On March 16, five days after the Fukushima Daiichi reactors were shutdown in the wake of a large earthquake that was followed by a tsunami, Gregory Jaczko, the Chairman of the US Nuclear Regulatory Commission, announced that he was recommending that all Americans within fifty miles of the nuclear power station evacuate the area. That recommendation insulted the technical expertise of a key American ally, added unnecessary transportation burdens to an already stressed infrastructure, and added additional stress to an already miserable population of tens of thousands of Japanese who were not being told to evacuate by their own government.
I wrote about my disagreement with the recommendation at the time. I thought it indicated a complete lack of perspective regarding the very real dangers of trying to move a large number of people compared to the non-existent heath risk to anyone outside of the area that the Japanese government had already evacuated.
In the more than 2 months since that order was issued, it has become apparent to me that the organized opposition to the continued use of nuclear energy plans to use knowledge of the order as a basis for demanding a vastly expanded Emergency Planning Zone (EPZ) for all nuclear power plants in the United States. The current EPZ is 10 miles; expanding it to 50 miles multiplies the affected area by a factor of 25. That will add an enormous planning and coordination burden on top of currently operating reactors, may lead to several forced plant closures, and could very well be the deciding factor that halts all new nuclear power plant development for any country that goes along with the decision.
Like Jaczko’s initial order, the expansion of the EPZ would have zero benefit for public safety with regard to radiation exposure and it would dramatically reduce overall public safety because of an increasing reliance fossil fuels like coal and natural gas. Those replacement energy sources have demonstrably worse safety records – both on the basis of routine hazards like fine particulate emissions and acid-rain-causing sulfur dioxide and on the basis of accident risks like fires, explosions, and waste pond floods of millions of gallons of toxic sludge.
On May 31, 2011, Chairman Jaczko once again defended his order in a press release titled NRC Chairman Gregory B. Jaczko’s Statement on NRC’S Commitment to Safety. The document is virtually identical to Jaczko’s May 26, 2011 Huffington Post article titled Ensuring Nuclear Safety. (I used the word virtually because I have not checked the two documents side by side, but the first few paragraphs match.) Here is how the Chairman described his recommendation:
Third, during our Japan nuclear incident response, I approved a courageous safety recommendation by our most senior, expert staffers. As we were monitoring the fluid situation in Japan, NRC staff became concerned that the situation could worsen and impact Americans living there. Using all of their training, the best available data, and centuries of combined nuclear safety experience, the staff recommended to me that we needed to advise American citizens to stay fifty miles away from the troubled nuclear site, recommendations that differed from the advice of the Japanese government. The staff did not focus on what might be popular with the nuclear industry but instead recommended action in the best interest of safety.
There are a number of problems with that defense of his evacuation recommendation, including the fact that it was based on an incorrect or superficial interpretation of the document that is actually based on centuries of combined radiation and public safety experience, the Environmental Protection Agency’s Manual of Protective Action Guides and Protective Actions for Nuclear Incidents revised in 1991, reprinted in May 1992.
That document is the one that is used to train people who are responsible for implementing actions in times of crisis. The training is done on a regular basis so that if emergencies do occur, the decision makers have the benefit of practice that allows them to remain calm when others are panicking. The March 16, 2011 press release that the NRC issued to recommend the evacuation refers to the guidance contained in that document with the following statement:
Among other things, in the United States protective actions recommendations are implemented when projected doses could exceed 1 rem to the body or 5 rem to the thyroid. A rem is a measure of radiation dose. The average American is exposed to approximately 620 millirems, or 0.62 rem, of radiation each year from natural and manmade sources.
That is not what the manual says. According to table 2-1 (page 2-6) “PAGs for the Early Phase of a Nuclear Incident” protective actions that include Evacuation (or Sheltering) start with a projected dose to the body of between 1-5 rem. There are two footnotes on the table:
aSheltering may be the preferred protective action when it will provide protection equal to or greater than evacuation, based on consideration of factors such as source term characteristics, and temporal or other site-specific conditions (see Section 2.3.1).
bThe sum of the effective dose equivalent resulting from exposure to external sources and the committed effective dose equivalent incurred from all significant inhalation pathways during the early phase. Committed dose equivalents to the thyroid and to the skin may be 5 and 50 times larger, respectively.
The manual includes a range for a reason – actual situations require careful judgment and balancing other factors. Using that guidance, evacuation may not be necessary even with projected doses of 5 rem to the body or 25 rem to the thyroid.
Here is what section 2.3.1 has to say about factors to consider when weighing the decision between evacuation and sheltering:
…In addition, under unusually hazardous environmental conditions, use of sheltering at projected doses up to 5 rem to the general population (and up to 10 rem to special groups) may become justified. Sheltering may also provide protection equal to or greater than evacuation due to the nature of the source term and/or in the presence of temporal or other site-specific conditions. Illustrative examples of situations or groups for which evacuation may not be appropriate at 1 rem include: a) the presence of severe weather, b) competing disasters, c) institutionalized persons who are not readily mobile, and d) local physical factors which impede evacuation.
Evacuation seldom will be justified at less than 1 rem. The examples described above regarding selection of the most appropriate protective action are intended to be illustrative and not exhaustive. In general, sheltering should be preferred to evacuation whenever it provides equal or greater protection.
If you go back and read news reports of the situation on the ground at the time of the evacuation, essentially all of the factors that complicate and add challenges to evacuations existed. The weather was frigid, transportation infrastructure was severely compromised, there were at least two competing disasters, and there were several pockets of institutionalized persons who would be difficult to move.
Aside: I took the above quotes from the section of the Manual of Protective Action Guides that is designed to be used in the early stages of an incident. It is debatable whether the Fukushima situation still qualified for that treatment on March 16, but the section for the intermediate phase is even more cautious about using evacuation as the protective action. End Aside.
The Chairman’s recommendation for evacuation also violated another caution contained in the manual. In a lengthy discussion about computing the projected doses, the manual clearly indicates a preference for using conditions at the source that have been planned in advance as to trigger notification of off site officials so that evacuation can be implemented in an orderly fashion. The manual then states that as the incident progresses, actual measurements might be used as the basis for implementing further protective actions. It recognizes that there may be a situation with far more unknowns so it might be necessary to take action based on the results of models. However, here is what it says about using models for projected dose calculations:
The calculation of projected doses should be based on realistic dose models, to the extent practicable. Doses incurred prior to initiation of a protective action should not normally be included. Similarly, doses that may be received following the early phase should not be included for decisions on whether or not to evacuate or shelter. Such doses, which may occur from food and water, long-term radiation exposure to deposited radioactive materials, or long-term inhalation of resuspended materials, are chronic exposures for which neither emergency evacuation nor sheltering are appropriate protective actions.
All indications available in the United States showed that the Japanese government was proceeding in the same fashion as we would have proceeded in the US, with a well-coordinated effort to move people within predefined limits. Chairman Jaczko’s expanded recommended evacuation for Americans vastly complicated an already challenging situation, violated the guidelines produced by the Environmental Protection Agency, and did nothing to improve public safety. Radiation protection professionals should challenge the NRC’s emergency decision making process and find out exactly what the “most senior, expert staffers” that Jaczko says provided the recommendation were using as the basis for their conclusion that evacuation was the correct strategy.
Aside: Sources inside the NRC have told me that the decision was unilateral and not based on expert staff recommendations. Other commissioners have indicated publicly that they were not consulted before the order was issued. End Aside.