United States
Environmental Protection
Agency
Air And Radiation
(ANR-460)
402-R-92-001
April 1992
Implementing Protective Actions
For Radiological Incidents
At Other Than
Nuclear Power Reactors
Proceedings Of A Workshop
Held In Montgomery, Alabama,
In September 1991

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                PROCEEDINGS OF A WORKSHOP

                        HELD AT THE
           U.S. ENVIRONMENTAL PROTECTION AGENCY
               OFFICE OF RADIATION PROGRAMS
  NATIONAL AIR AND RADIATION ENVIRONMENTAL LABORATORY
                   MONTGOMERY, ALABAMA
                    SEPTEMBER 25-26, 1991
                   Office of Radiation Programs
               U.S. Environmental Protection Agency
                     Washington, D.C. 20460
O
CO
                       HEADQUARTERS i.'BRARY
                       ENVIKON^EKfAi. PROTECTION AGEMCY
                       WASHINGTON. D.C. 20460

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                    PROCEEDINGS OF A WORKSHOP ON
             IMPLEMENTATION OF PROTECTIVE ACTIONS FOR
                         RADIOLOGICAL INCIDENTS
               AT OTHER THAN NUCLEAR POWER REACTORS

                                 CONTENTS
                                                                          Page

Introduction	  1

Workshop Participants	  7

Workshop Working Group Assignments  	11

Workshop Agenda 	13

Speakers' Papers 	17

      Welcome and Introduction, by Sam Windham  	19

      Welcome, by Aubrey V. Godwin	21

      Overview of the  Workshop, by Allan C.B. Richardson	23

      Lessons Learned from Emergency Planning at Hanford,
       by Robert Mooney 	27

      The Relationship between Protective Action Guides and
       Emergency Planning Zones, by Robert Trojanowski	31

      The Basis for Protective Action Guides and Their Application to
       Non-Reactor Source Terms, by Allan C.B. Richardson	37

     Implementation  of Protective Action Guides at a Large Plutonium
       Processing Facility, by Philip C. Nyberg	45

     Mixed Hazard Incidents (Chemical/Nuclear Incidents), by William Klutz  	55

     Arkansas' Titan II Experience, by Bernard Bevill  	57

     Review on the Basis of Guidance for Sheltering as a Protective
       Action in a Plutonium Release Accident, by Bradley Nelson	63
                                      ill

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Submitted Papers	73

      Lessons Learned by the Illinois Department of Nuclear Safety
       from Participation in FFE-2, by Gary N. Wright, Roy R. Wright
       and Charles W. Miller	75

      The Usefulness of Information Provided by Field Measurements
       During Unplanned Releases into the Environment, by Robert W. Terry	79

Working Group Summaries	85

      Working Group A
      Differences in Modeling of Releases, Exposure Pathways,  and Field
       Monitoring,  in REP at Nonreactor Nuclear Facilities Compared
       to REP for Nuclear Power Plants  	87

      Working Group B
      The Planning Basis and the Roles of Planning and Response Authorities	91

      Working Group C
      The Need for Specific Guidance on Dose Protection, Protective Actions,
       Training, and Exercises for Implementing PAGs for Nuclear Incidents
       at Nonreactor Nuclear Facilities	95

      Working Group D
      Integration of Emergency Response for Incidents in Which the Release
       Includes Both Hazardous Chemical and Radiological Contaminants
       (Mixed Incidents)	99
                                        IV

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                                INTRODUCTION
      The Workshop was held at the Environmental Protection Agency's (EPA) National
 Air and Radiation Environmental Laboratory in Montgomery, Alabama on September 25-26,
 1991.  Hosted by the EPA's Office of Radiation Programs, the Workshop was attended by
 State emergency response officials who have major nonreactor nuclear facilities in their
 State,  and by  Federal  officials  responsible for  developing  guidance on  emergency
 preparedness.

      The principal objective of the Workshop was to provide a forum for the States to
 identify  and discuss  issues regarding  implementation  of protective actions following a
 radiological accident involving a Federal or commercial nuclear facility,  with emphasis on
 source terms other than power reactors.  EPA's impending issuance of revised Protective
 Action  Guides (PAGs) for evacuation and  sheltering  provided  the  key incentive  for
 conducting the Workshop at this time. Previous PAGs, which were applicable only to reactor
 incidents, had been revised to be applicable to source terms from nonreactor incidents as
 well.  The dose quantities for expressing the  PAGs were also revised so that they would
 encompass all of the risk that may be  avoided by the relevant protective  action,  and  the
 accompanying text was clarified to  provide more complete guidance on the factors that
 should or should not influence the choice between evacuation and sheltering.

      The Workshop included two plenary sessions and one working group session in which
 four working groups met to address  different issues. In the first plenary session a variety
 of speakers discussed State and Federal perspectives on the issues. This provided background
 information for  the working group sessions.  The second  plenary session consisted of
 presentations  and  discussions  from the  four  working groups.   Although  some  key
 organizations were not represented  at the workshop, a great  deal of information was
 compiled that should be useful to those responsible for the development and exercising of
 emergency response plans.

      The purpose of this document is to provide a summary of the key issues based on the
formal presentations on specific topics,  the associated discussions, and discussions of the
work that went on in the four working groups.  Separate reports that summarize the results
of the deliberations of the working groups are  provided later.
General Findings and Conclusions

      Although several types of nuclear facilities other than power reactors were discussed,
there was general consensus that the most significant source terms at nonreactor nuclear
facilities  for which  detailed emergency planning is important are those associated with
Federal facilities; primarily those operated by or for the Department of Energy (DOE) and
Department of Defense (DOD).

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      It was pointed out that emergency planning had been conducted by State officials and
facility operators at some of the Federal facilities, but in less detail than for nuclear power
faculties. In some cases facility emergency response plans have been exercised with State
participation.  Also, Federal funds have been provided to some States to assist them in their
planning efforts, and some State officials have received DOE "Q" clearances to  reduce
communication problems with faculty operators.

       Among the responsibilities of the Federal Emergency Management Agency (FEMA),
as chair of the Federal Radiological Preparedness Coordinating Committee (FRPCC), is the
following: "Establish policy and provide leadership via the FRPCC in the coordination of all
Federal assistance and guidance to State and local  governments for developing, reviewing,
assessing and testing the  State  and local  radiological emergency plans"  (44 CFR Part
351.C.351.20).  This same  document requires the  DOE and DOD to participate in these
planning activities for their contractor-operated faculties.  However, none of the planning
activities mentioned  above were carried out  under the auspices  of the FRPCC.   Some
attendees were aware of a major effort begun several years ago by DOE  and FEMA to
develop guidance for preparing and exercising State and local emergency response plans for
Federal nuclear facilities. This guidance would have been parallel to the guidance developed
for nuclear power plants.  However, the effort was  discontinued.

      EPA discussed the proposed revisions to the "Manual of Protective Action Guides and
Protective Actions for Nuclear Incidents" (PAG Manual). Considerable discussion centered
around whether the revised PAGs for the early phase of response to a nuclear incident could
be reasonably  applied for all types of nuclear incidents. No circumstances (except nuclear
war) could be  identified that would require different PAG values,  dose quantities, or time
periods for calculation of projected dose in order for the PAGs  to be applied to nonreactor
incidents. It was concluded that the revised PAGs  for the early phase could reasonably be
applied to any type of nuclear incident except nuclear war.

      There are some positive indicators that progress is being made regarding emergency
response planning at Federal facilities. For example:  1) key officials in some states are
getting security clearances, 2) some Federal facility  officials are meeting with State officials
regarding potential  source term for  incidents, and 3) some states  are  being  funded
temporarily for emergency  planning by DOE.  The following summarizes the major issues
identified by attendees at the Workshop that require resolution with regard to planning for
response to incidents at nonreactor nuclear facilities.  Additional issues are identified in the
individual reports of the four Working Groups.
Conclusions from Initial Presentations

1.    The lack of regulatory oversight for planning at Federal facilities is a major problem.
      Regulatory oversight similar to that provided for emergency planning activities at
      commercial  nuclear power  faculties  is needed  for nonreactor nuclear  facilities.
      Resolution of many of the other issues identified at the Workshop is dependent on
      resolving this issue.

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      A planning basis is needed for nonreactor facilities.  The planning basis for nuclear
      power facilities dealt with size of the planning area, time frame for response, and
      radionuclides to plan for.  Due to the variability among sites and source terms for
      Federal  nuclear facilities, a different  basis may be appropriate for each  facility.
      Guidance is needed on how to  develop a planning basis.

      Nuclear  power facilities are a source  of stable long-term funding for emergency
      planning by State and local agencies.  Similar funding is needed for State and local
      planning at Federal facilities.   In some cases funding has been provided, but it is
      neither stable nor long-term.

      At some facilities, arrangements are needed for communication between the facility
      operator and offsite officials regarding classified information.  Clearances  for key
      offsite individuals have been useful to facilitate communication in instances where
      they have been implemented.

      After emergency response plans are developed, exercises and training programs are
      needed.  Training programs already developed in support of response to nuclear power
      plant accidents and transportation accidents are not totally adequate for response to
      accidents at Federal nuclear facilities.
Key Issues Identified Durii
tercises at Federal Facilities
1.    At some facilities, States were not considered to be an equal partner with the facility
      operator.  For example:

            Communications were generally ineffective.  This was because communications
            at the facility were through a third party to a responsible party offsite.

            No debate  or justification of recommendations  on protective actions was
            provided to offsite officials.

            The technical expertise of the State was not recognized.

2.    Accident  classification was confusing because of the  lack  of  a standard  set  of
      classifications.

3.    Public information was ineffective.  This was sometimes a result of facility rules that
      did not  allow discussions of onsite activities with outsiders.

4.    The distinction between recommendations and decisions on protective  actions was
      sometimes not clear.

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Key Lessons Learned from the Titan II Incident in 1980

1.     The impossible can occur.

2.     Emergency plans should allow for flexibility so that the response can be tailored to
       the situation.

3.     Special monitoring equipment  related to the potential source term is needed. This
       relates primarily to the need to monitor for alpha radiation.

4.     Training programs are needed in relation to specific source  terms applicable to
       nonreactor facilities.

5.    An accident does a lot to improve emergency planning.  Some results were:

             Communication between State and Air Force was improved.

             Emergency plans were developed.

             Communication with citizens was improved.
Key Conclusions from
      Regardless of the  nature of the tools  to be used  to  assess  offsite  radiological
      consequences, it is an inherent responsibility of the facility operator to develop these
      tools and make them available to offsite agencies.

      The absence  of gamma-emitting radionuclides in releases from incidents at several
      categories of nuclear facilities will require acquisition of expensive field and laboratory
      instrumentation not currently available to offsite response organizations.   Such
      instrumentation will be needed to verify the presence or absence of an airborne
      plume.

      More  important than the instrumentation  itself, are the procedures and training
      required to prepare samples and use the equipment. The analysis of transuranics and
      mixed  chemical/radiological  sources  were  identified in particular as areas  where
      training is needed.

      Far too little information is currently available to offsite planning agencies regarding
      the nature of the hazards at many of the Federal facilities. Some may present mixed
      chemical/radiological  hazards.  It was concluded that the current implementation
      procedures for evacuation and sheltering will require expansion to address these
      different types of hazards. An assessment  of the potential for accidental release of
      mixed  source terms at Federal facilities was identified as a project that should be
      completed as soon as possible.

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8.
9.
10.
The responsibility for developing information and models for characterizing hazards
of accidental releases  should fall to the owner/operator  of facilities,  whereas the
responsibility to expand current implementation procedures should rest with EPA, in
coordination with FEMA, DOE, and NRG. The development of standards for alpha
contamination was specifically identified as an area requiring the attention of EPA.

Due to the difficulty in collecting field monitoring data in a timely fashion, it will be
necessary to make early decisions on the need for protective  actions based on facility
status. Emergency action levels and corresponding source terms in potential releases
are needed to support  these early decisions.

Agreements between nuclear facility operators and offsite response officials should be
developed  as needed  for security  clearances to facilitate  communication  during
emergencies.

Concern was expressed that radiological professionals would tend to overlook chemical
hazards during an event involving a mixed chemical/radiological  release thus posing
a threat to themselves  and others.   Cross training between  the chemical  and
radiological personnel was recommended.

The Federal government should continue to streamline and consolidate authority to
aid States in knowing who is in charge for incidents involving mixed releases.

The Federal agencies  should participate realistically  during  exercises  at Federal
nuclear facilities by including all the resources that would actually be used in an
emergency.
      The consensus of attendees at the Workshop  was that it was a success.   They
indicated that the information developed would be helpful to those preparing guidance for
the development  of emergency plans and exercises as well as to those required to develop
such plans and exercises.  EPA was encouraged to proceed with publication of the revised
PAGs, and EPA  and FEMA were encouraged to follow through on the development of
additional guidance applicable to emergency preparedness at nonreactor nuclear facilities.

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       WORKSHOP ON IMPLEMENTATION OF PROTECTIVE ACTIONS
                      FOR RADIOLOGICAL INCIDENTS
               AT OTHER THAN NUCLEAR POWER REACTORS

                                PARTICIPANTS
Mr. Robert Baumgartner
Radiological Defense Officer
Idaho State Bureau of Disaster Services
650 West State Street
Boise, ID  83720
(208) 334-3460
Mr. Bernard Bevill
Health Physicist Supervisor
Nuclear & Environmental Safety Section
Division of Radiation Control and
 Emergency Management
Arkansas Department of Health
4815 West Markham Street, Slot 30
Little Rock, AR 72205-3867
(501) 661-2301
Mr. Clarence L. Born
Manager, Emergency Response
 Planning Program
Bureau of Radiation Control
Texas Department of Health
1100 West 49th Street
Austin, TX 78756
(512) 835-7000
Mr. Gary W. Butner
Senior Health Physicist
Department of Health Services
Nuclear Emergency Response
Environmental Management Branch
714 P Street, Room 616
Sacramento,  CA 95814
(916) 323-5027
Mr. William Condon
Chief, Environmental Radiation Section
New York State Department of Health
Bureau of Environmental
  Radiation Protection
2 University Place, Room 325
Albany, NY 12203
(518) 458-6495
Mr. Kevin Driesbach
Health Physics Supervisor
Ohio Department of Health
Post Office Box 118
Columbus, OH 43266-0118
(614) 644-2727
Mr. Leslie P. Foldesi
Director, Virginia Department of Health
Bureau of Radiological Health
Main Street Station
1500 East Main Street
Richmond, VA  23219
(804) 786-5932
S.W. (Felix) Fong, Ph.D.
Chief, Nuclear Facilities &
 Environmental Radiation
 Surveillance Section
North Carolina Division of
 Radiation Protection
Department of Environment,
 Health & Natural Resources
Post Office Box 27687
Raleigh, NC  27611-7687
(919) 571-4141

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Mr. Eloy A. Garcia Jr.
Water Resources Specialist II
New Mexico Health and
 Environment Department
1190 St. Francis Drive (N2300)
Post Office Box 26110
Santa Fe, NM 87502
(505) 827-2935
Mr. Aubrey V. Godwin
Director, Division of Radiation Control
State Department of Public Health
State Office Building
Montgomery, AL  36130-1701
(205) 242-5315
Mr. James C. Hardeman Jr.
Manager, Environmental Radiation
 Program
Department of Natural Resources
4244 International Parkway, Suite 114
Atlanta, GA 30354
(404) 362-2675
Mr. John C. Heard
Chief, Technological Hazards Branch
Federal Emergency Management Agency
Region IV
1371 Peachtree Street, NE, Suite 700
Atlanta, GA 30309-3108
(404) 853-4468
Mr. Larry Jensen
Office of Radiation Programs
(5AT26), Region V
Environmental Protection Agency
230 South Dearborn Street
Chicago, IL  60604
(312) 886-5026
Mr. Harlan W. Keaton
Manager, Environmental Radiation
  Control
Florida Department of Health and
  Rehabilitative Services
Office of Radiation Control
Post Office Box 680069
Orlando, FL 32868-0069
(407) 297-2095
Mr. William Klutz
On-Scene Coordinator, OSWER
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 347-3931
Mr. Joe Logsdon
Consultant
Scientific and Commercial Systems Corp.
4651 King Street, Suite 200
Alexandria, VA  22302
(703) 824-8240
Ms. Cheryl L. Malina
Emergency Programs Specialist
Office of Radiation Programs (ANR-460)
Environmental Protection Agency
401 M Street, S.W.
Washington, DC  20460
(202) 260-1518
Mr. Stanley R. Marshall
Supervisor, Radiological Health Section
Health Division
Department of Human Resources
505 East King Street
Carson City, NV 89710
(702) 687-5394
                                        8

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Mr. Robert Mooney
Supervisor, Nuclear Safety Section
Division of Radiation Protection
Department of Health
217 Pine Street, Suite 220
Seattle, WA 98101
(206) 464-7274
Mr. Bradley Nelson
Office of Radiation Programs (ANR-460)
Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
(202) 260-9620
Mr. Jim Rabb
Emergency Response Coordinator
Centers for Disease Control
1600 Clifton Road, N.E.
Atlanta, GA  30084
(404) 639-0615
Mr. Thomas Reavey
Environmental Chemist
Office of Radiation Programs (ANR-460)
Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
(202) 260-9620
Mr. Philip C. Nyberg
Environmental Protection Agency
Region VIII
Suite 500 (8ART-RP)
999 18th Street
Denver, CO  80202-2405
(303) 293-1709
Mr. Jon Richards
Nuclear Engineer
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 347-3907
Ms. Colleen F. Petullo
Office of Radiation Programs
Environmental Protection Agency
Post Office Box 98517
Las Vegas, NV 89193-8517
(702) 798-2446
Mr. William Phillips
Certified Health Physicist
EMSL-LV
Environmental Protection Agency
Post Office Box 93478
Las Vegas, NV 89193
(702) 798-2326
Mr. Allan C.B. Richardson
Chief, Guides & Criteria Branch
Office of Radiation Programs (ANR-460)
Environmental Protection Agency
401 M Street, S.W.
Washington, DC  20460
(202) 260-9620
Mr. Felix Rogers
Health Scientist
Centers for Disease Control
1600 Clifton Road, MS:F28
Atlanta, GA 30333
(404) 488-4613

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 Ms. Debra Shults
 Environmental Specialist V
 Division of Radiological Health
 TERRA Building, 6th Floor
 150 9th Avenue, North
 Nashville, TN 37243-1532
 (615) 741-7812
 Dr. John A. Volpe
 Ph.D., Manager, Radiation Control
  Branch
 Kentucky Cabinet for Human Resources
 275 East Main Street
 Frankfort, KY 40621
 (502) 564-3700
 Mr. Marlow J. Stangler
 Federal Emergency Management Agency
 SLPS-OTH-RP
 500 C Street, S.W., Room 633
 Washington, DC 20472
 (202) 646-2856
Mr. Robert W. Terry
Senior Health Physicist
Radiation Control Division
Colorado Dept. of Health
4210 East llth Avenue, Room 54
Denver, CO 80220-3716
(303) 331-4816
Mr. Paul Wagner
Radiological Health Officer
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 347-3907
Mr. Vern Wingert
Chief, Policy Development Branch
Federal Emergency Management Agency
500 C Street,  S.W., Room 633
Washington, DC 20472
(202) 646-2872
Ms. Sandra J. Threatt
Radiological Emergency Planning
  Coordinator
South Carolina Department of Health
  and Environmental Control
Bureau of Radiological Health
2600 Bull Street
Columbia, SC 29201
(803) 734-4629
Mr. Robert Trojanowski
Regional/State Liaison Officer
Nuclear Regulatory Commission
Region II, Suite 2900
101 Marietta Street, N.W.
Atlanta, GA 30323
(404) 331-5599
Mr. Gary N. Wright
Senior Nuclear Engineer
Illinois Department of Nuclear Safety
1035 Outer Park Drive
Springfield, IL 62704
(217) 785-9867
Mr. Sam Windham
Director, National Air and Radiation
 Environmental Laboratory
Environmental Protection Agency
1504 Avenue A
Montgomery, AL 36115-2601
(205) 270-3401
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       WORKSHOP ON IMPLEMENTATION OF PROTECTIVE ACTIONS
                     FOR RADIOLOGICAL INCIDENTS
              AT OTHER THAN NUCLEAR POWER REACTORS

                     WORKING GROUP ASSIGNMENTS
Working Group A

James C. Hardeman Jr. (GA), Leader

Harlan W. Keaton (PL)
Bernard Bevill (AR)
Leslie P. Foldesi (VA)
S.W. (Felix) Pong (NC)
Jon Richards (EPA, Region IV)
Felix Rogers (CDC)
Marlow J. Stangler (FEMA)
Working Group B

Stanley R. Marshall (NV), Leader

Sandra J. Threatt (SC)
Robert Mooney (WA)
Gary W. Butner (CA)
Paul Wagner (EPA, Region IV)
Bradley Nelson (EPA, ORP)
Philip C. Nyberg  (EPA, Region VIII)
Vern Wingert (FEMA)
Robert Trojanowski (NRC, Region II)
William Phillips (EPA, EMSL-LV)
Working Group C

Gary N. Wright (IL), Leader

William Condon (NY)
Robert Baumgartner (ID)
Robert W. Terry (CO)
John A. Volpe (KY)
Cheryl L. Malina (EPA, ORP)
Larry Jensen (EPA, Region V)
Working Group D

Debra Shults (TN), Leader

Kevin Driesbach (OH)
Aubrey V. Godwin (AL)
Eloy A. Garcia Jr. (NM)
Clarence L. Born (TX)
Jim Rabb (CDC)
Thomas Reavey (EPA, ORP)
John C. Heard (FEMA, Region IV)
Colleen F. Petullo (EPA, ORP/LVF)
                                    11

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        WORKSHOP ON IMPLEMENTATION OF PROTECTIVE ACTIONS
                       FOR RADIOLOGICAL INCIDENTS
               AT OTHER THAN NUCLEAR POWER REACTORS

                       U.S. Environmental Protection Agency
                           Office of Radiation Programs
                National Air and Radiation Environmental Laboratory
                                 1504 Avenue A
                              Montgomery, Alabama

                              September 25-26, 1991
                                   AGENDA
 Workshop Objective
 The principal objective is to provide a forum for the States to identify and discuss issues
 regarding implementation of protective actions following a radiological accident involving a
 Federal or Commercial Facility, with emphasis on source terms other than power reactors.
 It is not expected that issues will be resolved or guidance developed at this workshop.


 September 25, 1991

 8:00 to 8:30 a.m.   Registration
                 Cheryl L. Malina, Bradley Nelson, Thomas Reavey (EPA, ORP)
8:30 a.m.
8:50 a.m.
9:10 a.m.
9:30 a.m.
               Plenary Session
  Moderator:  Allan C.B. Richardson (EPA, ORP)

Welcome and Introduction
      Sam Windham (EPA, NAREL)
Welcome
      Aubrey V. Godwin (AL)

Overview of the Workshop
      Allan C.B. Richardson (EPA, ORP)

Lessons Learned From Emergency Planning at Hanford
      Robert Mooney (WA)

Generic Nonreactor Source Terms:  Transuranics,  Tritium,  Other
Possibilities
      To be Announced (DOE/DOD)
                                      13

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Agenda
September 25, 1991 (Continued)
 9:50 a.m.



10:10 a.m.



10:30 a.m.

10:45 a.m,



11:05 a.m.


11:25 a.m.


11:45 a.m.



12:05 p.m.

 1:10 p.m.
  The Relationship Between Protective Action Guides and Emergency
  Planning Zones
        Robert Trojanowski (NRG, Region II)

  The Basis for Protective Action Guides and Their Application to Non-
  reactor Source Terms
        Allan C.B. Richardson (EPA, ORP)

  Break

  Implementation  of Protection Action Guides at a  Large  Plutonium
  Processing Facility
        Philip C. Nyberg (EPA, Region VIII)

  Mixed Hazard Incidents (Chemical/Nuclear Incidents)
        William Klutz (EPA, Region IV)

  Arkansas' Titan II Experience
        Bernard Bevill (AR)

  Review on the Basis of Guidance for Sheltering as a Protective Action in
  a Plutonium Release Accident
        Bradley Nelson (EPA, ORP)

  Lunch

  Tour of Lab
  2:00 p.m.
2:15 p.m. to
 5:30 p.m.

8:30 a.m. to
 10:00 a.m.
             Working Group Sessions
Working Group A Leader: James C. Hardeman Jr. (GA)
  Working Group B Leader: Stanley R. Marshall (NV)
    Working Group C Leader: Gary N. Wright (IL)
     Working Group D Leader: Debra Shults (TN)

  Organization of Working Groups
        Allan C.B. Richardson (EPA, ORP)

  Working Group Discussions and Drafting of Summary Reports
  Working Groups Meet to Organize Presentations
                                       14

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Agenda
September 26, 1991
10:00 a.m.

10:45 a.m.

11:00 a.m.

11:45 a.m.

12:30 p.m.

 1:30 p.m.

2:15 p.m.


3:00 p.m.
               Plenary Session
       Moderator: Aubrey V. Godwin (AL)

Working Group A Presentation and Discussion

Break

Working Group B Presentation and Discussion

Working Group C Presentation and Discussion

Lunch

Working Group D Presentation and Discussion

Audience Discussion and Review of the Most Important Issues
     Aubrey V. Godwin (AL)

Closing Remarks and Adjournment
     Allan C.B. Richardson (EPA, ORP)
                                      15

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SPEAKERS' PAPERS

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                      WELCOME AND INTRODUCTION

                                  Sam Windham

              National Air and Radiation Environmental Laboratory
                          Office of Radiation Programs
                      U.S. Environmental Protection Agency
                              Montgomery, Alabama
      As director of the National Air and Radiation Environmental Laboratory (NAREL),
I would like to welcome you here for this important meeting.  Cheryl Malina and Allan
Richardson from the Office of Radiation Programs (ORP), and Dr. Charles Petko, from the
laboratory, have worked to assure the meeting is a success and that the time you spend here
is productive and pleasant.

      For those of you who may not be familiar with the NAREL, we are an environmental
radiation laboratory, a part of the ORP.  The laboratory was first established in 1959 in
support of the  Bureau of Radiological Health, and when the Environmental Protection
Agency (EPA)  was formed in 1970, we were transferred to EPA.  Not only  do we work
closely with our ORP headquarters organization, but we also support EPA regional  offices
and other federal and state government agencies in environmental radiation related projects.
The laboratory has a staff of 39 federal employees and about 30 other employees who are
contractors, co-op students, etc.

      About 18 months ago, we moved into our new facility, a 65,000 square foot modern
laboratory, of which we are very proud.  We have set aside a time during this meeting to
take you on a tour of the facility.

      We have arranged to have lunch each day at the Gunter Air Force Base Club adjacent
to the  lab. There is a room reserved to accommodate our group.  Our  receptionist will
handle messages for you during the meeting. Please check with  her at the front desk at each
break.  Again, welcome to the NAREL, we are glad you are attending the PAG workshop.
If there is anything the NAREL staff or I can do to assist you  during your visit, please let
us know.
                                       19

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                                  WELCOME

                               Aubrey V. Godwin

                          Division of Radiation Control
                          Department of Public Health
                             Montgomery, Alabama
      On behalf of Governor Hunt, welcome to Alabama. We anticipate a good meeting on
the PAGs. I hope you found the accommodations in good order. This is a fine facility, and
I am sure the Environmental Protection Agency (EPA) will want to show you around as
then* guests.

      This workshop is to discuss the problems of implementing the PAGs for federal
facilities. The Guides are out and are not being discussed at this workshop. The results of
this workshop will be used by the federal agencies to identify problems and to develop policy
regarding those problems.  So, now is your opportunity to affect the National policies which
may be developed.
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                       OVERVIEW OF THE WORKSHOP

                               Allan C.B. Richardson

                            Guides and Criteria Branch
                           Office of Radiation Programs
                       U.S. Environmental Protection Agency
                                Washington, D.C.
 Introduction

      Welcome to this Workshop on Implementation of Protective Actions for Radiological
 Incidents at Other Than Nuclear Power Reactors. (I will elaborate on the slight change in
 emphasis represented by the current versus the previously announced title later.)  The
 planning group has put forth considerable effort to bring this workshop together, and it is
 our hope that the information developed here will be of great value in identifying any new
 guidance needed for the host of different situations that the Protective Action Guides (PAGs)
 now address, in contrast to their original focus - commercial nuclear power reactors.

      We hosted a  similar workshop  two years ago on  Protective  Action  Guides for
Accidentally  Contaminated Food and Water in  Washington, D.C.  The purpose of that
 workshop was to identify issues and relevant experience that should be considered in the
 development  of PAGs for water and food.  It was, I believe, a clear success and helpful to
 those responsible for the development of PAGs for ingestion.  Several of you participated in
 that workshop and I want to thank you again for your assistance. You will be familiar with
 the process today and tomorrow, since it will be very similar.

      We are also taking advantage of the opportunity provided by this workshop to show
off our new laboratory, which has been open for less than two years. We believe this to be
the best  environmental radiation laboratory in the country, and possibly in the world, and
are quite proud  of it.  The  Environmental Protection Agency (EPA)  is in great debt to
Charlie Porter,  whom I am sure many of you  know, for conceiving  the  idea of a new
laboratory and for pushing it through the bureaucracy to completion over a period of several
decades.  Charlie retired last year and Sam Windham, who has been involved in management
at the EPA Radiation Facility in Montgomery for many years and who participated in the
design of this new facility, is the new Laboratory Director.  He has agreed to conduct a tour
this afternoon for all of the workshop participants.

Participants and Roles

      Co-sponsors of this  workshop are the EPA, the Federal Emergency Management
Agency (FEMA),  the Department of Agriculture (USDA), the Food and Drug Administration
(FDA), and the Conference of Radiation Control Program Directors, Inc., (CRCPD).  Our
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Planning Committee  for the workshop included  Aubrey Godwin (AL-CRCPD), Marlow
Stangler (FEMA), Janet Quissel (USDA), Donald Thompson (FDA), Jim Rabb, Centers for
Disease Control (CDC), Rosemary Hogan, Nuclear Regulatory  Commission (NRC), Jim
Fairobent, Department of Energy (DOE), Michael  Schaeffer (DNA) and myself from EPA.
We are responsible for the  organization of the workshop, including development  of the
agenda. Cheryl Malina (EPA) has been responsible for the administrative effort required to
make everything happen. Joe Logsdon, formerly of EPA, did most of the work on suggested
issues for the working groups. The CRCPD arranged for invitations to State representatives
who have major nonreactor nuclear facilities in their State.  The CRCPD has also agreed to
manage the publication of the proceedings  document.

      EPA recommended PAGs for the early phase in 1975 (and revised them in 1980).
These PAGs applied  to planning and  carrying out radiological emergency response  at
commercial  nuclear power facilities.  The  1975 (and 1980) PAGs addressed the need for
evacuation or sheltering, based on projected doses to the whole body from external gamma
radiation and to  the  thyroid from  inhalation of  radioiodine.   Inhalation  of particulate
materials and exposure of the skin to beta emitters were not considered. Thus, emergency
response planners have had no PAGs for evacuation and sheltering for source terms where
neither whole body exposure to gamma radiation nor inhalation of radioiodines are the
leading exposure pathways.

      In response to this need, EPA has now developed revised  PAGs for evacuation and
sheltering that apply to all types of nuclear incidents (except, of course, nuclear war).  Last
year we issued similar PAGs for relocation.  Since states are responsible for implementing
PAGs, and have extensive experience in implementing them during exercises  of emergency
response plans for commercial nuclear  power facilities, we thought it would be useful to
provide an opportunity for the states to collectively identify and evaluate  potential problems
associated with implementation of these new PAGs at nonreactor nuclear faculties. We
have,  therefore, organized this workshop and invited emergency preparedness officials from
all of the states  that have  major nonreactor nuclear facilities.  We have also invited
representatives from the Federal agencies that would provide assistance in the event of a
radiological incident with potential offsite consequences.

      I noted the change in the workshop title earlier. We have expanded the scope of this
meeting from incidents at Federal facilities to any incident not caused by  a commercial
power reactor. We made this change, in response to suggestions from DOE, the Department
of Defense (DOD), and FEMA, because we believe it makes good sense. The new PAGs now
apply to any nonreactor source term, not  just those at Federal facilities, the nonreactor
sources that most readily come to mind.  Other examples now covered by the PAGs include,
among others,  fuel cycle faculties licensed by  the NRC, satellites using nuclear  power
sources, and radiopharmaceutical manufacturers.  You may also have noticed the absence
of DOE and DOD as co-sponsors. We regret this. They were invited. They have advised us
that they do not feel comfortable with this sort of meeting at this time,  and do not believe
it would be productive. I hope we will prove their apprehensions  wrong on both counts.  It
is not our intention to focus on possible past inadequacies, but on what we need to do in the
future.  In any case, the results of this workshop will be available to all in published form.
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      The purpose of this workshop, then, is to provide a forum for State and Federal
officials to identify and evaluate the issues and problems associated with implementation of
the new PAGs in the event of an incident at a nonreactor nuclear facility.  However, since
there is so much experience in planning and exercising of plans for incidents at commercial
nuclear power plants, we should make a particular effort to evaluate the extent to which
plans and procedures for nonreactor facilities can be the same as, as well as where they
should differ from,  those developed for power plants.   For incidents at  some of these
facilities,  it will also be appropriate to consider the  issues and problems associated with
response to incidents involving simultaneous releases of chemically toxic and radioactive
materials  (mixed releases), and we have included a special working group to focus on this
problem.

Format for the Workshop

      As you can see from the agenda, the workshop will consist of two plenary sessions and
one working group session.  This first  plenary session is intended to provide background
information that may stimulate you to identify issues or problems that should be discussed
by the working groups. Each presentation in this session is scheduled for 15 minutes, with
an additional 5 minutes for questions. Although there is limited time, I plan to be somewhat
flexible  with regard  to individual presentations.  In other words, we do not want to miss
important information because of a time constraint, but, on the other hand, speakers, please
do not feel obligated to use all of your allotted time. If questions and discussions tend to be
lengthy, they will be deferred to the appropriate working group in the afternoon session.
A second  plenary session will be convened tomorrow  morning to hear and discuss  the
deliberations of the working groups.  Then, tomorrow afternoon, we will attempt to sum up
what we have learned.

Working Groups

      The planning group prepared a list of topics that included all of the relevant issues
that we could identify.  After categorizing them into four topic areas (one for each working
group), they were sent to each of you with a request to identify your first, second, and third
choices for working group assignments. We have reviewed your selections and have assigned
each of you to a working group as shown on one of the handouts. Noone has been given his
third choice, although a few of you  did not get assigned to your first choice. I will make
additional assignments, if necessary,  and provide additional suggestions regarding operation
of the working groups when they are convened this afternoon. If anyone is not happy with
their assignment please see me during lunch.

Use of Workshop Results

      We  do not expect this workshop to produce consensus solutions or recommendations.
However, we encourage individuals to express opinions or to make recommendations on any
relevant issues.  Also, if consensus opinions can be developed on what the outstanding needs
are, we will welcome their presentation.
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      The proceedings of the workshop will include the papers that were presented in the
plenary session plus any others that were submitted for use or consideration by the working
groups. It will also include summaries prepared by each of the four working groups.  The
document will then be distributed to all of you, to relevant Federal agencies, and to any
other interested parties. Most importantly, I hope it will be a useful resource for identifying
any additional  guidance and for identifying any  special  plans or procedures needed for
emergency response based on these new PAGs.

      Thank you for coming. I hope that when you leave you will feel that your time has
been well spent. If you have any questions about the workshop, either now or later, please
do not hesitate to ask either me or any of the other EPA staff members present.
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  LESSONS LEARNED FROM EMERGENCY PLANNING AT HANFORD

                                 Robert Mooney

                              Nuclear Safety Section
                         Division of Radiation Protection
                              Department of Health
                               Seattle, Washington
Introduction

      Thank you for the opportunity to speak at this workshop. My involvement with the
Environmental Protection Agency (EPA) and Protective Action Guides (PAGs) dates back
to the 1970's.  I am pleased we are finally bringing federal faculties into the emergency
planning process. My remarks will not cover the technical aspects of PAGs. The working
groups provide the forum for us to do that. Instead I will deal with two main concepts which
are poorly understood in emergency planning.  Since they are so poorly understood, when
it comes time to implement protective actions, the parties involved experience both grief and
consternation.    These  two  concepts  are  Guidance  versus  Legal  Authority and
Recommendations versus Decisions.  Following a discussion of these two concepts, I will
elaborate on lessons learned from our experience at Hanford.

Guidance versus Legal Authority

      Usually overlooked in the application of PAGs is the fact that they are exactly that,
Guides. Quoting from the Federal Register of October 22,1982, "these recommendations are
voluntary guidance to State and local agencies."  (1) The legal authority for protecting public
health and safety rests with the state and/or local government.  Therefore, when  federal
guidance becomes "official," the process is not over. It has just begun. Failure to address this
key point sets up recurring pitfalls in implementing PAGs.

Recommendations versus Decisions
issue.
      The Legal Authority issue leads directly to the Recommendations versus Decision
       Once an accident occurs at a nuclear facility, facility operators are responsible to
provide Recommendations to the offsite agencies responsible for public health and safety.
The agency with the legal authority then must make a Decision and implement it.  Buried
in the emergency planning trees, we often forget that the purpose of the forest is to make
the process between the start of the accident and implementation of a protective action
decision fast, smooth and effective.  The offsite decisions  must range from NO  ACTION
(minor accident) to AUTOMATIC EVACUATION (major accident).
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       There is a big gray area between these two extremes.  For adequate public health
 protection to occur when we find ourselves in the gray area, trust and credibility must be
 strong and communications must be flawless. For nuclear power plants, over ten years of
 planning and exercises have brought us a long way down that road. For Federal exercises,
 we have  barely begun the journey.  Also, Federal facilities start with a major credibility
 problem.   Because of this, one would expect Federal officials to spend major efforts on
 effective communications.  Yet the opposite is happening.

       At  recent Federal exercises I have evaluated, the entire communications with offsite
 agencies is shunted to a third party "communicator."  No one-to-one conversations occur
 between onsite and offsite decision makers.  This problem of poor personal communications
 is well documented in a report titled, Human Factors of an Emergency Response Center by
 Moray, Sanderson, and Vicente. (2) The report identifies three inputs required for effective
 decision making:

       (1)  Status data from the facility.
       (2)  Data on meteorology and health physics.
       (3)  Data on the status of offsite agencies.

 It is this third area where serious inertia exists. Progress cannot really begin until Federal
 officials see offsite agencies as equal partners in the joint mission of protecting public health
 and safety.

      Once this equal partnership framework is established, major technical differences
 must be resolved.  I call this the Fix Fatal Flaws process.  The Flaws we are striving to
 fix at Hanford are:

      o     Planning Basis
      o     Planning Zones
      o     Long Term Stable Funding
      o     Independent Regulatory Oversight

Planning Basis

      It is ironic that emergency planning at Hanford has begun after all major facilities
have been shut down.  At one time, Hanford included fuel fabrication, nine production
reactors, plutonium extraction, and waste storage.  Thus the entire nuclear fuel cycle,  except
for enrichment and uranium milling was represented at Hanford. Now the only operating
facility is the FFTF breeder reactor, and it is expected to shut down soon.  So what accidents
are left that we might have to respond to?  There are two major sources of significant
radionuclide inventory: spent fuel from the last years of N reactor operations, and over 100
tanks of high level radioactive waste. The tanks have been identified as having potential for
significant explosions due to ferrocyanide and hydrogen gas.  What Safety Analysis Reports
(SARs) do exist have been shown to be inadequate (3). Thus no technical basis exists that
defines the maximum credible accidents which could occur at Hanford.
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Planning Zones

      In the absence  of a sound technical basis for  planning,  the  establishment  of
appropriate planning zones sits in limbo.  The State's position has been to use the nuclear
power plant 10- and 50-mile planning zones as a default until adequate SARs can justify
something else.  Rather than  a 10 mile planning zone for the plume pathway, the U.S.
Department of Energy (DOE) uses a 4.5 mile zone for their spent fuel storage facility.
Ironically, the 4.5 mile  zone magically stops just short of the Hanford boundary. DOE has
been unresponsive to the State's efforts to resolve this issue.

Long Term Stable Funding

      Washington's position on emergency  response funding is that the facility pays the
costs of state and local agency planning efforts. In 1981, Governor Spellman of Washington
wrote to DOE requesting funding support for emergency planning at Hanford. Nine years
later,  in March 1990, the state received the first funds from DOE to  begin emergency
planning at Hanford. In accepting these funds, the state documented that the initial funding
was inadequate, and laid out a three year budget that was consistent with our ten year old
planning program for nuclear power plants.  Eighteen months later,  we are still negotiating
with DOE for adequate funding.

Independent Regulatory Oversight

      Presently, emergency planning at federal facilities is done on a voluntary basis. Thus
the criteria at Hanford  are established by DOE in a vacuum.  The Conference of Radiation
Control Program Directors, Inc. (CRCPD) went on record this year to bring federal facilities
under the same regulatory umbrella as private industry. This is a key milestone in bringing
credibility and a sound technical basis to emergency planning at Hanford.

      The State of Washington has partial regulatory authority over Hanford operations.
This includes authority over chemical and toxic wastes, waste clean-up operations, and air
emissions of radionuctides.  Neither Washington nor any other state or federal agency has
authority to require emergency planning.

      In closing, two conditions need to be established at Hanford to effectively implement
PAGs:

      Equal  Partnership

      Fix Fatal Flaws

These conditions require a major cultural change to occur on the part of DOE, and major
state and federal legislative actions. In the  meantime, state and local officials have begun
the process of emergency planning.  In the event the accident happens "today", we aim to be
as prepared as resources allow.

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3.
                           REFERENCES

Food and Drug Administration, Accidental Radioactive Contamination of Human Food
and Animal Feeds: Recommendations for State and Local Agencies, Federal Register.
Vol. 47, No. 205, October 22, 1982, p. 47074.

Moray, N., Sanderson, P., and Vicente, K., Human Factors of an Emergency Response
Center:  A Field Study,  Third  Topical Meeting on Emergency Preparedness and
Response, April 17, 1991, Chicago, Illinois.

General Accounting Office, Consequences of Explosion ofHanford's Single-Shell Tanks
Are Understated, October 1990.
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    THE RELATIONSHIP BETWEEN PROTECTIVE ACTION GUIDES
                   AND EMERGENCY PLANNING ZONES

                               Robert Trojanowski

                       U.S. Nuclear Regulatory Commission
                                    Region II
                                 Atlanta, Georgia
Introduction

      Good morning. The Nuclear Regulatory Commission (NRC) is pleased to participate
in this interesting and important workshop.

      In order to discuss the relationship between the Protective Action Guides (PAGs) and
the Emergency Planning Zones (EPZs), it is important to take a brief historical perspective
as to the basis for the development of each of these concepts. The PAGs and the EPZs,
which as you know, have been subsequently implemented as "guidance tools" and "planning
mechanisms,"  respectively.   Also,  it  is important to historically review  the  Federal
regulations and guidance as related to emergency preparedness, both prior to and after the
accident at the Three Mile Island (TMI) facilityi in order to fully understand how we got to
where  we are from where we were in the early days of the commercial nuclear power
industry.

      These are some of the things I would like to discuss with you today, and then during
the workshop phase of this program, we can hopefully have a thorough discussion of how
these concepts can  be applied to radiological incidents  involving Federal facilities.
Unfortunately, I understand that the representatives from the Department of Energy (DOE),
Department of Defense (DOD), and the National Aeronautical and Space Administration
(NASA) who were expected to participate in this workshop will not be joining us today.

The Period Before the Incident at TMI

      Yankee Rowe, located in Western Massachusetts was the first licensed nuclear power
reactor to go on-line and began commercial operation  in July 1961.  Others were licensed
and came on-line shortly thereafter.  During this early period of the commercial nuclear
power industry, emergency planning considerations were initially set forth in Title 10,
Department of Energy, Code of Federal  Regulations, Part 100 (10 CFR 100), Reactor Siting
Criteria, which was published in 1962.  These 10 CFR 100 criteria specified that for each
reactor site an exclusion zone (EZ), low population zone (LPZ), and a population center be
established and identified.  By definition, the utility operator was required to have total
control over the EZ, which essentially meant that this area was company-owned property.
Its exact size was determined through accident analyses consistent with the criteria specified
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 in 10 CFR 100 which required that an individual located on any boundary point of the EZ
 for a two-hour period  immediately following a fission product release from the  reactor
 coolant would not receive a total radiation dose of 25 rem whole body or 300 rem to the
 thyroid from plume exposures.

      The size of the LPZ was similarly defined such that an individual located on any point
 of its outer  boundary  continuously  over  a thirty day period would not receive  a  total
 radiation dose in excess of 25 rem whole body or 300 rem thyroid from fission product plume
 exposures. Additionally, the utility operator was required to demonstrate that there was a
 reasonable probability that appropriate protective measures, including evacuation, could be
 taken to protect the LPZ populace in the event of an accident.  LPZs were generally defined
 at distances of two to three miles from the site. Regarding the designated population center,
 no  dose guidance values were  given, but were assumed  to be lower than those values
 associated with the LPZ. Population centers were generally defined as the areas within fifty
 miles of the site, and the utility operator was required to demographically characterize these
 areas.   Not a great deal of concern  was given to the need for implementing protective
 measures in the designated population centers, since the dose criteria established for the EZ
 and LPZ were considered to be extremely conservative based on the site-specific calculated
 doses over a broad range of design-basis  accidents.

      This general philosophy prevailed during the decade, and although in a traditional
 sense the state and local governments are responsible for public health and safety, these
 entities did not play a large role in emergency planning around commercial nuclear power
 plants.  The risks from  these facilities were generally considered to be consistent with the
 risks associated with other industrial facilities such as steel  making plants, chemical plants,
 etc., and the utility operators were bound by the regulations specified in 10 CFR 100.  In this
 regard, engineered safeguards were designed and put in place to mitigate the consequences
 of all identified design-basis accidents.   Hence,  the general thinking was that the public
 domain was not at risk  even for the class 9 accident, i.e., core melt or containment failure.
 While the occurrence of a class 9 accident was plausible, the probability of it happening was
 thought to be so small that no special emergency planning requirements were considered to
 be necessary.

      In  1970,  10  CFR 50,  Appendix E  was  published  which  did  contain  explicit
 requirements for dealing with emergencies; however, these requirements were again directed
 to the utility operators, and required them to include provisions in their emergency plans
 for participation of offsite governmental authorities or outside groups. The obvious dilemma
 which developed is that the  Federal Government did not have statutory authority over the
 states and local governments with regard to emergency planning, yet the  utility operators
 were required  to  incorporate governmental  participation  into their  emergency planning
 process.  At best, this could only be accomplished on a cooperative basis but raised questions
 of effectiveness and legal liability.

      During the period of the early to mid seventies not only was there an increase in the
 number of power plants coming on-line commercially, but the reactor core inventories were
being substantially increased. Consequently, both the states and Federal Government began
to raise concerns  regarding the potential offsite consequences to  the general public  as a

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 result of a major accident.  Additionally, the Federal Government  also questioned the
 capability  of state and local governments in responding to a major nuclear incident,
 particularly in light of the Federal regulations  which required the utility  operators to
 coordinate  state and  local government participation  into  the overall response effort.
 Consistent with these concerns, the NRG published the WASH-1400, Reactor Safety Study,
 in 1975; and,  the Environmental Protection Agency (EPA) developed and published the
 Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, also in
 1975.  In  1976, the Conference of Radiation Control Program Directors,  Inc. (CRCPD)
 petitioned the  Federal Government to identify  the offsite threat, and to assist  in the
 development of state and  local emergency plans.   In  response to these requests, NRC
 published NUREG-75/111, Guide and Checklist for Development and Evaluation of State and
 Local Government Radiological Emergency Response Plans in Support of Fixed Nuclear
 Facilities.  Regarding the identification of the offsite threat, a joint  NRG/EPA Task Force
 on emergency  planning was formed  and its findings  were  published in NUREG-0396/
 EPA-520/1-78-016, dated December 1978, Planning Basis for the  Development of State and
 Local Government Radiological Emergency Response Plans  in  Support of Light Water
 Nuclear Power Plants.  These actions gave rise to the Regional Advisory Committees (RACs)
 which were originally chaired by NRC, and the joint Task Force findings established the
 concept of the 10-mile plume EPZ and the 50-mile ingestion EPZ.   Initially, the RAG
 program was strictly voluntary for the states and the Federal Committees assisted in the
 development of state emergency plans, to include testing these plans in exercises.  The RACs
 had no statutory jurisdiction and consequently, the state plans were not "approved" by the
 RACs, but  rather the Committee simply granted a statement  of "concurrence."   This
 statement of concurrence acknowledged that the plan was developed in accordance with the
 NUREG-75/111 guidance criteria, concurred in by the RAC, and successfully tested by means
 of a demonstration exercise.

      The joint NRG/EPA findings concluded that the major threat for design-basis accidents
 to be in the range of 2 to 5 miles, and out to ten miles, and possibly beyond, for the class 9
 accident.  The relationship between EPA PAGs of 1 rem to 5 rem  whole body, and 5 rem to
 25 rem thyroid, and the establishment of a ten  mile EPZ is an extremely conservative
 approach to emergency response.  The Task Force concluded that incident response generally
 would not involve taking response actions in the entire ten mile EPZ, but if necessary,  the
 detailed essential planning mechanisms would be  in place.

 The Period After the Incident at TMI

      As you know, after the accident  at the TMI facility, greater emphasis was placed on
 emergency preparedness concerns.   The NUREG-75/111 guidance  criteria  became  the
 foundation  for NUREG-0654/FEMA-REP-l, which  placed more emphasis  on defining
 emergency organizations, communications, notifications, alert and notification systems, etc.
Additionally, the ten and fifty mile EPZ concepts which were derived in the joint NRG/EPA
 Task  Force study  were also  incorporated into  NUREG-0654.   Federal  Emergency
Management Agency (FEMA), through Executive  order, was given responsibility for offsite
emergency preparedness. Consequently, the Chair of the RACs was transferred to FEMA
from NRC, while NRC retained regulatory jurisdiction for emergency preparedness onsite.
NRC also revised its regulation  in 10 CFR 50, Appendix E to incorporate the planning

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 standards in NUREG-0654.

      Although the NRC did not have  statutory authority  over  the state  and local
 governments, its regulations authorized the operation of commercial nuclear power plants
 only in those states which have implemented a FEMA-approved emergency plan. Hence, the
 RAG program  which heretofore was  advisory and voluntary,  shifted to  a more  formal
 program and became somewhat regulatory.  This basically brings us to where we are today,
 and I assume that most of you are familiar with FEMA's plan review and approval process,
 as well as their program for evaluating exercises.

 Emergency Planning Requirements for Fuel Processing Facilities

      In contrast to the emergency preparedness requirements for reactors, I want to briefly
 comment on the NRC regulations governing fuel processing facilities. These regulations are
 contained in  10 CFR 70.22. Based on worst case accident analyses, which show that 1 rem
 effective  dose at the site boundary will not be exceeded, there are no established EPZs for
 NRC licensed fuel processing facilities.  Also, the regulations were revised to eliminate the
 "Unusual Event" and "General Emergency" classifications. I only mention these regulations
 to show that the risk to the public is based on the source term activity and potential offsite
 effect, and that the concept of EPZs is really only a planning mechanism, i.e., worst case
 accident  analyses may  indicate that the delineation of a specific EPZ is not necessary to
 protect public health and safety.

Relationship Between PAGs and EPZs

      The PAGs were  developed and published by  EPA in 1975.  As you know, they  are
expressed over a range for whole body exposures and exposures to a child's thyroid. EPA
intends that the PAGs  be utilized as guidance for triggering appropriate  protective actions
in order to protect public health and safety and to minimize exposures to the general public
and emergency  workers.  The PAGs should not be  viewed as acceptable dose limits; and,
although  the PAGs and EPZs complement each other, they should not  be utilized  to
determine the size of an EPZ, i.e., the boundary at which the whole body PAG is exceeded
should not be the EPZ  demarcation boundary.

      EPZs are planning mechanisms  which, for  any given facility, are  based on a whole
range of accidents and other variables such as population demographics, meteorological data,
terrain,  ingress and egress routes, etc.   They  should be  developed  and defined in a
conservative manner such that in the event of an accident, incident response will not involve
the entire EPZ, but if necessary,  appropriate emergency plans  are in place.   Incident
response  beyond the EPZ, if necessary, will have to  be developed on an ad-hoc basis at the
time; however, if the EPZ is properly defined, such actions will be unlikely.

      As I previously mentioned during our discussion of NRC licensed fuel processing
facilities,  if an EPA PAG cannot be exceeded at the facility boundary, there should be no
need to develop and define an EPZ for such a facility.
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      Before closing, I would like to briefly discuss the current philosophy within the NRC
regarding evacuation relative to power reactor incidents.  Presently, at the declaration of
general emergency, the NRC regulatory scheme requires that, at a minimum, licensees
recommend that sheltering be implemented in the area encompassing the 0-2 mile radius
of the plant. However, the current thinking, as noted by some of you as expressed in NRC's
Response Technical Manual 91 (RTM-91), calls for the automatic evacuation of the 0 - 2 mile
sector at the declaration of a general emergency.  Currently, actions are under way within
the NRC to adapt this scheme as a regulatory requirement.  Please note that this evacuation
may be based solely on plant conditions in the absence of an actual radiological release, and
obviously, prior to reaching an EPA PAG trigger level.

      I would be happy to respond to any questions you may have.
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             THE BASIS FOR PROTECTIVE ACTION GUIDES
    AND THEIR APPLICATION TO NON-REACTOR SOURCE TERMS

                              Allan C.B. Richardson

                           Guides and Criteria Branch
                          Office of Radiation Programs
                      U.S. Environmental Protection Agency
                                Washington, D.C.
Overview

      The Protective Action Guides (PAGs) for decisions on evacuation and sheltering (also
known as the PAGs for the early phase) were first published in the  Environmental
Protection Agency  (EPA) Manual of Protective Action Guides and Protective Actions for
Nuclear Incidents in 1975, and were reissued in slightly revised form in 1980.  In 1990, we
added PAGs for  relocation as well as the 1982 recommendations of the Food  and Drug
Administration (FDA) on PAGs for food. As you know, EPA has been in the process of
revising the PAGs for the early phase since early in the 1980s.  My discussion today will
focus primarily on the reasons why the PAGs required revision and the considerations that
have led to the new PAGs.   I will also touch on implementation guidance that we have
developed for these new PAGs, including examples of some recent situations to which they
have been applied.

      There are three types of problems that Jsd to the decision to update  the 1975 PAGs
for the early phase of a nuclear incident.  First, the scope of the PAGs was inadequate; e.g.,
some important exposure pathways were not covered and the source term  did not include
long-lived materials. Second, we needed to consider new radiation risk projections. Finally,
implementing guidance for use  of the  range and the choice  between evacuation  and
sheltering had been occasionally misinterpreted and required clarification.

The PAGs Were Limited in Scope

      a)    Limited Source Term

           The  old PAGs for the early phase were adequate for protection of the general
           public  from a reactor accident, but they did not apply  to other nuclear
           incidents, unless the principal exposure was  from radioactive noble gases or
           radioiodines.  This is the case because these PAGs were developed specifically
           for atmospheric releases from power reactors, for which  the leading pathway,
           in terms of health effects, is either whole body exposure to gamma radiation
           from the  plume (plume shine), or thyroid exposure from  inhalation of
           radioiodines.   The deficiency is most  noticeable  in  planning for  incidents
                                       37

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       involving releases of particulates when radioiodine is not a major component.

       To put the matter succinctly, we needed to generalize the PAGs so they would
       apply to the dose from any combination of radionuclides. The new PAGs solve
       this problem simply; they are now expressed in terms of effective dose, rather
       than whole body or  organ dose.  This  assures that dose to any  organ is
       accounted for, regardless  of the radionuclide  or pathway.  We have  also
       developed dose conversion factors for 141 radionuclides that cover almost any
       conceivable incident; these have been added to the implementation guidance.
       However, there were other problems.

b)     Long Term Exposure

       Whole body dose from exposure to a plume only accumulates while the plume
       is present. And,  due to the short half-lives of most radioiodines, thyroid dose
       from short-term inhalation of radioiodines also accumulates over a short period
       of time.  However,  inhalation of long-lived particulates results in doses that
       accumulate over a long period, in some cases for a lifetime. Similarly, surface
       deposits of long-lived particulate materials can result in long-term exposure due
       to inhalation of resuspended materials.  Since, as we will  see  later, risk of
       delayed health  effects from radiation dose is the primary basis for selection of
       the PAGs, all of these doses should be  considered for decisions on protective
       actions.

       The PAGs that have already been developed for relocation take into account
       long-term exposure to deposited  materials during the intermediate phase, both
      direct whole body exposure and inhalation of resuspended materials, because
      they are expressed in terms of the committed  dose, rather than annual dose.
       However,  long-term internal dose from inhalation of particulate materials from
      the plume were not addressed by the 1975 PAGs for evacuation and sheltering.
      This deficiency has been solved by expressing these PAGs in terms of the
      committed dose as well.

      Thus, we have now adopted, for emergency response, both of the improvements
      introduced by ICRP-26 in  1977 and in use now for a number of years in
      regulation of occupational  exposure  and exposure of the public to routine
      releases, the concepts of effective and of committed dose.

c)     Additional Exposure Pathways

      Two exposure pathways not included in the old PAGs were, (a) exposure of the
      skin from  beta radiation from an airborne plume and from materials deposited
      on the skin, and (b)  whole body exposure to gamma radiation from radioactive
      materials  deposited on  surfaces (ground  shine).   For an airborne plume of
      beta/gamma emitters,  calculations indicate that the health risk from skin dose
      will  almost  always  be secondary to the risk  from other doses, but only if
      exposed persons wash and change clothes within several hours after exposure

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             of the skin begins. Therefore, since skin dose is not included in the summation
             over  organs represented  by effective  dose, there may be situations  where
             guidance is needed for evacuation or sheltering based on skin dose.  Likewise,
             whole body dose from ground shine could  be a major exposure pathway if
             relocation PAGs are not implemented within a few days after exposure begins.
             These deficiencies were solved by adding separate guidance for skin and by
             adding short-term exposure to ground  shine to the dose included in the PAG
             for evacuation and sheltering.

 Risk Estimates Have Changed

      In 1975, the International Commission on Radiation Protection (ICRP) assumed that
 the risk of fatal cancer from low level exposure was approximately 1 x 10"4 rem"1.  At that
 time, EPA assumed a risk of about 2 x 104 rem'1. Now, fifteen years later; these risk
 estimates have increased approximately 5-fold.  The 1991 risk estimates published by the
 National Academy of Sciences correspond, for total radiogenic cancer incidence to 5 to 10 x
 10"4 rem"1, depending on the rate at which the dose is delivered.

      We have addressed these increased risk estimates in two ways.  First, we have  taken
 a new look at the PAGs in terms of the basic principles for their selection. Second, we have
 reviewed experience on  how the old PAGs were implemented, to make sure  that they are
 applied in a manner consistent  with our judgments on risk.

      The four principles that EPA has selected as  the basis for choosing PAG values are
 shown in Table 1.  Principles 1, 3, and 4 are similar  to those recommended by the ICRP in
 Publication 40 and in the recently published Publication 60.  We have added Principle  2 and
 a similar consideration has been recognized by the International Atomic Energy Agency in
 its recently re-issued Publication 72.

      Principles 1 and 2 limit the risk to health of individuals from radiation independently
of other considerations.  The first calls for avoiding dose that exceeds the threshold for
prompt health  effects; the second calls for keeping the risk  of delayed  health effects  to
reasonably low levels.

      We assume that there is a threshold dose below which prompt effects are not expected
to occur, and that threshold is much higher (50 to 300 rads) than any PAG that would
satisfy the remaining three principles. Thus, Principle 1 has no effect on the choice of the
PAG level.  However, there is no threshold associated with delayed effects,  and, therefore,
the choice of PAGs based on the second principle is  not so simple.

      a)    Risk of Delayed Effects

            Since there is no threshold dose for delayed health effects, the determination
            of a dose value that is "adequately protective of public health under emergency
            conditions"  requires one to select an acceptable risk value and relate  it to the
            corresponding dose. One approach is to compare risk levels commonly used by
            EPA in setting standards for other  carcinogens. These levels fall in the range

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      of lifetime risks of death of 10'4 to 10"6; that is, EPA almost always chooses its
      standards to reduce the lifetime risk of fatal cancer to less than 1 in 10,000,
      and rarely establishes a standard requiring a risk level less than 1 in 1,000,000.
      This  implies a maximum dose in the range of 100 to 200 millirem.  This
      maximum risk applies to standards for normal releases.  Although there is no
      clear  precedent for choosing different acceptable  risks  for normal versus
      emergency  conditions,   we  concluded  that a  factor  of 5  to  10  is not
      unreasonable. This leads us to the conclusion that  a projected  dose of 1 rem
      would satisfy Principle 2.

b)    Cost of a Protective Action

      Principle 3 requires that we carry out any further reduction  of risk that is
      achievable at acceptable cost, and thus it acts as a supplement to Principle 2.
      That is, if the risk level established under Principle  2 can be reduced by cost-
      effective  measures, then the  PAG should reflect this. A recent landmark court
      decision  under the  Clean Air Act directed EPA not  to  set environmental
      standards on the basis of cost unless the risks are lower than those found to be
      "safe" without consideration  of cost.  This criterion  has since been applied to
      other standards set by EPA, including PAGs.  Using our conclusion for
      Principle 2  of 1 rem as the definition of "safe," under this criterion cost of
      implementation cannot be used to justify a higher dose, but it can be used to
      drive the risk to a lower value.  Our analyses of cost of evacuation for several
      combinations  of reactor  accident  categories, meteorology, and  evacuation
      models indicates that the cost-effectiveness of avoiding the risk associated with
      1 rem by evacuation is well within the range considered acceptable by the EPA,
      but not so low as to warrant a further reduction in the PAG.  Since power
      reactors  probably represent  the worst case  we can reasonably conjecture, we
      take this as a general conclusion. Therefore, cost was not an influencing factor
      in establishing the PAGs for the early phase.

c)     Risk from the  Protective Action

      Principle 4 is simply an exercise in the application of common sense.  It says
      that one  should never apply a protective action if the risk from the action itself
      is greater than the risk that  would be avoided.

      In evaluating  the  risk from evacuation, the principle risk, for the  average
      member  of the  population  under normal  circumstances, is that from the
      associated  transportation.    An  additional potentially significant, but
      unquantifiable, risk  is the psychological risk from evacuation.  However, this
      risk may be offset by the psychological risk to those who would be concerned
      about not being evacuated.   The risk from transportation associated with
      evacuation for ambulatory persons and under normal environmental conditions
      was calculated to correspond to the  risk associated with a dose of about  30
      mrem. This is, of course, small  compared to 1 rem. However, if evacuation
      involves persons who are at much more than the normal risk from evacuation,

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             or if the environment is more risky than normal, then evacuation at a dose of
             1 rem could result in more risk from the evacuation itself than would be caused
             by the radiation. To avoid this situation, sheltering provides an alternative to
             evacuation. The PAGs provide for substituting evacuation, therefore, up to a
             dose 5 times higher than the recommended level for evacuation under normal
             circumstances for situations where evacuation carries a high risk. There may
             be other reasons, such as physical constraints to evacuation, or special source
             term characteristics that argue for sheltering. The new guidance also provides
             that sheltering should be substituted for evacuation for any situation where
             sheltering will provide equal  or greater  protection.   But, caution is advised
             regarding possible shelter failure mechanisms for situations where the projected
             dose exceeds  10  times  the PAG  level   for  evacuation  under  normal
             circumstances (1 rem).
                                      TABLE 1
                           Principles for Establishing PAGs
  1.     Acute effects on health (those that would be observable within a short period of
        time and which have a dose threshold below which such effects are not likely to
        occur) should be avoided.

  2.     The risk of delayed effects on health  (primarily cancer and genetic effects for
        which linear nonthreshold relationships to dose are assumed) should not exceed
        upper bounds that are judged to be adequately protective of public health under
        emergency conditions, and are reasonably achievable.

  3.     PAGs should not be higher than justified on the basis of optimization of cost
        and the  collective risk of effects on health.  That is, any reduction of risk to
        public health achievable  at acceptable cost should be carried out.

  4.     Regardless of the above principles, the risk to health from a protective action
        should not itself exceed the risk to health from the dose that would be avoided.
PAGs Have Been Misinterpreted

      An additional problem associated with the old PAGs for evacuation and sheltering was
their frequent misinterpretation with regard to whether evacuation was the protective action
of choice at 1 rem in the absence  of other  risk factors or constraints, or was only
recommended for consideration at this level. The intent of the guidance was that evacuation
was normally to be the protective action  of choice at  1  rem, but some portions of the
published guidance on implementation were capable of multiple interpretations. This was
further complicated by the absence of a published rationale. Both  of these problems have
been corrected in the revised guidance through detailed explanations and examples of the
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intended implementation of the PAGs, and by including background information on the
process used to develop them.

Implementation Guidance is Based on Postulated Source Terms

      During  the early phase  of an incident when dose, or dose commitment,  can be
accumulated rapidly, there is an urgent need to implement decisions for protective action
promptly.  For reactor incidents, potential source terms have been defined for different
combinations  of emergency  plant conditions  and meteorological  conditions  so  that
recommendations for evacuation/sheltering can be made early for close-in populations, and
generally prior to a  major release.  The new guidance encourages this process for all  fixed
nuclear facilities that require radiological emergency response plans.

      a)    Short-Term versus Long-Term Dose

            Before  getting into guidance on dose projection, I want to discuss a common
            misunderstanding regarding the period of time over which dose is calculated to
            evaluate risk of health effects.  Since deterministic health effects occur within
            a short time (usually within two months), dose received after  this period is of
            no importance for evaluating whether a threshold level of concern has  been
            exceeded.  Therefore, dose calculations  for these effects usually include only
            prompt external exposure to plus the dose that would accumulate over about
            30 days from long-term exposure pathways such as inhalation of particulate
            materials.   Some dose models calculate  these short-term doses, and some
            emergency planners make the mistake of comparing these doses to PAGs for
            purposes of decisions  on protective  actions. However, the primary risk of
            concern for PAGs is the risk of cancer, for which there is no threshold and for
            which the  risk continues to accrue  from chronic doses received  over many
            years.  Therefore, a dose model is required that takes these longer term doses
            into account. In short, the dose of relevance is the entire committed dose, not
            the annual, or any other shorter term dose.

      b)    Projection  of Effective Dose

            "Effective dose" is a new dose quantity for PAGs. This quantity allows us to
            include all of the significant exposure pathways: direct gamma, inhalation, and
            ground shine. The first two will generally predominate. The component from
            ground shine may continue over many years, depending on the half life of the
            deposited materials. However, since relocation PAGs may be implemented to
            protect  the  public from  long-term exposure  to  ground  shine following
            evacuation, the only dose from ground shine to be considered for decisions on
            evacuation is the portion that would be accrued prior to the implementation of
            relocation.  Based on experience with exercises, we have concluded that 4 days
            is sufficient time, in most cases, to collect sufficient information to implement
            relocation,  if necessary.
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            Some  concern has  been expressed regarding the  difficulty in calculating
            effective dose, in comparison to calculating whole body dose, as required for the
            current PAGs. In fact, it is no more difficult to calculate effective dose.  It is
            just a  matter of using different dose conversion factors.  Chapter Five of the
            new guidance includes a single dose conversion  factor for each  of 141
            radionuclides that  can be used  to calculate  effective dose  from the three
            exposure pathways combined (plume shine, inhalation, and 4 days of ground
            shine). These 141 dose factors should accommodate any reasonably conceivable
            source term.

Application Experience

      The revised PAGs for the early phase have been implemented successfully for some
special applications.  The most notable were for the standby emergency responses for the
launch of Galileo and  Ulysses spacecrafts, which carried large quantities of Pu-238 as an on-
board power source.  In these  cases, the limited road system was inadequate for timely
evacuation of the large temporary population that would be there to view the launch.  For
this reason sheltering was considered and, since it provided the greatest exposure reduction,
and could be implemented within the guidelines, was the recommended protective action.

      Another special application was developed for potential reentry into the atmosphere
over the United  States land mass of Cosmos 1900 in 1988.  This spacecraft was powered by
a fission reactor  similar to one that crashed in a sparsely populated area of northern Canada
in 1978 and contaminated a large area with widely dispersed, highly radioactive, small "hot
particles."  In preparation for possible similar consequences if Cosmos  1900 crashed in the
United States, it was necessary  to develop procedures  for monitoring and for calculating
projected dose from widely dispersed hot particles, so  that the projected dose  could be
compared to the PAGs for purposes of decisions  on evacuation and relocation.  These
procedures were on  standby when reentry occurred (over the ocean, fortunately). These two
examples provide an indication that the new PAGs are flexible and that it is possible to
develop special implementation procedures for defined accident source terms and conditions.

      In summary  then, the new PAGs now apply to any source term, the dose units in
which they are expressed encompass all of the risk that may be  avoided by the relevant
protective action, and the accompanying text has been  clarified to provide more complete
guidance on the  factors that should or should not influence the choice between evacuation
and sheltering.

      I hope this discussion will be helpful to you in your workshop deliberations this
afternoon and tomorrow.  I will be around if needed to further discuss any of these points,
as will Joe Logsdon who participated in development of the PAGs and the implementation
procedures.
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         IMPLEMENTATION OF PROTECTIVE ACTION GUIDES
            AT A LARGE PLUTONIUM PROCESSING FACILITY

                                 Philip C. Nyberg

                      U.S. Environmental Protection Agency
                                   Region VIII
                                 Denver, Colorado
 Introduction

      The State of Colorado, with the assistance of the U.S. Department of Energy (DOE),
 has developed a Radiological Emergency Response Plan for the DOE Rocky Flats Plant.
 Several serious accidents at the plant in the past caused the Governor of Colorado to require
 an emergency response plan equivalent to that required for a commercial nuclear power
 plant.  That planning process began in 1977 and has continued to the present.  The planning
 basis since 1980 has been the maximum credible accident (MCA), which was defined for the
 plant as the maximum airborne release of plutonium which could occur with a frequency of
 more than once  in ten million years.  The State  chose to use the  MCA as  the bounding
 accident for planning purposes, although it acknowledges that this is different  than the
 planning  basis currently  required by the  Nuclear Regulatory Commission (NRG) for
 commercial nuclear power reactors.  The State developed protective action guides (PAGs)
 based on the Environmental Protection Agency (EPA) guidance available in 1980 as well as
 other information relevant to limiting lung dose, believed to be the most serious hazard for
 an airborne release of plutonium particles.   A review of the MCA  and the emergency
 planning zones (EPZs) for the plant was initiated in  1988 and continues to the present.
 Phase II of that effort, the development of information to assist the State in revising its plan
 on an interim basis, was recently completed.  The observations in this paper are drawn from
 the Phase II EPZ Project.

      The Rocky Flats Plant is a major plutonium processing and fabrication facility owned
 by DOE and located on 384 acres of land about 16  miles from downtown Denver, Colorado,
 as shown in Figure 1.  The facility itself is centered within a 6,550-acre buffer zone which
 extends to a radius of roughly 2 miles from the center of the plant site  in all directions.
 EPZs have been established,  and federal, state and local agencies have participated  in
 exercises which have tested the efficacy of the  offsite emergency plan.

      Changes in the operations at the plant, particularly the cessation of transuranic
 radioactive waste shipments, caused the Governor of Colorado in 1988 to  request a review
 of the plan to assure its continued validity in the face of increasing waste volumes stored on
 the site.  DOE committed its operating contractor, then Rockwell International  and  now
 EG&G/Rocky Flats, Inc., to provide Task Teams that would develop the necessary technical
information to validate the MCA and to  update and improve the emergency plan.  That
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 information  would be reviewed and evaluated by an oversight committee  consisting of
 representatives from the Colorado Division of Disaster and Emergency Services (DODES),
 the Colorado Department of Health (CDH), DOE (Rocky Flats Area Office), and EPA (Region
 VIII Office).

      Recognizing the magnitude of the task, it was decided to divide it into four time-
 sequenced phases, each of which would provide the State with a summary of the technical
 information developed in that phase.  Phase I was a revalidation of the MCA, while Phase
 II was an interim analysis of the EPZs for a radiological accident. Phases III and IV would
 develop more complete information on  a spectrum  of radiological and  non-radioactive
 hazardous material accidents.  The activities of Phase II form the basis for this paper.

 Background

      According to A.J. Hazle (Ref. 1), Colorado has used a MCA as its bounding accident
 for planning purposes.  The assumption is that, by basing its plan on such a relatively
 improbable event, the State would be prepared to handle more probable but less severe
 events as well. It was not considered a prudent expenditure of State funds to develop a plan
 for more  severe,  less probable accidents, although the current plan certainly provides a
 sound basis for response in that unlikely event.

      The MCA currently  defined for the plant is the airborne release  of 100 grams of
plutonium (primarily Pu-239, -240 with some Am-241 ingrowth).  The scenario developed
in the Rocky Flats Plant Final Environmental Impact Statement (Ref. 2) was that of a large
airliner crashing into a plutonium production building, with the resultant penetration of the
building and jet-fueled fire providing the mechanism  and driving energy for the  release.
Release fractions for burning plutonium were taken from the available literature, and worst-
case  meteorological conditions were assumed to maximize the off-site impact in the FEIS
analysis.

      When the current emergency plan was developed in 1977-80, the State considered the
then-available EPA PAGs to be only partially appropriate for the Rocky Flats situation,  as
they  recommended action based on either whole body or thyroid radiation dose. The doses
expected  from the Rocky  Flats MCA would  come  primarily from inhalation of airborne
plutonium particles.  This would result in a dose to the lung that  would have a relatively
long commitment period because of the long half life of plutonium and its relative immobility
when deposited  in the lung  (although  the doses to the liver  and gonads were also
considered).  The State chose to use the recommendations of the British Medical Research
Council  (Ref. 3) to take protective action to avoid doses exceeding twice the maximum
permissible annual dose for radiation workers.  By the standards of the day, this PAG
translated to a projected lung dose of 30 rem,  a bone dose of 10 rem,  and a gonadal dose of
5 rem. Calculations quickly revealed that the lung dose would be the controlling factor, i.e.,
if the lung dose were maintained below the guideline, the other doses would also be well
below their respective guides as well.

      Using  the  expected worst-case meteorology,  dose versus distance  curves  were
developed for an airborne release of 100 grams of plutonium, and three zones  were defined

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corresponding to the EPA Category I, II, and III protective actions.  They were: Category I,
projected dose greater than 30  rem (lung), consider evacuation/sheltering; Category II,
projected dose between 6 and 30 rem (lung), sheltering; and Category III, projected dose less
than 6 rem (lung), confirmatory sampling. The corresponding distances were 0 to 4 miles,
4 to 10 miles, and greater than 10 miles, as illustrated in Figure 1.

1988 Phase II Review

      The  current review, begun  in late 1988,  was conducted to ensure  that the
accumulation of transuranic waste at the Rocky Flats Plant had not created a situation in
which  the assumed MCA, i.e., the "credible" release of 100  grams of plutonium,  could be
exceeded,  and to update  and revise  the existing EPZs  by considering more recent
developments in dosimetry  and PAGs.

      Dosimetry

            Consistent with  the recommendations  in the  International  Commission on
      Radiological Protection (ICRP) Publications 26 and 30 (Ref. 4 and 5), the State had
      decided  at the outset to use the "committed effective dose equivalent" concept as its
      primary measure of radiation risk.  This necessitated substantial changes from the
      "organ dose" concept  employed in the existing  plan. Furthermore, the previous dose
      calculations had been based  on an assumed particle size distribution of 0.3 /xm
      (AMAD: activity median aerodynamic diameter) and a dose commitment period of 70
      years.  For consistency  with national and international practice, it was agreed to
      change the assumptions to a particle size distribution of 1 pm (AMAD) and a dose
      commitment period of 50 years in the Phase II revision.

      Protective Action Guides

            PAGs are recommended levels of projected radiation dose at which actions to
      protect the public should be taken following an accident at a nuclear facility involving
      an actual or potential release of radioactive material.  They are response guidelines,
      rather than mandatory levels at which actions  must be taken.   State  or  local
      government agencies may take  actions  at other projected  doses  or based upon
      conditions at the facility. They may  also  refrain from taking protective action if that
      action would result in a higher immediate risk to the  public than the radiation risk
      avoided by the action.

            PAGs have been issued by the EPA (Ref. 6 and 7) for the United States, and
      the ICRP has provided similar guidance  internationally (Ref.  8).   These two groups
      espouse  similar, though not identical, principles for their recommendations, and the
      action levels are somewhat different.  EPA recommendations are given in Table 1
      while ICRP recommendations are given  in Table 2.  In reviewing the use of PAGs
      world wide, the task  team found significant variations among facilities, states, and
      countries. The EPA recommendations employ the lowest action levels in common use,
      and are  presented  in units of "committed effective dose equivalent" (CEDE).  The
      ICRP action levels are somewhat greater, and there is some ambiguity concerning

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     which dosimetry units are intended.  The task team noted five possible PAG options
     for the State's consideration, including:

     *      EPA PAGs, December  1990 draft
     *      EPA PAGs, 1980 (revised 1988) draft
     *      ICRP Publication 40 PAGs
     *      Modify current State PAGs for the Rocky Flats Plant to incorporate CEDE
     *      Develop new PAGs specifically for this site

                                      TABLE 1
         EPA PAGs FOR THE EARLY PHASE  OF A NUCLEAR INCIDENT
    Protective Action
PAG (Projected Dose)
        Comments
 Evacuation (or sheltering")
        1-5 remb
Evacuation (or, for some
situations, sheltering8)
should normally be
initiated at 1 rem.  For
further guidance, see Ref.
7.
     Administration of
       Stable Iodine
        25 reme
Requires approval of State
Medical Officials.
"Sheltering may be the preferred protective action when it will provide protection equal to or greater than
evacuation, based on consideration of factors such as source term characteristics, and temporal or other
site-specific conditions.

bThe sum of the effective dose equivalent resulting from exposure to external sources and the committed
effective dose equivalent incurred from all significant inhalation pathways during the early phase.
Committed dose equivalents to the thyroid and to the skin may be 5 and 50 times larger, respectively.

"Committed dose equivalent to the thyroid from radioiodine.
     Emergency Planning Zones

           EPZs are areas surrounding a nuclear facility  within which local  and state
     authorities have developed specific plans to protect the public in the event of an actual
     or potential release of radioactivity at that facility.  For nuclear power reactors, the
     two zones are areas within a 10-mile radius of the plant (of greatest concern during
     the early phase  of an accident) and areas from 10 to 50 miles in radial distance (of
     concern in the intermediate and late phases of an accident). At Rocky Flats, there are
     effectively  three zones  as  previously indicated, differentiated by  the maximum
     expected dose and type of protective action.  These zones were originally defined by
     projected doses relative to the PAGs at various distances resulting from the MCA.
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                                TABLE 2
             ICRP GUIDANCE ON INTERVENTION LEVELS
Critical Organ Dose Equivalent (rem)
Countermeasure
Sheltering and Stable
Iodine Administration
upper dose level
lower dose level
Evacuation
upper dose level
lower dose level
Control of Foodstuffs
upper dose limit
lower dose limit
Relocation
upper dose limit
lower dose limit
Whole Body
5
0.5
50
5
50
5
50
5
Individual Organ
(including lung & thyroid)
50
5
500
50
50
5
Not Anticipated
(Extracted from ICRP Publication 40 (Ref. 8), Tables Cl and C2)
      Current thinking at both EPA and  NRC disavows such a specific linkage
between EPZs and PAGs.  Both agencies agree that EPZs should be large enough to
include all areas where the MCA might cause exposures sufficient to produce acute
health effects, and also large enough  to provide an adequate planning  area for
implementing the PAGs (plus a basis for expansion if doses are predicted to exceed
the PAGs beyond the EPZ). The dilemma at Rocky Flats, as well as many other non-
reactor nuclear facilities, is defining an EPZ large enough for protection and small
enough for effective planning.

      The distance from the plant to which a PAG would be exceeded in the event of
a MCA is an important component of EPZ development.   This  protective action
distance can be determined by comparing the dose versus distance relationship
calculated for the  MCA and some assumed meteorology  to PAG  thresholds. This
distance can be highly variable, however, depending upon the selected wind speed and
atmospheric stability.  In  the case of Rocky Flats, several years  of meteorological
observations are available  from  which to characterize these parameters in  terms of
their probability of occurrence,  although only one year was used in this  analysis in
order to comply with strict data quality guidelines.

      Three annual meteorological probabilities were chosen as illustrative of the
complete distribution.  The median meteorology  was chosen to represent  "typical"
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       conditions at the plant, reflecting an annual meteorological probability of 0.5 (50% of
       the time it would be more favorable, 50% less favorable).  A meteorological probability
       of 0.05 was chosen to represent the "worst case" - the level used in previous analyses
       at the Rocky Flats Plant. This level implies that only 5% of the time in one year
       would the conditions be less favorable than this. The third meteorological probability
       chosen for illustration was 0.005, corresponding to the "extreme worst case" conditions
       defined in NRG Regulatory Guide 1.145 (Ref. 9). This implies that only 0.5% of the
       time in one year would conditions be less favorable than this.

             Figure 2 illustrates  the  effect  of increasingly conservative  meteorological
       assumptions on the distance at which any given  PAG would be exceeded for the
       assumed MCA at the Rocky Flats Plant. For example, for the same accident scenario,
       a dose of 1 rem might be exceeded at distances ranging from less than 6 to greater
       than 80 kilometers (less than 4 to greater than 50 miles), depending on the chosen
       meteorology. What is an appropriate assumption in this case?  As a guide, it may be
       appropriate  to remember the compounding of probabilities.  If the MCA has a
       probability of one in ten million (1 x 10"7) per year, then the probability of achieving
       the dose-distance curve from the median meteorology is the product of the  two
       probabilities, or 5 x 10"8 per year. Similarly,  the probability of achieving the extreme
       worst case curve is 5 x 10"10 per year. Is it appropriate to utilize such extremely small
       probabilities in the emergency planning process?  This is less a technical than a policy
       question for the particular planning agency.

Summary

       A technical  review of the information needed by the Colorado emergency planning
agency to revise and update the radiological emergency response plan for the DOE Rocky
Flats Plant was conducted by a multi-agency oversight committee.   This information may
be used by the State to redefine the EPZs. The choice of PAGs plays an important but not
definitive role in determining  the  most appropriate EPZ boundaries.  The  assumptions
underlying the MCA, the meteorological probability, and several other factors will also affect
the EPZ determination. Future activities contemplated for this project include investigation
of more realistic meteorological models than the straight-line Gaussian model used in this
analysis, analysis of a spectrum of possible accident  probabilities and outcomes,  and the
incorporation of procedures for coping with non-radioactive  hazardous material accidents
which could have off-site consequences.

Acknowledgements

       The effort described above is not  mine but is the combined achievement of many
individuals working together often under difficult circumstances  and with short deadlines.
Special acknowledgements go to the PAG  Task Team,  and  to  the  entire Oversight
Committee, who have furthered my education in the emergency planning process.
                                         50

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                                   FIGURE 1
                     U.S. DOE Rocky Flats Plant and Vicinity

          Approximate Boundaries for Colorado Emergency Response Plan
                        and "Area of Concern for Housing"

           Adapted by EPA Region VIII Radiation Program - Revised 1985
                                              PLUTONIUM - 239

                                              CONTOURS (mC/km2)
GRAPHIC SCALE
  (MICE.S)
Adapted from   P.. W, Krey and E.P. Hardy, Plutonium in soil around the Rocky Flats Plant, US AEC
	          Report HASL-235, (1970)
                                         51

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                               FIGURE 2


                     NRC Guide 1.145 Dose Calculations
  PROJECTED

    DOSE    (REJVJ,  CEDE)
   .
o o
> 33
  m
  X
  -IO
  s:
  o
  33
  C/3
  -1
  m
                                                          CD

                                i
                                                                        o
                                                                        o
                                                                        2
                                                                        P~
                                                                        in
                                                                        O
                                                                        O
                                                                        O
                                                                        O
                                   52

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                                  REFERENCES

 1.    Personal communication, A.J. Hazle (Colorado Department of Health), March 25,
      1991.

 2.    U.S. Department of Energy, Final Environmental Impact Statement for the Rocky
      Flats Plant Site, DOE/EIS-0064 (3 volumes), April 1980.

 3.    United Kingdom Medical Research Council, Criteria for Controlling Radiation Doses
      to the  Public After Accidental Escape  of Radioactive Material,  HMSO,  London
      (England), 1975.

 4.    International  Commission  on  Radiological Protection,  Recommendations of the
      International Commission on Radiological Protection, ICRP Publication 26, Pergamon
      Press, Oxford (England), 1977.

 5.    International  Commission on Radiological  Protection, Limits  for Intakes  of
      Radionuclides by Workers, ICRP Publication 30, Pergamon Press, Oxford (England),
      1978.

6.    U.S. Environmental Protection Agency, Manual of Protective Action  Guides and
      Protective Actions for Nuclear Incidents, EPA 520/1-75-001, Draft 1975, Revised 1988.

7.    U.S. Environmental Protection Agency, Manual of Protective Action  Guides and
      Protective Actions for Nuclear Incidents, EPA 520/1-75-001, Revised 1991.

8.    International Commission on Radiological Protection, Protection of the Public in the
      Event of Major Radiation Accidents: Principles for Planning, ICRP Publication 40,
      Pergamon Press, Oxford (England), 1984.

9.    U.S. Nuclear  Regulatory Commission, Atmospheric Dispersion Models For Potential
      Accident Consequence Assessments at Nuclear Power Plants, Revision 1, Regulatory
      Guide 1.145, February 1983.
                                        53

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                         MIXED HAZARD INCIDENTS
                     (CHEMICAL/NUCLEAR INCIDENTS)

                                   William Klutz

                                     OSWER
                      U.S. Environmental Protection Agency
                                    Region IV
                                 Atlanta, Georgia
     Emergency Response Capabilities to an Incident Involving Radioactive Materials
                    or Mixed Hazardous and Radioactive Materials
      Emergency response to a release of radiation or a release of hazardous and radioactive
materials will be the responsibility of the Environmental Protection Agency (EPA) Region
IV, Emergency Response and Removal Branch.  This Branch maintains a 24-hour duty
officer who will receive the information directly and will determine whether the Regional
first responder, an On-Scene Coordinator (OSC), should respond to the release.   EPA
receives notifications through the National Response  Center (NRG) in Washington D.C.,
which is the national clearinghouse for reporting spills or releases of CERCLA 101 listed
hazardous substances or the releases of oil.   The listed  hazardous  substances includes
hazardous waste,  hazardous air pollutants, hazardous  substances,  and the Title III list of
extremely hazardous substances as well as all radionuclides.  All of the hazardous substances
have an associated reportable quantities, which is the minimum quantity which determines
whether the spill  must be reported to either EPA or the Nuclear Regulatory Commission
(NRC).  The reportable quantities are reported in pounds for hazardous substances and in
curies for radioactive materials.

      After notification of a spill or release, the regional duty officer assesses the quantity
and hazard, and then determines whether to send an EPA OSC, or to utilize the capabilities
of our Technical Assistance Team (TAT) contractor, or in the case of major spills, both EPA
and TAT. Response to a spill of radioactive or mixed material would, at a minimum, require
the use of TAT for immediate monitoring for radiation. If additional radiation monitoring
is  necessary  or an extensive  cleanup  was required,  the OSC  has  the capability and
contracting  authority  to utilize the  Emergency  Response  Contract Services  (ERGS)
contractor to perform  a  cleanup.  Through  either TAT  or ERGS contractor,  specialty
contractors for radiation monitoring,  health physics and radioactive materials emergency
response cleanup could  be obtained within 24 hours in an extreme emergency. In the case
where a viable responsible party is present, EPA OSC has the authority to issue immediate
cleanup orders.
                                        55

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      Region IV has used the services of Chem-Nuclear,  Westinghouse, and Numanco as
subcontractors on removal actions which involved the removal or stabilization of radioactive
or mixed waste.  Through TAT, EPA could procure all the  necessary laboratory services for
both  mixed waste or radioactive materials.  The capability of EPA to  respond is  also
enhanced by being able to use the services of the EPA Emergency Response Team (ERT) and
its contractor services.  The ERT has the capability for radiation monitoring or would be
able to procure specialized equipment.

      In addition to the ability to procure  contractor services,  Region IV has a mobile
command post, satellite and cellular communications capabilities, which can be mobilized
immediately. We also have the ability to use the services of the U. S. Coast Guard Strike
Team and all of their resources, including level A personnel protection.

      EPA Region IV OSC has the ability to procure up to $50,000 on-scene during an
emergency.  If additional funds are necessary for a response action, the regional contracting
officer could approve an additional $200,000,  and in the case of a catastrophic release up to
$2,000,000 in funds could be made available.

      In summary, in the case of a radioactive or mixed waste release, EPA Region IV or
any Region could and would have the necessary funds, equipment and necessary personnel
on-scene within minimal time.  We would  have available the latest in communication
equipment,  monitoring  equipment and would be able to procure any needed specialty
services or equipment.
                                        56

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                     ARKANSAS' TITAN II EXPERIENCE

                                   Bernard Bevill

                     Nuclear and Environmental Safety Section
             Division of Radiation Control and Emergency Management
                               Department of Health
                               Little Rock, Arkansas


Introduction

      A Flash....a deafening Blast ushered in a dawn of a new Day.  The unplanned, the
unthinkable, the IMPOSSIBLE had  occurred.  An American nuclear warhead had been
propelled from an underground missile silo.  Its final target was not a Russian city or a
Soviet military complex thousands of miles away.  It was on American soil within 1000 feet
from its Titan II silo.  As the warhead lay near the edge  of the silo complex grounds in the
dark of the early morning, state and local government officials were also in the dark. Due
to U.S.  Air Force policy, the existence of this nuclear device and its final destination could
not  be  discussed with civilians.  This, of course, lead to political and public relation
nightmares for all. Without adequate coordination with the Department of Defense (DOD),
state and local governments each worked separately.  In some cases, alarming false data
surfaced, creating panic among our major administrators. I will in my talk today:

      *     Review the specific details of this Titan II missile incident near
            Damascus, Arkansas, and

      *     Discuss an overview of activities that came  after this incident to
            better protect the health and safety of the citizens.

Background

      In 1980, the American land based Intercontinental Ballistic Missile (ICBM) nuclear
arsenal  consisted of 1000, what was then considered, "Modern" Minuteman missiles and a
few aged Titan II missiles. At that time, 54 Titans were sited in underground silos within
Arkansas, Kansas, and Arizona.

      As their name implied these were large missiles capable of delivering large megaton
warheads. (In fact, these 54 made Ys of the land based U.S. megatonage). They had been
deployed in 1963. Seventeen years later their existence may have been poker chips in the
Arms reduction game.

      These "geriatric giants" began to create problems for the Air Force in the field. As
they aged, liquid fuel leakage problems became more numerous, dangerous and on occasion
fatal. Between 1975 and 1980, 125 leaks had been reported with the  Titans. In 1978, two

                                        57

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 leaks had occurred where two airmen had been killed.  Another 29 were injured.

       One such Titan II missile and its nine megaton thermonuclear warhead was sited in
 a 146 foot underground silo near Damascus, Arkansas.  This is a small town approximately
 60 miles north - northeast of Little Rock. Two years earlier (in 1978) problems with leakage
 at the silo had occurred. Liquid vapors had leaked into the air  and seven people from the
 Damascus area required hospitalization.

 The Incident

       On Thursday, September 18, 1980, routine maintenance was being performed on the
 103 foot Titan missile.  An Air Force technician dropped a 3 pound wrench socket. After
 falling 70 feet it punctured the first  stage fuel tank (The missile's skin was thin.).  Fuel
 (Aerozine-5O) vapors began to escape. The workmen evacuated the silo.

      The automatic sprinkler system was activated once a fire had started. With  100,000
 gallons of water the fire was put  out.  Yet, the  leak continued.  Vapor concentrations
 continued to rise.  A two mile evacuation  was ordered by the missile crew on site.

      Approximately 61/2 hours after the  initial accident a two member emergency team
 entered  the  silo's access chamber to plug the leak.   They found at that  time vapor
 concentrations were continuing to increase. As these concentrations increased so did the
 probability of spontaneous combustion.  Just as the team was leaving the access chamber
 the vapor, and air mixture exploded.  This ignited the remaining fuel. The 750 ton concrete
 roof was demolished.  It was hurled across the country side as aluminum foil discarded from
 the weekend picnic. The nine megaton warhead was catapulted out of the silo approximately
 200 yards.

      One airman died of chemical pneumonia from inhaling fumes. Another was critically
 injured. Twenty more were hurt.  Approximately 1,400 people were evacuated from the area.

ADH's Response

      In September 1980, the Department's Division of Environmental  Health Protection
 (now named Division of Radiation Control and Emergency Management) had a hazardous
 Chemical Response group. This section was staffed with chemists who responded to a wide
range of hazardous material mishaps  within the State of Arkansas.  A variety of chemical
test equipment could be taken on to a Hazmat scene and preliminary measurements could
be made to assess the impact of the incident.

      On Thursday September 18, 1980, at approximately 8 p.m., our director, E.F. (Frank)
Wilson, received notification that there was a fire at the missile silo complex near Damascus.

      The supervisor of our Hazardous Material Chemists was contacted and instructed to
obtain  test  equipment  and  proceed  to  the missile complex.   At the same time,  the
Department's Mobile Command Headquarters was activated.
                                        58

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       This Mobile Command Post is a refurbished Kentucky trailer that years earlier had
 been used as an x-ray van for the Tuberculous Examination Program.  At that time, it was
 pulled by a two-ton Dodge tractor.

       Mr. Wilson arrived on the scene at 10:30 p.m.  Upon arrival, he was briefed by the
 local Office of Emergency Services (OES) coordinator who informed him that there was no
 fire in the complex.  However, there was a leak.

       At 12:15  a.m., on the next morning (September  19)  our Field Headquarters van
 arrived on the scene.  A briefing was provided.  Then, the normal routine long wait as with
 many responses began.  But, at 3:01 a.m.,  the normal waiting was interrupted by the
 explosion.

       In world class speed and with physical feats of herculean magnitude, the mobile van
 was loaded up. The Department personnel jumped in the Dodge tractor and their personal
 vehicles.  They floorboarded the accelerators.  A mad dash similar to the land rush in the
 movie "Oklahoma" was in progress. We were racing away from the site following blue Air
 Force pickup trucks.

      Minutes and miles later contact with our director was made.  The van was directed
 to go to Damascus. Meanwhile, Mr. Wilson went to the State Emergency Operations Center
 in Conway, Arkansas (30 miles northwest of Little Rock).   Notification of our Medical
 Director,  other  state officials and our  emergency radiation monitoring  teams (Health
 Physicists (HP)) were made.

      By 6 a.m., our HP teams had arrived in Conway.  One team was directed to go to the
 Conway Memorial Hospital to monitor the Air Force personnel being treated for burns and
 wounds. No alpha contamination was detected.

      At 6:30 a.m., Mr. Wilson contacted the Department of Energy (DOE) to activate the
 IRAP team. He was informed that the Air Force had already alerted the system via another
 method. Since the Air Force  had alerted them they could not respond to the Arkansas
 request. However, later that day they did.

      Mr. Wilson was referred to the Albuquerque Operations Office for further information.

      Upon contact with that Operations Office, we were informed that a DOE team had
 been initiated.  From these discussions, it was indicated that the high explosives had gone
 off or burned in a reported mushroom shaped cloud. It was thought that it was possible that
 the warhead could be involved. The area should be monitored. (Keep in mind that at this
 time the Air Force was not talking to civilians about this incident. Thus, we were in a near
 vacuum desperate for any information).

      By 7 a.m., two ADH monitoring teams were dispatched to the Damascus area.

      One team was deployed to a paved county road a few miles west of the silo. While
traveling down the road one of the novice HP's stuck his Eberline alpha probe out of the

                                        59

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window of the vehicle. Due to internal instrument noise and perhaps faulty connections a
reading was obtained. Before followup readings and a plausible explanation could be made,
the erroneous reading was called in.

      A pound of lead sunk through the GI tract of those within the State Emergency
Operations  Center.   (This report became  one of our  Medical  Health  Officer's most
unforgettable moments in his brief career with the Department).

      The other HP  team was quickly deployed to this area. Both teams were able to
confirm the existence of no alpha contamination.  The EOC  staff was informed of these
findings.  Relieved, this staff was  able to coordinate activities between the various state
agencies, answer questions and talk on the telephone.

      Around 11:30 a.m.,  members of the DOE IRAP team arrived. They toured the area
around the silo. By early afternoon it was apparent that the Air Force had found their
wayward child and had safely secured it.  No alpha contamination had been detected.

      Finally, we  were stationed  at the missile complex gate.   The remainder of the
afternoon was spent standing and sitting in the late summer sun discussing the days events,
speculating and watching a wide variety of military helicopters fly over.

      By  5  p.m., we  were sent back to our duty stations in Little Rock.  Meanwhile,
Damascus, Arkansas enjoyed it's brief moment of fame as the lead-in story for all the major
networks and print media.

The Aftermath

      From this Titan  experience a new Dawn  was figuratively  ushered  in.   Better
communications between  the Military  (DOD), and the  state and local government was
established.

      From the standpoint of relationships between Arkansas officials and DOD, it was a
major catalyst in the Titan program.  The following were results of this event:

      *     A Memorandum of Understanding between the U.S. Air Force and
            the State of Arkansas was negotiated.

      *     Detailed emergency plans were developed.

      *     Canister masks could be made available for personnel protection.

      *     Periodic exercises of the Emergency Plans were  performed with
            the Air Force.

      State  agencies were kept informed of movement of missile propellants.   This was
especially true as the Titan II's were  phased out within the next 6 years.
                                        60

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Lessons Learned

      Of course, many lessons were learned.

      *     First  we  must  continually realize  that  the unplanned,  the
            unthinkable and even the impossible can  and will occur.  Our
            mode of thinking  must not rule these  out.  Here, we do not
            necessarily have to plan for the possibility of every  potential
            event.  Yet, our response policies and procedures must not be
            rigid.  Flexibility must be the standing order of the day.

      *     Adequate  monitoring equipment must be  available. After this
            event, the  Division was able to vastly update and upgrade it's
            radiation detection equipment inventory.

      *     Adequate staff training must also be provided. A routine training
            program was established. Both in-house and outside training is
            now provided to our staff. Even today, various survey equipment
            and techniques not normally encountered are covered in the rare
            event they  must be employed.

Conclusions

      Today, I have reviewed with you what  I hope was a very interesting chapter  in
American  Emergency Response  history.  Hopefully, we have gleaned lessons  as to how we
may respond to the unplanned.  The need for communication between DOD  and the state
and local officials can not be over emphasized.

      I believe that this workshop is a giant step toward a mutual working partnership.

      I will be glad to answer any questions.
                                        61

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    REVIEW ON THE BASIS OF GUIDANCE FOR SHELTERING AS A
    PROTECTIVE ACTION IN A PLUTONIUM RELEASE ACCIDENT

                                 Bradley Nelson

                          Office of Radiation Programs
                      U.S. Environmental Protection Agency
                                Washington, D.C.
Introduction

      Hazard

      Briefly,  I'll  review the hazard  from plutonium.   For  Pu-239,  inhalation of
      contamination in a cloud gives a dose of 5.2 x 108 rem per |iCi cm"3 h. Ground shine
      from deposited contamination is 1.5 x 10, and direct skin exposure from immersion
      in a cloud is 4.7 x 10~2. Clearly, inhalation is the pathway of concern.1

      Air Exchange

      Protective action is based on the inhalation pathway. Evacuation removes the public
      from the plume, breathing uncontaminated air at another location. Sheltering keeps
      the public indoors breathing air which does not reach equilibrium with the plume.

      In this discussion shelter means any building: a home, a school, a factory,  an office
      building, a hospital, or any other building of opportunity. The discussion is weighted
      toward homes because, on average, only 40 hours of a 168 hour week are spent at
      work. The effectiveness of a shelter is a function of the number of exchanges of clean
      inside air with  contaminated outside  air.  Shelter,  in this case, is unrelated to
      shielding.  Please note that this is very different than Civil Defense (CD) fallout
      sheltering. Shelter here means air-tight.

      Three Areas of Consideration

      The number of contaminated air exchanges depends on three things:  (1) the tightness
      or air exchange rate of the  shelter, (2) the nature of the plume at the shelter,  and
      (3) the understanding of the public in sheltering techniques.

Tightness of the Shelter

      Typical Exchange Rates

      Typical air exchange rates vary from 0.07 to 4.0 complete air changes per hour.2 Even

                                       63

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 for a specific building, air exchange rate or tightness varies with a number of factors,
 one of the largest being the weather.

 Weather Variance

 Indoor/outdoor temperature differences cause density differences which cause pressure
 differences that drive infiltration.3 Wind also causes a driving pressure that produces
 natural ventilation.4  Exchange rate more than doubles for a doubling of wind speed
 above 6 mph.

 Figures 1  and 2 show comparable wind driven and temperature driven infiltration
 rates. One graph shows a "tight" house and the other shows a "loose" house.

 Filtration

 Air infiltrates through open windows and doors, cracks, and  directly through solid
 wails. These pathways essentially do not filter the incoming air. An entrained 2 jim
 particle of plutonium will not be removed.5

 Dose Reduction Factor (DRF) is the ratio of the time-integrated concentration of
 contaminants inside the shelter to  that outdoors.  This means that a DRF  close to
 zero is desired and that a DRF of 1.0 offers no protection. The graph of the DRF of
 a shelter immersed in a plume takes the form of 1 - &'**.  This is shown in Figure 3.

 Some buildings draw in outside air directly and filter it as it comes in, other buildings
 filter recirculating air, and some do neither.   If air is filtered at any step of the
 process, the equilibrium contamination ratio of indoor to outdoor air will be less than
 one.

 The types of heating and cooling systems also affect the tightness of the building. For
 instance a radiant heating system such as hydronic will affect infiltration differently
 than  a forced air system.  A combustion based heating system will  cause more
 infiltration than an electric based system. An air conditioning system which uses
 evaporative coolers rather than refrigerant coolers  may have an indoor/outdoor
 equilibrium contamination ratio of greater than one.6

 Overall Estimate

 There really is not a good ballpark number to use for air-exchange rate or DRF in an
 emergency.  If  sheltering is  to be considered  as  a  protective action, emergency
 response plans must evaluate buildings on a case-by-case basis. In very general terms,
 modern homes built  since the energy-conscious mid 70's seem to offer the most
 protection. Industrial  buildings offer the least protection and other buildings  fall
 somewhere in between. Again, for any real sense of sheltering effectiveness,  specific
buildings in the area must be evaluated in advance.
                                   64

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Plume Considerations

      Duration

      The nature of the plume itself also obviously affects indoor air contamination
      concentration.  For a long duration release, a shelter's indoor air contamination
      concentration value will more closely approach equilibrium. A shelter subject to five
      air changes inside the plume has nearly achieved equilibrium.  Based on a range of
      0.07 - 4.0  air changes  per hour this is anywhere from  1.25 to  71  hours.   The
      Environmental Protection Agency (EPA) guidance on implementing Protective Action
      Guides (PAGs) is that sheltering is usually not appropriate for exposure lasting more
      than two air exchanges of the shelter.7  This translates to 1/2 to 29  hours.

      Concentration

      The shelter's  location  in the plume  is a self evident  concern.   What  is  the
      concentration?   Is  it low enough that  the increment  of protection afforded by
      sheltering reduces projected concentration below the PAG Derived Response Levels?

Sheltering Technique

      Sealing the Shelter

      The third area of concern is public understanding. A shelter is a device which must
      be operated properly to be effective.

      Ventilation must be secured.  Heating and air conditioning (HAG) in general is worth
      0.33 +. 0.37 air changes per hour.8  Note that Figures  1 and 2 are given with the
      assumption that HAG is turned off.

      Operation of kitchen and bathroom exhaust fans will also increase infiltration by the
      amount of air being exhausted. This makes sense intuitively.  If air is being removed
      from the house at one point,  then air must be coming into  the house at another.
      Otherwise the exhaust fans would draw a vacuum on the house and a person's ears
      would pop as they walked outside (or they would pass out as all the air was removed
      from the house.)  Attic  fans also greatly increase infiltration by creating pressure
      differences. See Figure 4.

      Post Plume Ventilation

      Not to be overlooked is the dose received from contaminated air trapped indoors after
      the  plume  has  passed.   A  shelter must  be aired-out.  Otherwise, the  indoor
      contamination concentration will be an exponential die-off (e"a) based on the same air
      exchange rate.
                                        65

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 Summary
       Highlights have been presented here.  For planning purposes, thorough discussions
       should be  consulted in the EPA PAG Manual, Chapter 5 and the Department of
       Energy (DOE) publication Effectiveness of Sheltering in Buildings and Vehicles for
       Plutonium DOE/EH-0159T UC-160.   Experienced  Heating,  Ventilation and Air
       Conditioning  (HVAC)  engineers  familiar  with American  Society  of Heating,
       Refrigeration, and Air Conditioning Engineers (ASHRAE) Fundamentals and local
       building customs should be consulted about building tightness and infiltration.

       CD sheltering considerations are very different than those presented here. Reliance
       on CD plans and techniques could very well be worse than useless in a plutonium
       release accident.

       Three Areas of Concern

       In a plutonium release accident, sheltering does provide some protection for the
       airborne pathway, the pathway of concern.  To  rely on sheltering as a protective
       action, three major considerations must be evaluated in advance:  1) air-tightness of
       available shelters, 2)  duration  and concentration  of the  plume, and 3)  public
       understanding of sheltering technique.
 U.S. Environmental Protection Agency (EPA); Manual of Protective Actions for Nuclear
Incidents. Draft. Tables 5-3, 5-4, and 5-5; 1991.

2Engelmann, R.; Effectiveness of Sheltering  in  Buildings and Vehicles for Plutonium.
DOE/EH-0159T  UC-160. U.S. Department of Energy (DOE), p.23; 1990.

3American Society of Heating, Refrigeration, and Air Conditioning Engineers (ASHRAE);
Fundamentals, p.22-3;  1985.

4Ibid., p.22.2.

5Engelmann; p.8.

6Ibid., p.9.

7EPA; p.5-29.

8Engelmann; p.26.
                                        66

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1. Building Tightness
2. Plume Concentration and
   Duration
3.  Sheltering Technique
            67

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                         FIGURE 1
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                                       70

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FIGURE 4
   71

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SUBMITTED PAPERS

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                             LESSONS LEARNED
        BY THE ILLINOIS DEPARTMENT OF NUCLEAR SAFETY
                      FROM PARTICIPATION IN FFE-2

                Gary N. Wright, Roy R. Wight and Charles W. Miller

                       Illinois Department of Nuclear Safety
                                Springfield, Illinois
      The second Federal Radiological Emergency Response Plan (FRERP) (Ref. 1) Federal
Field Exercise (FFE-2) was conducted  June 23-25, 1987, at the Commonwealth Edison
Company's (CECo) Zion Nuclear Power Station (NPS) in Zion, Illinois. The first day of this
three-day exercise was the biennial regulatory exercise involving CECo, the States of Illinois
and Wisconsin, the U.S. Nuclear Regulatory Commission (NRC), and Lake (IL) and Kenosha
(WI) counties. On the second day, these participants were joined by the Federal Emergency
Management Agency  (FEMA),  the  U.S.  Department   of Energy  (DOE),  the  U.S.
Environmental Protection Agency (EPA), and other Federal agencies.  The time line of the
exercise was advanced seven days at the end of day two, so that day three of the exercise
corresponded to  day ten of the simulated accident.  Altogether, over 1,000 players at 30
different locations and over 150 controller/evaluators took part in FFE-2. In addition, there
were 130  foreign visitors from 17 countries, and 126 official U.S. visitors who visited the
exercise emergency response facilities in the Zion area.

      The Illinois Department of Nuclear Safety (IDNS) played a key role in FFE-2. Under
the Illinois  Plan for Radiological Accidents (IPRA), IDNS is  responsible for providing
technical support for emergency response activities in the event of a nuclear  power plant
accident in the State of Illinois. During FFE-2, IDNS activated approximately 100 persons
during day one,  and then maintained  the level of activity in cooperation with Federal
personnel during days two and three.  IDNS shifted its primary technical functions from
Springfield on day one to the Federal Radiological Monitoring and Assessment Center
(FRMAC) for days two and three.  IDNS also participated in the management leadership of
the FRMAC to ensure that it supported the needs of the states.

      All  agencies  involved in FFE-2 learned many valuable lessons as a result of their
participation in this exercise. The purpose of this paper is to present some of the major
lessons learned by IDNS as a result of participating in FFE-2.

      The lessons learned from an activity usually refer  to actions that need to be taken in
the future to improve what is being done. While that is certainly the case with FFE-2, it is
important to begin by pointing out  an important general conclusion; that is, the State of
Illinois did demonstrate an ability to protect the health and safety of its citizens in the event
of a nuclear reactor accident similar in  scope to the accident simulated for FFE-2.  If an

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actual release had occurred under the conditions of the exercise, no members of the general
public would have received significant doses from this accident. State and local government
agencies worked together closely and effectively to implement  IPRA, and there was good
coordination with the key Federal agencies.

      An important factor in the success of FFE-2 was the extensive planning that took
place prior to the actual exercise.  This planning began 18 months before the June 1987
exercise.  It included two practice drills that took place before the full exercise:  a Tabletop
exercise in January, 1987; and in May, about six weeks before the exercise, a Dry Run at
Zion where many of the players assembled and participated in a dress rehearsal. In addition,
there were  many smaller groups of players that held extensive planning meetings.  For
example,  the field monitoring staff of the  FRMAC  held meetings  to  identify potential
problems  and solve them before they could occur during the exercise.

      The reason these meetings and all this planning were so important was that Federal
agencies seldom participated fully in normal regulatory exercises. As a result, the meetings
that were held  prior to FFE-2 were important for improving communication links and
settling questions of responsibility and capability.  "What do you do?" was the typical kind
of question that was asked and answered.  Recently, NRG has participated more frequently
in exercises, and we feel that is a very positive sign.

      One of the insights gained from this exercise and planning process is that Federal
guidance  with regard  to protective action recommendations is currently  in a period of
transition. The official guidance from the NRG suggests that dose assessment be used to
evaluate various protective action  decisions such as sheltering versus evacuation (Ref. 2).
During the Dry Run, however, the staff of the NRG Incident Response Genter demonstrated
a different approach to decision making. Their procedure calls for making protective action
decisions on the basis of in-plant parameters wherever possible, not dose assessments, and
evacuation before a release starts is the preferred protective action (Ref. 3). Although this
is an approach preferred by IDNS, it represents a change in philosophy on the part of NRG,
and it initially caused  some confusion between GEGo, state and local officials, and NRG.
Discussions prior to FFE-2 removed this confusion from the exercise itself.  However, it is
interesting to point out that  this philosophy has neither been universally accepted by the
technical community nor formally promulgated as NRG guidance to licensees. Further, the,
two licensees  in the State of Illinois and IDNS are still concerned about just what would
happen in the event of a real accident, despite NRC's position that there is no conflict.

      The integration of the capabilities of IDNS with those of the various Federal agencies
also needs further studying. In a large-scale radiological emergency, the Federal government
would be asked to augment the technical capabilities of the state. During FFE-2, Federal
agencies did supply extensive  resources, including equipment, technical manpower, and
facilities.  However, the integration of the state's  and Federal resources was  not always
smooth.   For example, during FFE-2  the  start-up  of the  various  facilities was  often
unrealistically staged. At the end of day one, the Federal facilities were not yet operational.
At the beginning of day two, however, they were suddenly all in place and fully functional.
Expectations from the Federal facilities were not always realized either. For example, dose
assessments were not produced at the FRMAC as  rapidly as  many expected.   This led to

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 delays in production of useful information from the FRMAC.  Finally, the management of
 the Federal facilities to meet the state's needs was not always as effective as it should have
 been.

      An important conclusion  from FFE-2 is that  realistic exercises involving Federal
 capabilities need to be continued and must be frequent enough to retain the joint capabilities
 developed during FFE-2 (Ref. 4), For example, recovery and re-entry following the release
 were important considerations  during the third day of the exercise.  As the Chernobyl
 accident illustrated, these would be important concerns following a severe nuclear reactor
 accident. Time does not allow sufficient demonstration of these activities during normal
 regulatory exercises, which  generally run from 8:00 in the morning until 3:00 or so in the
 afternoon. During FFE-2, a multi-agency re-entry and recovery group was formed to support
 the states. Staff from IDNS provided direction for this group, and the output of the group
 was in fact very useful to decision makers, but more work needs to be done in this area. The
 recovery and re-entry group needs to be better defined and formalized, and special exercises
 to consider decontamination and re-entry questions need to be conducted.  Furthermore, if
 these re-entry  exercises are going to be effective, they must include Federal participation.

      FFE-2 also served as a proving ground for many of the technical tools that have been
 developed by IDNS.  For example, IDNS normally receives about 1,000 operating parameters
 from each of the  13 nuclear reactors in  Illinois on a near real-time basis.  Simulated
 parameters for Zion NFS were provided during FFE-2. A full set for Zion was not available,
 but  enough   data  were provided  to test IDNS's  computerized analysis software under
 simulated accident  conditions.  Such data  are desirable for all exercises, but they  are not
 always available during regulatory exercises because of the time, money, and effort required
 to develop consistent values for all of these parameters.

      A new PC-based radiological dose assessment model was used for the first time during
 FFE-2 (Ref. 5).  This model allows for very rapid dose projections to be performed. It can
 also generate a picture of the radioactive plume and the pattern  of the ground deposition,
 and can incorporate radiological dose measurements  gathered by the field teams to augment
 model calculations.   These and other IDNS tools have been modified and improved as a
 result of the experience gained from FFE-2.

      Finally, one of the most important lessons confirmed by IDNS from FFE-2 is the fact
 that  final  protective action recommendations  are based on more  than technical and
 operational considerations.  Under IPRA, the Governor of the State of Illinois is the final
 decision maker with regard to protective action recommendations for the general public.
 The Governor or his designee makes this decision on the basis of a variety of considerations.
 There are technical considerations such as the plant conditions, and operational factors such
 as the availability of evacuation routes. However, there are also other concerns to be taken
 into account.  During the Chernobyl accident, for example, governmental agencies in Europe
 often made protective action recommendations that were more  conservative than the
 recommendations of the technical experts they consulted.  During FFE-2, the Governor's
 designee recommended evacuation of certain areas before receiving such a recommendation
 from  IDNS.  It is clear that in a severe nuclear reactor incident  political considerations
would likely play a  key role in protective action decision making.  Those involved in the

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 technical aspects of emergency planning need to remain aware of this fact at all times.

       In conclusion, FFE-2 was a good learning experience for IDNS.  IDNS also firmly
 believes that Federal agencies need to participate in emergency exercises on a more  regular
 basis, and some of the Federal agencies seem to concur (Ref. 4). Most importantly, however,
 Illinois did demonstrate the ability to carry out its responsibilities to protect the health and
 safety of its citizens in the event of a nuclear power plant accident similar in scope to the
 accident simulated in this exercise,
                                  REFERENCES

1.    Federal  Emergency Management  Agency  (FEMA).  1985.  Federal radiological
      emergency response plan, concurrency by all 12 Federal agencies and publication as
      an operational plan. Federal Register 50(217): 46542-46570 (November 8, 1985).

2.    U.S. Nuclear Regulatory Commission  (NRC).  1980.  Criteria for  preparation and
      evaluation of radiological emergency response plans and preparedness in support of
      nuclear power plants. NRC Report NUREG-0654  (FEMA-REP-1), Rev. 1.

3.    U.S. Nuclear Regulatory Commission (NRC). 1987. Pilot program: NRC severe reactor
      accident incident response training manual. NRC Report NUREG-1210, Vol. 1-5.

4.    Baker, G., 1987.  NRC says changes are needed  in Federal emergency response plan.
      Inside NRC, December 7, 1987.

5.    Impell.  1987. User's Manual, MESOREM, Jr. Atmospheric  dispersion  and  dose
      assessment system.  Impell Corporation, Lincolnshire, Illinois.
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            THE USEFULNESS OF INFORMATION PROVIDED
    BY FIELD MEASUREMENTS DURING  UNPLANNED RELEASES
                         INTO THE ENVIRONMENT

                                 Robert W, Terry

                            Radiation Control Division
                              Department of Health
                                Denver, Colorado
      The emergency response manager is required to rapidly evaluate minimal amounts
of information in order to decide whether or not to implement protective measures as an
incident develops. Alarming effluent monitors will likely provide the only measurements of
material actually released into the environment.   For hours, or even days, after a release
event  it  may  be  impossible  to obtain  good  information about  the quantities  and
concentrations  of material at receptor locations.  Therefore, the emergency response
manager will place heavy reliance on modeling of releases.  In preparing for  unplanned
releases,   emphasis  should  be  placed on realistic  expectations  of  survey  instrument
measurements, of the time required to collect and analyze samples from the field, and of the
type of information that can be provided.  This report provides  specific examples that
illustrate both the limitations and strengths of measurement  information in managing an
emergency response.
      Decision making under uncertain conditions is a difficult challenge, and emergency
situations that can  affect the immediate or future well-being of a large segment of the
population present challenges that only a few people have the temperament to accept. Good,
thorough planning can help to achieve the best outcomes for such unfavorable situations,
and may even lead to design or procedure modifications  that keep hazards to a minimum.

Basic Preparation for Unplanned Releases

      The time required to evaluate a release  of material into the environment, to make
decisions  regarding protective  actions, and to implement  those decisions,  will usually
determine the effectiveness of the  response.   Environmental  sample  collection  can only
evaluate releases after they have reached their receptor locations; therefore, they  will be
useless to  the emergency response manager in the initial stages of the  response.

      The emergency response manager will  rely  primarily on modeling techniques to
project the seriousness of the hazard to the public and make decisions regarding protective
actions. Ordinarily, models should be incorporated into  computer programs as part of the
planning and preparation processes,  in order to assure that calculations are made as rapidly,
and accurately, as possible.
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       The computer programs should be interactive and friendly, with default values clearly
 provided to users as an option. In this way, if the first experts who are available to evaluate
 releases lack proficiency with the specific models employed, useful information can still be
 obtained.

       Primary responsibility for developing the models should lie with the facility, but state
 and local government personnel will participate in their development and should be skilled
 in their use and interpretation. In the event that a release does occur, diversity of opinion
 among experts should be encouraged -- provided that the cadre of experts who advise the
 emergency response manager  will produce a succinct consensus opinion,  with a realistic
 assessment of their uncertainty.

       All models must be based on site-specific information; default values for the models
 will be based on worst-case scenarios for design-based releases. The site-specific information
 will be used to project  off-site concentrations and radiation doses.  Relevant information
 about target organs will follow naturally from the dosimetry calculations. All other things
 being equal,  reactor releases will require the most complicated models because the relative
 quantities of the various radionuclides will depend heavily on the recent operating history
 of the reactor.

 Releases to the Air and the Inhalation Pathway

       The fastest pathway to receptors is the airborne release. Airborne releases can reach
 the downwind  population in a matter of minutes.  Protective actions will  invariably be
 initiated before monitoring teams can even reach the field.

       Since the uncertainty about the on-site situation, together with the uncertainty in the
 model projections,  is  so great,  extreme  caution  should be exercised when deploying
 monitoring teams to the field.

      Consider the release of 100 grams (6.13 curies, or 227 GBq) of Pu-239  into the air and
 assume that it all falls to the ground, evenly distributed over a 25 square mile (65 km2) area.
 The resulting surface contamination would be about 2000 dpm/100 cm2.  Of course, not all
 of the material  will fall on the ground in such a small area, and it will not be  evenly
 distributed.  At the facility boundary it is unlikely, even in the event of such a catastrophe,
 that any measurable radioactivity will  be found on the ground with a survey  meter,
 assuming a detection limit of 20 dpm/100 cm2.

      Air sampling poses equally intractable problems for both gross alpha and gross beta
 analysis. Both alpha- and beta-emitting decay products of radon and thoron in  outdoor air
pose a sufficiently great interference in the measurement that the sample will have to be
held for five to 24 hours before an accurate measurement can be made. Sample preparation
for  alpha spectrometric analysis would delay  the  measurement even more.  Gamma
 spectrometric analysis is also time-consuming and will also be subject to interference from
short-lived naturally-occurring material. Nonradioactive contaminants will typically require
elaborate and time-consuming sample preparation prior to measurement, as well.
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       Air  sampling can provide a  very  accurate  evaluation of airborne contaminant
 concentrations, but only after the fact of the release.  Therefore, air sampling will be useful
 only for reconstruction of the incident's impact after the initial and most critical phase of
 the incident has passed.

       If airborne concentrations are to be accurately evaluated, reliance  will have to be
 placed on continuous air samplers that are used for routine surveillance. Placement of air
 sampling devices after an incident has begun probably will not be timely and creates an
 unnecessary hazard for field personnel.

       The best short-term evaluation of the airborne release  will rely  on monitoring
 outbound vehicles at traffic control points, coupled with preprinted questionnaires about the
 passengers' traverse of the plume, that can be filled out  and mailed in at leisure.  Law
 enforcement personnel cannot be expected to carry survey meters and questionnaires in their
 cars in anticipation of an unlikely event; however, this activity may be the most effective use
 of field teams in the early stages of airborne release event.

       Releases to  the  air, which result in deposition on  the  ground,  will also  result in
 deposition on the surface of open reservoirs, lakes and rivers. While the ingestion pathway
 through drinking water and fisheries from an airborne plume will ordinarily be a relatively
 minor hazard  to the public, it will require evaluation; protective actions should not  be
 overlooked. The techniques for coping with this hazard will be similar to those for releases
 directly into the water, with the exception that the reservoir cannot be closed off from the
 source.

 Releases to Surface Water  and the Ingestion Pathway

       With a little bit of luck, downstream reservoirs usually can be closed off before
 contaminated water reaches them, provided a mechanism is in place to warn the affected
 water supplies immediately,  and that plants have adequate control over the  intakes to stop
 the  flow into the  reservoir.   In  many  locations  reservoir  intakes  are  several  miles
 downstream from the release  point, but at the Rocky Flats Plant in Colorado one large
 municipal water system has  an intake directly across the street from the Plant, only about
 one  mile from the release point.

       The Rocky Flats  Plant experience  also points out another problem. In 1973 a release
 of tritium  into the stream, and subsequently into the water supply, occurred for several
 weeks before  it was  discovered by state public health personnel; it was actually several
 months before  Rocky Flats Plant personnel accepted the validity of the measurements and
 identified the cause.  Fortunately,  the radiation dose to the affected population was only
 about five  millirem (0.05 mSv), but experiences of this type should emphasize that even a
 well-developed  emergency response program can be thoroughly defeated if the operating
 conditions at the subject facility are not adequately monitored.

      Initially, both the intake to the reservoir and the intake to the water treatment plant
should be closed off, until good information about the release can  support a decision to
reopen them with confidence.
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       Analysis of alpha emitters will require very elaborate and time-consuming analysis;
 considering sample preparation time, a minimum of eight hours will be required to obtain
 the first gross alpha/gross beta radioactivity measurement.  Alpha spectrometric,  liquid
 scintillation, and gamma spectrometric analysis will require still more time, even before the
 first sample analysis is complete.

 Contamination of Crops, Feed, and Livestock, and the Ingestion Pathway

       Contamination of crops, feed, and livestock will ordinarily follow an airborne release.
 The Workshop on Protective Action Guides (PAGs) for Contaminated Water and Food, held
 in Washington, D.C., on September 13-14, 1989, resulted in several helpful recommendations
 for establishing PAGs and implementing protective actions.   The Codex Alimentarius
 Commission, a joint body  of the World Health  Organization  (WHO)  and the Food and
 Agriculture Organization (FAO), held in Geneva, Switzerland, from July 3-12, 1989, resulted
 in several recommendations based on lessons learned from the Chernobyl incident.

       Both of these groups focussed primarily on the Chernobyl experience, a disaster that
 produced  off-site contamination on such an enormous scale that extreme actions, and
 extreme compromises to the quality of food as well, had to be considered.

      Most of the scenarios that are likely to occur will not produce such widespread and
 extreme contamination.

      The most perishable agricultural products, dairy  products, will require the highest
 priority for assessment.  Emergency response managers should always consider isolation of
 dairy products in the affected areas until conclusive measurements can be performed.

      If a release occurs immediately before planting time, or immediately before harvesting
time, the priority for evaluation of pathways through crops should be elevated.

      Ranchers  and herdsmen will consider  moving their livestock out  of the area,  or
substituting feed.  Public health and agricultural experts  should be prepared  to quickly
provide accurate and authoritative information to this group. Plans should also be made to
assist in the orderly removal of livestock if ranchers and herdsmen so desire, whether or not
 the situation warrants such action.

      Contamination of fisheries is another issue, but is only mentioned here as an item that
warrants additional planning.

Public Expectation  and Measurement and Surveillance Requirements

      PAGs generally are based on the assumption that evacuation or  other protective
measures will affect large populations, or that such a large portion of the food and water
supplies will be  affected  that alternative  supplies will  not be adequate to meet the
population's needs.
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       As experts in this area we have a fairly realistic understanding of the hazards
 involved, and realistic estimates of the effect that intermediate radiation doses will produce.

       Ordinary, reasonable citizens have rather different expectations.  They will ordinarily
 wish to leave an  affected area, no matter how small the actual hazard, unless they can be
 highly motivated to stay in place.  And in this country of bountiful resources, tainted food
 and water, no  matter how small the contaminant concentration is, will be unacceptable,
 particularly where alternative sources are available.   The marketability  of agricultural
 produce can be destroyed unless there is public confidence that every  item in the grocery
 store is absolutely free of contamination from industrial releases.

       We, therefore, should consider emergency response plans that are based on a realistic
 evaluation of public expectation. Law enforcement agencies should be prepared to facilitate
 citizen-initiated evacuation. Water supplies should make every effort to keep their reservoirs
 isolated  until the quality of their product can be confirmed.  Similarly, all food sources
 should be held  in quarantine after a release event until confirmation is obtained that they
 are absolutely free of contamination.

       By "free of contamination" we must agree that  the  laboratory must  measure
 contamination  with extreme sensitivity, not just to the concentrations established by PAGs.
 Good surveillance programs at each facility should consolidate preoperational measurements
 into a complete and thorough summary, and should evaluate contamination during normal
 operations. This  evaluation should not be made to meet minimum regulatory requirements
 that are established by  standards for protection  under ordinary circumstances;  this
 evaluation  should  exploit all available detector time and other excess capacity in the
 laboratory, after basic regulatory requirements have been  met.  Then, in the aftermath of
 a release to the environment, every effort should be made to duplicate the sensitivity of the
 baseline  measurements.

      Continuous air sampling devices should be placed at each point of the compass, and
 maintained to evaluate plumes in the event that releases do occur. Streams, lakes and every
 conceivable food pathway should be measured.  All coefficients that  are used in dosimetry
 analysis  should be reviewed and updated as insight is gained into their site-specific
 application.

Measurement Equipment Needs

      The TABLETOP Exercise in Baton Rouge, Louisiana, conducted on August 28 and
September 18, 1990, concluded, among other things,  that on-site, state, and local personnel
have the expertise to address the problems of implementing  PAGs, but  that  physical
resources are limited. The report of lessons learned from that exercise  recommended that
the Federal  government should keep available large amounts of equipment that can be
deployed on short notice. While there are limitations on the usefulness  of such equipment,
anything will be a help.
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 Conclusions and Recommendations

       The greatest obstacle to measurement of contamination following a release event is
 the quantity of very expensive and sophisticated equipment that is required. A good gamma
 spectrometry system, employing a single detector, costs a minimum of $75,000. A single
 detector system can only analyze one sample at a time.

       Following a release  event the demands for detailed analysis will consume all the
 capacity of an analytical laboratory, no matter how well equipped it is. Effective emergency
 planning will consider a variety of release scenarios and establish a sampling plan that will
 provide optimum use of scarce, identifiable resources. Some allowance should be made for
 discretionary analysis, but strict discipline should be enforced to adhere to the analysis
 priorities that are established in advance. In that way the emergency response manager can
 follow a realistic timetable  for the receipt of measurement reports.

       Finally, the models employed in making projections of hazards from releases should
 use reasonable coefficients.  Models should not build conservatism into projections.  Every
 effort should be  made to make the most accurate estimates possible, and then provide the
 emergency response manager with a clear understanding of the uncertainty involved. It is,
 after all, the emergency response manager's responsibility to exercise caution when needed.
 If the projected hazards lack credibility,  decisions will place  little or  no reliance  on
 information that could have been the best basis for a decision available. And if the projected
hazards are overly cautious, resources may be squandered at a time when they can never be
adequate to meet all the demands  of the situation.
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WORKING GROUP SUMMARIES

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      magnitude" dose estimates for 1 curie releases of a variety of radioactive materials,
      and also for releases from 1 curie quantities of radioactive materials involved in a fire.
      The presentation of this data in the pocket card format appears to be very useful.

4.    What important  differences are there between  monitoring the ingestion
      exposure pathway for incidents at nonreactor nuclear facilities  compared
      to similar monitoring at nuclear power plants?

      Working group members noted that releases from several categories of facilities may
      consist  only of beta-emitting  or  alpha-emitting  radionuclides.   The  absence  of
      gamma-emitting radionuclides will require both different field instrumentation and
      laboratory instrumentation to assess the concentrations of radionuclides  in food and
      water.   DOE airborne monitoring resources, which will be  critical  to the rapid
      assessment of deposited radionuclides as a result of a reactor accident, appear to have
      limited utility for releases from certain nonreactor facilities.  The consensus among
      the working group  members was that more time would be required to monitor such
      releases than releases from reactor facilities.

5.    What important lessons regarding exposure pathways and field monitoring
      have been learned from exercises at nonreactor  nuclear facilities?

      The  working group members  had little experience in exercises  with  nonreactor
      facilities, and thus few "lessons learned" could be gleaned from this source. Based on
      previous presentations and other experiences of the working group members, it was
      agreed that airborne pathways would almost always be dose-dominant,  and that at
                 short term, inhalation would be the controlling pathway.

6.    Wnar problems would DC encountered in monitoring an airborne plume of
      pure alpha emitters or pure beta emitters? Is time a serious constraint for
      choosing protective actions? What effect, if any, should the time required
      to verify such airborne plumes have on the choice of the basis  for taking
      protective actions?

      The working group members agreed that current equipment available to offsite
      agencies would not  permit a "real-time" indication of airborne concentrations of alpha-
      and beta-emitting radionuclides, as a Geiger counter or a pressurized ion chambef
      would for gamma-emitting radionuclides.  Current technology would be limited to
      collection  of an air sample  and subsequent analysis either  in the field  or at  a
      radiochemical laboratory, yielding monitoring results minutes to hours after collection
      of a sample.

      Members of the working group noted a trend among operators of commercial nuclear
      facilities and offsite  agencies to  recommend  and implement measures  for  the
      protection of the general  public based solely on plant  status - regardless of the
      existence of a radioactive materials release.   In these  instances, the protective
      measures are based on the potential for a release of radioactive materials.  Working
      group members urged the use of facility status in the determination of protective

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8.
 measures, particularly for those faculties where "real-time" monitoring of released
 radioactive materials would be difficult or impossible.

 Several members of the  working group indicated that an instrument  such as a
 field-portable continuous air monitor (CAM) would be useful in providing a limited
 real-time indication of airborne plumes of alpha- and/or beta-emitting radionuclides.
 Fixed CAM systems are used in a variety of facilities to continuously sample and
 analyze air for the presence of radioactive materials.

 Members of the working group also noted that field monitoring and  laboratory
 procedures and laboratory equipment may not be adequate to verify the presence of
 an airborne plume of alpha- and/or beta-emitting radionuclides. The working group
 indicated a need for guidance and training in this area.

 What additional monitoring equipment will be needed by state and local
 responders for incidents at nonreactor nuclear facilities?  Consider:
 *      emergency response teams
 *      off-site personnel
 *      contamination on food and other surfaces
 *      minimum detection levels compared to derived response levels

 As mentioned above,  the working group recognized a  need for field-portable
 instrumentation to provide a real-time indication of the presence of airborne alpha-
 and/or beta-emitting radionuclides. For contamination monitoring, the working group
 indicated  that alpha  scintillators and Fidler probes would probably be adequate for
 alpha-emitters, and  that existing beta-gamma instruments may be adequate for
 high-energy beta-emitters.

 Monitoring for the presence of low-energy beta-emitters (e.g., H-3, C-14, etc.) would
 require either additional equipment or the services of a radiochemical laboratory.

 What early monitoring services can be implemented by nonreactor nuclear
 facility operators?  Should a list of these services and methods for accessing
 them be identified in state plans?

 The members of the  working group recognized that facility operators are uniquely
 qualified and  equipped  to deal with radionuclides  used at their facilities.   More
 importantly, they are familiar with the systems in use at their faculties to detect the
 presence of abnormal conditions.  At major facilities, these  systems  may  include
 real-time  effluent or environmental radiation monitoring systems and/or vehicles
 specifically equipped  to  monitor for radioactive materials. The facility  operators
 should provide for, and the state  plan should identify the methods for state personnel
 to obtain access  to monitoring data gathered by the facility operator.  This system
 should also allow for the faculty operator to access monitoring data gathered by offsite
response agencies.
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9.    Are there any types of special laboratory analytical equipment that are not
      available to states that would be necessary for monitoring in the event of an
      accident at a nonreactor nuclear facility?

      The major laboratory analytical  systems required for monitoring releases  from
      nonreactor facilities (i.e., liquid scintillation (LS) counters, alpha-beta counters, alpha
      spectrometry  systems)  are likely to be  already  in  place  and in  use  by  state
      radiochemical laboratories,  with the  possible exception of  alpha  spectrometry
      capability.  The working group members did note, however, that most states would
      be ill-equipped to handle a large number of samples under "emergency" conditions
      with these systems.  More important than the equipment itself are the procedures and
      training required to prepare samples for analysis by these systems.  Working group
      members identified a specific need for training, particularly in the area of analysis for
      transuranics.

10.   What problems can be identified regarding the use of the dose limits for
      workers performing emergency services as prescribed in the revised PAG
      manual?

      The most obvious problem identified by the working group is the inability to monitor
      radiation doses delivered to radiation workers in real time when dealing only with
      alpha- and beta-emitting radionuclides. This problem led the members of the working
      group to conclude that the performance of monitoring activities would likely require
      the use of respiratory protection.  In order  to conclusively determine  internal
      radiation doses, offsite agencies would need a bioassay program, including baseline
      bioassay data.

11.   How should the inability to accurately project dose from an accident at a
      nonreactor nuclear facility affect decisions to take protective actions?

      The language of the question implies that we have the ability to "accurately project"
      dose from accidents at reactor facilities.  Members of the working group suggested
      replacing the phrase "accurate project" with "estimate," highlighting the inherent
      uncertainties  in the assessment of offsite  consequences  from releases of radioactive
      materials.

      The inability to estimate offsite radiation doses,  coupled with the inability to monitor
      for airborne alpha- and beta-emitting radionuclides in real time, should drive facility
      operators and offsite responders to base protective action decisions on the status of
      systems required for the protection of the public (plant status).  The inability to
      rapidly confirm radiological status may cause offsite agencies to "err on the side of
      public health and safety," basing protective action decisions on assumptions which
      may later prove to be substantially conservative.
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                     SUMMARY REPORT OF WORKSHOP B

                         Leader: Stanley R. Marshall, Nevada

TOPIC: The Planning Basis and the Roles of Planning and Response Authorities

      As a result of the group discussions, group consensus supported a general discussion
with  the full group,  addressing the general questions  when  appropriate but without
specifically using the questions to deliver our summary to the full group.

      The group members also voted that I should lead the Group B discussion with the full
group so I entitled the Group B discussion remarks, Raindrops, Dogpaddling  and PAGs:
What Do They Have In Common?.  The title, with some qualification, seemed appropriate
to me because the general emergency planning issue must  also be qualified  to describe
parameters by which emergency  response planning is conducted.  You may recall that I
referenced Aubrey Godwin's story about a 6-inch rain. Was the rain 6 inches deep or were
the raindrops 6 inches apart?  Whether discussing rain or PAGs, perspective is  important.

      I  have attempted to organize the group comments in order of the questions for
purposes of similar reporting by the other groups:
1.
What should be the basis for the size and shape of the Emergency Planning
Zones (EPZs)?

The group decided that the following minimum issues should be addressed in order
to develop appropriate nonreactor EPZ size and shape:
      1.     characterize the radiation source term.
      2.     characterize EPZs and other pathways.
      3.     identify population demographics.
      4.     characterize  maximum  "credible"  accident
            "incredible" accident scenario).
                                                (do  not devote  resources  to
2.
3.
How should probability of incident severity figure into selecting the size of
the EPZ?

The  group again agreed that  the  parameters  in  Issue 1 must be considered to
determine emergency action levels (EALs).

How would the time frame of release, notification, or response for incidents
at Federal facilities differ from those at nuclear power plants?

Release time, notification  and response time  will differ by significance of  the
parameters in Issue 1.

Education of planning agencies and obligation by a facility operator to provide
information allows planning agencies to develop response plans.

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 4.    How should size of the site affect the size of the EPZ?

      Group B participants agreed that onsite circumstances might not translate well to
      offsite areas.  Issue 1 answer indicates onsite parameters that have to be addressed
      in the effort to determine size of EPZ and degree of implementation of PAG activities.
      Some may not be appropriate based on onsite parameters.

 5.    What conditions at a  Federal  facility  would indicate  that an offsite
      emergency response plan or an EPZ is not needed?

      Again, Issue 1 answer parameters provide  the minimum conditions to determine
      whether an EPZ is needed.
6.
7.
8.
      1.    characterize the radiation source term.
      2.    characterize EPZs and other pathways.
      3.    identify population demographics.
      4.    characterize  maximum  "credible"  accident
            "incredible" accident scenario).
                                               (do not  devote  resources  to
How much information is available to State REP officials regarding source
term type, magnitude, and probability of occurrence: Is it adequate? What
(if any) additional information is needed?

The group recognized that some Federal information restrictions would prevent some
information from being available to state and local  planners.  Available onsite
information may also  not be in a form that is directly  usable by state or local
planners.  It is essential that state and local planners be provided opportunities to
meet with onsite personnel to understand information that is pertinent to emergency
planning.

What revisions to NUREG-0654  are necessary to make  it a satisfactory
outline for the  development of State and  local REP plans for Federal
facilities?

Revision of NUREG-0654 should require development of a well defined source term
to make it a satisfactory outline for state and local nonreactor plans.

To what degree should the Regional Advisory Committee (RAC) be used for
Federal facility REP plans and exercises?

Group  B did not believe that  RACs have any authority  for peacetime response
activities.  Typically, state legislation provides for state  and/or local agency response
designation without regard to federal agency organization or resources that may stand
ready to respond.
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9.    What roles should FEMA and other Federal agencies have in revising State
      and local plans to include response to incidents at Federal facilities?

      Group B did not believe that FEMA has authority for peacetime response activities.
      Typically, state legislation provides for state and/or local agency response designation
      without regard to federal agency organization or resources that may stand ready to
      respond.

10.   What role should FEMA and other Federal agencies play in exercising at
      Federal facilities?

      Consider planning, scheduling, scenario development, controlling, playing, evaluating,
      documenting findings, and concurring in the adequacy of response.  Group B did not
      believe that FEMA has authority for peacetime response activities, therefore,  FEMA
      should play only a supporting role to state and local agencies in exercise scenarios at
      state and local request.

11.   What agreements for planning, exercising and/or response need to be made
      between Federal facility operators and state and local officials?

      Consider  site access, classified areas, data, etc.  Again,  the degree of agreements
      between facilities  and state/local agencies will be  dependent on the  parameters in
      Issue 1.  The agreements will also depend on facility operation restrictions that may
      exist that provide state and local leverage for obtaining information, assistance and
      cooperation from the facility management/ownership.

12.   What restrictions are appropriate for public information releases from other
      Federal agencies and state and local governments? Are pre-prepared news
      releases  appropriate?

      The Federal government should never provide any press release unless the response
      information concerns a Federal facility. State and local government press releases are
      usually dependent on state/local administrative procedures that are developed.  Issues
      concerning terrorism or national security would require coordinated press releases
      from federal, state and local agencies.

13.   How will security restrictions at nonreactor facilities affect state and local
      officials in planning, exercising, training and response? What are potential
      solutions?

      Group B  participants who represented state  agencies did not think that security
      restrictions at nonreactor facilities were a problem. Comments during some open
      discussion indicated that states felt they needed clearance for Federal facilities; others
      indicated  they could implement adequate emergency plans without any level of
      Federal clearance.
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ISSUE:
      SUMMARY REPORT OF WORKING GROUP C

               Leader: Gary N. Wright, Illinois

The  Need  for  Specific Guidance on  Dose Projection,  Protective Actions,
Training, and Exercises for Implementing  PAGs  for Nuclear Incidents at
Nonreactor Nuclear Facilities
1.    Do implementation procedures in the PAG manual for evacuation  and
      relocation  (Chapters 5  and  7) require  expansion to  apply to  nuclear
      incidents at nonreactor nuclear facilities? If so, who should develop them?

      The group recognized that far too little information is currently available  to offsite
      planning agencies regarding the nature of the hazards at many of these  facilities.
      However, based on  what is known, many of these facih'ties may present hazards
      somewhat different  in nature than those presented by commercial  nuclear reactor
      facilities.  For example,  some may present mixed chemical/radiological  hazards.
      Therefore, the group felt that it is likely that the current implementation procedures
      for evacuation and relocation will likely require expansion to address these different
      types of hazards.

      The group felt that  the responsibility for developing the necessary information and
      models to characterize hazards should fall to the owner/operator of these  facih'ties.
      The responsibility to expand current implementation procedures should likely rest
      with the U.S. Environmental Protection Agency (EPA), in coordination with FEMA,
      U.S. Department of Energy (DOE), and U.S. Nuclear Regulatory Commission (NRC).

2.    What important lessons regarding dose projection, protective  actions,
      training, and exercises have been  learned  from exercises at nonreactor
      nuclear facilities?

      Although the group's experience in such exercises was limited, the group felt strongly
      that the level of planning, training, and exercises for some facilities should be at a
      level equivalent to that for commercial nuclear power plants. However, they felt that
      dose projection may be different in some cases than those for power reactors.  The
      level of knowledge and training for offsite responders for such facilities should be
      similar to that for power reactors.  All hazards at such facilities should be fully
      evaluated and exercises should include combinations  of  such hazards,  e.g. mixed
      chemical/radiological hazards.

3.    How will security restrictions affect  planning, exercises, training, and
      response?  What agreements are appropriate during the planning phase to
      avoid problems during response?

      The group  felt that any security  restrictions which limit offsite planner's  and
      resporider's knowledge of source term, dispersion characteristics, and site access could
      severely  hamper response.  Therefore,  the group felt that agreements should be

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6.
8.
 developed to alleviate such problems.  A generic format for such agreements should
 be negotiated  at  the highest levels, e.g. the National Governor's Association and
 appropriate federal agencies, to ensure some degree of uniformity throughout the U.S.
 These agreements might very well include provisions for key offsite planning and
 response personnel to obtain security clearances to ensure access to  necessary
 information and the site.

 What special planning in the areas of dose projection, protective actions,
 and training is needed to deal with possible broken arrows?

 The group decided that  some training is needed for all States since such an event
 could occur anywhere.  The unique nature of such devices requires training on the
 nature  of  the  source  term, possible  dispersal  characteristics,   and  monitoring
 instrumentation and techniques.

 What special  training will be needed  by offsite  responders to nuclear
 incidents at nonreactor nuclear facilities that is different from the training
 currently offered for planners and responders to incidents at nuclear power
 plants?

 Information regarding source term and dispersal modes for many of these facilities is
 not readily available to offsite responders, which makes it difficult to fully address this
 question.  However, the group agreed that most States have limited capabilities for
 field monitoring for alpha contamination. In addition, the need for training in dealing
 with mixed hazards will be necessary for response to some facilities.

What  additional  guidance is needed  regarding deposited radioactive
material on persons and other surfaces from nuclear incidents at nonreactor
nuclear facilities?  Who should develop it?

The group  decided that the EPA should give additional attention to alpha surface
contamination levels.

How does the State's responsibility to protect its citizens relate to the
sometimes large, onsite, non-worker populations at some nonreactor nuclear
facilities? Is it different from its responsibility at commercial nuclear power
plants?

The group decided  that  the owner/operators of  such facilities  has the primary
responsibility for protection of non-worker populations. However, their procedures
 should be developed in consultation with state and local governments.

What substantive revisions  to State and local REP plans, if any, are
necessary to  accommodate response  to nuclear incidents at nonreactor
nuclear facilities?

The group felt that for some facilities detailed site  specific planning, similar to that

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      for power reactors, will be necessary.

9.    What additional guidance is needed on planning and conducting exercises
      for nuclear incidents at nonreactor nuclear facilities?

      Additional guidance will be needed to deal with the different nature of some of the
      source terms and modes of dispersal presented by some nonreactor faculties.

10.   Can  circumstances be identified in which telephone  drills or table-top
      exercises could be used to reduce the magnitude and cost of field exercises
      at nonreactor nuclear facilities without reducing preparedness?  If so, who
      should develop and implement such drills or exercises?

      The group could not identify any specific circumstances. However, they felt that there
      are probably instances where telephone drills and tabletops could be used. However,
      these should not be used to  eliminate  full exercises which will be needed at some
      agreed-upon frequency.
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ISSUE:
      SUMMARY REPORT OF WORKING GROUP D

               Leader: Debra Shults, Tennessee

Integration of Emergency Response for Incidents in Which the Release Includes
Both Hazardous Chemical and Radiological Contaminants (Mixed Incidents)
      Eleven issues under this topic were provided to the group for discussion. Although
there were differing opinions on almost all the issues, the consensus of the group was that
the basic planning criteria and fundamental guidance needed for mixed incidents were so
closely related to those of a radiation incident that planning and exercising for these mixed
incidents could be accomplished.

      The group's discussions can be outlined in four major areas:
            1.     Risk Evaluation
            2.     Planning
            3.     Exercising
            4.     Federal Assistance

1.    Risk Evaluation

      Our experience involving mixed incidents to date  has indicated that the chemical
      hazard is usually  the  greatest hazard involved but not necessarily the one  that
      receives the most attention from the media  or those involved in responding to the
      incident.   There should be a mechanism in place  to compare risk levels  between
      chemicals and radioactive materials. If there were a philosophy or structure in place
      to compare the  two, it would need to be placed  into a  guidance document.  In
      comparing these risks, studies should be performed concerning the synergistic effects
      of the combinations  of chemicals and radioactive materials.  An assessment of the
      actual mixed source terms at Federal facilities should be made as soon as possible.

2.    Planning

      Most states are aware of the potential for mixed incidents at facilities which they or
      the NRC regulate. However, most states are not aware of the potential at Federal
      facilities which they do not regulate.  In planning for these incidents, expertise from
      all areas involved should be considered.  At both the state and Federal level, different
      response  structures are often used for chemical versus radiological response.  In order
      to provide adequate response, it  is essential  that there  be communication between
      these groups, an understanding of the command structure, and as much integration
      of the systems as possible.

      There is no need to write a separate plan for every possible  mixed incident. Planning
      should be done for the concept, not to each mixed hazard. Many states have separate
      written procedures for chemical and radiological  incidents.  These states might
      reference a "mixed" incident in their existing plans.
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3.    Exercising

      There was a real division among the group regarding the need for exercising mixed
      incidents.  Most believed states should exercise a mixed incident scenario if there is
      a possibility that one may occur at a facility within their state  or in transit within
      their state's borders.  Several states have included a chemical incident during a
      nuclear power plant exercise, but did not actually incorporate a mixed incident during
      these  scenarios.   There  was concern  expressed  by the  group that radiological
      professionals would tend to overlook chemical hazards during a real event thus posing
      a threat  to themselves and others.  The group believed that more cross training
      between  the chemical and radiological personnel should occur.

4.    Federal Assistance

      The Federal government  should continue to streamline and consolidate authority to
      aid states in knowing "who's in charge?" during a mixed incident.  The responsible
      parties could compare the relative risks of both hazards and  advise  the decision
      makers.   The Federal agencies also should  participate  realistically  during these
      exercises by including all the resources that would actually be used in an emergency.
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