After deliberating for a period of time approaching a decade, the US Environmental Protection Agency (EPA) has issued a new draft Protective Action Manual that includes Protective Action Guides (PAG) for people responsible for responding to radioactive material releases that might come from one of the following sources:
- a fire in a major facility such as a nuclear fuel manufacturing plant;
- an accident at a federal nuclear weapons complex facility;
- an accident at a commercial nuclear power plant (NPP);
- a transportation accident involving radioactive material;
- a terrorist act involving a radiological dispersal device (RDD) or yield-producing Improvised Nuclear Device (IND).
The “new” radiation dose response limits in the draft PAGs are virtually unchanged from the ones recommended in the currently active Protective Action Manual (13 MB PDF), which was issued in 1992. According to experts like Dr. Jerry Cuttler, who focuses on the health effects of low level radiation, the limits could be relaxed by a factor of 50 and still keep the public safe.
Not surprisingly, strongly antinuclear organizations like the Nuclear Threat Initiative (NTI) are working hard to portray the new guidance as a frightening relaxation of the limits in comparison to such scientifically invalid limits as the one that the EPA applies to long term nuclear waste disposal – 15 mrem per year, which is 1/20th of average natural background.
Groups that are fundamentally opposed to the beneficial use of nuclear energy have been working hard since 2005 to try to force the EPA to issue far more stringent guidance that would be virtually impossible to execute in any reasonably foreseeable radiological material release for any source other than a nuclear power plant. (Nuclear power plants can, with enough additional investment in modeling and more redundant layers of mitigation, probably meet any proposed standard.) Watching the politics of this evolution has been interesting; the fact that the guides are still sort of reasonable is largely a result of efforts to inject real world analysis by first responders representing the Department of Homeland Security.
In what seems to be a pure coincidence, the Government Accountability Office (GAO) recently released a report titled NRC Needs to Better
Understand Likely Public Response to Radiological Incidents at Nuclear Power Plants that criticizes the Nuclear Regulatory Commission for inadequately considering the possible effects of a panicked response to a nuclear power plant accident.
According to the GAO, the NRC has not adequately accounted for the possibility people outside of the 10-mile emergency planning zone (EPZ) might panic at the news of a nuclear plant accident and begin an unplanned “shadow evacuation.” If that happens, the GAO believes that it will produce unexpected traffic jams that slow planned efforts to relocate people who are within 10 miles of a nuclear power plant that has experienced a casualty.
Ironically, people like Jim Riccio and Paul Blanch, who have spent a good portion of their careers trying to spread fear about radiation, are being featured in AP stories about the GAO’s report. They feign concern about possibility that panic might prevent evacuation, but do not accept the notion that their efforts might be directly responsible for increasing the likelihood of irrational and unproductive response.
The new manual issued by the EPA and the report issued by the GAO are far more related in my mind that most people might understand. The primary purpose of Protective Action Guides is to consider, in advance of any unpredictable event, the actions that should be taken to best protect the general public. Though it is an activity that seems a little boring, with only distant and uncertain utility, the best time to plan for the unpredictable is when there are no events in progress. Advanced planning provides the opportunity for rational, calm, deliberate thinking. It allows planners to anticipate potential problems and to devise a variety of possible responses contingent on the measured circumstances.
You see, I think the GAO is probably right; under current circumstances, an accident at a power plant like Indian Point, situated on the Hudson River about 35 miles up river of New York City, could result in a catastrophic evacuation that harms thousands of people. Having spent many uncomfortable hours sitting near the Tappan Zee Bridge on a Sunday after Thanksgiving, I can imagine tempers flaring and shots being fired as parkways become parking lots.
That scenario can be prevented, but not by the path that antinuclear activists would prefer to follow. There is no need to acede to their often repeated demand to shut down any nuclear plants, even those that are located somewhat close to densely populated areas. Those plants do not pose a risk to the general population. That fact has been repeatedly studied and demonstrated, most recently by the release of the State-of-the-Art Reactor Consequence Analysis (SOARCA) which computed few, if any injuries to anyone in the general population – even without any evacuation.
For both the mitigated and unmitigated cases, the individual scenariospecific LCF (latent cancer fatality) risk for the EPZ was small, approximately 1×10-10 per reactor-year, assuming an LNT dose-response model.
When the selected SOARCA scenarios were assumed to proceed unmitigated (i.e., neither 10CFR 50.54(hh)implementation nor other key operator actions that would prevent core damage), MELCOR analyses indicated that the accidents progress more slowly and with smaller releases than the 1982 Siting Study SST1. Whereas the 1982 Siting Study SST1 case results in a large early release at 1.5 hours, the SOARCA analyses show no large early releases for the scenarios analyzed.
The individual early fatality risk from SOARCA scenarios is essentially zero. Individual LCF risk from the selected specific, important scenarios is thousands of times lower than the NRC Safety Goal and millions of times lower than the general cancer fatality risk in the United States from all causes, even assuming the LNT dose-response model. Using a dose-response model that truncates annual doses below normal background levels (including medical exposures) results in a further reduction to the LCF risk (by a factor of 100 for smaller releases and a factor of 3 for larger releases). LCF risk calculations are generally dominated by long-term exposure to small annual doses (about 500 mrem per year) corresponding to evacuees returning to their homes after the accident and being exposed to residual radiation over a long period of time.
(NUREG-1935 State-of-the-Art Reactor Consequence Analysis (SOARCA) Report Part 1 page 85)
When you factor in the careful planning and response mitigation efforts that nuclear power plant operators have already instituted both to limit public injury and to protect their large capital investment in the plants themselves, the risk from a nuclear power plant accident falls down on the worry priority list to a point somewhere below worrying about being hurt on the way up to the stage to accept my lottery winnings. (I never purchase lottery tickets.)
Instead of adding the enormous cost of trying to plan evacuations for ever larger response circles, a more productive response to the GAO’s concern about the potential effect of shadow evacuations would be panic prevention. It would involve a large dose of informative, open discussions about the tiny, mostly imaginary hazards associated with releasing small quantities of radioactive material when compared to to the known hazards of moving large populations away from their homes and livelihoods.
The preemptive, preventative path would involve affordable, mass-produced sensing equipment that comes with clearly written instructions for use – not because that equipment can do anything to stop radiation, but because knowledge is power. A father or mother that has a proven, reliable radiation detector and the confidence that they know how to use it will not be tempted to take the silly action of packing up their family to leave their home when the measured doses are far below any possible danger level. (Note: These devices should be sold, not given away. If people are not worried enough to purchase the device themselves, their panic prevention education is already sufficient.)
My preferred path might involved some simple-to-understand instructions about using time, distance and shielding to reduce exposures. It might include confidence building exercises that demonstrate how easy it is to remove contamination, even though actually getting contaminated is exceedingly unlikely.
This effort seems to me like a job for professional communicators, perhaps organized under the auspices of the Nuclear Literacy Project. It might involve modest, but sustained funding from the established nuclear industry, a group that is often loathe to spend money on projects that can be portrayed as self-interested advertising.
However, if decision makers would apply a little creative thinking about the potential for savings associated with improving public awareness of the negligible risk of being harmed by an event at a nuclear power plant – even one that becomes front page news and gets the talking heads preaching panic – they might be persuaded that the investment is prudent and overdue.
It’s a path worth trying; it has not been attempted since sometime in the early 1960s. That last public education and marketing effort was pretty successful and profitable; it contributed to the construction of our current fleet of reliable nuclear power plants that produce 800 billion kilowatt-hours of emission free electricity each year at a marginal cost of about 2.3 cents per kilowatt hour. That effort only took about 25 years.
New York Times (April 14, 2013) U.S. Rethinks How to Respond to Nuclear Disaster (Please read entire piece – we are making a difference in the discussion!)