&EPA
United States
Environmental Protection
Agency
Air And Radiation
(66O8J)
EPA 402-R-00-003
January 2OOO
Environmental Protection Agency
Radiological Emergency
Response Ran (RERP)
-------
-------
ENVIRONMENTAL PROTECTION AGENCY
RADIOLOGICAL EMERGENCY RESPONSE PLAN
- January 10,2000
U.S. Environmental Protection Agency
Office of Radiation and Indoor Air
Washington, D.C.
-------
-------
Foreword
I hereby endorse and commend for use by the Environmental Protection Agency this
Radiological Emergency Response Plan. It represents the EPA revised authorities, organization,
capabilities and concept of operations for responding to actual or potential radiological releases
in the environment. This Plan will be used as a guide for maintaining readiness to respond to
radiological emergencies in support of EPA responsibilities for protecting the environment and i
support of the Federal Radiological Emergency Response Plan and National Contingency Plan.
JAN 10
in
Date
-------
-------
TABLE OF CONTENTS
Disclaimer . iv
Preface v
I INTRODUCTION AND BACKGROUND 1
1.1 Introduction 1
1.2 EPA Radiological Emergency Response Mission 1
1.3 Background 2
1.4 Purpose 3
1.5 Scope and Applicability 3
1.6 Plan Considerations . . . . . 3
a. Federal Response Plans - NCP, FRP, FRERP, CONPLAN and RCPs ... 3
b. Roles of State, Tribal and Local Governments 5
c. Notification and Activation . 5
d. EPA Resources and Commitments 6
e. EPA Radiological Capabilities 6
f. Requests for EPA Assistance and Response Assets 7
g. EPA Coordination with other Federal Agencies 8
h. Reimbursement 8
i. Federal Lands 9
j. Enforcement Actions 10
k. International Coordination 10
1. NCP Special Teams 10
II CONCEPT OF OPERATIONS ., 11
2.1 EPA Responsibilities , 11
2.2 EPA Roles 11
2.3 Response Framework . . . . 13
2.4 Response Coordination 19
2.5 Response Termination and Recovery 21
m EMERGENCY PREPAREDNESS AND ADMINISTRATION ..22
3.1 Preparedness . . 22
3.2 Implementing Plan and Procedures 23
3.3 Training ,. 25
3.4 Drills and Exercises ;, 25
-------
-------
TABLE OF CONTENTS (cont.)
3.5 Resource Assessment 26
3.6 Plan Maintenance and Update 26
ANNEX A - AUTHORITIES ,.' A-l
ANNEX B - EPA-RERP RELATIONSHIP TO OTHER PLANS B-l
ANNEX C - DEFINITIONS '.'.'.]'.'.'.'.'.'. '. C-l
ANNEX D - OTHER HEADQUARTERS RESPONSE ORGANIZATIONS E-l
ANNEXE - REFERENCES .'...' E-l
ANNEX F - ACRONYMS . ; -. . ............. 7-1
BOX 2a - EPA Response to Radium Chemical. 13
BOX 2b - EPA Response to Chernobyl 14
BOX 2c - EPA Response to Three Mile Island Accident . . . . . . 14
BOX 2d - EPA Response to Terrorist Incidents . -..."; 15
TABLE 1 - Releases Impacting One EPA Region (primarily non-FRERP response) ........ 15
TABLE 2 - Releases Impacting Multiple EPA Regions (assumed to be FRERP response) .... 16
TABLE 3 - Releases from Sources Regulated by other Federal Departments/Agencies ...... 17
TABLE 4 - Releases from Terrorist Incidents ; ....... 18
FIGURE 1 - EPA Radiological Response Coordination 20
111
-------
-------
Disclaimer
This Environmental Protection Agency Radiological Emergency Response Plan (RERP)
represents EPA's current programmatic and operational concepts for responding to radiological
incidents and emergencies based on existing statutory authorities and obligations. The RERP is
intended solely as guidance. The RERP does not establish legal authorities, obligations, or any
other binding rights and duties. The RERP does not impose any legal obligations or duties on
any party other than those that exist under current law.
IV
-------
-------
Preface
The 1999 EPA Radiological Emergency Response Plan (EPA-RERP) is published by the
Office of Radiation and Indoor Air (ORIA), [formerly, Office of Radiation Programs], to replace
the 1986, EPA Radiological Emergency Response Plan. The EPA-RERP has been developed to
reflect changes in EPA's programmatic and operational concepts for responding to radiological
incidents and emergencies.
Programmatic changes include revisions of the National Oil and Hazardous Substances
Pollution Contingency Plan of September 1994 (NCP), and legislative mandates of the Superfund,
and Atomic Energy Act. Operational concepts have been streamlined consistent with the May
1996 Federal Radiological Emergency Response Plan and the April 1999 Federal Response Plan
(FRP). Additionally, the EPA-RERP incorporates the Presidential Decision Directive-39 (PDD-
39) issued in 1995, and the more recent directives: for Combating Terrorism (PDD-62) and for
Protecting America's Critical Infrastructure (PDD-63). Both PDD-62 and PDD-63 were issued
in May 1998, to address federal response to terrorist incidents of weapons of mass destruction
(nuclear, chemical and biological). .
Overall, the EPA-RERP represents the Agency's integrated approach to management of
radiological releases. Specifically, it integrates ORIA's Radiological Radiation Programs and the
Federal Radiological Emergency Response Plan into the response structure established by the
NCP, including headquarters and the ten regional Removal/Oil Response Programs and their
respective predesignated Federal On-Scene Coordinators (OSCs). Both the Office of Emergency
and Remedial Response (OERR) and Office of Chemical Emergency Prevention and Preparedness
(CEPPO), including regional representatives, have participated in the development of this plan.
The EPA-RERP is to be used as a guide for planning and maintaining readiness to respond
to those releases in accordance with EPA's mission to protect human health, welfare, and the
environment. Furthermore, this Plan distinguishes between EPA's role as a Lead Federal Agency
for response coordination under the FRERP, and its role as a lead agency for directing and
managing an emergency response pursuant to the NCP. It also accents the EPA-OSC's role in
managing/directing the emergency response actions as prescribed in the NCP.
ORIA is primarily responsible for the development of the EPA-RERP, with all other
offices being principally responsible for respective organizational input and representation.
Hence, ORIA would appreciate being informed of any errors/omissions so that they can be
corrected in future editions. Comments should be addressed to Mr. Craig Conklin, Director,
Center for Radiological Emergency Preparedness, Prevention and Response, EPA (6608J), 1200
Pennsylvania Ave., NW, Washington, DC 20460.
-------
-------
I. INTRODUCTION AND BACKGROUND
1.1 Introduction
This plan entitled the "Environmental Protection Agency Radiological Emergency
Response Plan ["EPA-RERP",or "Plan"]," supersedes the EPA Radiological Emergency
Response Plan dated 1986. The Plan represents the EPA's concept of operations consistent with
the federal policies, planning considerations and response provisions outlined in the 1994 National
Oil and Hazardous Substances Pollution Contingency Plan (NCP), Federal Response Plan (FRP)
revised, and issued in April, 1996 Federal Radiological Emergency Response Plan (FRERP), and
the interagency Counter-Terrorism Concept of Operations Plan (CONPLAN), currently in draft.
The EPA-RERP establishes organizational focus for management of potential or actual
radiological incidents and emergencies and coordination among the EPA On-Scene Coordinators,
(OSCs) community, regional radiation programs, Office Emergency and Remedial Response
(OERR), Chemical Emergency Prevention and Preparedness Office (CEPPO) and Office of
Radiation and Indoor Air (ORIA), including the two radiation support laboratories. Recognizing
that cross-agency consistency is critical for effective emergency response, this Plan does not
preclude or supplant regional planning and preparedness. Rather it provides the flexibility to EPA
regions to establish Regional Contingency Plans (RCPs) as required by the NCP, and to tailor
their radiological response operations to reflect their priorities, specific organization structure and
the regional/local conditions.
Within the EPA, the regional OSCs are responsible for coordinating and managing the,
emergency response under the NCP. For radiological response activities, however, a number of
programs, teams and groups in EPA Headquarters and Regions are responsible for preparedness
planning and response support involving potential or actual radiological releases at the national or
international level. The NCP is EPA's blueprint for emergency response guiding the funding
authority and response mechanisms necessary for the Agency to meet its response obligations for
releases of hazardous substances including radionuclide releases. The FRERP prescribes the
federal lead and support roles and obligations within the Federal Government including EPA.
The EPA-RERP integrates EPA's commitments pursuant to the CONPLAN, FRERP/FRP, and
the NCP. To this end, the Plan identifies EPA's internal response structure, coordination of
capabilities for regional and Headquarters response activities including the laboratories, in the
event of peacetime radiological hazardous substance and technological emergencies, and nuclear
terrorist incidents.
1.2 EPA Radiological Emergency Response Mission
The EPA missiqn in responding to radiological emergencies is subsumed in the Agency
response to other hazardous substances, pollutants, or contaminants under the Superfund program
-------
which has both enforcement and response responsibilities. In the event of technological
emergencies, or incidents of terrorist attacks involving a potential or actual release of
radionuclides, EPA may lead the response to ensure the protection of human health, welfare and
the environment from the adverse impacts associated with exposure to radiation. Working with a
broad spectrum of stakeholders, EPA may provide technical advice and response support to the
state, tribal, and local governments (referred to as state and local), site or facility owner/operator,
and other federal agencies. EPA has also the authority to order private party cleanup, and
oversee and monitor emergency response by others. EPA achieves its mission by:
evaluating the need for emergency, time-critical or non-time critical removal response to
protect health and the environment pursuant to the NCP;
evaluating the need for coordinating multi federal response pursuant to the FRERP;
establishing and maintaining a high-level of readiness through planning, training, and
drills/exercises;
providing upon request effective and efficient emergency response management support to
federal, state, Tribal, and local governments;
conducting emergency, time-critical and non-time critical removal response action
pursuant to the NCP;
providing "Special Forces" emergency response radiological expertise and support to the
On-Scene Coordinator for NCP removal responses through the Radiological Emergency
Response Team (RERT) of ORIA and their labs;
leading the FRERP response to radiological emergencies when assigned the Lead Federal
Agency (LFA) role;
* developing Protective Action Guidance (PAGs) and providing incident-specific protective
action recommendations;
performing timely, and accurate environmental measurements and assessments of
radiological conditions;
providing threat assessment, technical support, and operational support to the LFA in
potential or actual terrorist incidents; and
assisting in preparing long-term environmental monitoring and area restoration plans, and
recommended cleanup criteria.
1.3 Background
Radiological incidents or emergencies may occur at hazardous waste sites, fixed nuclear
facilities (domestic and foreign), and may involve satellites, nuclear weapons and devices,
transportation accidents, sabotage or nuclear terrorism. Incidents may also occur at smaller
nuclear facilities such as hospitals, and from contaminated imports, or improper waste
management and disposal anywhere in the United States (US). These situations may result in
radionuclide releases with actual, potential, or perceived harm or consequences to human health
and the environment within the US and its territories, possessions, or territorial waters.
-------
State and local government officials have the primary responsibility for protecting the
public during a radiological emergency. They must be prepared to respond during the first hours
of a radiological emergency. Consistent with the NCP, state and local jurisdictions, as well as
owners/operators of major nuclear facilities, should have compatible radiological emergency
response plans that have been coordinated and tested for timely, effective emergency response.
Federal assistance may be needed for emergencies that have the potential for significant offsite
consequences such those involving multiple jurisdictions, or those that extend beyond several
hours, and beyond the capabilities of the state/local community. Federal response to radiological
incidents and emergencies is carried out under the auspices of the Statutes, Agreements,
Memoranda of Understanding, Executive Orders, and Presidential Decision Directives listed in
Annex A.
1.4 Purpose
The purpose of this Plan is to describe EPA's concept of operations to implement the
various actions, when responding to a threatened or actual radiological releases in emergencies
and terrorist incidents. It identifies applicable response authorities and plans, the response
frameworks for different releases, response coordination, and organizational responsibilities and
resources required for effectively preparing and responding to peacetime radiological releases in
the US and its territories. The Plan is intended to be used by, and provide coordination among
EPA-OSCs, Regional Radiation Programs, EPA radiation labs, ORIA, OERR, and CEPPO.
1.5 Scope and Applicability
The scope of this Plan includes: ,
domestic radiological incidents and emergencies occurring at, or involving hazardous
waste sites, fixed nuclear facilities, domestic or foreign satellites, nuclear weapons and
devices, accidents in transportation of radioactive materials, or incidents of sabotage and
nuclear terrorism that have actual, potential, or perceived consequences to US and its
territories; and
international radiological emergencies such as the Chernobyl accident in the Ukraine,
subject to the International Atomic Energy Agency (IAEA) "Convention on Assistance in
the Case of a Nuclear Accident or Radiological Emergency."
The EPA-RERP applies to EPA radiological emergency response actions pursuant to the NCP,
FRERP, CONPLAN, and/or FRP.
-------
1.6 Plan Considerations
a. Federal Response Plans - NCP, FRP, FRERP, CONPLAN and RCPs
Details of the NCP, FRP, FRERP and CONPLAN are provided in Annex B. The EPA-
RERP is a framework for the regional removal and radiation programs to develop their respective
RCPs, and to integrate their radiological response resources within the operational structure(s) of
the FRP, FRERP and CONPLAN. The relationship between these plans and the EPA-RERP,
may be summarized as follows. The EPA-RERP provides the EPA OSCs and response teams
with guidance for the integration of the federal response plans into a response directed and
coordinated pursuant to the NCP. Current interagency agreements, Memoranda of
Understanding or Agreement, Executive Orders, Presidential Decision Directives or statutory
authorities are not superseded by the EPA-RERP.
Under the NCP, EPA is the lead response agency for releases of hazardous substances,
including radionuclides, in the Inland Zone of the US, pursuant to the Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 "CERCLA" (Superfund), and
excluding certain releases of radiological materials from Nuclear Regulatory Commission
(NRCom)1 licensed nuclear reactors and from uranium mill tailing sites. Sections 300.130 (f),
(g), (h), and (i) of the NCP incorporate by reference the FRERP and FRP provisions. The NCP
specifically adopts the applicable FRERP notification and assistance procedures for radiological
emergency response. Most radiological releases do not result in FRERP activation, and are
handled in accordance with the NCP.
The FRERP describes how federal agencies including EPA, should coordinate their
actions when responding to a peacetime radiological emergency that has actual, potential, or
perceived radiological consequences within the US, its territories, possessions, or territorial
waters that could require a response by several federal agencies. The FRERP is a federal
agreement/plan that describes how, when and where the EPA radiological resources will be
utilized. It however does not supersede NCP regulatory authorities.
The EPA-RERP recognizes that EPA must act consistently with the NCP when
conducting FRERP response activities where CERCLA is applicable including all situations when
EPA is the LFA for FRERP response. In these situations, the pre-designated EPA OSC has the
authority to take response action accordingly, to ensure effective and adequate federal response.
The Plan also recognizes that the EPA OSC is responsible for determining when a radiological
incident or emergency warrants activation of a multi-agency response within his/her area of
jurisdiction. ORIA provides the RERT as a "Special Force" under the NCP to assist federal
OSCs during NCP emergency responses. Although the FRERP was originally developed to
address large scale accidents at commercial nuclear power plants, it has been implemented in
response to small radiological incidents.
For the purposes of this document only, the acronym "NRCom" is used to refer to the Nuclear Regulator)' Commission, where as the
"XRC"' is used to refer to the National Response Center.
-------
The purpose of the FRP is to facilitate the delivery of all types of federal response
assistance to states to help them deal with the consequences of significant disasters with or
without Presidential Declaration. The Federal Emergency Management Agency (FEMA) is the
lead agency for coordinating response activities that include 26 federal departments and agencies
plus the Red Cross. Under the FRP, EPA is the Primary Agency responsible for coordinating
preparedness and response activities for Emergency Support Function #10 (ESF-10), regarding
hazardous materials including radiological releases, and leads ESF-10 responsibilities in dealing
with counter-terrorism consequence management. The EPA-RERP recognizes that OSC(s)
coordinate their response operations through the Federal Coordinating Officer (FCO), within the
response community framework when responding to FRP incidents.
The CONPLAN establishes overall guidance concerning how the federal government
responds to a potential or actual terrorist threat or incident that occurs in the US, particularly one
involving weapons of mass destruction (WMD). The CONPLAN implements Presidential
Decision Directives 39 and 62: United States Policy on Counter-terrorism, and Combating
Terrorism (PDD-39, PDD-62), respectively. It also establishes conceptual guidance for assessing
and monitoring a developing threat, notifying appropriate federal, state, and local agencies of the
nature of the threat, and deploying the requisite advisory and technical resources to assist the LFA
in executing a crisis and consequence management response to a threatened or actual terrorist
incident. Lastly, it defines the structure under which the federal government will marshal
resources to augment and support state and local governments in responding to a threatened or
actual terrorist incident.
b.
Roles of State, Tribal and Local Governments
The primary role of the state, Tribal and local governments is to provide for the health and
safety of the public and protection of the environment. EPA provides recommendations to these
governmental entities on actions to protect the health and safety of their communities. Using
incident-specific information and EPA's protective actions recommendations, the state/local
governments are responsible for determining which action(s) to implement. Protective actions
may include evacuation, sheltering, relocation, distribution of potassium iodide, or restrictions on
the consumption of water or certain foods, removal or control of the source, or decontamination,
or taking whatever response actions are necessary to protect public health and the environment.
Although it may not be practical for state. Tribal and local government responders to
maintain extensive radiological emergency response capabilities, they are always expected to
respond during the initial hours of a radiological accident. However, they may likely need federal
assistance for situations with potentially significant consequences requiring multi-^ jurisdictional
response, or for those that extend beyond several hours, days, or weeks.
-------
c.
Notification and Activation
Typically, notifications of incident, spills and emergencies are made to EPA through the
National Response Center (NRC) and Regional Response Centers (RRC). Notifications to the
NRC , are relayed directly to the appropriate RRC. If notifications are made directly to ORIA or
Regional Radiation Programs, they should immediately be relayed to the appropriate RRC. When
notified of an EPA LFA incident, the lead EPA official (usually the OSC) will assess the situation
("site") in order to determine if it is an emergency or otherwise requires EPA response action.
When a situation is beyond the sole resources of the local and state jurisdiction and licensee (or
responsible party), the EPA lead official will request appropriate EPA resources from the
Regional Radiation Program, ORIA and/or Superfund Program, as appropriate.
In most EPA Regions, the OSC may approve the use of Superfund in the amount of
S200K in an emergency, or $50K for non-emergency removal response and a Superfund account
number will be established for travel and other response costs requested by the OSC. Or in the
case of an incident that requires further assessment, the EPA OSC may conduct Superfund
assessment activities for which a Superfund account will be established. The OSC or ORIA lead
EPA official will request needed radiological resources based upon incident requirements,
availability of resources, regional arid national priorities and commitments, in consultation with
regional and Headquarters radiation program managers. If EPA radiological resources are not
available, the lead official may request radiological support from other agencies or from EPA
contractors which support the National Response System and FRERP.
d.
EPA Resources and Commitments
When notified of an emergency, EPA will assess the need for federal response pursuant to
the NCP, and will respond according to this Plan. EPA resources are available for technical
assistance and radiological response operations subject to prior commitments to fulfill other
essential statutory and operational needs. The EPA regional emergency response program
managers allocate available resources based on identified threats, jurisdictional/national priorities
and in coordination with the corresponding Headquarters counterparts.
If radiological resources are unavailable in the affected state or from a region, EPA
Headquarters will seek to provide an appropriate EPA alternative. ORIA serves as a central point
for information/coordination of nationally available radiological resources. The ORIA
Laboratories, the National Air and Radiation Environmental Laboratory (NAREL) and the
Radiation and Indoor Environments National Laboratory (R&IENL), provide environmental
monitoring, sampling and analysis support. The OSC may also consult with the Regional
Response Team or National Response Team to obtain support from other member agencies.
-------
e. EPA Radiological Capabilities ~
EPA has significant emergency response management and coordination capabilities,
managed by each of the Regional Removal Managers, and overseen by the Headquarters OERR.
In support of the National Response System (NRS) and EPA's emergency response program and
to fulfill its unique responsibilities under the NCP and FRERP, EPA's radiological capabilities
include trained responders, team commanders and specialists, and equipment and laboratory
capabilities to:
direct and conduct environmental monitoring activities and assess the
environmental consequences of radioactivity releases.
access response contractors, the Emergency Response Team, strike forces, RERT,
and other special forces of the National Response System.
analyze risk and recommend protective actions and other radiation protection
measures.
recommend acceptable emergency radiation levels in the environment.
determine routes of exposure and estimate effects of radioactive releases on human
health and environment.
prepare health and safety advice and information for the public.
provide nationwide environmental monitoring data from Environmental Radiation
Ambient Monitoring Systems (ERAMS) for assessing the national impact of a
release.
assist in .the preparation of long-term monitoring and area restoration plans; and
recommend cleanup criteria.
f. Requests for Assistance and Response Assets
EPA may decide to mobilize onscene during an emergency or incident to determine if
assistance is needed. Requests for EPA's assistance may come from a variety of sources
including state, Tribal, and local governments, the owners and operators of radiological facilities,
other federal agencies, or even the general public. Requests may be made directly to EPA
Headquarters, regional offices, or laboratories, or through the NRC. Upon notification, the NRC
first notifies the Federal OSC through the RRC, and then relays communications of incidents or
emergencies to pre-designated EPA personnel, including the EPA OSC, and the RERT, On-Scene
Commander (OSCom). It is important to note that pursuant to the NCP, EPA does not need a'
request from state or local officials to be a responder.
EPA responders work directly with their state and local counterparts to provide the
required assistance. When necessary, EPA emergency response action may go beyond
"assistance" to state and local jurisdiction, and may include Oil Pollution Act and/or CERCLA
Federal-lead response actions consistent with the NCP. For all radiological incidents and
emergencies, the affected EPA Region may provide regional OSC(s) and regional radiation
-------
program specialist(s) to coordinate EPA response activities. If the incident is of major
consequences or national/global significance, the EPA Headquarters organizations may provide
response support such as mobilization of the RERT and coordination, in addition to programmatic
and response guidance.
In all instances under the FRERP, the Department of Energy (DOE) has the lead
responsibility for coordinating the Federal Radiological Monitoring and Assessment Center
(FRMAC), for assistance during the early phase of the emergency. The FRMAC provides
expertise and equipment to handle requests for specialized response assets. EPA also may be
called upon to provide resources including personnel, equipment and laboratory support for
sampling and analysis, to assist DOE. DOE FRMAC assets can be requested through the EPA
RERT. During the intermediate and late phases of an emergency, EPA assumes control of the
FRMAC.
In instances where the Department of Justice/Federal Bureau of Investigations (FBI) has
the lead responsibility for coordinating a federal response to a radiological (terrorist) emergency,
EPA may provide crisis management technical assistance and advice to the FBI, as requested, and
to other federal agencies as well as to state and local responders. EPA also provides consequence
management as the lead agency for ESF-10, Hazardous Materials Annex, and in support of other
ESFsoftheFRP.
g. EPA Coordination with other Federal Agencies
Under the AEA NRCom regulates certain nuclear material in the US. The NRCom is
LFA for NRCom or Agreement States licensed materials. However, NRCom does not have
response funding or enabling legislative authority to fund or mount significant response actions
should the Licensee be bankrupt, missing, unable or unwilling to respond in a timely manner.
EPA may, at the OSC's discretion, undertake CERCLA response actions to control releases of
hazardous substances, pollutants, or contaminants which pose a significant threat from NRCom
licensed facilities. Excluded by definition are radiological releases from NRCom licensed nuclear
reactors. Based on the exigency of the situation, and after NRCom has taken reasonable steps to
enforce a Licensee cleanup under the AEA, CERCLA enforcement authorities should also be
evaluated and utilized before expending Superfbnd Trust Fund monies, as required by the NCP.
Request for Superfbnd assistance by NRCom should be made directly to the EPA Region or
Federal OSC.
Under the NCP and CERCLA Executive Order 12580, DOD and DOE provide the OSC
for releases from their facilities, and for technical support as may be requested by others.
Consistent with section 300.135 of the NCP, the OSC's efforts are coordinated with other
appropriate federal, state, local and private response agencies, including the Department of Health
and Human Services and Occupational Safety and Health Administration in cases involving public
health emergencies and worker health and safety issues.
-------
Because of the relationship between NRCornJs regulatory authority and its responsibility
as LFA, and EPA's CERCLA response authority, funding and resources, an NCP response will
not be required if the radiological incident does not involve a listed radionuclide or the actual or
potential release of a listed radionuclide exceeding the reportable quantity requirements. Hence,
both organizations must coordinate closely to keep one another informed of all releases of
radiological materials. Early coordination ensures timely and effective response, and transition of
responsibilities from to one agency to another, when necessary.
h.
Reimbursement
EPA is responsible for all of its own costs incurred when responding to a radiological
incident or emergency, regardless of whether activities are initiated by statutory responsibilities or
at the request of another federal or state agency. This does not, however, preclude EPA from
later seeking special appropriations to cover the response costs, or seek funds through
enforcement actions against the responsible parties, where appropriate.
In the event of a FRP disaster declaration and issuance of a mission assignment, EPA will
be reimbursed by FEMA in accordance with policies and procedures outlined in the Financial
Management Annex of the FRP. Though each federal department and agency is responsible for
providing its own financial services and support to its response operations in the field, FEMA may
reimburse funds to cover eligible costs for response activities and, in special cases, may advance
such funds.
EPA may expend Superfund monies to respond to releases of radiological materials
pursuant to the NCP and FRERP. CERCLA authorizes EPA to recover from potentially
responsible parties costs incurred for response actions, and trustee agencies may seek penalties
and compensation for damages to natural resources.
i. Federal Lands
A response to a radiological incident or emergency on or affecting federal lands not
occupied by a government agency should be coordinated with the agency responsible for
managing that land. This ensures that response activities are consistent with federal statutes
governing the use and occupancy of these lands to the extent required pursuant to CERCLA/
NCP. Coordination is particularly necessary in the case of Indian tribal lands, because federally
recognized Indian tribes have a special relationship with the US Government, and the state and
local governments may have limited or no authority on Indian reservations. Pursuant to
CERCLA, Indian tribes are in general treated as states.
For radiological emergencies occurring on or with possible consequences to Indian tribal
lands, the Department of Interior (DOI) will provide liaison between federally recognized Indian
tribal governments and the FRERP designated LFA, state, and local agencies for coordinating the
response and protective action(s) efforts. Additionally, DOI will advise and assist the FRERP-
-------
designated LFA on economic, social, and political matters in the Virgin Islands and the Territories
of Guam, American Samoa, and the Trust Territories of the Pacific Islands should a radiological
emergency occur in these areas.
In the event of a radiological accident involving a nuclear weapon or special nuclear
material (SNM), the owner of the weapon or material shall declare the area a National Defense
Area (for Department of Defense "DOD") or National Security Area (for DOE or National
Aeronautics and Space Administration "NASA"), depending on the circumstances of the
emergency. These areas are established only during the emergency to safeguard classified
information and/or restricted data or equipment and material. Establishment of these areas may
place non-federal lands under federal control. For emergencies involving DOD, or DOE, these
agencies shall provide the OSCs, and be responsible for taking all response actions. In the case of
NASA and other federal agencies, their OSCs will be responsible only for all response actions that
are not emergencies. Otherwise, the EPA provides the OSC to manage and coordinate
radiological emergency response for those agencies including NASA. It is possible that
radioactive contamination and emergency response actions would extend beyond the boundaries
Of these areas. (NOTE: IN ACCORDANCE WITH APPROPRIATE NATIONAL SECURITY
CLASSIFICATION DIRECTIVES, INFORMATION MAY BE CLASSIFIED CONCERNING NUCLEAR
WEAPONS, TERRORIST THREATS, SPECIAL NUCLEAR MATERIALS AT REACTORS, AND
CERTAIN FUEL CYCLE FACILITIES PRODUCING MILITARY FUEL.)
J-
Enforcement Actions
EPA under certain circumstances will exercise its discretionary authority to undertake a
radiological emergency response action pursuant to the appropriate enforcement provisions.
EPA, state, or local legal actions will be taken to obtain compliance with environmental laws,
rules, regulations, or agreements and/or obtain penalties or criminal sanctions for violations.
Under CERCLA, EPA will seek to require potentially responsible parties to .undertake full
response, and/or pay for the cleanup. In other situations, if investigations by EPA and state
agencies uncover willful violations, criminal prosecution may be sought through the Department
of Justice. EPA's removal program (emergency response) prevents, limits, or mitigates
threatening situations as quickly as possible at any emergency or incident involving uncontrolled
CERCLA hazardous substances, pollutants or contaminants including radioactive materials.
Enforcement actions are taken as time allows based on the incident specific threats.
k.
International Coordination
In the event of a radiological incident or emergency originating on foreign soil or,
conversely, a domestic incident with an actual or potential foreign or trans-boundary impact, the
EPA will immediately notify the Department of State (DOS) which has responsibility for official
notification of foreign governments. The DOS coordinates release notification and information
gathering/exchange activities with foreign governments, except when existing bilateral agreements
may permit direct communication. When EPA as the LFA has existing bilateral agreements
10
-------
permitting direct exchange of information, the Agency wfll keep DOS informed of
communications with their foreign counterparts. Agency officials should take care that
consultations do not exceed the scope of the relevant agreements(s). The EPA will ensure any
offers of assistance to or requests from foreign governments are coordinated with DOS
1.
NCP Special Teams
ORIA will coordinate the mobilization of the RERT, and may coordinate mobilization of
the Department of Energy's Radiological Assistance Program (RAP), and FRMAC It is
important to note that the Radiological Assistance Teams (RATs) mentioned in §300 145 of
earlier versions of the NCP are now called Radiological Emergency Response Teams (RERTs)
and are organized in ORIA. OERR will coordinate mobilization of the Environmental Response
Team (ERT) among other organizational response elements as appropriate. Requests for
mobilization of these response elements can be made directly through the OSC and/or the
National Response Center, which would the put the requester directly in communication with the
requested Special Teams' representatives.
II
-------
2. CONCEPT OF OPERATIONS
The concept of operations for radiological response is defined in terms of EPA's overall
responsibilities, roles, response framework, regional and Headquarters coordination, and
deactivation and recovery (termination). EPA's responsibilities for emergency response as
outlined in section 2.1, are established by the Agency mission and are predicated on vested
leenslative authorities. Section 2.2 describes EPA roles established by the federal plans'
provisions for emergency response. The response framework is designed to address four basic
type of incidents to which EPA may respond as delineated in Tables 1 - 4 in section 2.3.
Response coordination involving regional and Headquarters programs is discussed in section 2.4.
Annex D identifies other response organizations with a key role in the Agency emergency
response. Termination of EPA response; i.e., deactivation and recovery, is described in section
2.5.
2.1 EPA Responsibilities
In principle, during an emergency response to radiological releases, EPA's responsibilities
may include:
acting as a lead response agency, or as LFA,
determining which plan structure is applied and organize accordingly,
modifying and/or activate RRT members as appropriate
determining the need for Superfund (aka CERCLA) response,
undertaking and funding Superfund response actions,
directing support to state, tribal or local governments, in response operations at
radiological facilities,
developing protective action guidance (PAGs),
performing radiological measurements and assessments,
providing information and outreach to the affected community,
providing direct support to State, tribal or local governments, operators of
radiological facilities, or the public,
providing technical advice and assistance to the FRERP designated LFA, other
lead agencies including State and local officials, and
providing specialized radiological resources, representatives and assistance to
other federal responders.
2.2 EPA Roles
Lead Response Role. EPA may be the FRERP designated LFA in a multi-agency response, or be
the sole agency when responding to the following types of radiological incidents or emergencies:
12
-------
releases at a nuclear facility not licensed, owned, or operated by a Federal agency
or an Agreement State. These include facilities that possess, handle, store, or
process radium, other naturally occurring radiological material (NORM),
accelerator-produced radioactive material, or radioactive materials not covered by
existing regulations.
releases from accidents during transportation of radiological materials unknown,
not licensed, owned or operated by a Federal agency or an Agreement State -
unless material could be traced to a specific licensee or claimed by a federal
agency.
releases from a foreign source that has actual, potential, or perceived radiological
consequences in the US, its Territories, possessions, or territorial waters.
When responding to these types of incidents, EPA's responsibility is to:
provide the RERT On-Scene Commander (OSCom) and/or NCP OSC (the OSC
is an OSCom except in a multi-regional incident when ORIA assigns the FRERP
OSCqm);
determine the nature and extent of release, and determine the need for EPA
response,
evaluate the need for and coordinating appropriate NCP response actions pursuant
to CERCLA, as needed;
assist State and local governments in determining measures to protect life,
property, and the environment;
ensure that FEMA and other Federal agencies assist the State and local
government agencies in implementing protective actions when requested;
coordinate Federal response activities from the onscene Joint Operations Center
(JOC), or from its Headquarters' Emergency Operations Center (EOC);
coordinate with DOI for advice and assistance on economic, social, and political
matters in the US insular areas for incidents occurring on, or with possible
consequences to, Indian tribal lands;
oversee the onsite response; monitoring and supporting owner/operator (when
available) activities or providing technical support to them if requested;
provide a hazard assessment of onsite conditions which may have offsite impact,
and onsite measures taken to mitigate offsite consequences;
serve as the principal Federal source of information about onsite conditions; and
convene and coordinate the FRMAC and/or Advisory Group on Environment,
Food, and Health that includes representatives of the Departments of Agriculture,
Health and Human Services, and EPA when needed to analyze data and make
recommendations on protecting the environment, the food, and water supply, and
public health.
Support Role. When EPA assumes a supporting role in a multi-agency response under the FRP,
FRERP, or CONPLAN, EPA is responsible for :
13
-------
providing advice on protective actions to the LFA/states representatives,
providing information on the status of its response and on technical information,
assuming control for the FRMAC activities from DOE at a mutually agreeable
time, and thereafter coordinate activities of assets assigned to the FRMAC from all
federal agencies,
assisting in the development and implementation of a long-term monitoring plan,
providing technical advice and assistance to the FRERP-LFA, including
monitoring, identification of radionuclides, sample collection and analysis, and
decontamination activities, and
providing nationwide environmental monitoring data from the ERAMS for
assessing the national impact of an accident.
2.3 Response Framework
EPA's emergency response may proceed in five stages beginning with the notification and
evaluation of a release, and ending with the response termination. A variation of these stages may
occur depending on the extent of the response measures. Most frequent occurrences are four
types of incidents or emergencies to which EPA may respond. Tables 1-4 illustrate the response
framework for each, with examples provided in Boxes 2-a, 2-b, 2-c, and 2-d.
a) Table 1 shows EPA's response to an emergency impacting only one EPA Region,
involving radioactive material not licensed, owned, or operated by a federal agency or an
Agreement State. Unknown sources of radioactive material refers to that material whose origin
and/or radiological nature is not yet established. These types of sources include contaminated
scrap metal or abandoned radioactive material. The Radium Chemical response illustrated in Box
2-a, is an example of this'incident. This type of response is typically addressed under the NCP,
and will not generally require FRERP activation; however, FRERP resources would be available if
needed.
Box 2-a: EPA Response to Radium Chemical
State Inspections revealed continual violations of the law at Radium Chemical Company's Woodside, Queens,
facility in New York, including losl radium shipments and excessive radiation levels in the plant. After efforts
to bring the insolvent company's facility into compliance with State regulations failed, EPA's assistance was
called in. Due to the potential to cause significant harm to the public, EPA secured the site, evaluated the
need for removal/decontamination, removed dangerous radioactive material from the site and shipped it to a
low-level radioactive waste disposal site. EPA's response assets remained near the site during cleanup, due to
potential accidental release of materials. EPA also recommended that the State conduct a health survey of
former Radium Chemical Company employees.
14
-------
b) Table 2 illustrates EPA's response to an incident impacting multiple EPA Regions, such
as a foreign reactor (see EPA's response to Chernobyl summarized in Box 2-b), a spacecraft (e.g.,
the Soviet COSMOS satellite), radioactive fallout from atmospheric testing of nuclear devices.
For these types of incidents, EPA responds as the LFA under the FRERP, as well as NCP OSC
where "site" cleanup is needed, and provides all leadership and coordination for the multi-agency
response activities.
Box 2-b: EPA Response to Chernobyl
In April 1986, the accident at the Chernobyl Nuclear Power Plant (in former Soviet Union) became the World's
worst civil radiological accident, emitting large quantities of radioactive material. The White House designated
EPA as the leader in coordinating the U.S. response to this global emergency. EPA began monitoring and
assessing radioactivity in the United States, based in part on daily samples from its Environmental Radiation
Ambient Monitoring System (ERAMS). In addition, EPA dispatched response personnel to Europe to monitor
and assess the levels of radioactivity' in the Black Sea and Kiev Reservoir under a cooperative agreement with the
Soviet government.
c) Table 3 illustrates EPA concept of response in supporting another lead response agency.
This may include a nuclear facility licensed by the NRCom or an Agreement State, or a facility
owned or operated by DOD or DOE. During such incidents, EPA response activities include
environmental monitoring and assessment analyses and protective action guidance in support of
State and local governments and the LFA. EPA's response to Three Mile Island, an example of
this type incident, is summarized in Box 2-c.
Box 2-c: EPA Response to Three Mile Island Accident
The FRERP was not yet in place when the accident at the Three Mile Island nuclear power plant occurred in
1979. During the initial response, EPA deployed offsite radiation monitoring and assessment teams from its
labs, and provided onsite and Headquarters assistance to the Nuclear Regulatory Commission - the Lead Federal
Agency for the response. For eight years after the incident, EPA maintained a continuous environmental
radiation monitoring network in the area surrounding the plant. In 1988. Commonwealth of Pennsylvania took
over the responsibility of maintaining the permanent radiation monitoring network.
d) Table 4 illustrates EPA's response concept to nuclear sabotage and terrorism incidents.
These incidents represent complicating dimensions of the types of radiological emergencies, and
may warrant initialization of the CONPLAN, FRERP and NCP. CONPLAN invokes
coordination of the Federal response including EPA in support of the LFA; i.e, FBI. Whereas the
15
-------
FRERP would be used to coordinate consequence management activities under the lead of
FEMA. However, under both consequences and crisis management phases, the NCP would
govern specific field response and clean up activities by EPA in coordination with the FBI and
FEMA. Exercises Gauged Strength in 1998 and Mirrored Image in 1996, summarized in Box 2.d
below, exemplify this type of incident. The response activities undertaken for consequence
management are essentially the same whether the release resulted from an accidental or deliberate
act, since the response objective is the same - prevent, mitigate or contain a threatened or actual
release of radioactive material. For incidents involving improvised nuclear or radiation dispersal
devices, the response is further complicated by the magnitude of the threat and the need for
specialized technical expertise/actions.
Box 2-d: EPA Response to Terrorist Incidents
Several counter-terrorism exercises (including Mirrored Image, which was conducted in preparation for the
1996 Olympic Games in Atlanta. Georgia, and the 1998 "Gauged Strength" exercise) have provided EPA
the opportunity to examine its role in support of the FBI and FEMA in crisis and consequence
management, respectively. These exercises have validated the notion that EPA's traditional response
capabilities are well suited to responding to terrorist-related radiological incidents. EPA 's traditional
consequence management activities, were coordinated with the FEMA-led response, as in other radiological
emergencies warranting FREPxP response.
16
-------
Table 1. Releases1 Impacting One EPA Region (primarily non-FRERP response2)
EPA is notified and
evaluates release or
threat of release
EPA receives notice
from/through:
National Response
Center (NRC/
Response determination
EPA is the primary
Federal responder. and
tbeEPAOSC:
investigates and
Response preparation
When the need for EPA
response is established,
theOSC:
confers with
Response
implementation
EPA may act at state/
local governments'
request, or unilaterally in
order to fulfill its
statutory responsibility.
Response termination
The EPA OSC has the
discretionary authority to
terminate the response
when:
state/local responders,
designated HAZMAT
Team.
source owner/operator.
general public, and/or
other Federal agencies.
Where appropriate, EPA
may verify notice with:
state/local responders in
the source jurisdiction
other federal agencies
work with the
responsible party to
prevent mitigate or
control release.
determines actual.
potential or perceived
threat to public health or
welfare or the
environment,
establishes the type and
magnitude, quantity, and
source of the release,
consults with the
Regional Radiation
Program Manager
(RRPM) for expert advice
and radiation support,
and
determines the extent of
response consistent with
the methods and criteria
established in § 300.400
of the NCP. and plans the
federal response
accordingly.
RRPM/RERTCom.
plans the appropriate
level of activation
prepares the response
resources and capabilities
coordinates with
affected state/ local
governments
organizes various
response support teams
including EPA assets and
contractual support.
ensures that a worker
safety and health program
is in place at the response
site.
may establishes a joint
information center (JIC)
to convey information
about the response.
authorization of
appropriate Superfund
funding.
undertaking appropriate
CERCLA enforcement
actions.
At the scene, the EPA
OSC:
may establish a unified
command system.
directs and coordinates
all other response efforts
at the scene of release,
including, to the extent
practicable, collection of
pertinent facts about the
incident consistent with
the responsibilities
described in §300.120 of
the NCP.
manages Superfund
contractors to perform
cleanup activities
the release is stabilized,
as much as possible
considering the situation,
the emergency response
contributes adequately to
post removal site control;
the necessary post-
emergency response
actions are in place to
ensure the effectiveness
and integrity of the
response actions after the
completion of emergency
response.
1. For example, EPA response to Radium Chemical, illustrated in Box 2.A.
2. If FRERP activation is necessary, the OSC assumes the FRERP Commander role, implements the FRERP actions, activates the NCP/FRERP
special teams, as needed in coordination with OERR/ORIA, and activates DOE, DOD and/or NRCoin resources.
3. The NRC evaluates incoming information and immediately advises FEMA of a potential major disaster situation.
17
-------
Table 2: ReleaseJ Impacting Multiple EPA Regions (Assumed to be FRERP Response)
EPA is notified, and
evaluates release or
threat of release
Response
determination
Response preparation
Response
implementations
Response termination
EPA may receive notice
from:
NRC
International Atomic
Energy [IAEA]
DOS
responsible country
other federal agencies
including DOE. the
Nuclear Reg. Commission
media
others
*****
EPA may verify such
notification with:
IAEA
DOS
source Country
If FRERP response is
determined to address
multi-jurisdictional
releases, EPA (ORIA in
consultation with OERR2
and/or CEPPO3). may
activate the NICT4 to
provide support OSCs
and response teams.
*****
ORIA becomes the EPA
focal point for
coordination and
communication with
other organizations
internal and external to
EPA. and may activate
the EPA Emergency
Operation Center.
*****
EPA/ORIA is responsible
for:
assigning the FRERP
OSCom.
coordinating with
regional OSCs. OERR
and CEPPO.
facilitating availability
of radiological assets and
capabilities (e.g.. mobile
rad labs), and other such
federal resources.
coordinating with other
EPA offices and regions,
IAEA, and other federal
entities, and
providing infomiation
and responding to
inquiries from
public/congress! onal
inquiries.
****
In case of Presidential
Declaration of National
Disaster, a Federal
Coordinating Officer
(FCO) may be assigned
to coordinate all Federal
response, and OSCs
would coordinate through
the FCO.
When the emergency
requires a multi-agency
response and FRERP
activation, EPA as the
LFA, through
ORIA/RERT and the
OSCs, develop the
response measures,
including the PAGs and
radiological monitoring
and assessment.
*****
Where appropriate, the
EPA Administrator may
assign a SEPAO work
with the NICT, and other
teams - NRT, RRT,
RERT, in providing
respoase assistance.
In implementation of
FRERP response, ORIA
jointly with OERR and
OSCs and responses
coordinates EPA
radiological technical
support including OSCs.
assigns an RERT
Commander
(RERTCom)
assigns Scientific
Support Coordinators)
(SSCs)to assist and
provide scientific support
to OSC/ RERTCom.
*****
The response actions
would bo carried out
consistent with the
NCP/ESF #10, as
deemed appropriate.
if CERCLA site-specific
activities are necessary,
the OSC shall manage
such activities pursuant to
NCP under ORIA
coordination.
If multiple sites.
multiple OSCs may be
assigned, one for each
state.
OERR will support
ORIA Regions and OSC
with NCP response and
coordination activities.
OSC completes and
maintains documentation
of all actions taken under
the NCP to form the basis
of cost recovery.
EPA may terminate the
response when:
the emergency situation
is under
control/stabilized.
EPA's response
authority has been
fulfilled.
*****
OSC determines when .
individual site cleanups
are completed pursuant to
the NCP in consultation
with ORIA, the RRT and
others.
1. For example, EPA response to the Chomobvl Nuclear Power Plant illustrated in Box 2.B.
2. OERR (Office of Emergency & Remedial Response)
3. CEPPO (Chemical Emergency Preparedness nnd Prevention Office)
4. X1CT (National Incident Coordination Team)
18
-------
Table 3: Release from Sources1 Regulated by other Federal Departments/Agencies
EPA is notified and
evaluates release or
threat of release
Response determination Response preparation
Response
implementation
Response termination
EPA may receive notice
from:
National Response
Center (NRC/
state/local responders.
designated HAZMAT
Team,
source owner/operator.
general public, and/or
DOE.
DOD
National Aeronautics
& Space Administration
(NASA)
Nuclear Regulators'
Commission, and its
Agreement States
In the case of DOD or
DOE, the OSC from those
agencies shall Ir-
responsible for taking the
response action(s) as
directed in
§300.120(c)(l)and(d)
*****
Support response teams
may include: NRT, RRT,
RERT, USCG/NSF,
DOD and DOE. etc.
*****
In case of support
agencies involvement,
both lead and support
agency act consistent with
the notification and
assistance procedures
described in the N'CP and
FRERP
Assuming FRERP
response, the EPA OSC
will:
coordinate the EPA non-
radiological response in
accordance with NCP
applicable provisions,
monitor and support the
response activities,
place the RERT in
charge of radiological
action in support of other
Federal agencies
serve as a source of
information for onscene
conditions, advising/
reporting to other federal
agencies. -
*****
The OSC may engage
special support and expert
assistance to include
Scientific Support
Coordinators (SSCs),
designated to
communicate relevant
scientific information
*****
In case of a Stafford Act
declaration, the EPA
coordinates with the
Federal Coordinating
Officer (FCO), in
coordinating and directing
emergency assistance and
relief to impacted
jurisdiction.
*****
Response actions
involving nuclear
weapons are conducted in
accordance with the joint
DOD, DOE. and FEMA
Agreement for Response
to Nuclear Incidents and
Nuclear Weapons
Significant Incidents
(Jan.8, 1981)
In this c;ise, EPA supports
and assists Federal, State,
and local governments at
their request, consistent
with the Emergency
Support Function #10
(ESF-10).oftheFRPand
FRERP.
*****
EPA's assistance
includes:
providing field
monitoring and
assessment,
providing environmental
and water supply
monitoring.
recommending
protective actions,
participating with Dept.
of Agriculture and
Human Health Services
on the Advisory Team.
and
assessing the
consequences of
radioactivity releases to
the environment.
EPA may terminate its
response when:
the emergency situation
is stabilized, and/or
the threat has been
addressed.
*****
During all phases of
response, EPA responders
complete and maintain
documentation of all
actions taken under the
NCP to form the basis of
cost recovery.
1. For example. EPA response to the Three Mile Island nuclear power plant regulated by the Nuclear Regulatory Commission, illustrated in Box 2.C.
2. The NRC evaluates incoming information and immediately advises FEMA of a potential major disaster situation.
19
-------
Table 4: Releases from Terrorist Incidents1
How EPA receives and
evaluates release or
threat of release
Response determination Response preparation Response
implementation
Response termination
During the crisis
management, the Federal
Bureau of Investigation
(FBI) is responsible for
notifying the relevant
agencies.
*****
During the consequence
management, the Federal
Emergency Management
Agency (FEMA) is
responsible for notifying
the relevant
agencies/departments.
Including EPA. DOD,
DOEandHHS.
For terrorist incidents, the
EPA supports the FBI
during crisis management
and FEMA during the
consequence management
phase.
*****
As his or her capacity, the
EPA-OSC evaluates the
release to determine:
the size of the release,
the character of the
release, and
the nature of the threat
to public health, or
welfare of the US. ,and
address all pans of the
national response strategy
concurrently, giving
safety and stabilization
the highest priorities.
Onscene, the EPA
integrates its command
post in the existing
Incident Command
System (ICS).
OR
MayusetheISC/UC .
structure to establish an
emergency response
management
organization.
*****
For incidents involving
nuclear elements, the
OSC works closely with
ORJA in managing and
coordinating EPA
response. ORIA, through
the RERT, may provide:
onsite radionuclides
monitoring and analysis,
radiation health physics
and risk assessment, and
can also provide onsite
mobile laboratory for
sampling and analyses.
The FBI is responsible for
managing and directing
the support agencies
response.
*****
The EPA OSC will
activate the NCP
contractual response
operations in accordance
with the situation at hand.
*****
During the transition
period from crisis to
consequence management
phase, the Attorney
General hands off to the
Director of FEMA
responsibilities for
consequence management
actions.
Termination of the
response is determined by
theFBI/FEMAin
consultation with
supporting agencies.
*****
The lead agency and EPA
OSCs complete and
maintain documentation
of all actions taken.
1. For example. EPA participation as a support agency to the FBI during the 1994 Olympics in Atlanta, GA. illustrated in Box 2.D.
20
-------
2.4 Response Coordination
Figure 1 below depicts the lead within EPA for coordination of a radiological response.
The response coordination is presented as a dual function involving management and support
roles determined by the magnitude of the incident or emergency. The Regions have the
responsibility and authority to take emergency response actions deemed appropriate and
consistent with the NCP. However, some response actions may go beyond the regional
preparedness, capabilities and assets, warranting Headquarters involvement.
Headquarters Lead. For radiological incidents impacting one or more EPA Regions, ORIA in
collaboration with OERR and other offices internal and external to EPA, leads the response
coordination activities including mobilization of the radiological response teams and assets.
ORIA's coordination will focus on mobilization of the RERT, Advisory Teams, the Scientific
Support Coordinators (SSCs), and the Regional Radiation Program Managers (RRPMs).
However, individual sites within each Region shall be managed under the direction and authority
of the EPA/Federal OSC, as appropriate.
In the event of a radiological incident or release that crosses regional boundaries or that
overwhelms the regional response capability, or if there is a significant threat to population or
potential large damage to property or natural resources, ORIA, as a member, will assume primary
responsibility for activating, convening and coordinating the National Incident Coordination Team
(NICT) activities.
Regional Lead. For incidents impacting only one EPA Region, the regional response program
as the lead response agency will assume the lead for coordinating and managing the response
actions. In which case, the regional program office will assign an OSC to direct and manage EPA
response operations. The OSC also determines the need to convene the NRT/RRT through the
NCP authorities. The RRPM supports the OSC, and may assume the Scientific Support
Coordinator (SSC) role providing radiological expertise in consultation with ORIA and the
RERT.
For non-EPA, FRERP responses, national and regional coordination will involve the
respective regional and Headquarters program staff jointly providing EPA radiological support to
the LFA. The criteria for OSC-regional lead and the need for the NRT to convene are governed
by the NCP.
21
-------
o
a
H)
in
O
O.
CS
fv
JO
"o
'3
es
Oi
.£P
r Non-EPA Incidents |
eg
T3
g
to
c
o
'3
S
ng Multipl
*^j
u
§
£
w
1
o
2
c§
o
S
§
jr Incident Impacting One EPA Regi
eS
T3
cs
5
C
.2
tj
3
lE
i
8
Q
.
O
o<
ix
w
u
w
o
T-j
, in collaboration wii
<
2
o
-Scene Coordinator (OSC):
e
O
o.
UJ
e
0
o.
en
<2
NRCom (FBI for
terrorist) coordinate
her Hqs offices:
"o
a
CM
CO
assumes the On-Scenc Commander
*
c
u
E
cc
5
s
the response thai
Unified Command
o
en
0 0
ll
A-FRERP
major natic
cu
U3 -S
<2?
"O en
cs -s
S
S "
J
(OSCom) role,
is the lead federal official for CERC1
System (UCS).
^
he case wit
^-
global impacts as
Chcrnobvl.
FRERP response, responsible for
managing incidents with localized
EPA-OSC monitors
the response.
.
Is
P OSCom i
oordinatiol
d "
assumes the FRE1
is responsible for
a
impacts within respective EPA regie
and
EPA Regions and
*
_o
1
1.1
do
C/l Ci
radiological asset
is supported by r<
*
is supported by ORIA and/or RRPM
Hqs support LFA as
requested.
programs.
RRPM and ORIA
coordinate EPA
. -
a
CC
CS gJ
w r^
ll
"^
ORIA coordinate;
including RERT,
RRPMs provide scientific support
coordinators (SSCs) supporting the
CO
c -e
8-1
en CLt
&. 00
radiological support
to FRMAC, and
<-
s with ORI
«4
SSCs.
RRPMs coordinal
o
regional OSCs - CERCLA response
The ORIA coordinates mobilization
Advisory Teams to
LFA.
RRPM and ORIA
may be supported by
regional Superfund
personnel as
.
a
the RERT and radiological assets an
capabilities.
1
e
a,
3
'
a,
-------
2.5 Response Termination and Recovery -K-
On an incident-specific basis, EPA is responsible for determining when to terminate the
response. The following criteria provide the basis for such determination.
the situation is stabilized,
its statutory responsibilities have been fulfilled,
other federal assistance is available, or
EPA determines that its assistance is no longer required.
Prior to discontinuing its response operation, EPA will discuss its action with the State
and local governments, the LFA, and FEMA, if applicable. Should EPA be managing the
FRMAC, EPA will consult with the LFA, FEMA, other participating Federal agencies, and State
and local officials to determine when a formal FRMAC structure and organization is no longer
required. Normally, this will occur when operations move into the recovery phase and extensive
Federal multi-agency resources are no longer required to augment State and local radiological
monitoring and assessment activities.
The State or local governments have the primary responsibility for planning the recovery
of the affected area. (The term recovery, as used here, encompasses any action dedicated to the
continued protection of the public and resumption of normal activities in the affected area.)
Recovery planning will be initiated at the request of the State(s), but generally will not take place
until after the initiating circumstances of the emergency have stabilized and immediate actions to
protect public health and safety and property have been accomplished. The EPA will, on request,
assist the State and local governments in developing off-site recovery plans prior to deactivatiori
of the response. The LFA will coordinate the overall activity of Federal agencies involved in the
recovery process.
The radiological monitoring and analysis activities will be terminated when the EPA, after
consultation with the LFA and other participating Federal agencies and State and local officials,
determines that:
there is no longer a threat to the public health and safety or to the environment,
state and local resources are adequate for the situation, and
there is mutual agreement of the agencies involved to terminate the response.
23
-------
3. EMERGENCY PREPAREDNESS AND ADMINISTRATION
3.1 Preparedness
EPA stands ready 24 hours a day to respond quickly to protect the public and the
environment whenever a hazardous substance including radionuclides is released. The
responsibility for EPA's national preparedness to respond to environmental incidents and
emergencies is divided up among three headquarters organizations and the 10 EPA Regions.
Radiological emergency preparedness is a primary responsibility of ORIA, whereas preparedness
for oil and hazardous substance emergencies is the responsibility of the Chemical Emergency
Planning and Prevention Office (CEPPO) and Office of Emergency and Remedial Response
(OERR), and their regional program counterparts. The EPA Regions may operate autonomously
and somewhat independently of headquarters; however, they collaborate with headquarters during
many of the emergency response preparedness and operations. Both headquarters and regional
offices maintain a mutual core of responsibilities augmenting one another in time of need.
EPA Regions are delegated the programmatic authority to manage as well as to plan
emergency responses, and are provided with funding allocations accordingly. Each EPA Region
is primarily responsible for EPA's emergency response resources, procedures, plans, functions
and activities necessary for addressing all emergencies, in accordance with respective regional
priorities and needs. Specifically, EPA Regions:
are delegated the Superfund funding authority, and the regulatory authority and
responsibility to conduct EPA emergency responses and Superfund cleanups,
are responsible for developing regional radiation programs, and for predesignating
federal OSCs,
are responsible for up-front planning of their radiological response resources and
operations including the standing committees, Regional Response Teams, and Area
Committee as appropriate,-and
have contracting authority for emergency response and Technical Assistance
Contracts, and Special Support Teams.
ORIA in the Office of Air and Radiation (OAR), is responsible for maintaining a state of
readiness to respond to radiological incidents and emergencies. ORIA's preparedness measures
include:
coordinating emergency preparedness activities with other Federal and state/local
agencies,
maintaining the EPA-RERP and developing implementation procedures,
maintaining a radiation emergency response team capable of promptly and
effectively responding as mandated in this plan to foreseeable radiological
emergencies,
24
-------
identifying key RERT roleSj identifying personnel competent to fill these roles, and
providing adequate training both for these and for anticipated replacement
personnel in a timely manner,
procuring and maintaining RERT equipment and vehicles, including upkeep and
calibration of instruments and maintenance of up-to-date records of equipment
inventories and status,
developing and updating emergency response monitoring, laboratory, and
assessment methods and equipment to enhance the RERT effectiveness,
developing protective action guidance (PAG), and
performing resource assessments.
CEPPO is responsible for the overall coordination of national security, domestic and
international terrorism, and emergency preparedness for the EPA; in that capacity it provides the
Emergency Coordinator, Deputy Emergency Coordinator, Chair for the National Oil and
Hazardous Substance Response Team, and Emergency Operations Center for the Agency.
Additionally ,CEPPO provides leadership for the National Incident Coordination Team (NICT),
which is EPA's intra-agency team organized to deal with regional requests for support/assets and
policy coordination during significant emergency events. The NICT may also provide guidance to
the Regional Response Teams and Area Committees, on incident-specific basis.
OERR is the national domestic emergency response program office. OERR oversees
CERCLA removal policy and procedures as well as the national domestic emergency response
program. The EPA domestic emergency response program is implemented via delegated response
authorities from the Administrator to the EPA Regions and OSCs. OERR provides the EPA
Regional arid Headquarters Offices, U.S. Coast Guard, District Offices, other local, state and
federal Agencies and foreign governments, technical assistance in responding to environmental
emergencies such as oil spills and hazardous substance releases and in assessing and cleaning up
hazardous waste sites.
Together, ORIA, CEPPO, OERR and the 10 Regions are responsible for overseeing and
implementing EPA's commitments regarding preparedness and response and for natural and
technological disasters addressed in the FRP, FRERP and NCP. In that capacity, these
organizations are also responsible for providing programmatic guidance and policy directives to
the regional and field offices, and facilitating coordination with other federal departments and
agencies' headquarters and operation centers. All organizations, jointly and/or individually,
collaborate with other response entities to maintain the Agency readiness to respond, and provide
support to state and local governments and other Federal agencies.
25
-------
3.2 Implementing Plans and Procedures
Plans and procedures for implementation of the EPA-RERP should be developed by each
office and region, and made available to the federal, State, local government and Indian Tribes
emergency response communities, and disseminated to EPA headquarters and regional staff, and
members of the EPA emergency response teams. QRIA maintains up-to-date copies of all
implementation documents which define the duties and responsibilities of emergency response
personnel for each EPA organization as defined in the EPA-RERP. Each EPA office will
promptly notify ORIA of any changes in their applicable procedures.
The NCP serves as the basis for planning and utilization of Federal resources when
responding to releases or threats of radiological releases. Response actions under the EPA-
RERP will follow the policies, procedures, directives and guidance developed to carry out the
provisions contained in the NCP and other recognized rules and regulations, so that responses are
consistent with the NCP.
As necessary, ORIA will update the emergency preparedness and response guidance,
including the EPA-RERP, in order to reflect recent experience, and to provide a harmonized set
of emergency preparedness documents and opportunities for training. This will be accomplished
by revising the Agency guidance on the technical and programmatic elements of emergency
response, and developing practices that can be used to apply the procedures immediately. ORIA
will also conduct training workshops on best practices, and utilize the updated material as a basis
for technical cooperation/assistance efforts to enhance the emergency response capability of
States, local governments and Indian Tribes.
Implementing procedures should be reviewed every two years and revised as necessary to
incorporate changes to federal emergency response plans, the EPA emergency response mission,
plans and procedures, or lessons learned from training exercises. As a minimum, implementing
procedures/guidance should cover the following:
training and exercises
concept of operations
radiological assessment capabilities
notification and communication requirements
EPA personnel emergency response duties
medical surveillance
protective actions recommendations
long-term environmental monitoring
The EPA-RERP will be maintained under the direction of the Director of the Office of
Radiation and Indoor Air (ORIA), in consultation with the Office of Emergency and Remedial
Response (OERR), Chemical Emergency Preparedness and Prevention Office (CEPPO), and
26
-------
other members of the NICT. Each office should maintain a controlled distribution list for all
procedures developed to implement the requirements of the RERP. This distribution list should
be reviewed periodically to ensure that it remains up to date.
EPA Headquarters will develop, maintain, and distribute a "Policies and Procedures
Manual for the implementation of the EPA-RERP that will document the applicable operations
and procedures for this Plan (such as national-level policies) that are not covered in the
FRERP/NCP or other authoritative documents. When published, this manual will be an appendix
to the EPA-RERP. :
3.3 Training
Offices within EPA that have a significant role in responding to radiological incidents and
emergencies may develop and conduct training courses to ensure the readiness and competence
of the various agency response organizations. Such training should be conducted by personnel
experienced in radiological emergency response management, to provide detailed instructions
relevant to the position in which staff are employed or expected to be employed during any given
incident. The training may be conducted by EPA staff, other federal agencies/departments, or
private contractors. ORJA will maintain on an ongoing basis, a list of available training
workshops, seminars and courses.
At a minimum, ORIA will develop training program(s) to ensure that Agency emergency
response personnel are able to respond effectively to all types of radiological/nuclear emergencies.
ORIA will offer fundamental training classes and workshops, and may collaborate with others on
specific training activities. Training activities will be planned annually, offered as frequently as
allocated resources would permit, and will include the following topics relative to radiological
response plans, procedures, and equipment: .
federal emergency response planing,
procedures for using radiation monitoring equipment;
notification and communications requirements;
exposure reduction and hazard mitigation techniques; and
emergency dose limits.;
This training may be conducted by EPA, other federal departments/agencies, or their contractors.
ORIA will maintain a list of training classes or courses, and training programs.
Radiological emergency field responders must have successfully completed this training
program within a satisfactory period of time upon employment or before assignment that calls for
emergency response duties. Less experienced workers should not be assigned unsupervised
positions or activities. Seasoned employees should be encouraged to attend refresher courses to
maintain a maximum level of readiness and competency. Successful completion of radiological
27
-------
response training coureses should be reported to ORIA for record keeping and monitoring of the
staff readiness and capabilities to respond. ORIA will also develop indicators for the EPA
radiological training program consistent with the agency's overall goals for achieving exemplary
preparedness.
3.4 Drills and Exercises
Drills and exercises will cover a full range of response actions, and will involve the EPA
teams and participants from States and local governments, other federal agencies, and foreign and
international organizations, where appropriate. ORIA will take the lead for coordinating the
development and implementation of exercises and drills with CEPPO, OERR, field offices, and
other appropriate organizations. ORIA will also document and issue after action reports to reflect
participants'feedback, lessons learned, and exercise evaluation. These reports will be made
available and disseminated to interested parties. The lessons learned during these exercises help
the agency to focus its mission and objectives and streamline its radiological emergency response
program, modify operational procedures, and rectify response weaknesses.
The RERT members are periodically deployed to the site of an exercise. If possible, drills
and exercises should be timed to correspond to selected exercises of emergency response plans
conducted by Federal, State, Tribal, and/or local agencies. A separate training procedure will be
established detailing RERT qualification requirements, recurring training or retraining
requirements, exercise participation requirements, physical requirements, annual medical exams,
and member replacement criteria.
Additionally, the EPA in conjunction with State and local government, exercises the
FRERP, and coordinates its exercises with the Federal Radiological Preparedness Coordinating
Committee's (FRPCC's) Subcommittee on Federal Response to avoid duplication, and to invite
participation by other Federal agencies. Members of the senior, executive and upper
management will be invited to participate in these exercises. Where appropriate, ORIA assists
other Federal agencies and State and local governments with planning and training activities
designed to improve response capabilities.
3.5 Resource Assessment
A frequent review of the Agency's radiation resources should be conducted to examine,
evaluate and determine the level of radiological emergency preparedness needs, and establish
future planning requirements. ORIA will coordinate with OERR and CEPPO, a resource
assessment once every two years. A separate Assessment Procedure will be established and will
ensure comprehensive evaluation of the EPA radiological emergency response program. Review/
evaluation activities will address, at a minimum, the following:
28
_
-------
Organization and Management g ;,
Plans and Procedures
Training, Drills, and Exercises
Facilities, Equipment, and Resources
Accident Assessment
Notification and Communication
Personnel Needs and Protection
Public Information and Stakeholders Outreach
3.6 Plan Maintenance and Update
Plans and applicable procedures referenced in the EPA-RERP should be reviewed every
two years to determine currency and applicability. Response organizations involved in
radiological emergencies should document and report lessons learned from training, exercises and
drills. ORIA in consultation with OERR and CEPPO, will take the lead in coordinating further
review and revisions of radiological response plans, procedures and training programs, and for
addressing comments and discussion resulting from this process. Also, ORIA will maintain
control and distribution of the EPA-RERP, and will review it as necessary.
29
-------
-------
ANNEX A: AUTHORITIES
STATUTES, AGREEMENTS, MEMORANDA OF UNDERSTANDING, EXECUTIVE
ORDERS AND PRESIDENTIAL DECISION DIRECTIVES
The following Statutes, Agreements, Memoranda of Understanding, Executive Orders and
Presidential Decision Directives govern the EPA response to a radiological incident:
1. The Atomic Energy Act (AEA) of 1954, as amended, 42 USC 2011-2296; Reorganization
Plan no. 3 of 1970.
2. Robert T. Stafford Disaster Relief & Emergency Assistance Act (Public Law 93-288, as
amended).
3. National Oil & Hazardous Substances Pollution Contingency Plan (NCP), 1994.
4. Public Health Service Act, as amended, 42 USC 241 et seq. (1970).
5. Clean Water Act (CWA), as amended, 33 USC 1251 et seq. (1972).
'6. Oil Pollution Act of 1990 (OPA).
7. Safe Drinking Water Act Amendments of 1996 (SDWA).
8. Comprehensive Environmental Response, Compensation, and Liability Act of 1980,
(Public Law 96-510), as amended by the Superfund Amendments and Re-authorization
Act of 1986 (SARA), (Public Law 99-499).
9. Clean Air Act (CAA), as amended, 42 USC 7401 et seq. (1990).
10. International Atomic Energy Agency's "Convention on Early Notification of a Nuclear
Accident," and "Convention on Assistance In the Case of a Nuclear Accident or
Radiological Emergency" (1986).
11. Memorandum of Understanding Between EPA and the Department of the Air Force
(DAF); Department of Energy (DOE); Department of Health, Education and Welfare,
Food and Drug Administration (FDA); Department of Commerce, National Oceanic and
Atmospheric Administration (NOAA); Nuclear Regulatory Commission (NRC); and
Department of Transportation, Federal Aviation Administration (FAA) Concerning the
Federal Response to Radioactive Contamination from Specified Foreign Nuclear
Detonations (1979).
12. Assignment of Emergency Preparedness Responsibilities, Executive Order 12656 (1988).
13. Presidential Decision Directive No. 39 (classifiedSECRET), 1995.
14. Executive Order 12148, Federal Emergency Management, July 1979.
15. Presidential Decision Directive No. 62, Combating Terrorism, May 1998.
16. Presidential Decision Directive No. 63, Protecting America's Critical Infrastructures,
May 1998.
17. 44 Code of Federal Regulations, part 351, Radiological Emergency Planning and
Preparedness.
18. Executive Order 12656, Assignment of Emergency Preparedness Responsibilities,
November 18, 1988, 3 CFR, 1988, Comp., p. 585.
A-l
-------
-------
ANNEX B: EPA-RERP RELATIONSHIP TO OTHER PLANS
Within the Federal government, numerous plans, and programs outline responsibilities
for response and/or preparedness activities for radiological incidents or emergencies at the
national or international level. These include the Federal Response Plan, the Federal
Radiological Emergency Response Plan, and the National Contingency Plan.
1. National Oil and Hazardous Substances Pollution Contingency Plan
NCP Purpose. As required by section § 105 of CERCLA, and amended by the SARA, and by
§311 (d)(l) of the Clean Water Act, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 CFR Part 300, provides the regulatory provisions for emergency
response, and response organizational structure, procedures, and enforcement. Depending on the
nature of the release, the NCP assigns emergency response responsibilities to EPA, the
U.S. Coast Guard (USCG), DOE, or DOD, as appropriate. The NCP also assigns the OSC to
manage and coordinate the emergency response.
NCP OSC. The NCP OSC is a federal official predesignated by EPA for inland areas and by
the Coast Guard for Coastal areas. The OSC coordinates all containment, removal and disposal
efforts and resources during an incident. These include federal, state, local and responsible party
efforts. The OSC has access to the special forces when warranted, to support response efforts.
The OSC can also be a source of valuable support and information to the local response
community. In the case of EPA's response activities, the OSC is assigned to manage and
coordinate the emergencies, and to identify the requirements for funding, preparing and
responding to releases of oil, hazardous substances, pollutants, and/or contaminants.
NCP Scope. NCP response provisions are regulations governing EPA response to releases of
hazardous substances, including radionuclides. The NCP is applicable to EPA response
activities under all circumstances including EPA LFA FRERP responses and supporting most
other Federal LFA-FRERP emergency response activities. NCP Section 300.130(f) adopts
FRERP notification and assistance procedures requirements for both lead and support agency
activities, among the Federal family and when providing assistance to the state and local
government. Because the NCP applies, EPA can expend Superfund monies, and can invoke
CERCLA enforcement authorities. CERCLA ARARs and permit waiver provisions also apply,
as appropriate.
NCP Limitations. There are two important circumstances where CERCLA and, therefore, the
NCP do not apply. The NCP does not apply to certain releases of nuclear material from
NRCom- licensed nuclear reactors. Specifically, the NCP does not apply to releases of source,
byproduct, or special nuclear material during incidents subject to NRCom's requirements for the
financial protection of Section 170 of the AEA. Nuclear reactors are the only facilities currently
subject to NRCom's Price Anderson Act (AEA Section 170) requirements. This exemption is
very narrow (exempts from CERCLA), and only covers certain releases from NRCom or
B-1
-------
ANNEX B: EPA-RERP RELATIONSHIP TO OTHER PLANS
Within the Federal government, numerous plans, and programs outline responsibilities
for response and/or preparedness activities for radiological incidents or emergencies at the
national or international level. These include the Federal Response Plan, the Federal
Radiological Emergency Response Plan, and the National Contingency Plan.
1. National Oil and Hazardous Substances Pollution Contingency Plan
NCP Purpose. As required by section § 105 of CERCLA, and amended by the SARA, and by
§311 (d)(l) of the Clean Water Act, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 CFR Part 300, provides the regulatory provisions for emergency
response, and response organizational structure, procedures, and enforcement. Depending on the
nature of the release, the NCP assigns emergency response responsibilities to EPA, the
U.S. Coast Guard (USCG), DOE, or DOD, as appropriate. The NCP also assigns the OSC to
manage and coordinate the emergency response.
NCP OSC. The NCP OSC is a federal official predesignated by EPA for inland areas and by
the Coast Guard for Coastal areas. The OSC coordinates all containment, removal and disposal
efforts and resources during an incident. These include federal, state, local and responsible party
efforts. The OSC has access to the special forces when warranted, to support response efforts.
The OSC can also be a source of valuable support and information to the local response
community. In the case of EPA's response activities, the OSC is assigned to manage and
coordinate the emergencies, and to identify the requirements for funding, preparing and
responding to releases of oil, hazardous substances, pollutants, and/or contaminants.
NCP Scope. NCP response provisions are regulations governing EPA response to releases of
hazardous substances, including radionuclides. The NCP is applicable to EPA response
activities under all circumstances including EPA LFA FRERP responses and supporting most
other Federal LFA-FRERP emergency response activities. NCP Section 300.130(f) adopts
FRERP notification and assistance procedures requirements for both lead and support agency
activities, among the Federal family and when providing assistance to the state and local
government. Because the NCP applies, EPA can expend Superfund monies, and can invoke
CERCLA enforcement authorities. CERCLA ARARs and permit waiver provisions also apply,
as appropriate.
NCP Limitations. There are two important circumstances where CERCLA and, therefore, the
NCP do not apply. The NCP does not apply to certain releases of nuclear material from
NRCom- licensed nuclear reactors. Specifically, the NCP does not apply to releases of source,
byproduct, or special nuclear material during incidents subject to NRCom's requirements for the
financial protection of Section 170 of the AEA. Nuclear reactors are the only facilities currently
subject to NRCom's Price Anderson Act (AEA Section 170) requirements. This exemption is
very narrow (exempts from CERCLA), and only covers certain releases from NRCom or
B-2
-------
ANNEX B: EPA-RERP RELATIONSHIP TO OTHER PLANS (cont.)
* '? '' .
Agreement State licensed nuclear reactors. The vast majority of NRCom licenses are not exempt
from CERCLA.
In addition, CERCLA and the NCP do not_apply to certain releases from uranium mill
tailings sites designated under §102(a)(l) or 302(a) of the Uranium Mill Tailings Radiation
Control Act of 1978. Both of these exemptions are established in CERCLA Section 101(22),
under the definition of release. Not coincidentally, Congress provided funding from other
sources to address such releases. [Source material is defined as (1) natural uranium, thorium, or
any combination thereof or (2) ores which contain 0.05 percent or more (by weight) of uranium
or thorium. Byproduct material is (1) any material made radioactive by exposure to radiation in
the process of producing or using special nuclear material or (2) the wastes produced by the
extraction or concentration of uranium or thorium from ore. Special nuclear material is defined
as plutonium, or uranium enriched in 'the U-235 or U-238 isotope.]
NCP Reporting Requirements. Private parties including industry, governmental, non-
governmental organizations and citizens, are required to report releases of hazardous substances
in excess of reportable quantities to the National Response Center. For radionuclides the
reportable quantity is units of activity (curies), as identified in 40 CER, Part 302, reportable
quantities for radionuclides (Federal Register May 24, 1989). This does not limit in any way
EPA's ability to respond to a release of any amount of radiological material which poses a threat
to public health, welfare or the environment. The reporting requirements also do not apply to
radioactive releases that are in compliance with a legally enforceable license, permit, regulation,
or order issued pursuant to the AEA. However, any release that is above the federally permitted
level by an amount equal to the reportable quantity units (as established in Appendix B, Table
302.4, of 40 CFR Part 302.4) would be subject to the CERCLA notification requirements.
NCP-FRERP Provisions. If a discharge or release involves radioactive material, the NCP
requires, when appropriate, that Federal agencies act in accordance with the notification and
assistance procedures contained in the FRERP. Section 300.130 (f) of the NCP states that
"Where appropriate, when a discharge or release involves radioactive materials, the lead or
support federal agency shall act consistent with the notification and assistance procedures
described in the appropriate Federal Radiological Plan. For the purpose of the NCP, the Federal
Radiological Emergency Response Plan (FRERP) is the appropriate plan. Most radiological
discharges and releases do not result in FRERP activation and should be handled in accordance
with the NCP..."
Federally Permitted Releases. Federally permitted releases are exempted from CERCLA
reporting and liability (enforcement) provisions. However, Federally permitted releases are not
exempted from CERCLA response activity, but response costs for such response actions are
generally not recoverable. This exemption is sometimes misunderstood. CERCLA Section
B-:
-------
ANNEX B: EPA-RERP RELATIONSHIP TO OTHER PLANS (cont.)
101(10), the definition of Federally permitted release, provides that CERCLA does not apply to
legally enforceable license, permit, regulation or order issued pursuant to AEA. This exemption.
only applies to the "permitted" level of radiation cited in the permit, license, etc. Releases of
quantities, levels, concentrations, and kinds of radiative materials from such a facility which are
above permitted levels, or are not specifically permitted, are subject to CERCLA response
actions and cost-recovery. [This is no different from hazardous releases permitted by NPDES.]
Releases ofNRCom Licensed Nuclear Material are Subject to CERCLA/NCP Authority.
Releases ofNRCom licensed material, unless it is from an NRCom licensed Nuclear reactor, are
subject to CERCLA and the NCP. However, NRCom or the Agreement State should seek to
enforce NRCom regulations before EPA utilizes NCP authorities.
Superfimd Dollars Can not be Expended on DOD & DOE Materials. EPA will not expend
Superfund monies to address releases of DOE and DOD radiological material. Both the NCP
and Executive Order 12580 mandate DOE and DOD to provide their own OSCs. DOD and DOE
are also PRPs for releases from their own facilities. Such cleanups must be funded by DOE and
DOD. Pursuant to the NCP, EPA may expend Superfund monies to address a releases of NASA
materials in an emergency, but NASA should pay for such cleanups, and is FRERP LFA.
2. Federal Response Plan (FRP)
The Robert T. Stafford Disaster Relief and Emergency Assistance Act provides authority
for the Federal government to respond to disasters and emergencies in order to provide assistance
to save lives and protect public health, safety, and property. The Federal Response Plan (FRP)
establishes the basic mechanisms and structures for provision of Federal assistance to a State and
its affected local governments impacted by a catastrophic disaster or emergency situation.
Twenty seven (27) departments and agencies are signatories to the FRP, they are as follows.
1. Dept. of Agriculture
2. Dept. of Commerce
3. Dept. of Defense
4. Dept. of Education
5. Dept. of Energy
6. Dept. of Health & Human Services
7. Dept. of Housing & Urban Development
8. Dept. of the Interior
9. Dept. of Justice
10. Dept. of Labor
11. Dept. of State
12. Dept. of Transportation
13. Dept. of the Treasury
14. Dept. of Veteran Affairs
15. Agency for International Development
16. American National Red Cross
17. Environmental Protection Agency
18. Federal Communication Commission
19. Federal Emergency Management Agency
20. General Services Administration
21. Interstate Commerce Commission
22. National Aeronautics & Space Administration
23. National Communications System
24. Nuclear Regulatory Commission
25. Office of Personnel Management
26. Tennessee Valley Authority
27. U.S. Postal Service
Signatories to the Federal Response Plan
B-4
-------
ANNEX B: EPA-RERP RELATIONSHIP TO OTHER PLANS (cont.)
FRP Purpose. The FRP is based on the fundamental assumption that a significant disaster or
emergency will overwhelm the capability of State, Tribal, and local governments (hereafter
referred to as State and local governments) to carry out extensive emergency operations.
Consequently, resources of Federal departments and agencies, which are grouped into
Emergency Support Functions (ESF's), are used to provide Federal response assistance to the
State. Box B.I below lists the twelve ESF's delineated in the April 1992 version of the FRP.
New annexes specifically covering radiological emergencies and terrorist incidents are currently
proposed for the next revision of the FRP.
FRP Annexes. One of the proposed new annexes, Radiological Emergencies, will describe the
concept of operations for providing Federal assistance under the Stafford Act to State and local
governments in response to a radiological emergency. Additionally, it will describe the
relationship between the FRP and the Federal Radiological Emergency Response Plan (FRERP).
FEMA will employ this new annex to coordinate with the affected States the use of Federal
resources for situations in which the President determines that additional Federal assistance is
required to satisfy unmet needs of the State. FEMA would be responsible for coordinating non-
radiological support using the structure of the FRP.
Box B. 1 - Emergency Support Functions and Primary Agencies
Emergency Support Function
Primary Agency
ESF #1-Transportation ....Department of Transportation (DOT)
ESF # 2 - Communications .National Communications System
ESF # 3 - Public Works and Engineering1 Department of Defense (DOD)
US Army Corps of Engineers
ESF #4 - Firefighting1 ....US Department of Agriculture (USDA)
US Forest Service
ESF #5 - Information and Planning1... Federal Emergency Management Agency (FEMA)
ESF #6 - Mass Care American Red Cross
ESF #7 - Resource Support General Services Administration (GSA)
ESF #8 - Health and Medical Services Department of Health and Human Services
(HHS), US Public Health Service
ESF #9 - Urban Search and Rescue DOD
ESF #10 - Hazardous Materials Environmental Protection Agency (EPA)
ESF #11 - Food USDA
ESF #12 - Energy Department of Energy (DOE)
Other Annexes to the FRP:
Radiological Emergencies2 Lead Federal Agency
Terrorist Incidents Federal Bureau of Investigation (FBI) or FEMA
1 EPA supports the primary department/agency for these ESFs
2 The Lead Federal Agency (LFA) will be determined in accordance with the requirements of the FRERP
B-5
-------
ANNEX B: EPA-RERP RELATIONSHIP TO OTHER PLANS (cont.)
FRP Coordination. Under the provisions of the Stafford Act, the President will appoint a
Federal Coordinating Officer (FCO) as his representative to coordinate the overall delivery of
Federal assistance. Federal departments and agencies will provide response assistance directly to
the State, under the overall direction of the FCO. Should there be a Presidential decision not to
declare an emergency, the authorities of the Stafford Act do not pertain; FEMA and ESF primary
agencies may not use those authorities to task other Federal agencies or to access Federal
resources to provide assistance without a Presidential declaration. In this case, Federal agencies
will respond in accordance with their own statutory and funding resources. The FRP will be
used to supplement, not supplant, the provisions of the FRERP, which was developed under
department and agency statutory authorities other than the Stafford Act.
3. Federal Radiological Emergency Response Plan (FRERP)
FRERP Purpose. The Federal Radiological Emergency Response Plan (FRERP) establishes
an organized emergency response capability for timely, coordinated action by Federal agencies to
assist State and local governments in a peacetime radiological emergency. The FRERP describes
the capabilities, responsibilities, and authorities of Federal agencies and a concept for integrating
the activities of these agencies .to protect public health and safety. However, the FRERP
recognizes the role of State and local governments to determine and implement any measures to
protect life, property, and the environment in areas not under the control of a Federal agency.
FRERP Scope. The FRERP covers any peacetime radiological emergency 'that has or is
expected to have a significant radiological effect within the U.S., its territories, possessions, or
territorial waters and that could require a Federal multi-agency response. Emergencies occurring
at fixed nuclear facilities or during the transportation of radioactive materials, including nuclear
weapons, fall within the scope of the FRERP regardless of whether the facility or radioactive
materials are publicly or privately owned, Federally regulated, regulated by an Agreement State,
or not regulated at all. The FRERP covers the total Federal response, with emphasis on the "off-
site" area, or that area beyond the immediate site of the emergency.
FRERP Provisions. The FRERP does not alter the authorities or responsibilities ascribed to any
agency on a day-to-day basis. The FRERP is an interagency agreement written in the form of a
plan and has no statutory authority of its own. Each signatory agency uses its own authorities
when implementing a FRERP response. Box B- 2 below lists the seventeen Federal agencies
that participate in the FRERP. However, the FRERP does assign a responsibility to specific
agencies for leading and coordinating the activities of other agencies (referred to as Lead Federal
Agencies [LFA's] hi the FRERP) either under that agency's statutory authority or in response to a
request for assistance from an affected State. Therefore, each Federal agency is required to
develop and maintain an agency-unique plan that describes a detailed concept of operations
within the framework of the FRERP.
B-6
-------
ANNEX B: EPA-RERP RELATIONSHIP TO OTHER PLANS (cont.)
Box B-2 Federal Agencies Participating in the FRERP
1. Department of Agriculture
2. Department of Commerce
3. Department of Defense
4. Department of Energy
5. Department of Health and Human Services
6. Department of Housing and
Urban Development
7. Department of Interior
8. Department of Justice
9. Department of State
10. Department of Transportation
11. Department of Veteran Affairs
12. Environmental Protection Agency
13. Federal Emergency Management Agency
14. General Services Administration
15. National Aeronautics and Space
Administration
16. National Communication System
17. Nuclear Regulatory Commission
LFA Role. It is as follows: (1) deploys LFA response personnel to the scene and provide
liaison to the State and local authorities as appropriate; (2) designates a Federal OSCom at the
scene of the emergency to manage onsite activities and coordinate the overall Federal response to
the emergency; (3) establishes bases of Federal operation, such as the JOC and the JIC; (4)
coordinates the Federal response with the owner/operator; and (5) provides advice on the
radiological hazard to the Federal response.
FRERP Applicability. Box B-3 below shows various types of emergencies and identifies the LFA
under those circumstances. In the event of an unforeseen type of emergency, Federal agencies
will confer upon receipt of notification of the emergency to determine which agency is the LFA.
This determination will be made by representatives from headquarters and field offices of the
affected agencies.
The FRERP is used as the coordinating plan when the appropriate LFA determines that a .
radiological emergency may be expected to have a significant radiological effect. A FRERP
response may also occur as a result of a direct request for assistance from a State, Tribal, or local
official, radioactive materials licensee, an industry official, or member of the general public.
FEMA assists the LFA in coordinating emergency response activities critical to ensuring an
effective and efficient Federal multi-agency response to the emergency. However, FEMA's
responsibilities are limited to the non-radiological aspects of the emergency.
DOE, for example, may respond to a State or LFA request for assistance by dispatching a
Radiological Assistance Program (RAP) team. If the situation requires more assistance than a
RAP team can provide, DOE will alert or activate additional resources. This may involve the
establishment of a Federal Radiological Monitoring and Assessment Center (FRMAC).
In addition to assigning specific responsibilities to the LFA during a radiological
emergency, the FRERP also assigns DOE the lead responsibility for coordinating Federal
radiological monitoring and assessment assistance during the early phase of the emergency.
B-7
-------
ANNEX B: EPA-RERP RELATIONSHIP TO OTHER PLANS (cont.)
Box B-3 Lead Federal Agencies for Radiological Emergencies
Type of Emergency
1. Nuclear Facility
a. Licensed by the NRC or an Agreement State
b. Owned or operated by DOD or DOE
c. Not licensed, owned, or operated
by a Federal agency or an Agreement State
2. Transportation of Radioactive Materials
a. Shipment of Materials licensed by NRC
or an Agreement State
b. Materials Shipped by or for DOD or DOE
c. Shipment of Materials Not licensed or owned
by a Federal agency or an Agreement State
3. Satellites containing radioactive material
4. Impact from foreign source or unknown source
5. Other Types of Emergencies
Lead Federal Agency
NRCom
DOD or DOE
EPA
NRCom
DOD or DOE
EPA
NASA or DOD
EPA
LFA's confer
4. United States Government Interagency Domestic Counter-Terrorism Concept Of
Operations Plan (CONPLAN)
CONPLANPurpose. The CONPLAN establishes a structure for a systematic, coordinated, and
effective national response to threats or acts of terrorism in the United States, and defines
procedures for the use of Federal resources to augment and support local and State governments.
It encompasses both crisis and consequence management responsibilities, and articulates the
coordination and implementation between these missions.
CONPLAN Scope. The CONPLAN is a strategic document that reflects operational concepts and
provides planning guidance for responding to a terrorist threat or incident within the U.S.
Therefore, the CONPLAN serves as the foundation for further development of detailed Federal
agency, regional, State, and local operations plans and procedures to implement response
activities in a timely and efficient manner to deter or respond to acts of terrorism. The
CONPLAN outlines how the Federal response, encompassing both crisis and consequence
management, to a terrorist threat will be organized and directed. It includes guidelines for
notification of Federal agencies and coordination of emergency public information activities
across all levels of government. The CONPLAN suggests ways in which Federal, State and local
agencies can most effectively integrate and synchronize their response actions. The degree to
which the Federal resources and response activities will augment and integrate with local
agencies will be based upon the unique nature of each incident, the capabilities of the local
jurisdiction, and the activities necessary to prevent or mitigate the specific threat.
B-8
-------
ANNEX B: EPA-RERP RELATIONSHIP TO OTHER PLANS (cont.)
CONPLAN Authority. The CONPLAN does not supersede any existing authorities or
responsibilities assigned to any agency. Rather, it provides a coordination structure under which
the Federal agencies involved in responding to a threatened or actual terrorist incident will carry
out those responsibilities. In addition, the CONPLAN provides guidance on the responsibilities
of supporting agencies in assisting the Lead Federal Agency overall, and the FBI in crisis
management and FEMA in consequence management.
B-1
-------
-------
ANNEX C -DEFINITIONS
Advisory Team for Environment, Food, and Health (The Advisory Team) A team of
representatives from the EPA, HHS, and USD A, and representatives from other Federal agencies
as necessary, convened by the LFA when the radiological emergency has the potential for off-site
consequences. The primary function of the Advisory Team is to provide timely interagency
advice and recommendations to the LFA and the State in the following areas:
1. Environmental assessments (field monitoring) required for developing
recommendations;
2. PAGs and their application to the emergency;
3. Protective action recommendations using data and assessment from the FRMAC;
4. Protective actions to prevent or minimize contamination of milk, food, and water
and to prevent or minimize exposure through ingestion;
5. Recommendations regarding the disposition of contaminated livestock and poultry;
6. Recommendations for minimizing losses of agricultural resources for radiation
effects;
7. Availability of food, animal feed, and water supply inspection programs to assure
wholesomeness.
8. Relocation, reentry, and other radiation protection measures prior to recovery;
9. Recommendations for recovery, return, and clean-up issues;
10. Health and safety advice or information for the public and for workers;
11. Estimate effects of radioactive releases on human health and environment;
12. Guidance on the use of radio-protective substances (e.g., thyroid blocking agents),
including dosage and projected radiation doses that warrant the use of such drugs;
and
13. Other matters, as requested by the LFA.
Agreement State - A State that has entered into an Agreement under the Atomic Energy Act of
1954, as amended, in which NRC has delegated to such States certain regulatory authorities over
source, byproduct, and special nuclear material in quantities not sufficient to form a critical mass.
Assessment The evaluation and interpretation of radiological measurements and other
information to provide a basis for decision-making. Assessment can include projections of off-site
radiological impact.
Catastrophic Disaster Response Group (CDRG) ~ The CDRG is a headquarters-level group
which addresses national-level policy issues and support requirements from the FCO and field
response elements. Its members have access to the appropriate policymakers in their respective
Emergency Information and Coordination Center (EICC).
C- 1
-------
ANNEX C - DEFINITIONS (cont.)
Consequence Management -- Those activities conducted by Federal, State, and local emergency
response personnel in order to mitigate or eliminate the adverse impacts associated with nuclear,
chemical, or biological (NBC) terrorist incidents. FEMA is the Lead Agency for coordinating
consequence management activities at the Federal level of government.
Coordinate To advance systematically an exchange of information among principals who have
or may have a need to know certain information in order to carry out their role in a response.
Crisis Management Crisis management involves all the measures to confirm the threat,
investigate, gather evidence, locate and capture the terrorists and their weapons, and prosecute
the terrorists under Federal law. The FBI is assigned the role of Lead Agency for all crisis
management activities. EPA in support of the FBI takes preemptive, mitigative measures to
prevent, limit or mitigate threat of release or release while in the crisis phase of a response.
Disaster Field Office (DFO) A center established in or near the designated area from which
the Federal Coordinating Officer and representatives of Federal response agencies will interact
with State and local government representatives to coordinate non-technical resource support.
EPA Emergency Operations Center (EOC) The center located at EPA Headquarters
through which EPA coordinates its national-level activities for significant incidents.
Emergency Any natural or man-caused situation that results in or may result in substantial
injury or harm to the population or substantial damage to or loss of property.
Emergency Information and Coordination Center (EICC) The FEMA facility which
provides notification to Headquarters and Regional responders of the implementation of the FRP.
The EICC is located in FEMA Headquarters in Washington, DC.
Emergency Preparedness Advisory Committee ~ An intra-Agency response and coordination
team established to coordinate the development of Agency emergency response policies such as
continuation of operations and continuation of government (COOP/COG) plans.
Emergency Response Team (ERT) ~ A team of Federal interagency personnel headed by
FEMA deployed to the site of an emergency to serve as the FCO's key staff and assist with
accomplishing FEMA responsibilities at the DFO.
Federal Coordinating Officer (FCO) ~ The senior Federal official appointed to act for the
President in accordance with provisions of the Stafford Act, Public Law 93-288, as amended, to
coordinate the overall response and recovery actions. The FCO represents the President for the
C- 2
-------
ANNEX C - DEFINITIONS (cont.)
purpose of coordinating the administration of Federal relief activities in the designated area.
Additionally, the FCO is delegated and performs those responsibilities of the FEMA Director
outlined in Executive Order 12148 and the responsibilities delegated to the FEMA Regional
Director in Title 44 CFR, Part 205 and 206. This includes authority for tasking of Federal
agencies.
Federal Radiological Monitoring and Assessment Center (FRMAC) An operations center
usually established near the scene of a radiological emergency from which the Federal field
monitoring and assessment assistance is directed and coordinated.
Federal Radiological Preparedness Coordinating Committee (FRPCC) An interagency
committee, created by 44 CFR Part 351, to coordinate Federal radiological planning and training.
FRMAC Director The person designated by DOE or the EPA to manage operations in the
FRMAC.
Improvised Nuclear Device (IND) Incident An event resulting from a deliberate act,
involving nuclear weapons or nuclear materials which include the sabotage, seizure, theft, or loss
of a nuclear weapon or radiological nuclear weapon component or the fabrication and
employment of an IND or credible threat of either.
Interagency Committee for Public Affairs in Emergencies (ICPAE) The ICPAE is a
permanent body composed of public affairs representatives of Federal agencies, chaired by the
White House Press Secretary. Its purpose is to plan and to coordinate Federal emergency public
information activities during emergencies.
Joint Information Center (JIC) A center established to coordinate the Federal public
information activities on-scene. It is the central point of contact for all news media at the scene of
the incident. Public information officials from all participating Federal agencies should be
assembled at the JIC. Public information officials from participating State and local agencies may
assemble at the JIC also.
Joint Operations Center (JOC) Established by the LFA under the operational control of the
OSC, as the focal point for management and direction of on-site activities, coordination/
establishment of State requirements/priorities, and coordination of the overall Federal response.
During the Crisis Management phase of a counter terrorism incident, the FBI as the LFA
establishes and controls the JOC for coordination of the response operations.
Lead Federal Agency (LFA) ~ The agency which is responsible for coordinating all aspects of
the federal response under the FRERP. The type of emergency determines which agency bears
the LFA responsibility for a particular response. In situations where a Federal agency owns,
C- 3
-------
ANNEX C - DEFINITIONS (cont.)
authorizes, regulates, or is otherwise deemed responsible for the facility or radiological activity
causing the emergency and has authority to conduct and manage Federal actions onsite, that
agency normally will be the LFA.
License An authorization issued to a facility owner or operator by the NRC pursuant to the
conditions of the Atomic Energy Act of 1954 (as amended), or issued by an Agreement State
pursuant to appropriate State laws. NRC licenses certain activities under section 170(a) of that
Act.
Local Government Any county, city, village, town, district, or political subdivision of any
State; any Indian tribal agency or authorized tribal organization; or any Alaskan Native village or
organization, including any rural community or unincorporated town or village or any other public
entity.
Monitoring The use of sampling and radiation detection equipment to determine the levels of
radiation or the presence of radioactive material.
National Defense Area (NDA) An area established on non-Federal lands located within the
United States, its possessions or its territories, for safeguarding classified defense information or
protecting DOD equipment and/or material. Establishment of a National Defense Area
temporarily places such non-Federal lands under the effective control of the Department of
Defense and results only from an emergency event. The senior DOD representative at the scene
shall define the boundary, mark it with a physical barrier, and post warning signs. The
landowner's consent and cooperation shall be obtained whenever possible; however, military
necessity shall dictate the final location, shape and size of the NDA.
National Emergency Management Team (NEMT)-- An intra-Agency response and
coordination team established to address the essential functions and supporting activities
performed within the EPA necessary to fulfill the Agency's national security emergency
preparedness responsibilities as prescribed in Executive Order 12656, Assignment of Emergency
Preparedness Responsibilities, and other associated national security directives.
National Incident Coordination Team (NICT) EPA's intra-Agency team, composed of
representatives from all Headquarters offices, as well as regional points-of-contact, that brings
together EPA's technical, policy, program, and communications expertise, and serves as a focal
point within EPA for overall coordination efforts during significant events and situations that
occur outside of routine operations.
C- 4
-------
ANNEX C - DEFINITIONS (cont.)
National Security Area (NSA) An area established on non-Federal lands located within the
United States, its possessions or territories, for safeguarding classified information, and/or
restricted data or equipment and material belonging to DOE or NASA. Establishment of a
National Security Area temporarily places such non-Federal lands under the effective control of
DOE or NASA and results only from an emergency event. The senior DOE or NASA
representative having custody of the material at the scene shall define the boundary, mark it with a
physical barrier, and post warning signs. The landowner's consent and cooperation shall be
obtained whenever possible; however, operational necessity shall dictate the final location, shape,
and size of the NSA.
Nuclear Facilities Installations that use or produce radioactive materials in their normal
operations.
Nuclear Weapon Accident .An unexpected event involving nuclear weapons or nuclear
components that results in any of the following:
(1) Accidental or unauthorized launching, firing, or use by U.S. forces or U.S.-
supported allied forces of a nuclear-capable weapons system;
(2) An accidental, unauthorized, or unexplained nuclear detonation;
(3) Non-nuclear detonation or burning of a nuclear weapon or nuclear component;
(4) Radioactive contamination;
(5) Jettisoning of a nuclear weapon or component; and
(6) Public hazard, actual or perceived.
Nuclear Weapon Significant Incident An unexpected event involving nuclear weapons,
nuclear components, or nuclear weapon transport or launch vehicle when a nuclear weapon is
mated, loaded, or on board, that does not fall in the nuclear weapon accident category but:
(1) Results in evident damage to a nuclear weapon or radiological nuclear weapon
component to the extent that major rework, complete replacement, or examination
or re-certification by DOE is required;
(2) Requires immediate action in the interest of safety or nuclear weapons security;
(3) May result in adverse public reaction (national or international) or inadvertent
release of classified information; and
(4) Could lead to a nuclear weapon accident and warrants that senior national officials
or agencies be informed or take action.
Off-site The area outside the boundary of the on-site area. For emergencies occurring at fixed
nuclear facilities, "off-site" generally refers to the area beyond the facility boundary. For
C- 5
-------
ANNEX C - DEFINITIONS (cont.)
emergencies that do not occur at fixed nuclear facilities and for which no physical boundary
exists, the circumstances of the emergency dictates the boundary of the off-site area. Unless a
Federal agency has the authority to define and control a restricted area, the State or local
government defines an area as "on-site" at the time of the emergency, based on required response
activities.
Off-site Federal Support Federal assistance in mitigating the off-site consequences of an
emergency and protecting the public health and safety, including assistance with determining and
implementing public protective action measures.
On-scene The area directly affected by radiological contamination and environs. On-scene
includes both on-site and off-site areas.
On-Scene Commander (OSCom) The lead agency official designated by the LFA who at the
scene of the emergency manages on-site activities and coordinates the overall Federal response to
the emergency. Except for multi-incidents when ORIA provides the OSCom, the OSCom and the
OSC are one and the same for incidents occurring in a single region.
On-Scene Coordinator (OSC) The Federal official predesignated to coordinate and direct
hazardous substance removal actions. Depending upon the location of the incident, ownerships,
operation or jurisdiction, the OSC may be provided by either the EPA, USCG, DOD, or DOE.
For non- emergency removals, the OSC may be provided by other Federal agencies responsible
for coordinating and directing actions at their respective agency facilities.
On-site The area within: (a) the boundary established by the owner or operator of a fixed
nuclear facility, (b) the area established by the LFA as a National Defense Area or National
Security Area in a nuclear weapon accident or nuclear weapon significant incident, (c) an area
established around a downed/ditched U.S. spacecraft, or (d) the boundary established at the time
of the emergency by the State or local government with jurisdiction for a transportation accident
not occurring at a fixed nuclear facility and not involving nuclear weapons.
On-site Federal Support Federal assistance that is the primary responsibility of the Federal
agency that owns, authorizes, regulates, or is otherwise deemed responsible for the radiological
facility or material being transported, i.e., the LFA. This response supports State and local
efforts by supporting the owner's or operator's efforts to bring the incident under control and
thereby prevent or minimize off-site consequences.
Owner or Operator The organization that owns or operates the nuclear facility, carrier, or
cargo that causes the radiological emergency. The owner or operator may be a Federal agency, a
State or local government, or a private business.
C- 6
-------
ANNEX C - DEFINITIONS (cent.)
Protective Action Guide (PAG) A radiation exposure or contamination level or range
established by appropriate Federal or State agencies at which protective actions should be
considered.
Protective Action Recommendation Federal advice to the State and local governments on
measures they should take to avoid or reduce exposure of the public to radiation from an
accidental release of radioactive material. This includes emergency actions such as sheltering,
evacuation, and prophylactic use of iodine. It also includes longer term measures to avoid or
minimize exposure to residual radiation or exposure through the ingestion pathway such as
restriction of food, temporary relocation, and permanent resettlement.
Public Information Officer (PIO) - Official at headquarters or in the field responsible for
preparing and coordinating the dissemination of public information in cooperation with other
responding Federal, State, and local agencies.
Radiological Emergency - A radiological incident that poses an actual, potential, or perceived
hazard to public health or safety or loss of property. .
Radiological Emergency Response Team (RERT) - A response team dispatched to the site of
a radiological incident by the Team Commander, or requested by a federal OSC for support in
response to a radiological incident. RERT's members are comprised of staff at EPA
Headquarters, ORIA-Labs, and Regional Offices.
Radiological Response Coordinator The Radiological Response Coordinator is a term used in
the NCP for the designated ORIA member who receives emergency notification, notifies the
appropriate Agency personnel, assesses the need for response and makes response
recommendations to the Director of ORIA. The designated ORIA member maintains cognizance
of accident conditions and responses, and documents the accident and the EPA response.
Regional Operations Center - The temporary operations facility for FEMA's coordination of
Federal response and recovery activities, located at the FEMA Regional Office (or at the Federal
Regional Center) and led by the FEMA Regional Director or Deputy Director until the DFO
becomes operational. Coordination of operations shifts to the State EOC upon arrival of the ERT
at that location. From that time forward, the Regional Operations Center performs a support role
for Federal staff at the disaster scene.
Regional Radiation Program Manager (RRPM) - The RRPM is a designated program
manager and/or unit supervisor responsible for the radiation program activities in the EPA
regional office. Each of the EPA Regions has assigned a RRPM. He/She is responsible for the
regional radiation program activities and coordinates with ORIA and the two laboratories.
C- 7
-------
ANNEX C - DEFINITIONS (cont.)
Recovery Recovery, in this document, includes all types of emergency actions dedicated to the
continued protection of the public or to promoting the resumption of normal activities in the
affected area.
Recovery Plan A plan developed by each State, with assistance from the responding Federal
agencies, for the responsible party to restore the affected area.
Reportable Quantity CERCLA requires that persons in charge of vessels or facilities from
which a hazardous substance, including any radionuclide, has been released within a 24-hour
period in a quantity equal to or greater than its reportable quantity immediately notify the National
Response Center of the release. Reportable quantities for radionuclides are specified in 40 CFR
302.4, Appendix B.
Senior EPA Official (SEPAO) - The EPA person responsible for the direction and coordination
of all the activities of Agency personnel in the field in accordance with the relevant agency
policy, delegation and/or directives. This individual represents EPA in all phases of the on-scene
response. The duties of the SEPAO include assigning, deploying, and returning EPA staff and
equipment committed to the emergency response; maintaining an awareness of the emergency
conditions and responses and any changes in them; providing frequent status reports to the
Radiological Response Coordinator in Washington and the appropriate Regional Radiation
Program Manager; and arranging for media briefings on EPA activities. (If FEMA is present,
FEMA will provide briefings on all Federal activities.) Official appointed by the Director of
ORIA to assume the role of FRMAC Director at the transition of response coordination
responsibility.
Scientific Support Coordinator (SSC) - Under the direction of the OSC, the SSCs provide
scientific support for response operational decisions and for coordinating on-scene scientific
activity. Generally, SSCs are provided by the National Oceanic and Atmospheric Agency
(NOAA) in coastal and marine areas, and by EPA in inland Regions.
Subcommittee on Federal Response - A subcommittee of the Federal Radiological
Preparedness Coordinating Committee formed to develop and test the Federal Radiological
Emergency Response Plan. Most agencies that would participate in a Federal radiological
emergency response are represented on this subcommittee.
Transportation Emergency For the purpose of this plan, any emergency that involves a
transportation vehicle or shipment containing radioactive materials.
Transportation of Radioactive Materials The loading, unloading, movement, or temporary
storage en-route of radioactive materials.
C- 8
-------
ANNEX D-OTHER EPA ORGANIZATIONS
During emergencies, various agency headquarters offices play a role in EPA's response to
radiological releases. The key offices involved are as follows.
1. Office of the Administrator (OA) -. The Administrator is responsible for the overall
radiological incident/emergency response.
2. Office of Congressional and Intergovernmental Relations (OCIR) - This office
supports OAR in responding to media and Congressional inquiries during a radiological incident.
The Office of Congressional and Intergovernmental Relations (OCIR) coordinates all direct
contacts with members of Congress and Congressional staff. OCIR also coordinates with FEMA
Headquarters and the LFA to arrange EPA participation in Congressional relations during multi-
Federal agency responses. The responsibility for management of Congressional relations is
assumed according to the level of response. When EPA responds alone, the EPA Regional
Congressional Liaison assists the Regional Office and the Senior EPA Official in contacting
appropriate Congressional offices and providing informational briefings, as necessary.
For a Federal multi-agency response, FEMA, in coordination with the LFA Congressional
Liaison Officer, provides information to members of Congress. This information is coordinated
with other Federal agency Congressional Liaison Officials, in accordance with the FRERP. In
support of FEMA, EPA Regional Congressional Relations Staff coordinate with FEMA Regional
Offices to respond to inquiries from local Congressional staff and provide informational briefings.
FEMA coordination does not preclude direct communication and information exchange between
Congressional representatives and individual Federal agencies. Federal agencies should, however,
report such contacts to EPA and FEMA to ensure Federal agency information is consistent.
3. Office of Emergency and Remedial Response (OERR) - Within OSWER, OERR is
responsible for coordinating regional oil and hazardous substance response personnel and
activities, and for response funding, guidance, training, and other "'national" activities. Also,
OERR participates in a radiological emergency involving CERCLA response authority to address
releases of radionuclides including manmade radionuclides. A CERCLA response could take the
form of an emergency, time critical, non-time critical, or a remedial response action. If CERCLA
authority is used, the response action is carried out in accordance with the NCP. NCP responses
do not require a State request. All NCP activities are directed by the On-Scene Coordinator
when operating under the authority of the NCP, in coordination with OERR, ORIA and the
Regional Radiation Program Manager.
4. Office of Communications, Education, and Media Relations (OCEMR) - The extent
of EPA management of press and public relations depends to a large degree on whether EPA
responds alone or as part of a Federal multi-agency response. When EPA responds alone,
OCEMR assists EPA Regional Offices and the Senior EPA Official in arranging and conducting
D-l
-------
ANNEX D - OTHER EPA ORGANIZATIONS (cont.)
local media briefings and preparing local news releases. OCEMR performs similar services for
OAR at EPA Headquarters and, for multi-agency coordination, provides representatives to the
Interagency Committee on Public Affairs in Emergencies (ICPAE).
The ICPAE, chaired by the Press Secretary to the President, coordinates overall Federal
agency emergency public information activities during emergencies. Federal information released
to the public and media during the post-event period will be coordinated and disseminated from
headquarters offices by the establishment of a ICPAE National Joint Information Center (JIC) in
Washington, D.C., until an on-scene JIC is operational in the affected area. Once the on-scene
JIC is declared operational, it will assume primary responsibility for originating and coordinating
Federal information released to the public and news media. The ICPAE National JIC will
continue to support the Washington press corps, provide policy guidance and support, and
provide coverage for the President and other Federal agencies, for as long as needed.
When EPA is the LFA, OCEMR establishes a JIC near the emergency in coordination
with other Federal, State, and local officials. EPA encourages all Federal emergency response
organizations to dedicate a JIC spokesperson to the site. The JIC provides timely, accurate, and
consistent information regarding the radiological incident status, response actions, and
instructions for th'e affected population. Public information coordination is most effective -when
the owner/operator, Federal, Slate, local, and other relevant information sources participate
jointly. The primary location for linking these sources is the JIC.
During a Federal multi-agency response, FEMA works with the LFA to disseminate public
information concerning Federal emergency response activities, in accordance with the FRERP.
The EPA Regional Public Affairs Office, ORIA's public outreach groups and OCEMR at EPA
Headquarters assist the LFA in understanding EPA involvement in the response and arrange for
EPA participation in media interchanges.
5. Office of Water (OW) - This office coordinates and assists State and local emergency
response agencies to ensure availability of potable water during a radiological incident. For
States that have accepted primary enforcement responsibility to provide potable water under the
authority of the Safe Drinking Water Act, OW only monitors State emergency response efforts
and takes no action unless requested by the affected State or unless information indicates that the
State is unsuccessful in providing potable water.
In the event State agency capabilities are exceeded, OW facilitates and coordinates EPA and other
Federal assistance to prevent or control the use of radiologically contaminated water. All
Headquarters OW activities are coordinated through ORIA. In addition, the OW, upon request,
assists and advises the Senior EPA Official for all technical areas within its organizational
responsibility, which include:
D-2
-------
ANNEX D - OTHER EPA ORGANIZATIONS (cont.)
1. Establishing, in cooperation with ORIA, emergency guidance for
radioactivity in drinking water;
2. Providing data on public water systems to identify and notify affected
licensees and States;
3. Providing technical assistance to States or licensees concerning water
treatment techniques, bypass procedures, alternate sources, and other
activities related to maintaining drinking water quality and service;
4. Assisting on-scene personnel in coordinating activities to minimize the
adverse impact of drinking contaminated water; and
5. Assisting State and local governments, in non-primacy States, in
implementing plans and activities to provide emergency potable water
supplies.
Office of Research and Development (ORD) - This Office maintains several laboratories
and technical assets throughout the country which may be called upon to assist ORIA and
the Regions in the event of a radiological emergency.
National Incident Coordination Team (NICT) - This team complements existing
emergency response functions, and serves as a headquarters' focal point for overall
support and national policy efforts during certain events. It is also responsible to bring
together a multi-program team to deal with broad issues during extraordinary emergency
situations.
Regional Response Teams (RRTs) - are responsible for regional planning and
preparedness activities before response actions, and for providing advice and support to
the OSC when activated during a response. RRT membership consists of designated
representatives from each federal agency participating in the National Response Team
together with State and local government representatives.
National Response Team (NRT) - The NRT's membership consists of 16 federal
agencies with responsibilities, interests, and expertise in various aspects of emergency
response to pollution incidents. The NRT is primarily a national planning, policy, and
coordinating body and does not respond directly to incidents. The NRT provides policy
guidance prior to an incidents and assistance as requested by the OSC via a RRT during an
incident. NRT assistance usually takes the form of technical advice, access to additional
resources/equipment or coordinating with other RRTs.
D-3
-------
-------
ANNEX E - REFERENCES
1. Assignment of Emergency Preparedness Responsibilities, Executive Order 12656 (1988).
2. Atomic Energy Act of 1954, as amended, 42 USC 2011 et seq. (1970), and President's
Reorganization Plan Number 3, 42 USC 2021 (h).
3. Clean Air Act, as amended, 42 USC 7401 et seq. (1990).
4. The Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(SUPERFUND), 42 USC 9601 et seq. (P.L. 96-510, December 11, 1980), as amended by
the Superfund Amendments and Reauthorization Act of 1986 (PL 99-499) (1986).
5. Federal Radiological Emergency Response Plan (FRERP), Operational Plan, Federal
Register, Vol. 61, No. 90, May 8, 1996.
6. Memorandum of Understanding Between EPA and the Department of the Air Force;
Department of Energy; Department of Health, Education and Welfare, Food and Drug
Administration; Department of Commerce, National Oceanic and Atmospheric
Administration; Nuclear Regulatory Commission; and Department of Transportation,
Federal Aviation Administration Concerning the Federal Response to Radioactive
Contamination from Specified Foreign Nuclear Detonations, April 15, 1979.
7. National Incident Coordination Team, Operational Guidelines, U.S. Environmental
Protection Agency, October, 1988.
8. The National Oil and Hazardous Substances Pollution Contingency Plan, dated October
17, 1994 (40 CFR Part 300).
9. Oil Pollution Act, as amended, 33 USC 2701 et seq. (1990).
10. Presidential Decision Directive No. 39 (SECRET) (1995).
11. Public Health Service Act, as amended, 42 USC 241 et seq. (1970).
12. Radionuclide Reportable Quantity Adjustment Rule-making (40 CFR 302), 54 FR 22524,
May 24, 1989.
13. The Safe Drinking Water Act, 42 USC 3 OOf et seq. (1971).
14. Presidential Decision Directives No. 62, Combating Terrorism, May 1998.
15. Presidential Decision Directive No. 63, Protecting America's Critical Infrastructures, May
1998.
E-l
-------
-------
ANNEX F - ACRONYMS
AA Assistant Administrator
AEA Atomic Energy Act
CDRG Catastrophic Disaster Response Group
CEPPO Chemical Emergency Preparedness and Prevention Office
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
CONPLAN Counter-Terrorism Concept of Operations Plan
CWA Clean Water Act .
DFO Disaster Field Office
DOC Department of Commerce
DOD Department of Defense
DOE Department of Energy
DOI Department of Interior
DOJ Department of Justice
DOS Department of State
DOT Department of Transportation
DVA Department of Veterans Affairs
EICC Emergency Information and Coordination Center (FEMA)
EOC Emergency Operations Center
EPA Environmental Protection Agency
ERAMS Environmental Radiation Ambient Monitoring System
ERT Emergency Response Team (FEMA-led)
ESF Emergency Support Function
EST Emergency Support Team
FBI Federal Bureau of Investigation
FCO Federal Coordinating Officer
FEMA Federal Emergency Management Agency
FRERP Federal Radiological Emergency Response Plan
FRMAC Federal Radiological Monitoring and Assessment Center
FRP Federal Response Plan
FRPCC Federal Radiological Preparedness Coordinating Committee
GSA General Services Administration
HHS Department of Health and Human Services
HUD Department of Housing and Urban Development
IAEA International Atomic Energy Agency
ICPAE Interagency Committee on Public Affairs in Emergencies
JIC Joint Information Center
JOC Joint Operations Center
LFA Lead Federal Agency
MOU Memorandum of Understanding
NAREL National Air and Radiation Environmental Laboratory, Montgomery, AL
F-l
-------
ANNEX F - ACRONYMS (cont.)
NASA National Aeronautics and Space Administration
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NDA National Defense Area
NEMT National Emergency Management Team
NICT National Incident Coordination Team
NOAA National Oceanic and Atmospheric Administration (DOC)
NORM Naturally Occurring Radioactive Materials
NRC National Response Center
NRCom Nuclear Regulatory Commission
NSA National Security Area
OAR Office of Air and Radiation
OCEMR Office of Communications, Education, and Media Relations
OCIR Office of Congressional and Intergovernmental Relations
OD Office Director
OW Office of Water
OERR Office of Emergency and Remedial Response
OPA Oil Pollution Act
ORD Office of Research and Development
ORIA Office of Radiation and Indoor Air
OSC On-Scene Coordinator (NCP Designation)
OSCom On-Scene Commander (FRERP Designation)
OSWER Office of Solid Waste and Emergency Response
PAG's Protective Action Guides
PIO Public Information Officer
RCC Regional Coordination Center
RERP Radiological Emergency Response Plan
RERT Radiological Emergency Response Team
RJOENL Radiation and Indoor Environmental National Laboratory, Las Vegas, NV
RRPM Regional Radiation Program Manager
SARA Superfund Amendments and Reauthorization Act of 1986
SEPAO Senior EPA Official
SFO Senior FEMA Official
SNM Special Nuclear Material
SSC Scientific Support Coordinator
USCG U.S. Coast Guard
USD A U.S. Department of Agriculture
F-.2
------- |