Health Canada/Radiation…

   Health Canada/Radiation Protection Bureau welcomes the opportunity to provide its input on the Planning Basis discussion paper and proposed updates to the PNERP Master Plan.

  1. ‘List of Proposed Changes to the PNERP’ and ‘Discussion Paper’: These make several references to Health Canada Guidelines for Protective Actions during a Nuclear Emergency but only in general terms. The documents should clarify which elements of the Guidelines are considered for adoption.

  It should be noted that HC guidelines state that they are applicable for all categories of events as defined in the Federal Nuclear Emergency Plan (FNEP); however, there may be events where provincial involvement is required but that do not escalate to a level requiring federal support under the FNEP. For example, the PNERP implementing plan for “Other” radiological events includes transport accidents, which are explicitly not included in FNEP and are not mentioned in the Guidelines. The document should describe how this will be considered.

  It is also noted that the HC guidelines are not yet finalised, and therefore may be subject to revisions as part of the drafting process prior to their finalisation.

  Finally, the ‘List of Proposed Changes to the PNERP” indicates that the PNERP is “to be aligned with revised Health Canada Guidelines on Protective and Precautionary Measures.”  Health Canada is updating its Guidelines on Protective Actions during a Nuclear Emergency.  It is assumed that this is the document referenced in the List of Proposed Changes, so this should be corrected.

  2. Section 5: Studies and Technical Analysis.  The Province of Ontario is commended for taking into consideration a suite of national and international standards, guidance, reports and best practices that have been produced since the previous version of the PNERP, and particularly in response to the 2011 Fukushima-Daiichi nuclear accident.  In this regard, the IAEA Report by the Director General on the Fukushima-Daiichi Accident, particularly volume 3 on emergency preparedness and response, should also be cited and considered (http://www-pub.iaea.org/books/IAEABooks/10962/The-Fukushima-Daiichi-Accident).

  3. Section 7: Considerations for the Current Planning Basis Review: The CNSC Study on the Consequences of a Hypothetical Accident and Effectiveness of Mitigation Measures considered projected doses based on average weather over a year, rather than possible extremes based on actual weather over the short duration of a release in an emergency. This has the potential to underestimate the types of doses that could be seen in actual emergency situations. With respect to the Health Canada/ECCC Study - ARGOS Modelling of Accident A and Accident B Scenarios, this report does consider actual weather scenarios, but only over a short period of time.  A broader range of actual weather scenarios should be considered in order to identify possible but realistic extremes that could lead to higher or lower public doses.  In this regard, because release during an accident generally occurs over a short time, it may be more relevant to consider the MAX dose rather than the MEAN dose.

  Finally, reference is made to the UNSCEAR Report on the Levels and Effects of Radiation Exposure due to the Nuclear Accident after the 2011 Great East Japan Earthquake and Tsunami. While experience from this event with respect to implementation of protective measures is important, the comparison of resulting doses is of less value, as the doses from the Fukushima-Daiichi event were related to both the size and composition of the radioactivity release from that event, and the weather patterns that determined its distribution in the environment. Both of these may be very different for the scenarios considered in the PNERP planning basis.

  4. Section 8. Conclusions & Recommendations: The report concludes that the current planning zones are still applicable.  However, the link between the hazard assessment and this conclusion is not clear.  The way in which the hazard assessment has been considered in the determination of the PNERP planning zones should be explained in greater detail.

  There is no solid rationale explaining why the Contingency Planning Zone (CPZ) has been set at 20 km, other than indicating that it is double the distance of the Primary zone. There should be a clear link to the hazard assessment, and decision on acceptable risk. Additionally, there is no clear explanation of the choice of arrangements proposed for the CPZ. This should be explained in greater detail in terms of the planning objective for this zone.

  Increasing zone distances should also be considered.  A 15 km primary zone is in line with IAEA recommendations and the US standard of 10 mi (16 km)*(Noting that both distances are derived for light water reactors).  HC does not have set recommendations for zone distances, but looking at various modeling results for an unsheltered child would indicate that 10km may not be sufficient for a Primary Zone, and so should be looked at in greater detail.  The distances in the new contingency planning zone should also be evaluated based on the potential doses to an unsheltered child.  The contingency planning zone should consider potential scenarios for protective actions that would avert both a Total Effective Dose and the Thyroid Dose. Making these considerations would indicate that distances should be somewhere in the range of the IAEA recommended 50-100 km. The Secondary Zone of 50 km is significantly less than that recommended by the IAEA and US counterparts.  HC modeling of severe accidents yields distances similar to the PNERP ingestion control zone for the Fermi facility.  A commodities control zone (Secondary Zone) distance between 80-100 km may be more appropriate.

  Finally, the link between Ontario’s planning zones for the Fermi Site 2 and the Canadian intervention guidelines is not clear, and should be better explained.

  5. Emergency Planning Zone Nomenclature and descriptions should be updated to align with CSA N1600 and HC Guidelines which are similar to IAEA EPR-NPP Public Protective Actions Documentation. • N1600 (Automatic Action Zone, Detailed Planning Zone, Contingency Planning Zone and Ingestion Control Zone);

 • HC Guidelines (Automatic Action Zone, Detailed Planning Zone, Contingency Planning Zone and Ingestion Control Zone);

 • IAEA (Precautionary Action Zone 3-5 km, Urgent Protective Action Zone 15-30 km, Extended Planning Distance 50-100 km, Ingestion and Commodities Planning 100-300 km); and

 • Ontario PNERP (Contiguous Zone 3 km, Primary Zone 10 km, New Contingency Planning Zone 20 km, Secondary Zone 50 km)

  6. Section 10: Iodine Thyroid Blocking (ITB): It is indicated in the paper that ITB is not a component of the Planning Basis. Health Canada recommends that this not be the case. A framework for protective actions and response actions as they relate to ITB needs to be included in the PNERP.  The IAEA’s GSR Part 7, CSA’s N1600 and Health Canada’s Guidelines include requirements, standards and recommendations related to a potential thyroid dose.  The PNERP identifies the responsibilities of facilities for resourcing ITB and municipalities for stocking and distribution, but does not acknowledge the accountability of the province to provide a framework for its coherent integration within the current plan. While it is recognised that decision making with respect to ITB rests with the Provincial Medical Officer of Health, that authority is constrained by not addressing the issue in the PNERP. Therefore, full consideration of this topic needs to be included within planning zones to address concurrent protective actions like sheltering that would be used to avert a thyroid dose.

  7. General: The revised PNERP should consider the requirement in IAEA Safety Standard GSR Part 7 related to  ‘Plans and procedures for emergency response’ (Requirement 23).

[Original Comment ID: 210075]