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 plant accidents.

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 accident.

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:

1. 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.

2. 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.

3. 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 evacuation.

   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 emergency.

   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.

4. 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 different events.

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 Planning.

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 information) costs.

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 failure.

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 down.