DONNA J. MILLER HASTIE BS, MS
EMERGENCY PREPAREDNESS SPECIALIST
Thank
you, Mr. Chairman.
My
name is Donna Miller Hastie. My
experience in emergency planning includes 23 years in the commercial nuclear
power industry in the U.S. and abroad.
Before joining the nuclear industry, I supervised a nuclear medicine
program in a hospital. During my
career, I have served as an evaluator or observer at over 500 emergency
preparedness drills and exercises. And,
for many years, I have had the pleasure of co-sponsoring and teaching emergency
preparedness in a continuing education course at Harvard University. I have also made presentations or taught at
MIT, Rutgers, and the Leadership School at Wharton.
My
experience includes:
·
Manager
of the Emergency Preparedness (EP) program for the Beaver Valley Power Plant in
Pennsylvania, including onsite emergency response readiness and coordination
with offsite state and local emergency response organizations. The 10-mile emergency planning zone (EPZ)
for Beaver Valley included three States, three counties, 30 municipalities,
three NRC regions, two FEMA regions, and 37 federal agencies that make up the
Regional Advisory Council (RAC).
·
Program
Manager in the emergency preparedness division for the Institute of Nuclear
Power Operations (INPO). During my 14
years at INPO, I completed 280 plus plant visits and at the time of my
retirement, was manager of the emergency preparedness program for the
Institute. I have been to every plant
in the United States at least once, many more than once, and many outside the
US. INPO’s EP program included
identifying areas of strengths and recommendations for enhancements for
emergency response programs at nuclear power plants.
· Manager of the Emergency
Preparedness program at PSEG, (Salem/Hope Creek plants) in New Jersey for five
years. The 10-mile EPZ for PSEG
included two States, four counties, one NRC region, two FEMA regions, and again,
multiple other federal agencies.
Since
my second retirement in August of 2001, I have worked as an emergency
preparedness consultant in the nuclear industry.
As
you can see, most of my career has been in emergency planning in
radiation-related fields. And, like
many people whose career is devoted to one area, I am occasionally reminded
that many people are not familiar with the extensive history and experience in
emergency planning that is the standard for commercial nuclear power plants.
I
look at my testimony today as an opportunity to provide enlightenment about an
area that has, since September 11, generated considerable concern and much
speculation among many Americans, and that is, the history of emergency
preparedness programs at U.S. nuclear power plants.
Emergency
planning for nuclear plants actually goes back to 1970. In my testimony today, I will review how the
work of the past 30 years has put in place emergency preparedness program
elements to protect the health and safety of the public. This will include sections on:
·
What
is Emergency Planning?
·
What
is the Regulatory History of Emergency Planning?
·
What
are the Existing Roles and Responsibilities?
·
What
are the Existing Emergency Preparedness Program Elements?
·
What
is the Experience with Nuclear Plant Emergency Response Programs?
What
is the Nuclear Industry’s Commitment to Emergency Planning?
Any
comprehensive history of emergency planning must include the regulatory
history, complete with titles and citations that can often make for laborious
reading. But to not detail that history
would be a disservice to this committee.
Emergency Preparedness has three goals: 1) to protect the plant worker; 2) to protect the plant equipment; and 3) to protect the health and safety of the general public. An emergency plan and implementing procedures provide the basis for safeguarding the population and the work force.
Since 1980, every nuclear power plant in the United States has been required by federal law to create an on-site emergency response plan and ensure that off-site plans exist to protect public health and safety. The Nuclear Regulatory Commission (NRC) approves on-site plans. Approval of off-site plans is coordinated between NRC and the Federal Emergency Management Agency (FEMA). Both on-site and off-site plans must be approved for the plant to obtain and retain an operating license.
Total emergency preparedness requires plans for the response of both systems and people. The engineering design of the plant provides for safe operations. The operating procedures address appropriate systems response during emergencies. The emergency plan and implementing procedures provide the basis for safeguarding the population and the work force.
In the nuclear industry, effective emergency preparedness depends on mutually supportive planning. The multi-jurisdictional nature of the emergency planning zone (EPZ) plan requires that arrangements must be made at multiple governmental levels – contiguous counties within the 10-mile EPZ cooperating with mutual aid agreements, joined by state and federal agency coordination. Federal departments and agencies, State and local governments, voluntary disaster relief organizations, and the private sector work together to meet basic human needs and restore essential services after an emergency.
B. REGULATORY HISTORY
In December 1970, the NRC (then the Atomic Energy
Commission) introduced emergency planning requirements into the
regulations. (35FR19568, December 24,
1970) The content of application, technical information section was amended
to include Section 10CFR50.34 “A discussion of the applicant’s preliminary
plans for coping with emergencies”.
10CF50.34 embodying the first emergency planning rules, required a
discussion of plans for coping with emergencies, and set forth-minimum requirements.
Also, Appendix E provided additional items that shall be included in
these plans. (35FR19568, December 24, 1970).
In 1973, the Federal interagency responsibility for radiological incident emergency response planning was identified in the Federal Register Notice of January 17. (38FR2356). The notice was revised December 24, 1975, and published in the Federal Register (40FR248).
In the January 17, 1973 notice, the Environmental Protection Agency (EPA) was assigned the responsibility for:
(1) establishing protective action guidelines;
(2) recommending appropriate protective actions;
(3) assisting State agencies in the development of emergency response plans;
and
(4) establishing radiation detection and measurement systems.
In December 1974, the NRC developed NUREG75-111, “Guide and Checklist for the Development and Evaluation of State and Local Government Radiological Emergency Response Plans in Support of Fixed Nuclear Facilities” to assist in developing the offsite plans.
In September 1975, the EPA issued EPA-520/1-75-001, “Manual of Protective Action Guides and Protective Actions for Nuclear Incidents.”
In 1975, the NRC published Regulatory Guide 1.101 that set out the format and content of on-site emergency plans. At that time, off-site emergency planning was required for licensing purposes only in the low-population zone (LPZ) located within about a 3-mile radius of the plant. The EPZ was defined in 10CR100.11. At this time the only plan required to be submitted was the plant plan.
In 1976, a Task Force of NRC and EPA representatives determined the appropriate degree of emergency response planning efforts. A joint EPA/NRC document in December of 1978: NUREG-0396, “Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants.” introduced the concept of establishing emergency planning zones (EPZs) – the Plume Exposure Pathway (0 to 10 miles) and the Ingestion Pathway (0 to 50 miles.
In December 1979, FEMA was assigned lead responsibility for the evaluation of offsite planning and response by President Carter in a White House statement and Fact Sheet. FEMA developed a review process, established in the 44 CFR350 regulations. These regulations were finalized in the Federal Register Notice on September 28, 1983 (48FR44332). NRC retained jurisdiction over plant licensing and operation and on-site emergency preparedness.
In August 1979, extensive changes were made to the NRC’s regulations following the TMI accident. The changes were noticed in the August 19, 1979 Federal Register pages 55402 – 55418. There were several key changes to the regulations. These included the addition of 10CFR 50.47 and major additions to Appendix E. The additions included detailed instruction for developing the emergency response organization, assessment action, activation of the emergency organization, notification procedures, emergency facilities and equipment, training, emergency procedures, recovery efforts and emergency computer systems.
In November 1980, a joint NRC/FEMA document, NUREG-0654/FEMAEP-1, “Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants” establishing the substantive basis for both on-site and off-site emergency planning. It required joint licensee/state/off-site agency participation in an annual simulated accident scenario (exercise) as a condition for an operating license.
On December 16, 1980, memorandums of understanding written between the NRC and FEMA were formalized.
In September 1984, the Federal Radiological Emergency Response Plan (FRERP), published as an interim document in the September 12, 1984, Federal Register (29FR35896) outlined the authority and responsibility of each of the 12 federal agencies that have the resource and capabilities needed to respond to a radiological emergency. The plan was first tested in a full-scale exercise at the St. Lucie Nuclear Facility on March 6 - 8, 1984. FEMA published the final operational FRERP in the November 8, 1985, Federal Register (50FR46542).
In February 1985, the NRC/FEMA response was published in NUREG-0981/FEMA-51, Rev. 1, “NRC/FEMA Operational Response Procedures for Response to a Commercial Nuclear Reactor Accident”.
In November 1985, FEMA issued FEMA-REP-10, “Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants”. The Guide establishes the areas to be reviewed and the acceptance criteria.
In November 1986, FEMA issued Guidance Memorandum EV-2, “Protective Actions for School Children”. The purpose of the guidance is to assist State and local government officials and administrators of public and private schools in developing emergency response plans for use in protecting the students.
In 1992, the Federal Response Plan (FRP) was implemented. (This comprehensive plan may be implemented concurrently with the Federal Radiological Emergency Response Plan (FRERP), which details the Federal response to a peacetime radiological emergency). The FRP describes the policies, planning assumptions, concept of operations, response and recovery actions, and responsibilities of 27 Federal departments and agencies, including the American Red Cross, that guide Federal operations following residential declaration or emergency.
In July 1996, a Federal Register notice announced the strategic review of FEMA’s Radiological Emergency Preparedness (REP) program and requested comments.
In 1999, the Environmental Protection Agency (EPA) published the EPA Radiological Emergency Response Plan (EPA-RERP) to replace the 1986, EPA Radiological Emergency Response Plan. The EPA-RERP has been developed to reflect changes in EPA’s programmatic and operational concepts for responding to radiological incidents and emergencies. The new plan represents EPA’s integrated approach to management of radiological releases.
In 1999, the NRC’s risk significance program; the Reactor Oversight Process integrated the NRC’s inspection, assessment, and enforcement programs. The Operating Reactor Assessment Program evaluates the overall safety performance of operating commercial nuclear reactors and communicates those results to licensee management, members of the public, and other government agencies.
The assessment program collects information from inspections and performance indicators (PIs) in order to enable the agency to arrive at objective conclusions about the licensee’s safety performance. Based on this assessment information, the NRC determines the appropriate level of agency response, including supplemental inspection sand pertinent regulatory actions ranging from management meetings up to and including orders for plant shutdown. The NRC’s revised inspection program includes three parts: baseline inspections; generic safety issues and special inspections; and supplemental inspections performed as a result of risk significant performance issues.
In April 2001, NRC published new EP inspection procedures to determine, in conjunction with the performance indicators, whether a licensee is meeting the Cornerstone Objective and Performance Expectation. The cornerstone objective is “To ensure that the licensee is capable of implementing adequate measures to protect the public health and safety in the event of a radiological emergency”. The cornerstone performance expectation is “Demonstration that reasonable assurance exists that the licensee can effectively implement its emergency plan to adequately protect the public health and safety in the event of a radiological emergency.”
In September 2001, FEMA published the “Radiological Emergency Preparedness: Exercise Evaluation Methodology“ (66FR47526), the Radiological Emergency Preparedness exercise evaluation areas and associated criteria, to be effective October 1, 2001.
In April 2002, FEMA published corrections to certain provisions of the ”Radiological Emergency Preparedness Exercise Evaluation Methodology” exercise evaluation areas.
Since 1979 more than 2000 graded exercises have been conducted. In-depth critiques are conducted following each exercise and areas for improvement, as well as strengths, are identified. The improvement areas are corrected and tested in subsequent exercises to prevent recurrence.
C. ROLES AND RESPONSIBILITIES
Before March 1979 accident at Three Mile Island (TMI), off-site emergency planning at nuclear power sites by utilities and local and state authorities was done under the NRC oversight and basically on a voluntary basis. Specific requirements for off-site emergency planning as a precondition for licensing had not been established, and as a result, the capabilities to respond to a radiological accident varied greatly.
One of the major lessons learned from TMI was the need for a comprehensive, coordinated response plan, by every level of government and integration with on-site and off-site plans.
To investigate these and other concerns, President Carter appointed a special investigative body, the Kemeny Commission, to study the Three Mile Island accident. Following the Commission’s report, the President directed that principal federal responsibility for off-site emergency planning around nuclear power plants would be transferred from NRC to FEMA.
FEMA had been established in 1978 (prior to TMI) in order in order to create a single emergency planning and response manager for the Federal government. FEMA coordinates off-site measures at all levels of government to safeguard the population, while NRC maintains responsibility to oversee emergency actions taken inside the nuclear plant boundaries. NRC maintains its authority as the licensing authority for commercial nuclear power plants; FEMA provides recommendations and findings to NRC for use in its deliberations. Both agencies have issued extensive instruction in the Code of Federal Regulations to explain how their respective responsibilities are carried out.
Following is a brief description of licensee, state, local, and federal responsibilities:
· Licensees are responsible for operating the plant in a safe manner and for being prepared to respond to a radiological emergency in a manner such as to effectively mitigate the consequences of the emergency. If an accident should occur, the licensee is responsible for stabilizing the situation, bringing the plant to a safe condition, limiting the consequences, implementing onsite emergency planning, making offsite initial notifications and protective recommendations and providing sufficient plant status information to assist in offsite emergency response. The licensee is responsible for monitoring the plant and radiological parameters to determine the level of the emergency (unusual event, alert, site area emergency, or general emergency and recommend onsite and offsite protective actions.
· State and local agencies are responsible for maintaining the offsite emergency preparedness. In case of an accident, the State and local designee will consider the emergency action recommendation of the licensee and make any offsite protective action decision, including sheltering and evacuation. The offsite authorities are responsible for activating the alert and notification systems. Having alerted the public, the State or local agency will provide additional information to the public through the electronic media including what protective actions should be taken.
· State Emergency Management Agencies are the lead organization responsible for developing the State Radiological Emergency Preparedness Plan and for coordinating the development of associated county plans. They have a lead role and responsibility for the training of State and local emergency response organizations and for the conduct of public information and education. (In California the local agencies have the lead role).
· State Departments of Health are the state technical agencies responsible for the assessment of the impact of a radiological emergency and the environment. These agencies also function as the technical advisor to the emergency management organization in radiological matters and protective actions.
· County and municipal emergency management officials are responsible for the development and implementation of their respective emergency response plans. The federal, state, county, and local governments have developed coordinated radiological emergency preparedness plans. The plans are coordinated with the licensee on-site emergency plan and periodically exercised to ensure a fully coordinated, effective response and the availability by the required off-site support for an on-site emergency. State and local emergency plans have been prepared for every commercial nuclear power site in the country. All have received FEMA 44CFR350 evaluation and have been tested in exercises.
· The federal government’s role is to support the licensee, State, and local agencies in an emergency.
· The Nuclear Regulatory Commission (NRC) is the Cognizant Federal Agency when an event occurs at a commercial nuclear power plant. The NRC/FEMA response is documented in NUREG-0981/FEMA 51, Rev. 1, “NRC/FEMA Operational Response Procedures for Response to a Commercial Nuclear Reactor Accident, “ February 1985. The agency maintains a 24-hour-a-day Headquarters Incident Response Center where the Operations Officer is an engineer or scientist specifically trained for that job. The Center functions as the NRC’s point of direct communication through dedicated telephone lines with all operating commercial nuclear power plants. The Center notifies additional NRC personnel, including regional offices, and other Federal agencies as needed. During an emergency, the NRC establishes three teams:
· the Reactor Safety Team follows the course of the plant event and attempts to anticipate future plant responses;
· the Protective Measures Team follows the event from the radiological standpoint; and
· the headquarters Executive Team determines if or when to escalate the NRC response
The teams also include Congressional, Government, and Public Affairs liaison. NRC participates in a licensee-graded exercise once each quarter.
· The Federal Emergency Management Agency (FEMA) is responsible for off-site emergency plans and maintains the Emergency Information and Coordination Center (EICC) in Washington, DC, with communications capability to its regions and other Federal agencies. FEMA’s Radiological Emergency Preparedness Program (REP) has a two fold emphasis:
1. assistance to state and local governments in developing emergency plans (44 CFR 350)
2. coordination of federal agencies’ assignments to carry out federal functions (44 CFR 351)
D.
WHAT ARE THE
ELEMENTS OF AN EMERGENCY PREPAREDNESS PROGRAM?
All U.S. nuclear reactor facilities are required to participate in independently reviewed; full-scale emergency exercises every two years (and training drills in off years). For each exercise, the licensee creates a confidential emergency scenario to be played out by plant staff and local emergency response organizations, including law enforcement, local hospitals, radiological monitoring teams and others. Post-exercise critiques by the Federal agencies and exercise participants identify areas that need to be corrected in future exercises or improvements that need to be made to the plan itself. Following is a brief summary of the elements that are tested regularly:
· ONSITE EMERGENCY ORGANIZATION
The licensee is responsible for developing the on-site emergency organization of plant staff personnel for all shifts. An emergency coordinator must be designated who shall be on shift at all times and have the authority and responsibility to immediately and unilaterally initiate any emergency actions required to protect the health and safety of the public. Certain responsibilities cannot be delegated to others in the organization, including the decision to notify and to recommend protective actions to authorities responsible for offsite emergency measures.
· EMERGENCY CLASSIFICATION SYSTEM
All utilities at all commercial nuclear power plants use a standard emergency classification system. The emergency classification system provides for graduated levels of response from minor events of low consequence to very severe events. Specific Emergency Action Levels (EAL) trigger each classification.
· EMERGENCY COMMUNICATIONS AND NOTIFICATION
METHODS AND PROCEDURES
The licensee must have the capability to notify responsible State and local government agencies within 15 minutes after declaring one of four emergency action levels. The licensee must also demonstrate that administrative and physical means have been established for alerting and providing prompt instructions to the public within the 10-mile plume exposure pathway. The notification system should have the capability to essentially complete the initial notification of the public within the EPZ within about 15 minutes once the offsite responsible State or local authorities decide to notify them. In November 1985, FEMA issued FEMA-REP-10, “Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants.
Offsite Communications:
Each licensee is responsible for a primary and backup telephone system to make notifications to offsite agencies (e.g., NRC, State, and counties) within 15 minutes after recognition and classification of an emergency condition at the plant. A dedicated telephone line has been established between the plant control room and the NRC’s headquarters Incident Response Center. IE Information Notice No. 86-97, “ Emergency Communications System,” dated November 28, 1986, defines the emergency communications requirements.
Public Alerting Systems:
Off-site emergency agencies are responsible for notifying the public of an emergency and activating the notification system. However, the licensee must be able to demonstrate that a notification system is available within the 10-mile EPZ. Sirens are the predominant method of public alerting around the U.S. commercial nuclear plants and federal regulations have established criteria for the design of acceptable siren systems. The number of sirens that are required for the 10-mile EPZ will depend on the population density, type of terrain and other limiting factors. The average site will have between 50 to 85 sirens positioned throughout their EPZ.
Public Notification:
Once the public has been alerted to an emergency, the capability must be in place to provide an informational message or instructions to the public through out the 10 miles EPZ within 15 minutes. This capability must be available 24 hours per day. The most common method of providing instructions to the public is local radio and television stations. Another method of providing instructions to the public is by the Alert Notification System (ANS), a system of AM and FM radio stations which provide or are capable of providing, 24 hours per day transmission and have backup power generation capability.
In order to instruct the public to tune to a specific radio, television, or an EBS radio station for emergency information once alerted, emergency preparedness public information brochures are distributed throughout the 10 mile EPZ. The brochures identify the method of alerting and measures to be taken once alerted. The brochures discuss the various protective measures that residents may be asked to take, including sheltering, evacuation, and use of thyroid blocking agents or other precautionary measures.
· PUBLIC EDUCATION AND INFORMATION
The responsibility to insure the education of the general public concerning radiological emergencies and protective actions is jointly shared by the licensee, the State and the local governments. Information is disseminated annually to the public within the 10-mile EPZ. Specifically, information is provided describing how they will be notified in the event of an emergency and what initial actions should be taken upon notification. In addition, educational information on radiation contacts and special needs for the handicapped are addressed, as well as how to obtain additional information.
· EMERGENCY FACILITIES AND EQUIPMENT
Adequate provisions must be made for facilities and equipment to support the response to a given emergency. This includes monitoring, assessment, decontamination, first aid treatment and transportation. The physical facilities include an onsite technical support center, an operational support center, a near-site emergency operations facility, an onsite and offsite communications system, and a media center.
Emergency Response Centers:
Control Room (Onsite)
The Control Room is the primary facility where plant conditions are monitored and controlled and where corrective actions are taken to mitigate degradation of reactor systems.
Technical Support Center (Onsite)
The TSC is an emergency operations work area from that designated technical and engineering personnel trend plant conditions in order to predict further degradation and to devise appropriate corrective actions.
Operational Support Center (OSC) (Onsite)
The OSC is the assembly point for personnel providing emergency assistance to the Emergency Organization. The purpose of the OSC is to provide an assembly and staging area for essential operations support personnel who are deployed into onsite areas.
Emergency Operations Facility (EOF) (Offsite)
The EOF is the primary offsite center for the management of the licensee’s emergency response, coordination of radiological and environmental assessments, and determination of recommended public protective actions.
Joint Public Information Center (JPIC)
(Offsite)
The JPIC is the principal media contact point for the licensee, state, and local communities during a radiological emergency.
State Emergency Operations Center (EOC)
This facility provides the management of offsite emergency responses. The State EOC will serve as a location from which local officials may request manpower and resource assistance.
Local Community Emergency Operations
Centers (EOC)
The local EOCs serve the purpose of maintaining a communications point within each community as well as providing this capability with other adjacent communities and the State. Each local chief executive can direct protective actions to be taken for his community and can activate the public alerting system for his community.
· ACCIDENT ASSESSMENT
The means for determining the magnitude of and for continually assessing the impact of the release of radioactive material must be available to respond to an accident. Dose assessment is performed using actual in-plant effluent radiation monitors to generate the radionuclide source term, meteorological instrumentation, and associated hardware to develop a dispersion model for an atmospheric release, hydrological instrumentation to develop dilution factos for a liquid release, and the assumption of appropriate dose conversion factors (DCF) to account for the isotopic mixture and its concurrent chemical and physical state.
As part of the Radiological Environmental Monitoring Program, nuclear power plants maintain a fixed environmental monitoring system, within the 10-mile EPZ, consisting of Thermoluminescent Dosimeters (TLDs), air particle detectors and another environmental media sampling stations. During and/or subsequent to emergency conditions, this program is modified to collect and analyze additional samples from existing stations. Results are used to confirm radiation exposure estimates and environmental calculations.
· PROTECTIVE RESPONSE
A range of protective actions for emergency workers and the public have been developed for the 10-mile EPZ. Systems are available to warn and advise onsite individuals including employees not having emergency assignments, visitors, contractors, construction personnel, or others in public access areas. Provisions have been made for these individuals to leave the site by designated routes to some suitable offsite locations.
If needed, monitoring and decontamination capabilities of individuals leaving the site have been established. Having requested non-essential personnel to leave the site, the licensee must have the capability to account for all individuals onsite and be able to provide the names of missing individuals within 30 minutes of the start of an emergency. The licensee must be able to account for all onsite individuals continuously after that time.
The licensee will also make recommendations, if needed, to the affected State and local authorities. This may include sheltering, evacuation, or use of potassium iodide in a sector around the plant, early dismissal of school children, or relocating individuals in a specific sector. As part of this process, the emergency plan includes a designated evacuation route and relocation centers in most areas and shelter areas. People whose mobility is impaired and the means for registering and monitoring of individuals at relocation centers have been established.
For the 50-mile ingestion pathway, the procedure for protecting the public from consuming contaminated foodstuffs is addressed. The requirement that dairy animals be put on stored feed is a protective action. Lists are available of the names and locations of all plants that process milk products and other agricultural products.
· RADIOLOGICAL EXPOSURE CONTROL
The licensee has established onsite exposure guidelines that
are consistent with the EPA’s Emergency Worker and Lifesaving Activity Protective Action Guidelines. These guidelines address providing first aid, performing assessment actions, and decontamination, removal of injured persons and providing transportation and medical treatment of the injured. As an example of guidance developed on this subject, FEMA issued Guidance Memorandum EV-2, “Protective Actions for School Children” dated November 13, 1986. The purpose of the guidance is to assist State and local government officials and administrators of public and private schools in developing emergency response plans for use in protecting the students.
· MEDICAL AND PUBLIC HEALTH SUPPORT
Local and backup hospitals and medical services are identified for medical support of contaminated injured individuals. The licensee is responsible for having the onsite first aid capability. Transportation arrangements of the injured persons to the medical facilities are also part of the emergency-planning program.
· RECOVERY AND REENTRY PLANNING AND POST
ACCIDENT OPERATIONS
Following the accident and when the plant has been stabilized, the licensee will go into the recovery phase of the event.
· EXERCISES AND DRILLS
Each licensee is required to exercise its emergency plan annually. Each licensee is required to exercise with offsite authorities within the plume exposure pathway 10-mile EPZ biennially. All parties within the ingestion pathway 50-mile EPZ must exercise its plan every six years.
· CONTINUAL IMPROVEMENT
Critiques and Corrective Actions:
Following each exercise or drill, the licensee and Federal, State and local emergency response personnel conduct an in-depth critique. Areas for improvement are noted and placed in the licensee corrective action system. Corrective action attention is a year round responsibility.
· Audits, Reviews, and Self Assessments:
One element assuring corrective actions is the audit or program review process through which all emergency preparedness programs work. Program reviews (checks) range from one end of the spectrum to the other…from quarterly communications checks (internally and externally) and equipment/facility checks to independent program reviews of the EP program. Periodic (on a set schedule) tests of the prompt public notification system are also a part of this process.
Audits are conducted by the licensee’s own quality assurance departments and inspections are conducted at various times by outside regulatory groups such as the NRC. These audits/inspections cover all aspects of the emergency preparedness program. In all cases, the associated emergency plans and procedures must be reviewed at least annually and revised as necessary.
Licensee’s periodically self-assess their program elements. Frequently the licensee will request a subject matter expert from another department or licensee to participate in the self-assessment.
· EMERGENCY RESPONSE TRAINING
Annual training of company personnel (onsite and offsite) and training of non-company personnel (offsite at the local level) is conducted. This process is continual throughout the year. This element of emergency planning incorporates the following methods: classroom instruction; performance-based training, walk through for specific groups within certain emergency response facilities and between facilities; integrated drills; training drills; and medical drills.
·
EMERGENCY PLANNING ZONES
(EPZ)
In 1978, a joint task force of the US Environmental Protection Agency (EPA) and US Nuclear Regulatory Commission (NRC) developed the planning basis for offsite emergency preparedness efforts considered “necessary and prudent” for power reactor facilities. During the development of the planning basis, the task force received substantial input from other Federal agencies and the Inter-organizational Advisory Committee on Radiological Emergency Response Planning and Preparedness of the Conference of State Radiation Control Program Directors, which also included representatives of the National Association of State Directors for Disaster Preparedness and the U.S. Civil Defense Council.
Subsequently, the planning basis has been adopted by
the Federal Emergency Management Agency, which assumed the Federal lead role in
offsite radiological emergency planning and preparedness responsibilities under
order from President Carter in 1979.
This planning basis continues today as the primary basis utilized by the
Federal Radiological Preparedness Coordinating Committee (FRPCC)[1]
with respect to coordinating all Federal responsibilities for assisting State
and local governments in radiological emergency planning and preparedness
activities.
An important element of the planning basis developed by the NRC/EPA task force is that it defines the geographical area around nuclear power plants over which planning for predetermined actions should be carried out to protect public health and safety in the event of a radiological emergency at a nuclear power plant. In developing the planning basis, the task force did not attempt to define a single accident scenario. Rather, the task force considered a number of potential accidents, including the core-melt accident release scenarios of the Reactor Safety Study.
The planning basis was related to two predominant pathways by which a population might be exposed to radiation released as the result of an accident. The two exposure pathways include the following:
a.
The
plume exposure pathway includes direct exposure from radiation in a
plume as it passes, as well as from radioactive material deposited on the
ground or other surfaces. The pathway
also includes exposure from inhalation of radioactive material in the passing
plume. The recommended protective
actions for the plume exposure pathway are evacuation from the area, or sheltering,
if timely evacuation is not practical.
More recently, the States are considering whether to include the
distribution and use of potassium iodide to protect against exposure from
radioactive iodine in the plume, as a supplement to evacuation and sheltering.
b.
The
ingestion exposure pathway includes exposure from the consumption of
contaminated water, milk, or foods. The
recommended protective actions for the ingestion pathway include near-term
actions, such as removing cows from pasture and putting them on stored feed
supplies, as well as long-term actions such as monitoring and interdicting
sources of water, milk and foods, as necessary to protect public health and
safety.
The areas, over which planning efforts are carried out, referred to as emergency planning zones (EPZs), are associated with the plume exposure pathway and the ingestion exposure pathway. The EPZs are defined as the areas for which planning is carried out to assure that prompt and effective actions can be taken to protect the public in the event of an accident. The two EPZs are discussed in more details below:
a. The plume exposure EPZ includes a radius
of 10 miles (more than 300 square miles) around the plant. The size of the plume exposure EPZ is based
on the following conclusions by the NRC/EPA task force:
· Projected doses to the public from design
basis accidents would not exceed Protective Action Guide (PAG) levels[2]
beyond the 10 mile zone;
· Projected doses from most core melt
sequences would not exceed PAG levels beyond the 10 mile zone;
· For the worst-case core melt sequences,
immediately life-threatening doses would generally not occur beyond the 10 mile
zone;
· Detailed planning within the 10-mile zone
would provide a substantial base to support the expansion of emergency response
efforts in the event this proved necessary.
b. The ingestion exposure EPZ includes a
radius of 50 miles (more than 2500 square miles) around the plant. The size of the ingestion exposure EPZ is
based on the following conclusions by the NRC/EPA task force:
· The downwind range within which
contamination might occur will generally not exceed PAG levels beyond the 50
mile zone because of wind shifts during the release and travel periods;
· There may be conversion of radioactive
iodine suspended in the atmosphere during transit to chemical forms that do not
readily enter the ingestion pathway;
· Much of the particulate material in a
plume will have deposited on the ground during transit within the 50 mile zone;
and
· The small likelihood of exceeding ingestion
pathway PAG levels at 50 miles is comparable to the small likelihood of
exceeding plume exposure PAG levels at 10 miles.
The 10
and 50 mile EPZs are currently employed in nuclear power plant emergency
preparedness programs as the basis for planning, testing and exercising
predetermined emergency response capabilities.
D.
WHAT IS THE EXPERIENCE WITH NUCLEAR PLANT
EMERGENCY RESPONSE PROGRAMS?
Emergency
response plans developed by the nuclear industry have been activated
successfully by local officials for use in other emergencies. A few examples:
· The evacuation of 10,000 people from
Cedar Rapids, Iowa, in July 1985, following a fire at a city-operated sewage
treatment plant that dispersed a black cloud of toxic fumes over the city. State and local officials used a draft plan
developed for Alliant Energy’s Duane Arnold nuclear plant.
· The evacuation of 17,000 residents of St.
Charles Parish, La., following a leak from a nearby chemical plant in December
1982. State and local officials worked
from a draft plan for Entergy’s Waterford 3 nuclear plant, which was not yet
operating.
E.
WHAT IS THE NUCLEAR INDUSTRY’S COMMITMENT
TO EMERGENCY PLANNING?
Emergency
preparedness at U.S. nuclear power plants is an integral part of daily
operations. A commitment to excellence
throughout the industry coupled with continual training and testing, has
produced a high level of preparedness.
For example:
· Emergency response plans are constantly
upgraded through lessons learned from actual plan activation, as well as
repeated drills, exercises and independent critiques.
· Training programs are conducted annually
for all emergency response personnel.
The National Nuclear Accrediting Board accredits training programs for
operators and technical staff.
· Effective methods have been developed to
assess performance in drills and exercises, and to improve emergency
preparedness through lessons learned.
· State-of-the-art response facilities have
been built and existing facilities upgraded to aid effective handling of
emergencies.
· Sophisticated plant computer systems have
been developed to serve as effective tools for dealing with emergencies.
· Advancements in communications technology
have been incorporated to improve the industry’s ability to respond to
emergencies.
·[1]
The FRPCC is chaired by FEMA, and includes representatives from the Departments
of Commerce, Defense, Energy, Health and Human Services, Transportation,
Agriculture, Interior, Veterans Affairs, State, Housing and Urban Development,
Justice, and the General Services Administration, NASA, USEPA and USNRC.
[2] Protective Action Guide (PAG) levels refer to criteria that are established by the EPA. The PAG is a level of projected radiation dose from an unplanned release at which a specific protective action should be taken. For example, the PAG for initiating evacuation or sheltering is when members of the public are projected to receive 1 rem or more from an actual or anticipated release. The PAGs are published in EPA Report 400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents,” 1992.