Nuclear Energy Activist Toolkit #32
As the accident at Fukushima Daiichi demonstrated for those who missed or forgot the prior demonstrations at Three Mile Island and Chernobyl, a bad day at a nuclear power plants can have serious implications beyond the fences. Nuclear power plants normally send vast amounts of electricity out far and wide. Because they can also send out vast amounts of radioactive materials far and wide, emergency preparedness is not only a good idea—it’s the law.
Section 50.47, Emergency plans, of Title 10 of the Code of Federal Regulations (10 CFR) establishes the following 16 measures for protecting members of the public and workers in event of nuclear power plant accidents:
(1) Primary responsibilities for 10-mile emergency response by the plant owner and by state and local organizations within the emergency planning zones have been assigned and the emergency responsibilities of the various supporting organizations have been specifically established.
(2) Responsibilities of plant workers responding to nuclear plant emergencies are unambiguously defined, adequate staffing is available for the initial response, and initial response capabilities can be augmented in a timely manner.
(3) Arrangements for requesting and effectively using assistance from state and local organizations have been made.
(4) A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the plant owner and state and local organizations and response plans call for reliance on information provided by the plant owner for determinations of minimum initial offsite response measures.
(5) Procedures have been established for timely notification by the plant owner of state and local organizations and for notification of emergency personnel by all organizations; the content of initial and follow-up messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the emergency planning zone have been established.
(6) Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public.
(7) Information is made available to the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency (e.g., listening to a local broadcast station and remaining indoors).
(8) Adequate emergency facilities and equipment to support the emergency response are provided and maintained.
(9) Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.
(10) A range of protective actions has been developed for the emergency planning zone for emergency workers and the public. In developing this range of actions, consideration has been given to evacuation, sheltering, and, as a supplement to these, the use of potassium iodide (KI). Guidelines for the choice of protective actions during an emergency, consistent with federal guidance, are developed and in place.
(11) Means for controlling radiological exposures, in an emergency, are established for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides.
(12) Arrangements are made for medical services for contaminated injured individuals.
(13) General plans for recovery and reentry are developed.
(14) Periodic exercises will be conducted to evaluate major portions of emergency response capabilities and to develop and maintain key skills.
(15) Radiological emergency response training is provided to those who may be called on to assist in an emergency.
(16) Responsibilities for emergency plan development and review and for distribution of emergency plans are established, and planners are properly trained.
Appendix E to 10 CFR Part 50 provides additional detail on these emergency planning regulatory requirements.
Planning Zones and Emergency Exercises
This map illustrates the two emergency planning zones established for every nuclear power plant operating in the United States. A plume-exposure-pathway emergency planning zone of approximately 10 miles in radius is intended to protect people from harm caused by exposure to radiation released during an accident. These protective measures include evacuating, sheltering, or issuing potassium iodide for individuals to take. An ingestion-exposure-pathway emergency planning zone of approximately 50 miles in radius is also intended to protect people from harm caused by radiation released during an accident. These protective measures entail actions to control drinking of radioactively contaminated water and milk and consuming radioactively contaminated foodstuffs.
Hannibal Smith’s catch-phrase on the 1980s TV series A-Team was “I love it when a plan comes together.” Federal regulations require that the emergency plan for each operating nuclear power plant be exercised every two years. The Federal Emergency Management Agency (FEMA) grades the performance of state and local response organizations during the exercises while the NRC grades the plant owner’s performance. Because an exercise involves many representatives from state and local organizations, the NRC schedules them more than a year in advance. For example, the next biennial exercise for the Millstone nuclear plant in Connecticut will be conducted on September 9, 2014, the next exercise for Indian Point (NY) will be conducted October 6, 2014, the next exercises for Sequoyah (TN) and Braidwood (IL) will be conducted November 19, 2014, and the next exercise for Calvert Cliffs (MD) will be September 15, 2015.
The NRC and FEMA issue public reports on their assessments of the biennial emergency exercises. The NRC’s reports lack meaningful information, but the FEMA reports are quite informative (and not just by comparison to the NRC’s unintentionally blank pages). For example, FEMA issued reports on the biennial exercises conducted in recent years for Three Mile Island (PA), San Onofre (CA), and South Texas Project (TX).
The emergency plan requirements have good intentions—protecting the public and workers from harm caused by exposure to radiation during nuclear plant accidents. The biennial emergency plant exercises are good road tests for these good intentions. But the exercises are biased towards false hopes and overly rosy assurances and away from reality.
The exercises are scheduled many months in advance so all the primary players can mark it on their calendars and participate in the exercises. The exercises are scheduled during normal business hours during work days. The simulated nuclear plant accident begins around 9am and gets resolved in plenty of time for the post-event critiques to be completed before normal quitting time.
The Three Mile Island and Chernobyl nuclear plant accidents happened in the middle of the night.
The Fukushima nuclear plant accidents happened in the middle of a broader natural disaster.
Because nuclear plant accidents thus far have not been scheduled many months in advance, the responders have been those on duty by fate instead of by pre-arrangement.
Because nuclear plant accidents have occurred in conjunction with other disasters, the responders have been unable to focus undivided and unfettered attention to them.
Because nuclear plants are not like TV dramas that end before the hour (after the last commercial airs), they require more than a single roster of primary players.
The biennial exercises would be more realistic—and thus become better indicators of whether people could be adequately protected—if they periodically involved: (a) putting primary players on the bench to see if the understudies could be found and could step in to perform the necessary tasks, (b) simulated accidents on midnight or weekend shifts to judge how well response happens outside normal business hours, and (c) responders having to cope with more than a nuclear plant accident to see if prioritization decisions are made properly.
Right now, the biennial exercises assure people they could be protected against a nuclear plant accident scheduled many months in advance to occur on a normal workday morning and conclude before the afternoon rush hour traffic. That assurance is better than nothing, but we can and should aim higher.
The NRC, on its webpage titled “What Do I Do in a Nuclear Emergency”, offers this guidance:
If an accident occurs at a nuclear power plant near you, stay calm and listen to your local television or radio stations for updates and instructions from your state and local officials.
Similar guidance is provided by the Department of Homeland Security.
Even though the “stay calm” response would be easier if “What Do I Do in a Power Plant Emergency” or similar phrasing didn’t conjure up imagery of mushroom clouds and Godzilla, tuning into a local TV or radio station for instructions from state and local officials is extremely important. Failure to obtain and heed those instructions could result in you and your family moving into an area where you are exposed to higher levels of radioactivity. “Staying calm” is good. “Staying away from unnecessary radiation exposure” is way better.
The UCS Nuclear Energy Activist Toolkit (NEAT) is a series of post intended to help citizens understand nuclear technology and the Nuclear Regulatory Commission’s processes for overseeing nuclear plant safety.