Relaxed approach to protective action in case of radiological release
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.
Additional Reading
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!)
I find it strange that little if anything is said or publicized about the need for evacuation plans for those living or working in the vicinity of the many chemical, petrochemical and hydro facilities that dot the country. Some of these could release chemical toxins that never ever decay away, and a dam can collapse, causing drowning of tens of thousands of victims. Indeed, certain biased people (and newspapers like the Westchester County Journal News) living in Westchester County will loudly decry Indian Point as a hazard while ignoring the very real and present danger of something like the nearby Croton Dam, downstream of which many of these same people live. This lack of critical thinking skills is astounding. 🙁
PS, since Indian Point was mentioned in Rod’s post, I worked there for 18 years. It is without question one of the safest and best run facilities that I have ever worked at, and the people with whom I worked are among the most honorable and virtuous. They always place safety first, and they care about the community in which they work, unlike the anti-nuclear activists seeking to economically impoverish the region with a shutdown of this facility.
Re: Paul W Primavera “I find it strange that little if anything is said or publicized about the need for evacuation plans for those living or working in the vicinity of the many chemical, petrochemical and hydro facilities that dot the country. Some of these could release chemical toxins that never ever decay away, and a dam can collapse, causing drowning of tens of thousands of victims.”
You SO hit it on the head. When I see all the excessive and nearly bankruptive “safety” requirements and demands piled on nuclear vs nearly none for other long far more lethal industries, I can’t imagine a better case of institutionalized hypocrisy. Why the nuclear industry doesn’t balk for regulation parity across all industries just to strut a point boogles me.
James Greenidge
Queens NY
@James Greenindge
This is one more example that supports my contention that the main strength behind the anti-nuclear movement is different from what underlies most opposition movements. The same visible groups of people rally against chemicals, fossil fuels and “evil” corporations. They are just better supported financially and politically when they rally against nuclear energy.
My theory is that nuclear energy’s competitors actively support any activity that slows down its inevitable march toward domination of the power business.
Rod, could you edit to add in what LCF stands for (latent cancer fatality)? As a regular reader, even I had to look that one up.
http://www.foxnews.com/science/2013/04/13/dark-lightning/
Wonder how these exposures to thousands — at least — yearly figures in the argument of radiation health effect scales. Nuclear ads can justly say that you receive far less exposure even from “nuclear accidents” than a regular plane trip. BTW, there must be some kind non-radiation radiation health equivalency scale created to help laymen put radiation dosages in real-life perspective. Spouting millicuries don’t hack public comprehension and only serves to darkly mystify nuclear energy . If there was a translative radiation health equivalency measure to state that — say, 50 millrads is equivalent in health impact to a city bus with fumes passing by on the curb, etc, it’d do wonders to help the public get a handle on radiation’s effect. What real-world everyday health impact equivalence to radiation does the Fukushima resident face today in higher background? Like equivalent to being exposed to chlorine bleach while cleaning the bathroom once a week? Having a new smoking household member or a smoggy garbage truck passing your house weekly? You get the idea.
James Greenidge
Queens NY
James,
Dr Bernard Cohen has made tons of real life situations risk assessment (crossing the street 100 times, driving 250 miles in a car, wearing tight underwear etc) compared to radiation exposures.
I have forwarded you those bits of information a few times.
Ciao
Not exactly what you were asking for, but it puts radiation exposures in context.
http://xkcd.com/radiation/
These discussions of the sources are useful too.
http://blog.xkcd.com/2011/03/19/radiation-chart/
http://blog.xkcd.com/2011/04/26/radiation-chart-update/
Here is a web link to Dr. Cohen’s web page. near the bottom are sublinks to what he wrote.
http://www.phyast.pitt.edu/~blc/
Daniel and Paul;
Thanks, Cohen did a great job, but what I’m looking for are direct and tangible radiation equivalent health effect exposures of home or workplace chem agents on one’s body that the layperson can readily comprehend. A housewife doesn’t have a clue how riding down a highway a hundred times is more risk than living by a nuke. She _does_ understand that getting splashed by Clorox or an accidental spray of Raid or 6-12 must impact her health span somehow though it might be a big deal to her — but what if she knew its heath effect equivalence in radiation exposure? A splash of chlorine bleach or turpentine or borox powder or barbecue starter on your hands or mouth is equivalent in heath effects to how much radiation? That’s the kind of everyday layman comprehension scale I’m seeking.
Thanks for those tips,
James Greenidge
Queens NY
Not exactly what you are looking for but still very useful, comparing radiation risk from a large nuclear accident to risk from air pollution, passive smoking and obesity:
http://www.biomedcentral.com/1471-2458/7/49
One of the conclusions:
“It is probably surprising to many (not least the affected populations themselves) that people still living unofficially in the abandoned lands around Chernobyl may actually have a lower health risk from radiation than they would have if they were exposed to the air pollution health risk in a large city such as nearby Kiev.”
As long as we continue to saddle ourselves with the LNT fallacy, the scaremongers will continue to holler their nonscience nonsense.
Hi, James!
I wish I had a good response that would provide a simple comparison between household chemical exposure and radiation exposure. Unfortunately, sometimes the truth cannot be reduced to mere sound-bites. The facts have to be studied and critical thinking skills have to be employed to arrive at sound and reasonable conclusions (we all know that as nuclear professionals). In today’s internet environment, we have a wealth of access to all kinds of information, but more and more the critical thinking (or logical reasoning) that should be applied seems to be lacking. Maybe I am being overly pessimistic. Yet nuclear science – like chemical science – is not an easy subject, but it is a comprehensible one, and risk analysis is an old science that has been done for decades and decades if not a century or more by organizations like insurance companies. Perhaps we ought to get better at explaining this to our neighbors and friends instead of relying on a news media already biased against all things nuclear. Atomic Insights helps to do that.
I did find a few more web sites that provide perspective on risks:
http://www.physics.isu.edu/radinf/risk.htm
http://russp.us/BLC-4.html
These may have been provided above or elsewhere in different posts at Atomic Insights.
Folks,
I apologize for making another comment, but something occurred to me from my work history that relates to what James wrote above about comparing household chemical and nuclear radiological hazards. When I was at Indian Point Unit 3 some years ago, we had several systems that would place the Control Room HVAC at Unit 3 in the incident mode to protect the Operators:
Control Room High Radiogas (which might occur from a hypothetical radiological release)
Control Room High Area Radiation (again, which might occur from a hypothetical radiological release)
High Ammonia Gas Concentration
High Chlorine Gas Concentration
The last two were installed to protect against a toxic gas release from a railroad train accident. You see, there was a railroad which snaked along the western side of the Hudson River and Indian Point was on the eastern side. Trains traversing through the region routinely carried a myriad of toxic chemicals, including ammonia, chlorine, molten sulfur, etc. If a train derailed or underwent some other type of accident, then the chemicals would be spilled, and since the prevailing winds were from west to east, people at Indian Point (not to mention the Village of Buchanan and the City of Peekskill) would be exposed, perhaps with injurious if not fatal results. As a result, we installed a toxic gas monitoring system to ensure that if that event occurred – however unlikely its occurrence may be – the Operators in the Control Room would be protected, the staff on site could take protective measures, and they could still safely shutdown the reactor as the need may arise. This was a completely non-nuclear hazard originating from a non-nuclear off-site source outside the control of Entergy Nuclear (or its predecessors, Con Ed for Unit 2 and NYPA for Unit 3). It would however affect residents in the four county region of Westchester, Orange, Rockland and Putnam, yet it is ignored by the Westchester County Journal News and the politicians elected to office in NY State in favor of demonizing Indian Point.
When I was working at the James FitzPatrick nuclear power plant in Lycoming, NY, we has combustible gas detectors within our sewage treatment system, monitoring for sulfur dioxide and methane, as most all such treatment systems everywhere (e.g., municipalities, hospitals, universities, etc.) are required to have. No one in the news media cares one iota for the possible hazards from their local city’s sewage treatment system, yet the dangers from these are far more credible and likely to occur than some sort of hypothetical doomsday event at either Indian Point or FitzPatrick (or the adjacent Nine Mile Units 1 and 2).
Basically, non-nuclear hazards from railroad trains, chemical plants, etc., are far more prevelant and credible than anything at a nuclear power plant. Yet people ignore the former and express stark terror at the latter regardless of its non-credibility. Even Fukushima Daiichi didn’t kill as many people as a railroad train accident on the western side of the Hudson River would. And please correct me if I err, but didn’t only six or so people get killed outright at Fukushima, compared with the thousands who died from Union Carbide toxin release in Bhopal India in the 1980s?
We need to communicate better to our neighbors and friends, and we need to encourage the use of critical thinking skills. That’s the way to defeat this non-thinking fear mongering and hysteria.
Excellent comments Paul.
I would worry more about the Kensico Dam, a100+ year old stone structure which, if failed catastrophically, would rapidly inundate large sections of White Plains and Scarsdale along the Bronx River flood plain. I know of no warning or evacuation plans related to this contingency.
A curious citizen speculated about this a few years ago: http://www.city-data.com/forum/westchester-county/1223078-what-if-earthquake-hit-kensico-dam.html