Statement by Paul Gunter, Director, Reactor Watchdog Project, NIRS
July 13, 2001
Federal, State and local officials work together with nuclear power plant
operators to develop site-specific emergency response plans for nuclear power
The plans delineate evacuation routes, reception centers for those seeking
radiation monitoring and possibly decontamination. State and local governments,
with support from the Federal government and utilities, develop plans that
include a plume emergency planning zone (for evacuation and sheltering) with a
radius of 10 miles from the plant, and an ingestion planning zone (sheltering of
cows and stored feed) within a radius of 50 miles from the plant.
Residents within the 10-mile emergency planning zone are required to be
provided emergency information materials (via brochures, the phone book,
calendars, utility bills, etc.). These materials contain educational information
on radiation, instructions for evacuation and sheltering, special arrangements
for the handicapped, contacts for additional information, etc.
However, current emergency plans for populations living and working around US
nuclear power stations are unrealistic in several important aspects. The chief
flaw is that plans do not take into consideration the natural inclinations of
people to protect themselves and their families in the event of a nuclear
The lessons learned from the Three Mile Island accident provide a very
important experience for emergency planners to seriously consider in determining
the viability of executing their nuclear accident emergency plan. A study into
the human response in the aftermath of TMI was published in "Evacuation Behavior
In Response To Nuclear Power Plant Accidents," by Donald Zeigler and James
Johnson, Jr. in the May,1984 issue of The Professional Geographer.
Here are some of their findings:
- To plan for only a 10 mile evacuation is to significantly under plan for a
nuclear power station accident.
The 10-mile emergency planning zone is a politically arbitrary distance. It
has no bases in meteorology, radiation releases mechanisms and human behavior.
In fact studies of human behavior following the Three Mile Island accident in
1979, where a limited evacuation advisory was issued by Pennsylvania Governor
Thornberg, provides evidence that people will be spontaneously leaving their
homes well beyond the current 10-mile planning zones. This human behavior
phenomenon has been termed the "evacuation shadow effect." This evacuation
shadow is determined by people who believe themselves to be at risk who
evacuate even though they have not been ordered or advised to do so by
officials. The study of human behavior around the Three Mile Island accident
showed that if only the government advised people, specifically pregnant
mothers and pre-school children, had left a 5 mile radius, that number would
have been about 3400 evacuees. Instead, up to as many as 200,000 people
actually evacuated, approximately 39% of the population within 15 miles of the
reactor. The "shadow" evacuation phenomenon is not expected to begin to
diminish until approximately 25-miles out from the reactor. The study found
that in addition to the high rate of voluntary evacuation, those evacuees
tended to travel distances much greater than has been observed in previous
studies on non-nuclear related evacuation behavior (hurricanes, floods, etc.).
The TMI study evidenced that the median distanced traveled by evacuees was 85
miles. The NRC commissioned a study (Flynn 1979) that evidenced an average
distance of 100 miles of travel.
- To locate all the public shelters and reception centers immediately beyond
the 10-mile EPZ is to invite under-utilization and chaos.
Currently all shelters and reception centers for evacuees within the
current planning zone are located in a 10-20 mile range from the reactor.
Anyone who takes shelter in them will likely watch the resident population
from that zone pack into their cars and heads farther away. Ionizing radiation
is such a dreaded invisible threat people will want to put as much distance as
possible between them and the accident site.
- To depend on buses to evacuate populations without cars (school children,
the elderly, and prison and hospital populations) is to ignore role conflicts
within the emergency personnel designated as drivers and vital to successful
Those people who are depended upon to drive buses are not likely to be
professional emergency workers. They may not respond, especially if they have
family of their own. They may delay response as a result of role conflict
between emergency duty and home. It is reasonable to assume that they are most
likely to tend to their families first. Social surveys of personnel with
assigned emergency duties indicate the strong potential for role conflict to
interfere with the management of a nuclear emergency. Research conducted in
the vicinity of the now closed Shoreham nuclear power station on Long Island,
NY questioned bus drivers and volunteer fireman "What do you think you would
do first if an accident requiring a full scale evacuation of the population
within 10 miles of the nuclear reactor were to occur?"
The results found that 68% of 291 fire fighters, 73% of the 246 bus drivers
indicated that family obligations would take precedence over emergency duties.
The consequence of such choice would be a failed response to the nuclear
Additionally, during the TMI accident role conflict was documented among
many emergency workers including the exodus of physicians, nurses, and
technicians required to staff both the short term and long term medical
facilities. At one local hospital, only six of 70 physicians who were
scheduled for weekend emergency duty reported for work. None of the hospitals
researched in the study were in the 5 mile radius of the evacuation advisory.
Other instances where role conflict occurred were the Pennsylvania National
Guard and even nuclear power plant workers.
- To package information for radiological accident emergency planning as
similar to an emergency response to other disasters (i.e. hurricanes) is to
ignore that there are major differences in how people respond to these very
Nuclear power plant operators and emergency planners characterize nuclear
power plant disaster planning as no different than that for a hurricane or some
other disaster. The public clearly perceives a difference of threat and
consequences from a nuclear meltdown and that of a hurricane. But nuclear
utilities, emergency planners and the NRC refuse to acknowledge these distinct
differences in actual threat, public perceptions and fears of the harm that can
occur as the result of a nuclear power accident on scale of the Chernobyl
accident in Ukraine, and other catastrophes. The harm derived from a nuclear
accident both short term and long term includes deadly radiation sickness,
cancer, birth defects and spontaneous abortions. The magnitude of public
response to be greater than an evacuation from a natural disaster should be
acknowledged and factored into emergency planning.
5) To expect to "manage" the evacuation response is not realistic.
People will manage their own evacuation response. They will head out in their
own cars as quickly as possible and try to get on the few available roads and
will slow the entire evacuation process down. They will end up in traffic jams
in bottlenecks that are beyond the evacuation zones that will likely trap the
intended evacuees in traffic jams closer to the nuclear reactor and most
immediately under any escaping radiation plume.
The public and their State and local authorities should be aware of what the
United States Nuclear Regulatory Commission and the nuclear industry are already
planning under the revised regulatory oversight process for reducing agency and
utility costs by reducing performance requirements in the area of Emergency
In a move by the nuclear industry at the request of the NRC, a large Midwest
nuclear utility initiated discussion on a series of petitions for rule changes
for the industry that includes emergency planning regulations. Commonwealth
Edison, now merged with PECO Energy and British Energy to form Exelon
Corporation, the operator of 17 nuclear power stations in Illinois, Pennsylvania
and New Jersey, has proposed a series of sweeping changes in a number of areas
including cutting the emergency planning zones down to 5 miles instead of 10 to
achieve utility cost savings.
Emergency planning has recently come under the scrutiny and budgetary knife
of the NRC and the nuclear industry to reduce "unnecessary regulatory burden"
and the associated costs to a deregulated electric industry.
Regulations contained in 10 CFR 50.47 (c)(2) stating that "Plume exposure
pathway emergency planning zone (EPZ) shall consist of an area of 10 miles in
radius" are being reviewed by industry to be reduced to 5 miles under the
justification that the industry has revised its estimates of the "source term,"
or the amount of radiation likely to be released in a catastrophic accident. The
sole reason for reducing evacuation planning zones by 75% is that the industry
seeks a savings in terms of reduced emergency siren maintenance costs and public
information distribution (i.e. the printing of calendars with emergency
The industry is considering a rule change to eliminate the requirement for
updating emergency evacuation time estimates. The industry would call for
eliminating updated evacuation time estimates regarding such variables as
population densities and geographic factors change. The industry seeks to save
administrative costs to updating these evacuation time estimates for the
families, schools, businesses and communities living around atomic plants.
In the same cost savings effort, Exelon is trimming its emergency planning
staff (23 people from its 53 staff) at its three Pennsylvania reactor sites
(Three Mile Island Unit 1, Limerick 1 and 2, and Peach Bottom 1 and 2) through
consolidating their respective Emergency Operations Centers for its reactors
into a common center at a remote locations 60 miles away from reactor control
rooms. Emergency operations facilities are typically located 10 miles from
control rooms to serve as headquarters for nuclear industry decision-makers in
the event of an accident such as what occurred at Three Miles Island Unit 2 on
March 28, 1979. Eric Epstein of the non-profit EFMR Monitoring Group which
radiologically monitors the Pennsylvania reactors said, "In the event of an
emergency, you would like to be able to plan the response from a location that
has the same area code." The group criticized the utility move as cost cutting
that "demonstrates the worst aspect of deregulation."
The fact that questions and concerns are being ignored regarding realistic
human behavior in the face of nuclear catastrophe and the steady whittling away
of emergency planning plans under utility cost savings constitutes a widening
and dangerous gap in emergency planning as the industry ages toward equipment
The industry and regulatory changes do little to build public confidence in
the intent and sincerity of efforts to first provide for the health and safety
of large populations living in the shadow of an aging and increasingly dangerous
nuclear power industry. In fact, these profit driven changes further erode
public confidence in emergency planning and the planning authorities.
Regardless of the federal regulations, local and state authorities have the
power to realistically plan for emergency for catastrophic nuclear accidents.
The first step in that process is to demand answers to these outstanding
questions and many others. Officials must also oppose unrealistic
economically-driven changes to already faulted planning.
Ultimately, the only relevant protection, however, is prevention. If you want
real civil defense, then we must shut these dangerous and aging reactors