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Act. . E.', ,

PEMORANDUP FOR: Harold P. Denton, Director *

Office of Nuclear Reactor Regulatien

Darrell G. Eisenhut, Deputy DirectorOffice of f.'uclear Feactor Regulation

James P. Taylor. DirectorOffice o' Inspection f. Enforcerent

Edward L. Jordar. DirectorDivision of Emergency Preparedness

and Engineering Response

Robert P. Bernero, DirectorDivision of Systems Integration

Themis P. Speis. DirectorDivision of Safety TechnologyOffice of Nuclear Peactor Regulation

Joseph F. Scinto, Deputy Directorof the Fearing Division

Office of the Executive Legal Director

FRCP: Frank H. Rowsome, Assistant Directorfor Ter.brology

Division of Sr'ety TechnologyOffice of Nuclear Reactor Reguletion

SUEJECT: EMERGEFCY PREPAREDNESS

There are a number of reasons tc look at reform of the trcublesone emergencypreperedness (EP) regulatiers that do net depend upon source-tern reductiers.In my view, the case shapes up as follows:

1. The emergency preparedness rules and implementttion under the NRC/FEP/.aoreenert of NUREG-065a have failed to reduce offsite radiological risk.This was first documented in the Indien Point heering. Many of theredundant reasons for tnis conclusion are generic. Reexamination ofthe bases for this conclusion suggests that it can be extended to allplerts. The techr.ical basis for this argument is sketched in theattachmeat. At a re t, emergency preparedness fails as a final layer

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a aess g , , , , , , , , , , ' , , , , , , , , , , , , , ,, , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , o"".an.."" .

l satt g . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . " . " . . . . . . . " . " . " . . . . . ~ . " . " " " " " . " " " " " " "

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i of de'ense-in-depth; it does not enhance the safety cf the public aroundnuclear power plants.,

2. The erwrgency preparedness regulations are fatally flawed as examples4

! of scund regulatien. They place responsibility with those whg have noautherity insofar as they mardate participation by offsite state and'

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local governments. It offers a tempting legal gambit for local!| authorities te balk in the face of rate shock, something it wts rever; intended to do. The " graded energency response" proposals initially

developed by ASTP0 e year ago (and advocated by IDCOR today) do nothingto cure this vicious " Catch 22" aspect..

3. The vagueness as well as the " Catch ?2" features of the regulations *.

| constitute a fertilizer for litigation, delay, controversy, e.nd badpublic relations that has a legel nexus - thanks to the reculations -1

i but no technical relevance to public health and safety. The resultunnecessarily irvolves the courts, attenuates NRC control, are damagesthe institutional fabric of reactor safety regulation, as well ascosting massive amounts of money.1

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j 4 Even if emergency preparedness could eliminate early casualties, asprojected with WASH-1400 source tems, the value of doing so would be"

many orders of magnitude less than the ecsts of conpliance, under theregulatory analysis conventions employed in generic stentardsdevelopment, backf1t policy, in the proposed safety goals, or those

j suggested in the Indian Point Hearings on risk. Since we intend to use r

i the same conventions in our effort to scrub the rules of unproductive i-

i fertures, emergency preparedness is a natural application of this ;

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| Note that none of these arguments that the energency preparedness' regulations warrant overhaul depend upon reductions in WASH-1400 source ,

tems. Should we regard source-tem reductions as ripe for use in technical.

! standards development, the reductions would constitute e fifth reason for 4

i refom of the EP regulations.

! I see e route out of this dileme that might be called the " Good Neightcr" !

: policy. Since evacuation planning is virtually worthless as a risk reductiontactic, I propose that we abandon the EP rules ir favor of a recognition that i

! nuclear power plants can and rust be made safe enough te be " good neighbors" || in the absence of offsite emergency pierning. The new rule would not recuire <

any state nr local participation in emergency planning or drills, althoughthese local authorities would be kept informed. The rule would pair the

j ebandonment of NUREG-0654 planning with the imposition of the further severeaccident safety analysis, called for in the draft Severe Accident Policy, to,

i debug the cperating plants of outliers, and with the accident managementinitiatives to extend emergency operating procedures fron the preventier of-

core damace irto the realm of managing core melt accidents or site. We,

; could truiy portrey the new rule as providing better limitation of offsitei~ || .e. , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

, , , , , , , , , , ' , , , , , , , , , , , , , ,4sensg g . . . . . . . . . . . . , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , . . . . . . . . . . . . . . . ., , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , ,.

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radiological risk than the current regulations de, thus blunting the argurentthet we appear to be relaxing the rules. The attachnent sketches sonealternatives for the new rule.

I hope you give this prepesal serious consideration and pass it or - as foodfor thought - to Vic Stello and Bill Dircks.

Original signed byFrank H.Rowsome

Frank H. Rowsone, Assistant Directorfor Technolog;*

Division of Safety TechnologyOffice of Nuclear Reactor Regulation

Attachment:Pisk Reduction fron

Emergency Preparedness

cc: F. Gillespie

S. Sebwart:A. ThadariD. MullerP. MinrersP. Jar.gochianS. Acharya

Distribution Copies:Central FilesAD/T r/fDST c/f

.TSpeisFRowsome

AN '

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AITACHMENT .'i

RISK REDUCTION FR0fi EMERGENCY PREPAREDl!ESS I

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Realistic analyses of t'he consecuences of severe radiological releases fror

; nuclear power plants have always shown that the number of latent casualties

| are largely unaffected by the speed or timing of evacuation or relocation.

! Thus, it is widely acknowledged that short-term emergency response isi motivated by the desire to limit early casualties. I will not go into the

; reasons why short-term emergency response does not influence latent

j casualties here, but the reasons are well known..

| fn the Indian Point hearings on risk, a number of pieces of evidencedemenstrated that energency planning - as currently conceived - has little

; or no effect on early casualty projections.

! 1. First, PRA always employs data in preference to judgment in assessingthe reliability or performance of safety functions. There is some dataon the influence of emergency planning upon the effectiveness ofemergency response. It shows that unplanned evacuations proceed as

i rapidly as planned evacuations. 1he data originate in chemical spills,floods, storms, and other non-nucl. ear contexts. The data are not so

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extensive as one might prefer. Nonetheless, the message of the data isclear: sonntaneous, unplanned evacuations work very well. The

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historical record suoports the conclusion that once a hazard isrecogni:ed and a decision to evacuate is trade, state and local

| authe-ities can carry it out quickly and effectively vithout elaborateprior planning. This, alone, would have sufficed to support a PRA

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assessment that emergency planning doesn't make a difference to risk.Nete that this conclusion is generic; it is not limited to Irdian Point.However, the testimony wen'. on to assess the effect of emergency

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: response variables on risk,i' m.

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For each releese category event, it was fcund that early casuelties are ;e .-

no more rumerous when evacuation fails than they are when evacuation'

works as planned. The default, scenario, developed to model cases in

which anticipatory evacuation fails to take place, was defined asrelocation from hot spots of offsite radiological contenination eight to

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twelve hours after plune passage. The " successful" evacuatier scenaries

|with which it was compared assumed a delay time, which was a function of |the in-plant accident scenario, followed by anticipatory evacuation at a'

pace chcsen to match the evacuation time estinates developed by specialistconsultants on the speed of evacuation. The surprising result thatanticipatory evacuation works :no better than relocation was traced to itsorigins in the calculation of' reactor accident consecuences. The

results of this detective work reveal why we obtained this surprising

resul t. Accidents that take long enough to evolve into a release toenable the people to get out ahead of the plume would net have yielded

early casualties even if the people had steyed home. Slowly developing

accidents simply posa negligible threats of early casualties. Note that

WASH-1400 source tems were used in this assessment. For the rapidly'

ceveloping accidents that give rise to virtually all the projected earlycasualties, many evacuees fail to beat the plune. Houses and work

places tend to provide better shielding than cars or busses. Thereforethe attendant risks of exposing evacuees to the plume while in transit >

penerally compensated for any advantage to those escaping the plume orgetting farther away before the plune reached them. Some specifics of

this analysis are site dependent. For example, the expert estimates of

evacuation rates for the Indian Point site may be longer than those for

: some other sites. However, the basic finding is generic to any appli-

catior of WASH-1400 source terris: accidents that develop slowly enough

for evacuation to clear the EPZ ehead of the plume do not yield appre-

ciable, early casualties in any event. The attendant risks of exposure

in-transit tend te counterbalance the berefits of anticipatory evacu-atior for the rapidly develeping accidents that give rise to the bulk of

|. the early casualties. The conclusion is inescapable: anticipatory

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evtcuation carnot be expected to lower early casualties reliably oreffectively from severe reactor accidents. Since this conclusionapplies to the full spectrum of WASH-1400 release categories, it can beexpected te remain true if source terms increase a little or decrease agood deal.-

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3. At Indian Point, the bulk of the risk was attributed by the staff toaccidents triggered by earthquakes or hurricanes. Initiators of thiskind will only trigger reactor releases if they are of extraordinaryseverity. They can be expected to preclude ground transportation andinterfere with communication throughout the EP2. Many people might also

be deprived of shelter by such an initiator. This is a plant-specificconclusion which is probably not unique to Indian Point, but is far froma universal pattern among nuclear plants.

FF.A has been used as a basis for the development of the emergency prepared-

iess rules and NUF.EG-0654. For example, NUREG-0396 employed sensitivity

studies on.the. WASH-1400 consequence model to provide a technical basis for

the development of emergency preparedness guidelines. Theretore, it is

useful to examine why such. insights as those developed at the Indian Poir.t;

Hearino did not surface earlier.;i

The historicel data suggesting that unplanned evacuations work as well asplanned evacuetions' has been available'since the early 70's and is con-sistent with U.S. experience since then. This information is well knownin'the PP.A community. It appears to have had little influence on thedevelopeer.t of the rules and regulations, though.

The sensitivity studies in NUREG-0396 and comparable, more recent work are

| 2echnically correct but misleading. They show, as one might expect, that

| fait evacuation yields lower casualties than sloy evacuation. They tend to

assure that the alternative to evacuation is no evacuetion at all or very

slow evacuation. They have not used relocation as the default case for |

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these situatiens in which anticipatory evacuation fails and beve not compared'the potertial to improve relocation times compared with evacuation rates.

The accident at Three Mile island demonstrates the viability of relocatien as'

the " default" scenario. Within hours of the time that TMI was recognized tohave the pctential to be radiologically severe, the environs of the plantwere crawling vith health physicists monitoring the environment. .They camefrom the licensee, from the NRC, DOE, EPA, FEMA, and the Defense "Hirteents

I an told. It can be assumed that if there had been hot spots of residual

ground contamination in the surrounding counties after a severe release,these hot spots would have been mapped and the residents relocated within a#ew hours of plume passage. Thus, the nost accurate model of pre-1980emergency response and a good " default" model to portray the failure ofevacuation plans today, is to assume that the population is relocated fromhot spots of residual contanination within a few hours of plume passage.

Wnen such models of relocation after plume passage are compared with the4

spectrum of evacuation models, it is found that the default cause yieldsfewer early casualties than the models of slow or no anticipetery evacuation.They yield roughly the same casualty estimates as do the models of antici-patory evacuation with realistic evacuation rates, as the Indian Point recordsuggests. Very fast anticipatory evacuation looks better than relocation.However, fast relocatien looks nearly as good as fast evacuation, and thedifference in the logistical problems between the two approaches to emergencyresponse ray well indicate that the speed of selective relocation is moreperfectible than the speed of bulk population movement. The singular advantage

j held by anticipatory evacuation over relocation is that it supports an ALARAprinciple for exposures. In the slowly developing accidents that would not:ause early casualties in any event, successful anticipatory evacuation does

. evoid modest doses for those beating the plune.

'Tbc logistics of relocation after plume passage are quite different frerthose of anticipatory evacuation. In anticipatory evacuation, laroe numbers ;

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only the small numbers of people in hot spots of residual contaminationwarrant prompt relocation. This entails moving only small numbers of peopleshort distances in order to be successful. High levels of residual contam--

ination - at a level that could threaten early casualties in a few-days ofexposure - cannot cover much territory. If the contamination were moredilute, prompt relocation would not be necessary to avert early casualties.Relocation presumes tha't the residual contamination has been measured and

mapped within hours of plume passage. Thus it must be guided by a coord-inated group of health physicists who infern state and local authorities onwhat areas to relocate first, which second, and so forth. Should one wishto mandate preplanning for speedy relocation after plume passage, theessential element would be to coordinate the roles of licensee and federalhealth physicists in mapping contamination and prioritizing locales forrelocation, since speedy diagnosis of the situation requires a high level ofteam work among these federal and utility personnel. As both a legal and

; practical matter, state and local authorities should physically cenduct therelocation,' as planned by the health physicist team. In light of the good'

record of unplanned evacuations, the only essential element of state andlocal participatior. in reactor emergency preparedness is a clear understanding

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of the source from whom they can expect to get authoritative information onthe hazard and relocation priorities. The utility and federal health,

physicists (HP) who map the contaminetion and set relocation priorities needmore knowledge of severe reactor accident risk than is common among certifiedfps. If their effort to prioritize a ' relocation sequence is to be mostefficient, they need to be able to project accident secuences, source terms,understand the effect of weather upon consecuences and appreciate the

: thresholds of contamination, to be expected of accident releases, at whichearly casualties mignt be expected. They should also be familiar with theshielding factors to be expected of structures and vehicles. Much of this

j information is not well known to either utility or federal HPs. Therefore,i if we mean to take emergency preparedness seriously as a risk reduction

tactic, whether in its current form or in modified forn, there is much to be

done to accompidsh the relevant training.

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The foregoing 'assessmert of emergency planning for relocation presures that |the risk warrants some planning. The evidence suggests otherwise. Theprefected number of early casualties fron reactor accidents are alwaysdwarfed by the projected number of latent casualties, with any plausible

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source-term model, not to mention the preponderance of offsite and onsiteproperty damage in the risk prcfile of nuclear power plants. If a plant

poses an acceptable risk with respect to property denage and latent |

casualties, a case can be made that early casualties will be a non-problem,even with WASH-1400 source terms. All of the ways of conductingbenefit / cost analysis that have been suggested would indicate that thebenefit of even something as radical as the totel elimination of earlycasualties from the risk profile of a nuclear power plant would be worthvery small expenditures. An essessment for Indian Point suggested that thecosts of actually conducting evacuations, even if they took place only forgenuine core melt accidents, would be larger than their value, not tomention additional costs for preplannine. I conclude that if a p' art hasbeen adeouately debugged of prominent severe accident vulnerabilities te be

acceptable with respect to prcperty damage risks, then the early casualty riskwill be acceptable with ample margin. The plan suggested by the draftSevere Accident Policy calls for further decision making on the adequacy cfcontainment performance of reference plants and further severe accidentsafety analysis for each operating plant in order to meet two objectives:to verify that the generic decisier rede on the reference plant applies, andto debug the operating plants of outlier vulnerabilities. If this is done,

a convincing case can be made, I believe, that nothing further reeds to bedone to limit early casua.lty risk.

It is worth noting here that the proposed Commission sefety goals are illsuited to make this case. One characteristic of the safety goals inMUREG-0880, Rev.1, is that they are effectively very stringent for earlyfatelities and very lenient fer latent casualties. Therefore, a plant cantrip the early fetelity guideline and pass the cancer fatality guideline,-

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eventhoughNeprojectedlatentcasuratiesperunityearoutnumbertheprojected early casut1 ties by thousands to one. This remains true of the

safety gcal recomendations of the staff Safety Goal Evaluation Steering

Corcittee. In addition, the algorithm for assigning a value to ris,kreduction for use in benefit / cost analysis does not value the reduction ofearly casualties apart from societal dose reduction. The stringent earlyfatality guideline wi11'suggest that enough has been done without creditirgemergency planning. On the other hand, the perspective on the comparativeimportance of early and latent casualties and a more discriminatingvaluation of worth cf early casualty risk reduction will not be found in thesafety geals. As a result, the safety goals will be of much less value inputting emergency preparedness issues into perspective than one might hope.Thus, it may be desirable to make the safety goals more comprehensive anddiscriminating.

A case that current emergency planning accomplishes no risk reduction could

be made todey. It would require a little research to flesh out the documen-tatier, but it would require ne assumptions about source-term changes or theultimate implementation of forthcoming policy initietives such as those onsevere accidents er safety. gcals. It would support dropping the emergency -1

preparedness rule, or replacing evacuation planning with federal-licenseerelocation planning, and so eliminate the need for state or local participa-tien in planning and drills. That would solve the " Catch 22" problems in theexisting regulatiors. .

The abanconment of energency planning, beyerd the imposition of a reovirementfor onsite accident management planning, is, I think, the preferable answer.It more accurately reflects the realities of severe accident risk and dealswith all of the defects of the current EP regulations. However, couplinc'

EP reform with the debugging of operating reactors of their outlier vulner-ebilities in a " good neighoor" policy would take longer. Such a rulemaking

would reouire that our thinking be more mature than it is now about severeaccident manaoerent and the further severe accident safety analysis to debue

. pe :: *. i u, rncto.i. YU'. thc';c are tractabit probien. Such a ruit cnuid

take shape in about t year or less if we put our rind to it. I recomend it.

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