The author was a member of the initial response team (at Brookhaven National Laboratory) from the Department of aerosols have recently been indicated in the recent reviews Enugy Radiological Assistance Program (RAP). Region I. which of release data from a number of fuel melt experiments. arrived at Harrisburg at 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> on March 28. The teams deliberate tests, and unplanned inc.i dents at operating re- subsequent participation in DOE's larger response has been set actors, with and without containment. These data indicate forth by P. L Contelon and R. C. Williams. Crisis Contamed.

that except for the radioactive noble gases, the current esti. DOC /EV '10278.T1 (1980),

15. W. W. Scranton, u al Repon of the Gournor's Comanuion mates by the NRC of potential releases of fission products on Three Mile Island. Lieutenant Governor, Office. Harrisburg.

to the environment from power reactor malfunctions are Pa (February 1980).

unrealistically conservative. possibly by several orders 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

17. Pmsident's Commission on the Ac&nt at Dm We Nand support the desirability of some improvements in emer- Report of the Emererner Preparedness and Response TaA Force.

gency response. especially in its planning and organization. U.S. Preg. Omce (1980).

But neither T511 nor any other relevant experience appears 18 A. P. Hull. A Critreur of Source Term and Eniironmental Mca-to support the notion that the potential for airborne re. surements of Three Mile Island. BNL.26970 (1979).

19. President's Commission. Report of the Tas4 Group on Health leases from a power reactor malfunction is sufficient to ' " " '

warrant the kind and extent of emergency planning that is ,9, Ca i r n I com u tion. Jul 29. 1980.

currently being called for. Rather, it seems an example of 21. W. N. Bishop et al.. " Fission Product Release from the Fuel regulatory caution that does not necessarily constitute wis- Following the TMI.: Incident." presented April 9.1980 at 1980 dom and that could be potentially counterproductive to the ANS ENS Topical Meeting on Thermal Reactor Safety. Knm-optimum protection of the public as well as of questionable  ::. [ d n$ Comminion. Technical Staf Analisis Report on Al-cost effectiveness in most realistically ,magmable i situations. ternative Event Seguences. U.S. Prts. Office (1980).

In its review of the T5112 accident the Congressional 23. L Battist and H. J. Peterson Jr "Radiologiest Consequence-Subcommittee on Energy Research and Development con. of the nree Mile tiland Incident." in Radiarian Protecten.

Proceedings of fth International Congress of the International cluded that the NRC had devoted too much attention to Protedon A M adon (EinMor1 NL Pugamon pipe break accidents leading to sudden large ;oss of coolant **dI*'(,"

py, go 3 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- :5. K. M. Becker. Sicam Explosions in Light Water Reactors. KTH.

committee concluded that there is a need for the study of NEL.27 (1980L

26. USNRC " Emergency Pfanning" 10CFR30 and 70. Final rule.

scenarios that develop much more slowly. It also called for FR 45:162. pn. !!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. Remedial Actions Costs Be Compared to the Monetary value of By analogy, the T>ll-2 experience strongly suggests the the Health Effects They Sase?". IAEA.CN-39. Paper No fn im desirability of graded planning for emergencies, with the publication).

21 intunsd nal At nde Enugy Agency, r!anning for OAsite R..

emphasis on the more probable rather than the most ex- sponse to Radiation Acendener at Nuclear facthries. lAEA.

treme cases. TECDOC.2:! (1979).

29. R. Dupont. Nuclear Phobia: PhoMe Thinkung About Nuclear Power. The Media Institute. 3107 M Street. N.W Washington, Refererices o C. :0007 r19s0).

1. U.S. Atomic Energy Commission. Theoretical Possabilitses and 30. A. K. Burkhardt. "Modeling of Protective Actions in the Ger.

Consequences of Maior Acendents in large Nuclear Pomer Plants. ,,, y;,g g,,4,,. IAEA.CN-39 Paper 35 (in publication).

WASH-740 (1957)'

• L * " #*

• Mk W#* '* %** * ***

L . The satery of Nuclear Reutors. WASH.1:50 t t973).

Conwouencn of Sevue AcMents in Nudear Pomu Mants..

3. U.S. Nuclear Regulatory Commission. Emergency Plannene for IAEA.CN.39 Parer 8.2 (in publication).

Nuclear Power Plants. Regulatory Guide 1.101. Rev 1 (1977).

32. Japanese Nuclear Safety Commission. Odf-site Emrerency Plan-

4. . " Reactor Site Criteria." 10CFR100 (1967). S *b'* * *"'

S. S. M. Garrison. Report of the O!!ke of Chief Counsel on Emer. "'"' **# P*#"'" I*' N*'I'*' ! * *' !I""

on Off-site Emersency Planning and Preparedness for Nuclear

= rency Preparedness (to the President's Comnussion). U.S. Print.

Power Plants. Tokyo (1980).

ins Of5ce (1980).

& N. L Rasmussen et al.. Reactor saferv Studv. WASH.1400 (197!).

33. M. Icenson and F. Rahn, " Realistic Esumates of the Conse.

quences of Nuclear Accidents." paper presented at 19#0 Winter

7. Nauonal Conference on Radiation Control. Radiaten Benents and Risks: Facts. Issues and Optsons. HEW.FDA 77-8021 (1977). Meeting of ANS. Washington. D.C.

i

8. H. E. Collins et al., Planning Sasas for the Deitlopment of State 34. H. A. Morewits. " Fission Product and Aerosol Behavior Folton.

and Local Gasernment Radiolorocal Emergency Response Plans ins Destnded Core Accidents." to be published en Nuclear Tech.

m Support of Lieht Water Nuclear Pomer Plants. NUREG.0396 "olory-(1978). 33. R. Lemsre et al. Assessment of lodine Behavior un Contamment 9 U.S. Environmental Protection Asency. Munnel or Protecrire from a Chemscal Ferraectn c. AECL 6412 (1981).

9 Action Guides and Protectts e Actsons for Nuclear lacudents. EPA 36. U.S. Congress. Nuclear Pomer Pfar*t Salerr After Three Mde

'20175-00t (197!). Island. Subcomnuttee on Enersy Research and Production of

10. D. C. Aldrich. Ezaminarson of of-site Radioloercal Emererner the Comnuuee on Science and Technology. 96th Congrew. Com.

> Protocrise Measures for Nuclear Reactor Accidents imolsang mittee Print Serial J). U.S. Prts. Office (1980). .

- I NUCLEAR NEWS / APRit.1981 67