PNERP - Provincial Advisory Group Final Report

Provincial Nuclear Emergency Response Plan - Advisory Group Final Report

Sept. 2017 


Table of Contents

  1.   Introduction
    1.   PNERP Advisory Group
    2.   Mandate and Scope
    3.   Methodology
      1.   Written Submissions
      2.   Stakeholder Interviews
      3.   Indigenous Engagement
      4.   Document Review
  2.   Emergency Planning Principles
    1.   Societal Values and Risk Perception
    2.   The Precautionary Principle
    3.   Emergency Planning Considerations
    4.   Best Practices
    5.   Protective Action Levels
    6.   Consequences of Decisions
  3.   Nuclear Accidents
    1.   Past Nuclear Accidents
    2.   Accident Classification
    3.   Emergency Planning Basis
  4.   Planning Zones and Protective Actions
    1.   Criteria for Zone Distances
    2.   Source Term Identification
    3.   Contingency Planning Zone
    4.   Iodine Thyroid Blocking
    5.   Hazards from U.S.-based Reactors
  5.   Implementing Plans
  6.   Transparency and Public Participation
  7.   Conclusion
  8.   Appendices
    1.   Appendix A - Summary of Advisory Group Recommendations
    2.   Appendix B - Summary of Advisory Group’s Review of Proposed Changes to the PNERP (2009)
    3.   Appendix C - Member Biographies
    4.   Appendix D - Moving Forward – How Academia Would Approach Framing the Problem of Nuclear Response Plans
    5.   Appendix E - References

1. Introduction

Under Section 8 of the Emergency Management and Civil Protection Act (EMPCA), Ontario’s provincial government is mandated to set up a Provincial Nuclear Emergency Response Plan (PNERP), to ensure that there is an effective response to emergencies arising at nuclear installations, which include nuclear generating stations.

The accident at the Fukushima Daiichi nuclear power station on March 11, 2011 involving a meltdown of three reactors, caused by a magnitude 9.0 earthquake and multiple subsequent tsunamis, gave governments reason to re-evaluate their policies and approaches to response and preparedness. In the years following the (hereafter called the) Fukushima accident, the Office of the Fire Marshal and Emergency Management (OFMEM) within Ontario’s Ministry of Community Safety and Correctional Services (MCSCS or ‘ministry’) initiated a project to review the PNERP[1] and planning basis for nuclear emergency response to consider more severe multi-unit accident scenarios.

A key element of this review process was an invitation to the public to participate by reviewing and providing feedback on two consultation documents: a Planning Basis Discussion Paper[2] (OFMEM)’s review and recommendations for proposed updates to the PNERP Master Plan) and a separate document listing the proposed updates to the PNERP Master Plan. The aforementioned consultation documents were posted publicly to both the province’s Environmental Registry and Regulatory Registry on May 15, 2017. The posting period was initially 60 days, but was later extended to 75 days, ending July 28, 2017.

The province also established an independent PNERP Advisory Group (‘Advisory Group’) to review the comments received from both stakeholders and the public, and provide the Minister of Community Safety and Correctional Services (‘minister’) with recommendations on how this feedback should be incorporated into the PNERP. This report contains our final recommendations to the Minister (summarized in Appendix A), as well as our review of the ministry’s proposed changes to the PNERP (summarized in Appendix B), and our review and deliberations regarding public and stakeholder submissions and stakeholder interviews.

1.1 PNERP Advisory Group

The Advisory Group consists of independent experts in the fields of emergency management, risk assessment, nuclear and radiation safety, and nuclear emergency response (see Appendix C for full member biographies):

  • Dr. François Lemay (Chair), President of International Safety Research
  • drs. Chris Dijkens, Emergency Preparedness and Response Expert
  • Prof. David Etkin, Associate Professor of Disaster and Emergency Management, York University
  • Dr. David Novog, Professor, Department of Engineering Physics, McMaster University and NSERC-UNENE Industrial Research Chair in Nuclear Safety
  • Dr. Akira Tokuhiro, Dean and Professor of the Faculty of Energy Studies and Nuclear Science, The University of Ontario Institute of Technology

1.2 Mandate and Scope

The Advisory Group’s mandate is to review and consider public comments regarding the proposed changes to the Master Plan and associated Planning Basis, and provide advice to the minister on the incorporation of public feedback in the updated Master Plan.

In order to fulfill this mandate, the Advisory Group was directed to undertake the following activities:

  • Review written comments received from the public on proposed changes to the PNERP Master Plan and its Planning Basis
  • Provide a forum for consultation and consideration of comments from potentially affected First Nations and Métis communities and Indigenous partners
  • Provide a forum for groups/individuals who have submitted written comments, that are within the scope of the public consultation and the scope of the Advisory Group’s mandate, to make an oral deposition in support of their written comments at the discretion of the Advisory Group and,
  • Provide a disposition of all comments that are within the scope of the Advisory Group’s mandate

The Terms of Reference further specified that, in recommending changes to the PNERP Master Plan and Planning Basis, the Advisory Group may take the following actions:

  • Recommend that the changes to the updated Master Plan and/or Planning Basis be approved as originally proposed
  • Revise, modify, or reject proposed changes and, if appropriate, recommend for inclusion/implementation in the updated Master Plan and/or Planning Basis
  • Recommend any other matters of general significance within the scope of the Advisory Group’s mandate

The scope of the Advisory Group’s mandate was to consider:

  • Ontario’s ability to plan for, and coordinate the response to, nuclear emergencies and protect the health, safety, welfare and property of the province
  • Best practices with regard to off-site emergency preparedness and response activities and,
  • Changes related to international best practices arising from lessons learned from the 2011 Fukushima accident

Issues that do not fall within the exclusive jurisdiction of MCSCS were considered to be outside of the scope of the Advisory Group’s mandate.

1.3 Methodology

The advice provided in this report was generated through our review of written submissions, follow-up interviews with a selection of stakeholders, review of the current PNERP (2009), the list of proposed updates to the PNERP Master Plan, the Planning Basis Discussion Paper and associated reference documents, and the expert judgement and professional experience of the Advisory Group members.

1.3.1 Written Submissions

The Advisory Group was provided with all the submissions received by the Ministry of Community Safety and Correctional Services. In total, 1,568 submissions were received during the public posting period. Every one of these submissions was read and reviewed by at least one member of the Advisory Group.

1.3.2 Stakeholder Interviews

Several stakeholders were invited to meet with the Advisory Group in-person to present and discuss their positions. In order to understand not only the content of the respective submissions, but also the beliefs and assumptions underlying a broad spectrum of positions in the limited time available, we selected stakeholders that provided a representative cross-section of opinions on the Planning Basis Discussion Paper and proposed changes to the PNERP Master Plan. We also considered our mandate and scope, and the nature of the submissions received.

The following groups were identified and selected:

Office of the Fire Marshal and Emergency Management (OFMEM)

The Advisory Group met with the authors of the Discussion Paper to better understand their goals and the methodology used to develop the Discussion Paper recommendations and proposed changes to the PNERP Master Plan.

Health Canada, Radiation Protection Bureau and the Canadian Nuclear Safety Commission (CNSCM)

The Advisory Group gave specific consideration to these organizations which substantially contributed to the development of the Planning Basis Discussion Paper by providing the OFMEM with scientific data and expert input, and by having been involved in discussions with the ministry on the revision of the PNERP.

Ontario Power Generation (OPG) and Bruce Power

These two operating utilities were interviewed to discuss and obtain clarification on their submissions.

Greenpeace and the Canadian Environmental Law Association (CELA)

In order to ensure that the Advisory Group could discuss and understand the views expressed in the submissions regarding the revision to the PNERP, organizations whose contributions reflected the views of a large number of submissions related to the Discussion Paper were interviewed. Analysis of individual submissions demonstrated that Greenpeace and CELA are both organizations with a broad outreach to, and interaction with, communities living near nuclear installations, were representative of a large portion of the views expressed in the submissions of individuals and community organizations.

Regional Municipality of Durham

The Advisory Group wanted to understand the views of frontline organizations that are responsible for the implementation of the PNERP at the regional level and to gain insight into the feasibility of a modified response plan. In this regard, the Regional Municipality of Durham was selected due to its close proximity to two nuclear generating stations (Pickering and Darlington).

Inverhuron and District Ratepayers Association

In order to gain insight into the views of the local population in the immediate vicinity of an operating nuclear generating station, a representative of the Inverhuron and District Ratepayers Association was invited to meet with the Advisory Group.

Stakeholder interviews were 90 minutes long. While stakeholders were given the opportunity to provide a brief (15 minute) opening statement or presentation to clarify and support their written submissions, most of each meeting was dedicated to asking questions and engaging in open discussion with the invited group in order to obtain a deeper understanding of their respective positions. We considered the outcome of these interviews in our assessment of the proposed changes to the PNERP Master Plan and Planning Basis Discussion Paper, and in the development of the recommendations contained in this report.

1.3.3 Indigenous Engagement

As outlined in the Advisory Group’s Terms of Reference, an important part of the engagement process was receiving input from Indigenous partners, particularly those that are located close to nuclear generating stations. There are no First Nations or Métis communities located within the 10 kilometre (km) Primary Zone surrounding each nuclear generating station; however, three First Nations and associated Reserve lands (shown in brackets in the list below) are located within or in close proximity to the 50 km Secondary Zone of the nuclear generating stations:

  • Saugeen First Nation (Chiefs Point 28 and Saugeen 29) – Bruce Power Nuclear Generating Station
  • Mississaugas of Scugog Island First Nation (Mississaugas of Scugog Island and Islands in the Trent Waterway 36A) – Darlington and Pickering Nuclear Generating Stations
  • Bkejwanong – Walpole Island First Nation (Walpole Island 46) – Fermi 2 Nuclear Generating Station

In summer 2017, the ministry sent engagement letters to the leadership of these three First Nations, as well as the Chiefs of Ontario, inviting them to provide feedback on the proposed changes to the PNERP and on the engagement process. No comments were received from First Nations or Métis communities or organizations during the 75 day public consultation period. As such, we were not able to consult and consider comments from Indigenous partners.

1.3.4 Document Review

In addition to the submissions from the public consultation process, the existing PNERP Master Plan (2009) was reviewed chapter-by-chapter to assess its content and determine if changes were warranted. We also reviewed the Planning Basis Discussion Paper and OFMEM’s list of proposed changes to the PNERP Master Plan to evaluate the appropriateness of the proposed changes as well as the need for any further PNERP amendments. Finally, all of the supporting documents cited in the Planning Basis Discussion Paper were reviewed to ensure that relevant information was included in this assessment.


2. Emergency Planning Principles

In reviewing submissions, we noted a range of public and stakeholder comments on the principles and important values that should be used for emergency planning. Key themes are discussed in the following subsections. Based on the feedback we observed in a large number of submissions, it was apparent that the motivations and principles used in the ministry’s planning process were not clearly understood by the public.

2.1 Societal Values and Risk Perception

Support for the protection of the public good and the improvement of public safety were consistent themes expressed in virtually all of the 1,568 submissions, yet the Advisory Group observed some significant differences in the opinions expressed by various groups. These fractures are based upon different opinions on: (1) what is a tolerable level of risk for exposure to radiation, (2) the degree of belief in technical risk assessments and, (3) the ethical basis to be used for decision making.

While all of the positions expressed seek the well-being of the public, quite often the end conclusions reached by different groups are radically different. We have tried to consider the perspectives of every group that provided input into this process, and acknowledge where there are differences of opinion. We feel that the Discussion Paper would receive wider public support if it were to broaden its framing to include ethical decision-making perspectives in addition to risk assessment. See Appendix D for a discussion of how academia would approach framing the problem of nuclear response plans and a discussion of elements that could be included in future Planning Basis Discussion Papers.

2.2 The Precautionary Principle

Many community groups included ethical considerations such as the precautionary principle in their responses to the PNERP public consultation, and recommend detailed planning based upon an International Nuclear and Radiological Event Scale (INES) level 7 incident. We observe that there is a range of interpretations as to what constitutes the precautionary principle.

Beginning with the Rio Declaration in 1992[i], variations of the precautionary principle have been adopted by governments and other organizations. The Government of Canada has a policy document on this issue - “A Framework for the Application of Precaution in Science-Based Decision Making About Risk[3]”. One example of its application is observed in Planning for a Sustainable Future: A Federal Sustainable Development Strategy for Canada[4], released in 2010 by Environment Canada (now Environment and Climate Change Canada) which states that “Canada’s environmental policy is guided by the precautionary principle ... as required by the Federal Sustainable Development Act which states that the Minister of Environment must “develop a Federal Sustainable Development Strategy based on the precautionary principle””.

There are various definitions of the precautionary principle including ones such as the Wingspread Consensus Statement[5] that avoid the phrase “cost-effective”, which is present in the Rio Declaration, but none that are universally accepted. A brief on the precautionary principle within the Canadian legal system is available from the Environmental Law Centre at the University of Victoria[6] and A Canadian Public Health Framework has also been developed[7]. Two useful international resources are available from UNESCO[8] and the World Health Organization[9].

In general, the literature recognizes the importance and validity of the precautionary principle, but also that its application should be avoided where it is not warranted or where the conditions for its application are insufficiently met. The references cited above should provide sufficient guidance for the OFMEM to assess its relevance in this case.

Regarding the relevance of the precautionary principle in this case, we note that the academic literature provides support for the use of less detailed, more flexible plans when dealing with larger scale emergencies[10]. Studies of emergencies and disasters of various scales have shown that there are qualitative differences that emerge as a function of (physical) scale. Planning for a small event is different than for a very large one, in the sense that the plans cannot simply be scaled up. Larger events are more chaotic and complex, less predictable in terms of their evolution, less amenable to command and controls approaches, and require greater flexibility and adaptability.

2.3 Emergency Planning Considerations

In reviewing the submissions and conducting interviews, we observed a wide range of opinions on what considerations should be included in emergency planning. It was clear that emergency managers recognize that good emergency plans and preparedness measures can make the response more effective and reduce the potential harm from an evacuation. From a planning perspective, it is important to note that planning scenarios and actual disasters may be very different, and that the tools, people and infrastructure must be flexible enough to accommodate these differences. For an emergency manager, emergency plans and, more specifically, detailed planning zone distances must be optimized for a hazard. The planning basis describes the hazards and range of events that are considered in the emergency plan.

As an experienced emergency manager and responder explained to us, if a planning basis only covers the worst case scenario, the detailed planning zone size will be very large. The main impact of a large detailed planning zone is that all emergency response facilities, such as reception centres, must be located outside of that zone. This means that for any emergency, even those that are much smaller than the basis planning zones, evacuees will have to travel much longer distances to reception centres, which increases potential harm to individuals from an evacuation. It also means that emergency response facilities may be located outside the jurisdiction of the municipality in which the nuclear installation is located, which complicates preparedness. On the other hand, if a detailed planning zone is too small, then emergency facilities will have to be relocated during a larger scale emergency which will decrease the effectiveness of the response. Clearly, some judgement must be used to choose between the optimum planning distance for smaller accidents and larger accidents.

Page 46 of the Planning Basis Discussion Paper quotes the International Commission on Radiological Protection (ICRP) 109, section 2.1.1 on the issue of planning for a range of accidents: “while emergency plans should be based on a wide range of accidents, the amount of detailed planning should decrease as the probability of the accident’s occurrence decreases”[11]. We noted that OFMEM has also adopted a risk based approach, which uses a combination of probability and consequences, as the basis for Hazard Identification and Risk Assessment (HIRA)[12]. Some submissions emphatically rejected the concept of weighting based on the likelihood of events and urged the province to give more importance to the consequences of an event for the purposes of establishing the zone size. Other submissions supported the adoption of this methodology.

These approaches are fundamentally opposed, and the differences we observed in the submissions illustrate the need to describe the motivations, justifications and principles used to revise the emergency plan. The OFMEM discussion paper should, therefore, be clear about the methodology it is using, and why particular approaches are included or excluded.

Recommendation 1: Given the large number of public and institutional submissions related to the PNERP Discussion Paper, the Advisory Group recommends that the ministry clearly describe the motivations, justifications, and principles used to create or modify its emergency plans and that such basis should be formally outlined in the procedures governing the regular review of the PNERP. If such guidance/procedures do not exist, they should be created.

2.4 Best Practices

Several stakeholders we met with and many submissions we reviewed advocated for the use of international best practices as a guide to establishing planning zones; however, we observed that this term “best practice” has different meanings for different people. For some, best practice means the most conservative approach to decision making, with the largest safety margins, and zones and protective actions that go beyond compliance with standards and regulations. For others, best practice means that emergency plans should represent the best we can do to specifically prepare for a severe accident, because a severe accident is the most challenging to respond to.

Some submissions indicated that best practices are embodied by adherence to Canadian Standards Association (CSA) or International Atomic Energy Agency (IAEA) standards, while others used the term to mean best in some optimum sense (e.g., minimizing overall harm to individuals). For those who believe that best practice means optimization, the link between larger zone size and improved safety is not clear and may actually be wrong. Finally, many institutional submissions defined best practices as science and/or evidence-based, and relying on peer review and expert judgement.

Further, some submissions pointed to Germany (six operating units) and Switzerland’s (five operating units) recent changes to nuclear emergency planning as best practices, and urged Ontario to follow suit. While it is commendable that these jurisdictions have reviewed their emergency plans and introduced new planning measures as they have deemed necessary, it should be noted that both have also made the decision to phase out nuclear power. Ontario is not in the process of phasing out nuclear power; therefore, the decisions made in these jurisdictions may not necessarily be optimal in the Ontario context.

Clearly, there is a wide diversity of opinions on what best practices are and how they should be used in the context of emergency planning. This is not surprising since perceptions about risk acceptance underlay the concept of best practices, and risk acceptance depends on a variety of social and cultural norms. We are of the opinion that the PNERP Master Plan and Planning Basis should avoid using terminology such as “best practice” unless it also defines what those practices are. Benchmarking Ontario’s emergency plans against those of other jurisdictions may be very useful, but unilaterally adopting these practices may not lead to emergency plans that provide the optimum level of safety for the public.

2.5 Protective Action Levels

The Planning Basis Discussion Paper proposes changes to the Protective Action Levels (PALs) that trigger protective actions related to public protection. The current PALs are expressed in terms of projected radiation dose and radionuclide concentrations. The current PALs are also expressed as ranges: above the lower level of 10 millisieverts[ii] (mSv), protective actions (i.e., evacuation) should be applied unless valid reasons exist for deferring action; above the higher level of 100 mSv, protective actions shall be implemented unless implementation would clearly lead to greater risks for the people involved than the risks posed by the projected radiation dose.

The Planning Basis Discussion Paper proposes to replace the current PAL ranges with a new, single PAL in order to align with the proposed guidance from Health Canada[13] and the published standards from the IAEA[14] – a single level above which the protective actions shall be triggered. The proposed single level PALs (50 mSv) for evacuation falls within the range of the current lower-limit PAL (10 mSv) and higher-limit PAL (100 mSv). In considering the proposed change to PALs we reviewed international guidance on selecting PALs[iii], [iv]. Such guidance indicates that the value chosen should be based on minimizing the overall harm from all hazards, rather than minimizing or eliminating radiation hazards only. We reviewed several submissions that reject the ministry’s proposed change, arguing that the current lower-limit PAL (10 mSv) offered more protection from radiation harm than the new single PAL (50 mSv). We note that the lower-limit PAL was never intended to automatically trigger an evacuation; bad weather conditions, for example, would have justified evacuating at a higher projected dose.

We believe that the proposed single PAL of 50 mSv is acceptable based on the guidance from Health Canada. We find that this change is consistent with, and more conservative in some respects than, the IAEA guidelines. We believe this change may also provide greater clarity as the previous range of PAL allowed decision-makers a large degree of latitude and may cause confusion during an actual event. A single value for the PAL is thus desirable to avoid confusion in executing the plan.

In addition to the public PAL, there were discussions with stakeholders that indicated that the doses to emergency response workers need clarification. This is particularly important during a nuclear emergency where there exists concurrence of roles and responsibilities for emergency personnel, with possibility for acute and/or recurring radiation exposure. We note that Appendix 3 of Annex H in the existing PNERP (2009) provides dose limits for emergency workers but the values seem to be based on limits established for on-site nuclear energy workers employed by nuclear installations. Health Canada’s draft guidance is directly applicable to off-site emergency workers and should be considered in future versions of the PNERP.

Recommendation 2: The Advisory Group supports the proposed change to a single Protective Action Level based on Health Canada guidance, and further recommends that the ministry clarify the dose limits to be used for off-site emergency response workers during a radiological event.

2.6 Consequences of Decisions

In reviewing the Planning Basis Discussion Paper, we noted that it does not address the potential consequences of the proposed changes, which includes the associated implementing plans and procedures. The consequences of these changes need to be well understood as they may have an impact on decisions regarding the PNERP Master Plan. It is important that a feasibility study be conducted to examine the consequences of these changes with regard to preparedness and response during a nuclear accident in advance of implementation.

Recommendation 3: The Advisory Group recommends that the ministry carry out an assessment of the impacts of significant proposed changes to the Master Plan on the implementing and municipal plans (e.g., changes to planning zones and Protective Action Levels) as part of future PNERP reviews.


3. Nuclear Accidents

3.1 Past Nuclear Accidents

There have been three major accidents in the history of nuclear power reactors: Three Mile Island in 1979, Chernobyl in 1986 and Fukushima in 2011. The accident at Three Mile Island brought forward the need for nuclear accident emergency planning and initiated the introduction of the PNERP. The Chernobyl accident, the largest of the three major accidents, released a large radionuclide inventory into the off-site environment and had significant impacts on the surrounding populations which crossed national boundaries. Given these consequences, a post-Chernobyl PNERP revision was created that recognized the need for additional planning to deal with high consequence/low probability accidents.

In the case of the Fukushima Daiichi Nuclear Power Station, two natural events – an earthquake of large magnitude and the multiple subsequent large tsunamis – initiated a Declaration of Emergency as multiple engineered systems concurrently became disabled in three reactor units. As a result of a prolonged station blackout, three nuclear reactors cores partially melted and released a significant amount of radioactive material.

While the Fukushima accident had radiological releases significantly below those of Chernobyl, the event was a simultaneous accident at multiple units which had not previously been fully considered in some emergency planning discussions. One of the goals set forth in the Discussion Paper was to propose updates to the PNERP that specifically considered the events at Fukushima. In conducting this review, we observed that the term “Fukushima” has evolved to encompass various interpretations. This variability has implications for planning and preparedness; thus we define the term Fukushima as follows for the purposes of this report:

The term Fukushima is here understood to mean the occurrence of multiple events, either natural or human-initiated, in a short span of time that initiates a Declaration of Emergency (or requires an emergency response) at the nuclear installation. This emergency, in particular, may result in a significant radiological off-site release. The radiological release is understood to result from the breach and/or degradation of the nuclear reactor systems in multiple units simultaneously.

3.2 Accident Classification

The PNERP (2009) recognizes the unique nature of nuclear reactors and the hazards which can arise. Radiological releases resulting from an accident pose a risk which is a function of the hazard associated with the specific event, the likelihood of the event, and the vulnerability of the exposed population to the hazard. Within the spectrum of possible accidents there exist two general categories: 1) events where the hazard and radiological consequences are large but have a very small likelihood of occurring, and 2) events where the hazard and radiological consequences are small but with relatively larger likelihood of occurring. Within the high consequence category, there is a significant range of radiological source sizes.

The International Nuclear and Radiological Event Scale (INES) is a tool developed by the IAEA for promptly and consistently communicating to the public the safety significance of events associated with sources of ionizing radiation. It ranges from level 0 (no safety significance) to level 7 (major accident). The INES cautions that this tool is intended for informal reporting purposes only and is not meant to replace formal reporting requirements. Accordingly, the IAEA recommends that “the criteria of the scale are not intended to replace existing well-established criteria used for formal emergency arrangements in any country.” The IAEA further states that, “It is not appropriate to use INES to assess or to compare safety performance between facilities, organizations or countries” and that the scale “should not be used as a basis for determining emergency response actions”[15]. It is, however, useful to identify that the high consequence category of events typically falls within the range of 5 through 7 on the INES scale. While many submissions requested that INES level 7 events be explicitly considered in the revised PNERP, such direct application appears inconsistent with the INES User Guide.

3.3 Emergency Planning Basis

The PNERP Master Plan specifies the planning basis, preparedness goals/responsibilities, the structure and function of emergency response, operational responsibilities and the overall strategy for nuclear response. Additionally, it specifies how it would utilize other federal, provincial and municipal government organizations. Section 2.3.1 of the current PNERP (2009) recognizes that “because resources are not available to make full preparations for dealing with all possible events, a judicious choice must be made to select the optimum basis for emergency management.” In this regard, the PNERP considers both a basic off-site event as well as more severe but low probability event where additional planning is required (such as timely public alerting, prioritized evacuations, radiation monitoring and medical/counselling services).

Some submissions noted that empirical evidence shows that the probabilities of high consequence events are low in many Probabilistic Safety Assessment studies, but given that “worst” case scenarios (previously unknown or unidentified events with large consequences) have already occurred, such events should be used as a planning basis. In contrast, other submissions argued that completely unmitigated events across multiple units do not form a credible planning basis because new post-Fukushima technical barriers that have since been installed at Ontario’s nuclear generating stations to mitigate such events. These submissions also discussed the idea that ignoring such improvements may not provide optimal safety for more benign events. Indeed, significant improvements have been made at each nuclear installation with the specific aim of mitigating or preventing severe accidents; however, many submissions argued that these improvements should not be considered when planning for a nuclear emergency.

We observed from our interviews that emergency management organizations recognize that very low likelihood events may have consequences beyond the Contiguous and/or Primary zones, and are confident that the structures in place would enable them to adapt and react to events that occur beyond the planning basis; however, such details on response flexibility are more appropriately addressed in the implementing and municipal plans. Regardless, we believe that greater clarity with regard to how organizations are meant to incorporate flexibility into their planning would be beneficial (e.g., a detailed narrative describing the response to a severe accident using the proposed plan). While the PNERP (2009) includes a section addressing the concept of operations, the level of information could be improved. Section 2.1 of IAEA EPR-NPP Public Protective Actions, 2013[16] gives a good example of such a concept of operation.

Recommendation 4: The ministry should include a concept of operations in future revisions of the PNERP to provide a detailed narrative of how the plan would work in various scenarios, including a severe accident.

Finally, we noted that, although high consequence scenarios have a very low probability of occurring, the magnitude of their potential consequences justifies some level of consideration by emergency management organizations in their response plans, even if it is not at a detailed level such as that in the Primary Zone. Given the size and specific locations of the contaminated areas during the Fukushima accident, a key takeaway is that the capability to gather information in an emergency is critical, even outside of the Primary Zone. IAEA GSR Part 714 recognizes the need for increased measurements through its Extended Planning Distance (EPD), but it is unclear if the Contingency Planning Zone concept introduced in the Discussion Paper would accomplish such a goal.

Recommendation 5: The ministry must ensure that response organizations have the capability to survey, identify radiological hot spots, report, and take appropriate actions beyond the Primary Zone, similar to the concept of an Extended Planning Zone as recommended by the IAEA General Safety Requirements No. GSR Part 7. This planning should be implemented regardless of the size selected for the Primary Zone, or the implementation of a Contingency Planning Zone.


4. Planning Zones and Protective Actions

This section provides an analysis of the planning zones in the current PNERP Master Plan (2009) and the proposed changes in the Planning Basis Discussion Paper. The aims of these protective actions are to protect the public through: 1) increasing the distance between the public and the source of radiation (i.e., evacuation), 2) shielding the public from potential radiation exposure (e.g., sheltering), and 3) reducing the time the public is exposed to radiation.

4.1 Criteria for Zone Distances

The PNERP (2009) recognizes the unique reactor designs at Pickering, Darlington and Bruce as well as Chalk River Laboratories and Fermi 2, which is located outside of Ontario, but in close enough proximity to Ontario to warrant inclusion in the plan. The PNERP (2009) identifies three zones for the planning and preparedness activities:

  • Contiguous Zone (3 km)
  • Primary Zone (10 km)
  • Secondary Zone (50 km)

In principle, the zone boundaries should be selected to provide assurance that once protective actions are implemented, the public dose remains within acceptable levels. One of the main objectives of the Discussion Paper was to address new information obtained since the Fukushima nuclear accident and consider how this information should impact the selection of zone boundaries. This is a topic that is clearly of interest to the public, as a large number of submissions made reference to both the selection and implementation of these zones.

Many submissions and several stakeholder interviews raised the concepts of “world-class” or “best practices” with regard to how these zone boundaries should be set. As noted in section 2.4 of this report, such concepts are subject to interpretation. Some submissions noted the significant extension of planning zone distances in Switzerland and Germany as best practices, while others noted decisions made in the U.S., where planning zones were largely kept intact.

Independent of these jurisdictional examples, it was the view of some stakeholders that IAEA GSR Part 7 represents a potential best practice approach; however, other stakeholders asserted that the IAEA GSR Part 7 and other standards and guidance documents represent the lowest common denominator rather than the best practice. It is the opinion of the Advisory Group that decisions made in other jurisdictions and/or described in international guidelines and standards should be considered in the planning process but do not necessarily provide a definitive basis for planning.

We also noted a variety of opinions on the methodology that should be used to set planning zone distances. Suggestions included:

  • Direct adoption of IAEA zone distances and associated protective actions.
  • Test the existing zones boundaries against a judiciously selected set of events. This ‘stress test’ would help to determine the acceptability of the zone distances and also define which events may have consequences that extend beyond a given zone. Such information would allow planners and response organizations to assess flexible measures against the results of the test.
  • Develop new zone distances and actions within these new zones. This would be based on one or more predefined technical basis events within the range of possible accidents and consider all possible harms to individuals.

All of these methodologies may be sufficient for establishing zone distances, but a clear justification for the selection is warranted with careful consideration of the underlying assumptions. The distances proposed for the Contiguous, Primary and Secondary Zones in the Discussion Paper are likely adequate for multi-unit events, assuming the improvements in potential source term from post-Fukushima nuclear installation design improvements (on-site) are credited. The remaining issue consists of assessing the residual risk outside of the existing planning zones if source terms are determined from simultaneous multi-unit events without crediting post-Fukushima measures. There has to be some strategic consideration for such events even if they are not analyzed in detail. Such considerations would include additional provisions for monitoring and flexible actions beyond the Primary Zone as noted in the previous sections of this report.

There were submissions that questioned some of the assumptions used in the calculations discussed in the Discussion Paper since the appropriate sizes of the zones can vary by a large factor depending on these assumptions (e.g., assumptions of sheltering). All planning assumptions used for the technical assessment should be fully described and justified. In addition, it should be made clear whether the projected dose is calculated for a child or an adult, unprotected or protected (i.e., unsheltered or sheltered), and the duration of the exposure.

We also observed that there is some ambiguity in the third conclusion on Page 49 of the Discussion Paper. Based on our review of various submissions and the Health Canada ARGOS study[17], if no station improvements or post-Fukushima measures are applied when considering a simultaneous unmitigated multi-unit event, planning zone boundary size and effectiveness is unclear.  Nevertheless, the ARGOS study is incomplete in many respects and more technical analysis is warranted. In addition, recommendation #3 on page 51 of the Discussion Paper follows from the three conclusions listed on Page 50 – we believe this recommendation should be amended to state that for these low probability events, any additional actions beyond these zones (such as food restrictions or the expansion of zones) in the direction of plume passage would utilize the flexibility of the response organizations.

Recommendation 6: The Advisory Group recommends that the ministry initiate a more detailed and definitive technical assessment of potential doses, including an expanded sample of weather patterns, and use a well-documented basis for the source term, assumptions, and uncertainties. This would allow future PNERP review processes to rely on a significantly more robust model outputs for planning purposes.

Recommendation 7: The Advisory Group recommends that the ministry clarify the dose projection assumptions used in technical analyses and provide clear justification for these assumptions.

Section 2.4.5 of the current PNERP Master Plan (2009) defines the planning zones using minimum zone boundary distances combined with natural geographic features and infrastructure (i.e., roads), no changes to this practice are proposed in the Discussion Paper. In identifying planning zone distances, we encourage the ministry to also include the consideration of local weather patterns and topological features (e.g., escarpments or valleys) that would affect atmospheric dispersion and may be persistent over long durations, as these could give rise to the need to extend the Contiguous or Primary Zones in some areas. While region-specific considerations fall under the purview of the implementing plans, we believe this section of the PNERP Master Plan should be amended to require the implementing plans to include such considerations.

Recommendation 8: The Advisory Group recommends that the ministry amend the PNERP Master Plan to explicitly require the implementing plans to identify and consider local meteorological and topological effects in defining planning zone boundaries.

4.2 Source Term Identification

At a technical level, the analyses of public dose rely heavily on the nature of the radiation released (the source term), the timing of such releases, and weather phenomena. Source terms are dependent on these event assumptions and are highly sensitive to the assumed effectiveness of post-Fukushima measures that are implemented or in the process of being implemented at the nuclear installations.

In examining the effectiveness of the zones, the OFMEM reviewed several new consequence assessments that have been performed since Fukushima; however, the assessments used in the Planning Basis Discussion Paper included a variety of different radiological source terms and do not explicitly explain how post-Fukushima nuclear generating station improvements impact the basis for planning. Furthermore, in some cases, the analysis was confined to only a few weather patterns, and in others, the analysis used models which may not be appropriate for distances farther away from the nuclear generating station.

Given the limited scope of the assessments used in the Discussion Paper and the sensitivity to source term selection, they should not be considered definitive. Despite the limitations of these assessments, we were able to make two key observations:

  1. The existing planning zone sizes appear to be appropriate for a) single-unit unmitigated accidents and, b) multi-unit coincident events where some post-Fukushima improvements are credited in the source term calculation.
  2. The planning zone sizes may require revision if the planning basis includes a multi-unit failure event where none of the post-Fukushima improvements or mitigating actions are credited in the source term calculation.

The PNERP provision for flexibility was specifically included to address the second observation above and is the basis for the Advisory Group’s Recommendation 5, which addresses the ability to gather information and focus emergency efforts beyond the Primary Zones. It is therefore crucial that the implementing plans and preparedness include sufficient resources to provide radiation survey capabilities to identified areas, which is a prerequisite for adaptable response for such accidents.

4.3 Contingency Planning Zone

The OFMEM has indicated that the intent of the proposed introduction of a new planning zone, the Contingency Planning Zone (CPZ), is to ensure that municipalities consider possible alternate infrastructure and activities (e.g., backup reception facilities) that may be available beyond those currently designated, in the event that an evacuation must proceed outwards from the Primary Zone. Such evacuations would occur in the direction of the plume, which is a term used to describe the area of atmosphere where an airborne release of radioactive dust is carried off-site by the wind, resulting in areas where radiological particulates (i.e., solids) may settle on surfaces in higher concentrations than other areas. It was also noted in the Discussion Paper that the CPZ is intended to be consistent with CSA[18]. However we also note that the existing description of the CPZ is not fully aligned with the IAEA concept of an Extended Planning Distance. Because this is a substantive change to the PNERP Master Plan, we believe it is important for the ministry to provide additional rationale for such a change, over and above the desire to align with CSA N1600.

The information provided by operational agencies indicates that there is already a large degree of preparedness for the region from 10-20 km from each nuclear generating station, albeit not to the same extent as the planning within the 10 km Primary Zone. Written submissions from many municipalities expressed concern and confusion with regard to the intent of the proposed CPZ, the planning necessary, and the actions that would be required within that zone. For example, some municipalities noted that they have identified multiple options for response actions available in different sites across their municipality; however, all of these options are within the 20 km boundary of the proposed CPZ. Because these options are situated in different areas (e.g., one to the east of a nuclear generating station and one to the west), it is highly unlikely that both would be contaminated by plumes, but under the 20km boundary of the CPZ, both sites would no longer be considered acceptable alternatives in the planning basis. Furthermore, depending on the population distribution, geography and infrastructure of a given municipality, it may not be possible to locate an alternative site that is beyond the 20 km CPZ but still within municipal boundaries. Some municipal submissions expressed concern that adjacent municipalities may not agree to host alternate centers for the primary response municipalities.

While many submissions viewed the concept of the CPZ as a positive improvement that will help to facilitate the identification of alternate locations for emergency planners, others felt that the introduction of the CPZ is unnecessary and does not provide any improvements with regard to preparedness or safety. Overall, the Advisory Group supports the concept of the CPZ but the concerns raised by municipal stakeholders indicate that additional guidance on the implementation of the CPZ is needed to ensure that the positive improvements the ministry hopes to achieve are realized. This additional guidance could potentially include proactive measures to alleviate trans-municipality barriers to implementation.

Recommendation 9: The Advisory Group recommends that the ministry provide a more thorough rationale/motivation for the Contingency Planning Zone (abbr>CPZ), and provide affected municipalities with additional guidance on the implementation of the CPZ. Where alternative response sites outside the CPZ cannot be identified within the designated municipality, the ministry should proactively designate additional municipalities with responsibilities to provide assistance should the activation of plans in the CPZ be necessary.

4.4 Iodine Thyroid Blocking

The Planning Basis Discussion Paper states that no policy recommendations regarding changes to the stocking and distribution of potassium iodide (KI) tablets for the purposes of Iodine Thyroid Blocking (ITB) have been proposed because it does not form a component of the planning basis.

The current distance for the pre-distribution of KI tablets is based on a planning basis analysis performed by the CNSC[19], which also assesses the adequacy of the current detailed planning zone for evacuation. Several submissions asserted the belief that ITB is part of the planning basis, and as such, any evaluation of planning zone sizes should include an evaluation of ITB distances using the same methodology. Other submissions suggested that evacuation actions triggered by thyroid doses should be eliminated from the PNERP since the appropriate dose mitigation for thyroid exposure is ITB. We are of the opinion that the latter comment is applicable only if ITB are available for the full distance in which the thyroid dose PAL for evacuation can be exceeded. In any event, we observed thatITB should remain part of the planning analyses.

Recommendation 10: If a technical assessment of potential accidents is conducted, it should include an assessment of the planning zone distances for Iodine Thyroid Blocking.

4.5 Hazards from U.S.-Based Reactors

We received input from stakeholders and the public regarding general and specific risks/hazards generated by radiological incidents from U.S.-based nuclear generating stations located within close enough proximity to the U.S.-Canadian border that evacuation under a defined emergency plan could be necessary.

These U.S.-based nuclear generating stations are[20]:

  1. Enrico Fermi II Nuclear Power Plant, Newport, Monroe County, Michigan (‘Fermi 2’)
  2. Davis-Besse Nuclear Power Station, Oak Harbor, Ottawa County, Ohio
  3. Perry Nuclear Power Plant, North Perry, Lake County, Ohio
  4. R.E. Ginna Nuclear Power Plant, Ontario, Wayne County, New York
  5. James A. FitzPatrick Nuclear Power Plant, Scriba, Oswego County, New York
  6. Nine Mile Point Nuclear Station, Scriba, Oswego County, New York

Fermi 2 is the closest U.S. generating station to the Canadian border and is the only one requiring a site-specific response under both the current PNERP Master Plan (2009) and proposed revisions to the Master Plan. Fermi 2 is within 16 km of the Town of Amherstburg, Ontario, at its closest point, and 23 km at its farthest point. These distances appear to have been the basis for the previous Primary Zone for Fermi 2, which ranged from 16 – 23 km. The Planning Basis Discussion Paper notes that the planning zones associated with Fermi 2 differ from those set out for Ontario-based nuclear generating stations due to differences in technology (i.e., type of reactors in use) and jurisdiction, with Fermi 2 operating under a license issued by the U.S. Nuclear Regulatory Commission (NRC).

In line with these considerations, the ministry is proposing to amend the zone distances for Fermi 2 to reflect the NRC’s requirements for planning zones which are approximately 10 miles (16 km) for the Plume Exposure Pathway Emergency Planning Zone (equivalent to the Primary Zone) and 50 miles (80 km) for the Ingestion Exposure Pathway Emergency Planning Zone (equivalent to the Secondary Zone)[21]. Under these proposed revisions, Amherstburg would lie outside the Primary Zone for Fermi 2, but within the Secondary Zone. No Contingency Planning Zone is proposed for Fermi 2 in the Discussion Paper; however, the location of Fermi 2 near the Canada-U.S. border means that there is a possibility that a severe accident could require protective actions within a 20 km radius to protect the health of Ontarians. If the OFMEM believes there is value in the CPZ for Ontario reactors, then the Advisory Group is of the opinion that such a concept must be applied to U.S.-based reactors as well.

Recommendation 11: The Advisory Group recommends that the Contingency Planning Zone concept, if implemented, be applied consistently to all major nuclear installations under the PNERP, including U.S.-based nuclear installations.

A number of submissions received indicated that the planning related to Fermi 2 requires more consideration. With regard to the comments received on planning and preparedness measures for U.S.-based nuclear generating stations, we noted the following key points:

  • Emergency notifications to municipalities on the Canadian side of the border may come directly from Fermi 2, or indirectly through the OFMEM and/or federal authorities. Some submissions raised the possibility that Canadians may learn of an emergency only after U.S. residents have already been alerted.
  • Smaller municipalities may not have the resources (e.g., infrastructure, knowledge, expertise, organizational capacity) to respond effectively to a radiological emergency at a U.S.-based nuclear generating station and wish to be provided with the same support received by designated municipalities located in the proximity of Ontario-based nuclear generating stations. There is an expectation that either the Province or the nuclear operator would provide expertise, personnel, and training at the preparedness stage and full support during the response to an event.
  • Ontario communities located near U.S.-based nuclear installations expect the same level of preparedness to protect the drinking water supply as for Canadian nuclear generating stations.
  • Pre-distribution of ITB to within certain distances should be consistent with the distribution of ITB to communities located in the proximity of Ontario-based nuclear generating stations.

We reviewed the guidance contained in the current PNERP Master Plan (2009) and while it does explicitly mention emergency planning for Fermi 2 and other U.S.-based nuclear installations, we agree that additional information and detail regarding the plans that are in place should be provided to the potentially affected communities and members of the public in Ontario. We also noted that a radiological emergency at Fermi 2 or other U.S.-based nuclear installations may impact other populated areas, infrastructure, and the environment (both land and water) beyond the planning zones for Fermi 2.

Recommendation 12: The ministry should proactively communicate/clarify the planned response to an emergency at Fermi 2 and other U.S.-based nuclear installations (e.g., notification, alerting, distribution of Iodine Thyroid Blocking, etc.) to both municipal officials and the general public.


5. Implementing Plans

The Advisory Group received input on a number of issues related to the implementing plans under the PNERP Master Plan, primarily related to scope, planning and preparedness. Many stakeholders were either unware of the emergency plans that exist outside of the Master Plan (either in implementing plans or emergency plans administered by municipalities, other provincial ministries or the federal government) for many specific hazards, or found existing plans to be insufficient. Our Terms of Reference states that making recommendations about the specific implementing plans is not within the scope of our mandate; however, given the large amount of input received, we believe that the ministry should consider additional planning and/or communication of details of the existing plans related to the following concerns:

  • Spent fuel pools under accident conditions
  • Accidents and planning at university and research reactors
  • Accidents related to the transportation of nuclear waste
  • Accidents at mills, fuel fabrication plants, and other facilities processing nuclear substances
  • Contamination of drinking water sources in the event of an accident at a nuclear installation
  • Planning measures related to the implementation of sheltering and evacuation for vulnerable populations (e.g., children, the elderly, hospital patients) in the event of an accident at a nuclear installation
  • Measures in place to protect companion animals in the event of an accident at a nuclear installation
  • Concerns with the effectiveness of alerting systems; in particular, the use of FM alerting systems for additional alerts beyond nuclear emergencies

We believe that plans are in place that would address most, if not all, of the above concerns, but various stakeholders indicated that they were insufficiently informed of these arrangements. The province should clearly identify them and communicate this to the public, either in the PNERP or elsewhere (e.g., on the ministry website). Particularly large volumes of submissions raised concerns related to two topics from the above list – drinking water supply and vulnerable populations. We would suggest that the province prioritize public communication on emergency plans addressing these two areas in the short term.

Recommendation 13: In future revisions of the PNERP, the Advisory Group recommends that public documents discussing emergency preparedness (e.g. Planning Basis Discussion Paper) include an addendum discussing the concerns of the public related to implementing plans.

Some submissions identified communication issues between emergency management organizations during the planning process for the current review of the PNERP. Although there is a robust process for OFMEM to brief emergency response professionals at the municipal level through the Nuclear Emergency Management Coordinating Committee, it was left to these professionals to brief their elected officials. We feel that this is insufficient, and that elected officials should hear the rationale for proposed changes to the PNERP directly from OFMEM. Involvement of all branches of governments including direct dissemination of information to the responsible elected officials is recommended.

Recommendation 14: The Advisory Group recommends that a systematic process for ensuring the structured and timely dissemination of information directly to all levels of government, including elected officials (e.g., not just at the Nuclear Emergency Management Coordinating Committee level), be incorporated in future revisions of the PNERP.


6. Transparency and Public Participation

Throughout the submission review and stakeholder interview process, the Advisory Group heard concerns about the openness and transparency of the PNERP revision process. Some submissions asserted that the public has been excluded from participating in past PNERP reviews in favour of consultation with government and industry stakeholders. These submissions viewed the potentially affected public as the PNERP’s most important stakeholder. Many submissions also expressed the belief that effective public participation is not just a theoretical right, but also a key precondition for transparent and accountable governance, and a practical instrument to give members of the public the opportunity to influence the decision-making process on a topic that is very important to many Ontarians.

We also heard sincere appreciation that, for the first time, the province has brought the PNERP review process to the public for their input and feedback. Although many submissions applauded the province for taking this initiative, it was often noted that the review process was not timely and future public participation was not guaranteed because it was not a legislative requirement. In other words, public participation and consultation on such an important matter were felt to be ad-hoc and not embedded in Ontario’s government processes. While the Advisory Group feels that including public consultation in the current PNERP review and revision process succeeded in opening new channels of communication with the public, the ministry should strive to continuously improve the public consultation process moving forward.

Recommendation 15: The Advisory Group recommends that clear requirements for regular review of the PNERP, including guiding principles for transparency, engagement with provincial, municipal and federal stakeholders, and public participation, be incorporated in future revisions of the PNERP. The ministry should consider adopting procedures in line with Recommendation 1 to ensure future stakeholder involvement in the process.


7. Conclusion

We observed a large number of different perspectives in the submissions and interviews. The submissions have very different risk perceptions of nuclear plants based upon their respective worldviews. While all of these positions seek to protect the public good, quite often the end conclusions reached by different groups are radically different. This fracture makes communication between these groups difficult and can lead to distrust; however, we noted that there is a legitimate basis for all these viewpoints. We have tried to fairly consider the point of view of every group that provided input into this process, and acknowledge where there are differences of opinion. We feel that the Discussion Paper would receive wider public support if it were to broaden its framing to include ethical decision-making perspectives and an analysis of risk types in addition to risk assessment (see Appendix D for a discussion of elements that could be included in future Planning Basis Discussion Papers).

Some underlying themes in the public responses included the need for a more formal procedure for PNERP reviews and updates, the need for greater public engagement, and the need for this engagement to begin at an earlier point in the review process. We have provided fifteen recommendations related to the PNERP and the process used to generate future revisions. These recommendations are a result of our detailed review of submissions, stakeholder interviews, a review of the PNERP Master Plan (2009), the Planning Basis Discussion Paper and its references, and the list of proposed changes. Some of these recommendations can be made immediately and others may be included in the course of future PNERP updates. We commend the ministry and the OFMEM for their openness and responsiveness during this review process.


8. Appendices

8.1 - Appendix A. Summary of Advisory Group Recommendations

Recommendation 1: Given the large number of public and institutional submissions related to the PNERP Discussion Paper, the Advisory Group recommends that the ministry clearly describe the motivations, justifications, and principles used to create or modify its emergency plans and that such basis should be formally outlined in the procedures governing the regular review of the PNERP. If such guidance/procedures do not exist, they should be created.

Recommendation 2: The Advisory Group supports the proposed change to a single Protective Action Level based on Health Canada guidance, and further recommends that the ministry clarify the dose limits to be used for off-site emergency response workers during a radiological event.

Recommendation 3: The Advisory Group recommends that the ministry carry out an assessment of the impacts of significant proposed changes to the Master Plan on the implementing and municipal plans (e.g., changes to planning zones and Protective Action Levels) as part of future PNERP reviews.

Recommendation 4: The ministry should include a concept of operations in future revisions of the PNERP to provide a detailed narrative of how the plan would work in various scenarios, including a severe accident.

Recommendation 5: The ministry must ensure that response organizations have the capability to survey, identify radiological hot spots, report, and take appropriate actions beyond the Primary Zone, similar to the concept of an Extended Planning Zone as recommended by the IAEA General Safety Requirements No. GSR Part 7. This planning should be implemented regardless of the size selected for the Primary Zone, or the implementation of a Contingency Planning Zone.

Recommendation 6: The Advisory Group recommends that the ministry initiate a more detailed and definitive technical assessment of potential doses, including an expanded sample of weather patterns, and use a well-documented basis for the source term, assumptions, and uncertainties. This would allow future PNERP review processes to rely on a significantly more robust model outputs for planning purposes.

Recommendation 7: The Advisory Group recommends that the ministry clarify the dose projection assumptions used in technical analyses and provide clear justification for these assumptions.

Recommendation 8: The Advisory Group recommends that the ministry amend the PNERP Master Plan to explicitly require the implementing plans to identify and consider local meteorological and topological effects in defining planning zone boundaries.

Recommendation 9: The Advisory Group recommends that the ministry provide a more thorough rationale/motivation for the Contingency Planning Zone (CPZ), and provide affected municipalities with additional guidance on the implementation of the CPZ. Where alternative response sites outside the CPZ cannot be identified within the designated municipality, the ministry should proactively designate additional municipalities with responsibilities to provide assistance should the activation of plans in the CPZ be necessary.

Recommendation 10: If a technical assessment of potential accidents is conducted, it should include an assessment of the planning zone distances for Iodine Thyroid Blocking.

Recommendation 11: The Advisory Group recommends that the Contingency Planning Zone concept, if implemented, be applied consistently to all major nuclear installations under the PNERP, including U.S.-based nuclear installations.

Recommendation 12: The ministry should proactively communicate/clarify the planned response to an emergency at Fermi 2 and other U.S.-based nuclear installations (e.g., notification, alerting, distribution of Iodine Thyroid Blocking, etc.) to both municipal officials and the general public.

Recommendation 13: In future revisions of the PNERP, the Advisory Group recommends that public documents discussing emergency preparedness (e.g. Planning Basis Discussion Paper) include an addendum discussing the concerns of the public related to implementing plans.

Recommendation 14: The Advisory Group recommends that a systematic process for ensuring the structured and timely dissemination of information directly to all levels of government, including elected officials (e.g., not just at the Nuclear Emergency Management Coordinating Committee level), be incorporated in future revisions of the PNERP.

Recommendation 15: The Advisory Group recommends that clear requirements for regular review of the PNERP, including guiding principles for transparency, engagement with provincial, municipal and federal stakeholders, and public participation, be incorporated in future revisions of the PNERP. The ministry should consider adopting procedures in line with Recommendation 1 to ensure future stakeholder involvement in the process.


8.2 - Appendix B. Summary of Advisory Group’s Review of Proposed Changes to the PNERP (2009)

These proposed changes to the PNERP Master Plan (2009) were listed in one of the two documents posted for public comment; as such, they are subject to change, pending the results of the public consultation process. A summary of the Advisory Group’s review of the list of proposed changes is summarized in the table below.

PNERP (2009) that was posed on the Regulatory and Environmental REgistry's by MCSCS for public review and feedback. " title="Summary of the Advisory Group's Review of Proposed Changes to the PNERP (2009)">
Table: Summary of Advisory Group’s Review of Proposed Changes to the PNERP (2009)
Chapter/Section/Title Current Master Plan (2009) Proposed Changes Advisory Group Review
Chapter 2 – Planning Basis and Concepts

Sec 2.3 - Basis of Planning
Planning Basis – The Hazard

Characteristics of a two types of accidents - Basic Offsite Effect and Severe Accident – are defined.
  • Minor modifications may be made. The integrity of the Basic Offsite Effect description found in the current PNERP will be maintained.
  • The Severe Accident description from the current PNERP will be enhanced with the inclusion of multi-unit events.
A discussion of considerations related to source term identification is provided in section 4.2 of this report.
Chapter 2 – Planning Basis and Concepts

Sec 2.4 - Primary Zones and Sectors
Pickering, Darlington and Bruce Power CANDU stations:
  • 3 km Contiguous Zone
  • 10 km Primary Zone
  • 50 km Secondary Zone
Fermi 2:
The Primary Zone has an approximate radius of up to 23 km from Fermi 2.
The Secondary Zone is within an 80 km radius of Fermi 2.

Contingency Planning Zone:
Not mentioned in current Master Plan (2009)
Pickering, Darlington and Bruce Power CANDU stations:
The current PNERP 2009 Contiguous, Primary and Secondary zones will be maintained in addition to a proposed new Contingency Planning Zone (see below for details).

Fermi 2:
U.S. regulation sets a standard Emergency Planning Zone of 10 miles (16 km ) for U.S. nuclear power generating stations; the following zones will be delineated for the Fermi 2 site:
  • No Contiguous Zone
  • The Detailed Planning (Primary) Zone will be reduced to a radius of 16 kilometres to align with the standard set by U.S. regulation
The Ingestion Control (Secondary) Zone will be maintained at 80 km to align with the standard set by U.S. regulation

Contingency Planning Zone:
Provision for a new Contingency Planning Zone (CPZ) should be included to align with CSA N1600 and to provide for very low probability, severe accident situations.

The CPZ is the area within which arrangements in the event of a radiological release could be required to monitor the dose rates from deposition (also known as groundshine, which is defined as the radioactive materials that fall to the ground). This is done in order to locate areas, beyond the detailed planning Primary Zone, which may require exposure control measures (evacuation, sheltering, ITB and/or longer term relocation) once environmental monitoring results have been obtained. The following CPZs should be defined:
  • Pickering, Darlington and Bruce Power CANDU stations: 20 km
  • CRL: None
  • Fermi 2: To Be Determined
The CPZ for CANDU stations, defined as the area beyond the Primary Zone out to a radius of 20 km, has been determined by doubling the Primary Zone distance in order to provide a conservative buffer for nuclear emergency planning and response. Plans and arrangements for this CPZ include considerations for:
  • Subdivision into sub-zones.
  • Population estimates for each sub-zone.
  • Provision for this Zone in Scientific Section mechanisms and processes, including in the Environmental Radiation and Assurance Monitoring Group (ERAMG) Procedures and plume modelling, as applicable.
  • Familiarization sessions with impacted municipalities, as required.
  • Identify existing response centres that fall within the CPZ and develop a list of possible alternates located outside the CPZ.
  • No additional Thyroid Blocking requirements beyond those stipulated for the Secondary Zone.
  • No additional public education requirements - public education to be consistent with Secondary Zone requirements.
  • No requirement for designation of additional emergency response centres (including Emergency Operations Centres (EOCs), Emergency Information Centres (EIC), reception/evacuee centres, personal monitoring and decontamination facilities) beyond those designated for Primary Zone response purposes.
  • No additional public alerting and communications requirements beyond what is in place and consistent with existing provincial mechanisms.
Pickering, Darlington and Bruce Power CANDU stations:

A discussion of zone distances is provided in Section 4.1 of this report, and recommendations 5, 6 and 7 address this topic.

Fermi 2:
A discussion of issues related to U.S.-based reactors is provided in Section 4.5 of this report, and recommendations 11 and 12 address this topic.

Contingency Planning Zone:
Issues related to the CPZ are discussed in sections 4.2 and 4.3 of this report, and recommendations 9 and 11 address this topic.
Chapter 2, Sec 2.6 - Population Groups The need for a protective measure to take into account the projected dose to the most exposed individual in the Critical, Vulnerable and Special Groups. The revised PNERP to be aligned with revised Health Canada Guidance on population groups. A discussion of issues related to vulnerable and special groups in the technical analysis, and the requirements to justify these assumptions is provided in Section 4.1 of this report.
Chapter 2 – Planning Basis and Concepts

Sec 2.7 - Protection Action Levels
The PNERP provides for Protective Action levels which provide guidance in the pre-emission phase to determine the need to undertake protective measures. Operational Intervention Levels for protective action decision-making in the post-emission phase were not included. The revised PNERP to be aligned with Health Canada Guidance which includes Operational Intervention Levels for post-emission protective action decision-making. A discussion of Protective Action Levels is included in Section 2.4 of this report, and recommendation 2 addresses this topic.
Chapter 2 – Planning Basis and Concepts

Sec 2.9 – Concept of Operations – Nuclear and Radiological Emergencies (sub-sec. 2.9.1 - 2.9.2)
Operations to deal with a nuclear or radiological emergency will be conducted in two successive phases:
  • Response Phase
  • Recovery Phase
A review of revised Health Canada Guidelines and international best practices will be undertaken to determine whether a change to the PNERP’s emergency phases is required. A discussion of the concept of “best practices” is provided in section 2.4 and operational considerations are discussed in section 3.3. Recommendation 4 addresses the need for the ministry to develop a clear Concept of Operations for various accident scenarios.
Chapter 5 – Operational Responsibilities

Sec 5.5 – Notification System
Pursuant to the Nuclear Safety and Control Act and Section 6 of the Regulations for Class 1 Facilities made under that act, a nuclear installation or establishment in Canada makes an initial notification to the Provincial and Municipal authorities upon the occurrence of an event or condition which has implications for public safety, or could be of concern to the authorities responsible for public safety. The Notification Categories in place with each of the nuclear facilities will be reviewed to ensure that they reflect new severe accident management criteria. Section 5.5-5.7 in the PNERP deals with notification categories. In all cases, the PNERP directs the issue to Implementing Plans. The Discussion Paper does not provide any rationale for changes to the Implementing Plans or notification categories.  Therefore we have no recommendations in this regard.
Chapter 6 – Provincial Operational Response Strategy

Sec 6.2 – Provincial Response Levels
Upon receipt of notification of an emergency, the Province will adopt the appropriate response levels based on the following:
  • Routine monitoring
  • Enhanced monitoring
  • Activation (partial or full)
The Provincial Response Levels in place with each of the nuclear facilities will be reviewed in concert with the Notification Categories. A discussion of public and stakeholder feedback on various aspects of the PNERP Implementing Plans that are not highlighted in this table is provided in section 5, and recommendations 13 and 14 address these topics.

8.3 - Appendix C. Member Biographies

Dr. François J. Lemay
President, International Safety Research
Advisory Group Chair

Dr. Lemay is the President of International Safety Research, a corporation dedicated to nuclear and radiation safety, and nuclear emergency response. He has 31 years of experience in radiation protection, risk assessment, environmental impact assessment, safety analysis, emergency response plans, procedures and systems, emergency response standards and guidelines, audits and evaluations, emergency response exercises, courses and training, international projects and radiation transport.

As an internationally recognized expert in Nuclear Emergency Response (NER), he has conducted training in over five countries with the IAEA. Dr. Lemay has participated as an expert Emergency Preparedness in 6 IAEA Operational Safety Assessment Review Teams in Sweden, Bulgaria, Netherlands, United Kingdom, and France (twice).

Dr. Lemay is an expert in radiological and radiation and nuclear emergency preparedness and response, detection and decontamination. Dr. Lemay has been involved with emergency response exercises and evaluation for the Department of National Defense (DND) Nuclear Emergency Response teams. His level of involvement with DND included developing severe accident scenarios, delivering courses such as emergency management and decision making during nuclear accidents, and conducting and evaluating response exercises.

Dr. Lemay has also participated in international NER projects. He participated in the CONVEX international exercise that was sponsored by the IAEA and also delivered a course to the IAEA on the application of international requirements and guidance for emergency response. Dr. Lemay conducted and performed an evaluation of the Netherlands national NER exercise at the NPP Borselle. Dr. Lemay has also been an international Evaluator for Romania’s transboundary NER exercise and contributed to drafting the IAEA TECDOC 955: Generic Assessment Procedures for Determining Protective Actions during a Reactor Accident. In March 2011, Dr. Lemay participated in the IAEA expert meeting on the Preparedness and Response for a Nuclear or Radiological Emergency Concurrent with or Caused by a Natural Disaster. Dr. Lemay reviewed and assessed the Westinghouse-based SAMGs for Koeberg Nuclear Station, South Africa, for the purpose of evaluating the interface with emergency response. He developed and taught a course on severe accident progression, a comparative study between PWR and CANDU phenomenology. He is currently involved in the development of IAEA guidance on severe accident assessment for CANDU reactors.

Dr. Lemay is also involved with the preparedness of the Canadian nuclear industry by facilitating multi-disciplinary meetings of stakeholders and arranging large scale emergency exercises. For instance, he has been directly involved with NER exercises at Gentilly-2, Point-Lepreau, Darlington, and Pickering. Dr. Lemay has also been involved with the Ministry of Environment (Quebec) nuclear emergency procedures. Finally, Dr. Lemay is also presently part of the Canadian Standards Association Technical Committee for Nuclear Standards, and was a contributor to the CSA N1600-16 Standard General requirements for nuclear emergency management programs and the CSA N288.2-14 Standard Calculating the Consequences of a Release of Airborne Radioactive Material for Nuclear Reactor Accidents.

drs. C. (Chris) J. Dijkens
Expert, Emergency Preparedness and Response

Chris Dijkens works as Director International Enforcement Cooperation for the Human Environment and Transport Inspectorate (ILT) of the Ministry of Infrastructure and the Environment in the Netherlands. In that position he represents the Inspectorate in several international frameworks. After a career in the private industry as a researcher, he joined in 1980 the inspectorate where he worked in different (management) positions, mostly related to compliance monitoring, industrial safety, waste management, criminal investigations and crisis management. He graduated with Master degrees in Environmental Sciences and Business Administration.

In 2008 he was elected as the president of the Conference of the Parties of the United Nations Economic Commission for Europe (UNECE) Convention on the Transboundary Effects of Industrial Accidents. In 2010 and 2012 he was reelected for terms of two years. From 2013 – 2016 he chaired as well the UNECE Working Group on Development and led the process on the alignment of the Convention with the European Seveso III Directive and other Multilateral Environmental Agreements.

He is also strongly involved in the international frameworks for the worldwide strengthening of the preparedness and the response concerning emergencies with severe impact on the health and the environment. In 2007 he was elected as the chair of the global Advisory Group on Environmental Emergencies (AGEE). From 2009 till 2013 he chaired the Steering Committee of the AGEE. Chris Dijkens and the Ministry of Housing, Spatial Planning and the Environment in the Netherlands received the Green Star Award 2009 for his duties in connecting disaster operations and environmental impacts caused by emergencies.

Chris Dijkens is involved in European Union (EU) and global networks for compliance monitoring and enforcement of environmental legislation. From 2016 to the present, he has fulfilled the position of Chair of the European Union Network for the Implementation and Enforcement of Environmental Law (IMPEL). From 2012 – 2016 he served as the vice-chair of IMPEL. Within the EU frameworks he chaired from 2012 the Administrative Cooperation for market surveillance Group for the EU directives Ecodesign and Pyrotechnics. At a global level he fulfills the position of Co-Chair of the International Network for Environmental Compliance and Enforcement.

In his position within the Inspectorate he coordinates the cooperation on enforcement and compliance subjects with a variety of Chinese organizations on topics such as safe pyrotechnical articles, the safe maritime transport of dangerous goods as well the safe transport of dangerous goods by air, waste exports and waste management and the compliance of the quality of products with European legislation.

As an independent expert he is involved in executing assessments (peer reviews) on behalf of the International Atomic and Energy Agency. He acted in 2016 as the team leader of an international team in Hungary that carried out an Emergency Preparedness Review.

Prof. David Etkin
Associate Professor, York University

David Etkin is an Associate Professor of Disaster and Emergency Management at York University. He has contributed to several national and international natural hazard projects including the 2nd U.S. national assessment of natural hazards, the IPCC, was Principal Investigator of the Canadian National Assessment of Natural Hazards and is Past President of the Canadian Risk and Hazards Network. His areas of research include risk assessment, disaster ethics and climate change. He has over 80 publications including a textbook on disaster theory and six edited volumes.

Area of Specialization
Emergency Management

Degrees
M.Sc., York University
B.Ed., University of Toronto
B.Sc., York University

Dr. David Novog
Professor, McMaster University

Dr. David Novog is an NSERC/UNENE Senior Industrial Research Chair in Nuclear Safety and Professor in the Department of Engineering Physics. The focus of his research is related to safety of nuclear reactors and the tools and methods used to demonstrate their response in the event of an accident. The benefits of nuclear power are significant in terms of low cost production and secure base load supply. Reactors in Ontario provide over 50% of the electricity in Ontario with some of the lowest life cycle costs and CO2 emissions for any large scale power sources. Such performance is a key contributor to the manufacturing base, heavy industry and associated jobs and economic wealth of the province.  The focus of his research is on the safe operation of nuclear plants and experiments and computational analyses of their performance in postulated accidents. The nuclear accident at the Fukushima power plan in Japan was catastrophic in terms of environmental, social and economic impact. While no direct radiation fatalities occurred during the event the overall consequences highlight the importance of nuclear safety on a global scale. The analysis and lessons learned from this event form key drivers for improvements in our Research and Development methods.

With the advent of more realistic computational tools and detailed plant and human-factors modelling, best estimate predictions of accidents such as those that occurred in Fukushima are now possible. A major focus of Dr. Novog’s research group is the application of state-of-the-art tools and methods in the analysis of postulated accidents, and more importantly how the uncertainty in these models affects the evolution of the accident over time. This includes modelling and experiments related to existing reactors, GEN IV reactors and Small Modular Reactors as well as research into the continued benefits of nuclear technology through medical isotope applications and closed nuclear fuel cycles.

Degrees
B.Sc.(Eng.), University of Manitoba
M.Eng., McMaster University
Ph.D., McMaster University
P. Eng

Dr. Akira Tokuhiro
Dean and Professor, University of Ontario Institute of Technology

Akira Tokuhiro is currently Dean and Professor, Faculty of Energy Systems and Nuclear Science at University of Ontario Institute of Technology in Oshawa, Ontario. He joined UOIT from NuScale Power LLC (U.S.), a startup that completed and submitted a Design Certification Application of a Small Modular Reactor. At NuScale he led the Severe Accident Analysis group that developed and submitted a Licensing Topical Report on the technical basis for a smaller Emergency Planning Zone for the NuScale Small Modular Reactor design. Earlier he served as Director and Professor, Mechanical and Nuclear Engineering at the University of Idaho. He has also held appointments at Pacific Northwest, Idaho and Argonne National Laboratories in the U.S. He has a Ph.D. in Nuclear Engineering (Purdue), M.Sci. in Mechanical Engineering (University of Rochester), B.Sci. in Engineering-Physics (Purdue) and 10 years of international Research and Development experience at the Paul Scherrer Institute (Switzerland) and Japan Atomic Energy Agency.

While on faculty at University of Missouri-Rolla (now Missouri University, Science and Technology), he was Director of its nuclear reactor facility, as well as U.S NRC-licensed Senior Reactor Operator. During and post-“9.11”, he had to addressed security concerns at the facility. His research activities are across nuclear reactor engineering and design, thermal-hydraulics, safety, experimental measurement, modeling & simulation and energy analysis. Notably, he served on the American Nuclear Society President’s Committee on the Fukushima Accident and served as technical editor on a book on the accident.

Degrees
B.Sc.(Eng.), Purdue University (US
M.Sci. (Mech. Eng.), University of Rochester (U.S.
Ph.D. (Nucl. Eng.), Purdue University (U.S.
Senior Reactor Operator (U.S. NRC, 2001 – 2005)


8.4 - Appendix D. Moving Forward – How Academia Would Approach Framing the Problem of Nuclear Response Plans

Increasingly there is a literature arguing that the fields of ethical decision making and risk assessment need greater integration (e.g. Hansson, 2010). This trend is applicable to nuclear response planning, since both fields address different aspects of this problem and together they create a more holistic approach. Future discussion papers would benefit by broadening their framing beyond a risk assessment approach in order to address this issue in as comprehensive and robust a way as possible.

By incorporating these literatures, one can approach this issue by noting that there are three parts to framing a nuclear incident response plan. These three parts are not mutually exclusive, but inform each other and together form a more complete approach.

  • Part 1 - Ethical: The first part is ethical. This requires an acknowledgement of the values held by various stakeholders, and using those values within ethical analyses (utilitarian, rights-based, and possibly virtue-based, at a minimum) to develop arguments related to planning assumptions.
  • Part 2 - Risk Classification: The second part involves classifying the risk type. Depending upon the ‘kind’ of risk, different management strategies are appropriate to varying degrees. Good emergency management should blend an all-hazard with a risk-based approach.
  • Part 3 - Technical: The third part is a technical risk assessment where probabilities and consequences are estimated, along with the uncertainties associated with them. This section should include a discussion of what constitutes effective emergency response planning, and how well detailed plans can cope with a very large, complex event. For example, there is evidence that detailed planning for large, complex events should be replaced by flexible, adaptive strategies (e.g. Quarantelli, 2000; Koehler et al., 2014). It should also address costs associated with detailed planning at different levels, as compared to benefits.

Different perspectives on any of the above issues can, and do, lead to disagreement on planning assumptions and outcomes. There is a large literature on worldviews and risk perception that is relevant to this issue (e.g. Slovic, 2016; Wildavsky & Dake, 1990). This short discussion focusses on the ethical and risk classification aspects of the framing.

The current Discussion Paper by OFMEM focuses on the third part (technical)[v]. It is recommended that future papers can become more relevant to stakeholders if they also address parts one and two. With respect to part one this is mainly evident by some stakeholders invoking the precautionary principle as an argument for using a worst case scenario (or nearly worst case) for detailed planning purposes. The precautionary principle is not absolutist (Sandin et al., 2002) and, especially when a choice is not binary, should address “shades of grey” issues such as levels of acceptable risk. There is interesting literature on using worst case scenarios for planning purposes (e.g., Clarke, 2006, which provides a useful perspective and is different than a technical approach). We are not advocating that this principle should necessarily form the basis for planning, but rather that arguments for and against it should be considered within future discussion papers.

With respect to part two, some stakeholders indicated skepticism regarding the ability of science and technology to represent some aspects of the risk of a nuclear incident, as accurately as implied by the risk analysis within the Discussion Paper. There is support in the academic literature for this, particularly with respect to Normal Accident Theory (Perrow, 2011) and some recent empirical analyses of nuclear accident probabilities (Wheatley et al., 2016). This skepticism must be balanced against the credibility of the Probabilistic Risk Assessment (PRA). By noting and responding to critiques based upon Normal Accident Theory and complexity theory, future discussion papers may be viewed as more credible.

Values: The main values present appear to be (a) the sanctity of human life and health, (b) individual and community rights not to be exposed to harmful radiation beyond some acceptable level of risk (which may be zero for some), and (c) overall social welfare, which is served through the provision of nuclear power. There can be a tension between values b and c, which can result in an ethical dilemma.

Ethical Issues: A Utilitarian approach, which focuses on the greater good, will argue that a particular level of planning optimizes the benefits from a plan, while minimizing the downside. Utilitarian arguments accept harm to some (in this case those who are exposed to radiation risk) for the greater good (the availability of electricity). This type of argument should also note that planning assumptions based upon a worst case scenario have various negative impacts that must also be taken into account (such as the possible need for Emergency Operations Centres to be relocated outside of municipal boundaries or the impact of extended evacuation distances on the health of those affected).

A PRA-based approach such as that presented within the current Discussion Paper is based upon a utilitarian ethic, and does not answer rights-based questions such as:

  1. “To what extent do the risk-exposed benefit from the risk exposure?
  2. Is the distribution of risks and benefits fair?
  3. Can the distribution of risks and benefits be made less unfair by redistribution or by compensation?
  4. To what extent is the risk exposure decided by those who run the risk?
  5. Do the risk-exposed have access to all relevant information about the risk?
  6. Are there risk-exposed persons who cannot be informed or included in the decision process?
  7. Does the decision-maker benefit from other people's exposure?” (Hansson, 2007).

These are not easy questions to answer, but future discussion papers should attempt to discuss at least some of them to the degree possible and explain the positions taken by OFMEM. For example, a rights-based approach will note the obligation created by society at large to those near nuclear installations, who are at greater risk than others (this is a justice or fairness issue). Use of the precautionary principle (if it is considered relevant) would then place the burden of proof on the proponent of the plan to demonstrate that acceptable levels of risk are not exceeded. The current process requires that OFMEM demonstrate that the effectiveness of proposed measures meets acceptable health criteria.

Difficult questions that arise from this approach include, “How does one measure the greater good?”, “What constitutes proof?” and “What is the acceptable level of risk?” In a pluralistic society, there is unlikely to be a convergence of thought on these difficult issues. Even so, decisions need to be made.

An approach based upon virtues will ask whether the proponent is acting in a way that demonstrates various virtues such as competence, benevolence, courage, honesty, justice and wisdom. Evidence of virtues creates trust. This ethic is particularly relevant to process issues, and a process that is perceived as virtuous will create a better public consultation process. This also applies to OFMEM representatives who interact with the public. It is our assessment that the OFMEM has demonstrated many of these virtues in opening the Discussion Paper to public comment; by continuing an open, transparent process this will engender greater future trust.

There are many resources available to assist with developing an ethical decision making process. For example, the ethical network at Ryerson University[vi] has a helpful list of resources. When engaging in such a process, it is very useful to use a professional ethicist as a facilitator.

Risk Classification: There are many risk classification schemes that can be used to assist with the risk assessment process. An example of one is discussed by Renn and Klinke (2015). This scheme assists with the decision of what weight should be placed on traditional risk assessment techniques such as PRA, as compared to the precautionary principle and social discourse, depending upon the nature of the risk being assessed. They consider risks according to the following structure:

  • Damocles: high catastrophic potential, probabilities (widely) known (e.g. hurricanes)
  • Cyclops: no reliable estimate on probabilities, high catastrophic potential at stake (e.g. terrorism)
  • Pythia: causal connection confirmed, damage potential and probabilities unknown or indeterminable (e.g. H1N1)
  • Pandora: causal connection unclear or challenged, high persistency and ubiquity (e.g. bioaccumulation)
  • Cassandra: intolerable risk of high probability and great damage, but long delay between causal stimulus and negative effect (e.g. climate change)
  • Medusa: perception of high risk among individuals and large potential for social mobilization without clear scientific evidence for serious harm (e.g. genetically modified foods)

The three main management strategies discussed by Renn and Kiline are:

  • Risk based or risk informed management strategies (Damocles and Cyclops)
  • Precautionary or resilience based strategies (Pythia and Pandora)
  • Discursive (social discourse) management strategies (Cassandra and Medusa)

By classifying risks associated with nuclear incidents using the above structure, arguments for and against PRA and precautionary principle approaches can be better structured. While we do not advocate the direct use of such a methodology at this time, there is certainly value in considering the types of management strategies appropriate to nuclear response planning.

Summary: Moving forward the OFMEM can better engage various stakeholders and make their arguments more robust by incorporating the recommendations of a recent literature, which emphasizes the importance of merging the fields of ethical decision making and risk assessment. They can broaden the frame of future discussion papers to include (a) ethical considerations and (b) an analysis of risk types, as well as by addressing technical issues. The benefits of this approach would include improving public participation and acceptance of the emergency plans.


8.5 - Appendix E. References

Clarke, L. (2006). Worst cases: Terror and catastrophe in the popular imagination. University of Chicago Press.

Hansson, S.O. (2007). Philosophical Perspectives on Risk, Techné: Research in Philosophy and Technology, Vol. 11, no. 1 (Fall 2007).

Hansson, S. O. (2010). The harmful influence of decision theory on ethics. Ethical theory and moral practice13(5), 585-593.

Koehler, G. A., Kress, G. G., & Miller, R. L. (2014). What disaster response management can learn from chaos theory. Crisis and Emergency Management: Theory and Practice178, 111.

Perrow, C. (2011). Normal accidents: Living with high risk technologies. Princeton University Press.

Quarantelli, E. L. (2000). Emergencies, disasters and catastrophes are different phenomena. Available on the University of Delaware Library website.

Renn, O., & Klinke, A. (2015). Risk governance and resilience: New approaches to cope with uncertainty and ambiguity. In Risk Governance (pp. 19-41). Springer Netherlands.

Sandin, P., Peterson, M., Hansson, S. O., Rudén, C., & Juthe, A. (2002). Five charges against the precautionary principle. Journal of Risk Research5(4), 287-299.

Slovic, P. (2016). The perception of risk. Routledge.

Wheatley, S., Sovacool, B. K., & Sornette, D. (2016). Reassessing the safety of nuclear power. Energy Research & Social Science15, 96-100.

Wynne, B. (2001). Creating public alienation: expert cultures of risk and ethics on GMOs. Science as culture10(4), 445-481.

Wildavsky, A., & Dake, K. (1990). Theories of risk perception: Who fears what and why?. Daedalus, 41-60.

 

[i] United Nations, Report of the United Nations Conference on Environment and Development: Annex I Rio Declaration on Environment and Development, August 12, 1992. “In order to protect the environment, the precautionary approach shall be widely applied by states according to their capabilities. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.”

[ii] The millisievert is a measure of the absorption of radiation by the human body.

[iii] IAEA GSG-2, Criteria for Use in Preparedness and Response for a Nuclear or Radiological Emergency, paragraph 3.5: “In no case should urgent protective actions and early protective actions based on the generic criteria cause more detriment than they avert. Event specific conditions may warrant modification of the generic criteria.”

[iv] IAEA EPR-NPP Public Protective Actions, 2013, section 7.2: “Nuclear or radiological emergencies will have detrimental social, psychological, economic effects on the public. In addition, there have been cases of decision makers, members of the public and others (e.g. medical staff) taking inappropriate and damaging actions that result in injuries or increased risks to health that were not justified based on the radiation hazard. These non-radiological effects can be the most severe consequences of the emergency, occurring even if there is no release of radioactive material.”

[v] This is very common. A literature review shows that there is a significant disconnect between ethical decision making and risk assessment, even when both are aspects of the same social problem (Wynne, 2001; Hansson, 2007).

[vi] Available on the Ryerson University website.

Endnotes


[1] “Provincial Nuclear Emergency Response Plan: Master Plan (2009),” Ontario Ministry of Community Safety and Correctional Services. Available on the Ontario Ministry of Community Safety and Correctional Services website.

[2] Ontario Ministry of Community Safety and Correctional Services, Discussion Paper: Provincial Nuclear Emergency Response Plan – Planning Basis Review & Recommendations, Toronto, 2017

[3] Government of Canada, A framework for the application of precaution in science-based decision making about risk, 2003, http://www.pco-bcp.gc.ca/docs/information/publications/precaution/Precau...

[4] “Planning for a Sustainable Future: A Federal Sustainable Development Strategy for Canada,” Environment and Climate Change Canada, last modified October 2010. Available on the Environment and Climate Change Canada website.

[5] Wingspread Conference Participants, Wingspread Statement on the Precautionary Principle, Wisconsin, January 1998.

[6] University of Victoria Environmental Law Centre, The Precautionary Principle in Canada, British Columbia, June 14, 2010. Available on the University of Victoria Environmental Law Centre website

[7] E. Weir, R. Schabas, K. Wislon, and C. Mackie, “A Canadian framework for applying the precautionary principle to public health issues,” Can J Public Health, 101(5), 2010: 396-398.

[8] UNESCO, Report of the Expert Group on the Precautionary Principle of the World Commission on the Ethics of Scientific Knowledge and Technology (COMEST), France, March 2005. Available on the ‘Resources’ page of the UNESCO website.

[9] World Health Organization, The Precautionary principle: protecting public health, the environment and the future of our children, Denmark, 2004. Available on the World Health Organization website.  

[10] G.A. Koehler, G.G. Kress, and R.L. Miller, “What disaster response management can learn from chaos theory,” in Crisis and Emergency Management: Theory and Practice ed. Ali Farazmand (Routledge, 2014), 111-134

[11] International Commission on Radiological Protection, Application of the Commission’s Recommendations for the Protection of People in Emergency Exposure Situations, ICRP Publication 109. Ann. ICRP 39(1), 2009

[12] “Hazard Identification and Risk Assessment Workbook,” Ontario Ministry of Community Safety and Correctional Services. Available on the Emergency Management Ontario website.  

[13] Health Canada, Canadian Guidelines for Protective Actions During a Nuclear Emergency (Draft), Ottawa, April 2016

[14] International Atomic Energy Agency, Preparedness and Response for a Nuclear or Radiological Emergency: General Safety Requirements No. GSR Part 7, Vienna, 2015

[15] “The International Nuclear and Radiological Event Scale,” International Atomic Energy Agency, last modified November 17, 2016. Available on the IAEA Nuclear Safety and Security website.

[16] International Atomic Energy Agency, “EPR-NPP Public Protective Actions,” Actions to Protect the Public in an Emergency due to Severe Conditions at a Light Water Reactor, Vienna, May 2013

[17] Health Canada and Environment and Climate Change Canada, ARGOS Modelling of Accident A and Accident B Scenarios, 2017

[18] General Requirements for Nuclear Emergency Management Programs, CSA N1600: 2014

[19] Canadian Nuclear Safety Commission, Study of Consequences of a Hypothetical Severe Nuclear Accident and Effectiveness of Mitigation Measures, Ottawa, March 2015

[20] “List of Power Reactor Units,” United States Nuclear Regulatory Commission, last modified June 28, 2017. Available on the Nuclear Regulatory Commission website.

[21] “Emergency Planning Zones,” United States Nuclear Regulatory Commission, last modified September 29, 2014. Available on the Nuclear Regulatory Commission website.