NUREG-0396
                                   EPA 520/1-78-016
PLANNING BASIS FOR THE DEVELOPMENT OF
      STATE AND LOCAL GOVERNMENT
RADIOLOGICAL EMERGENCY RESPONSE PLANS
                IN SUPPORT OF
   LIGHT WATER NUCLEAR POWER PLANTS

                A Report Prepared by a
         U. S. Nuclear Regulatory Commission and
          U. S. Environmental Protection Agency
           Task Force on Emergency Planning
                    DECEMBER 1978
                 Office of State Programs
             Office of Nuclear Reactor Regulation
             U. S. Nuclear Regulatory Commission
               Office of Radiation Programs
             U. S. Environmental Protection Agency

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              Available from
   National Technical Information Service
        Springfield, Virginia  22161
Price:  Printed Copy $7.25 ; Microfiche $3.00

The price of this document for requesters outside
of the North American Continent can be obtained
from the National Technical Information Service.

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                                          NUREG-0396
                                          EPA 520/1-78-016
 PLANNING BASIS FOR THE DEVELOPMENT OF
       STATE AND LOCAL GOVERNMENT
RADIOLOGICAL EMERGENCY RESPONSE PLANS
                  IN SUPPORT OF
    LIGHT WATER NUCLEAR POWER PLANTS

                A Report Prepared by a
        U. S. Nuclear Regulatory Commission and
         U. S. Environmental Protection Agency
           Task Force on Emergency Planning
                  H. E. Collins*  B. K. Grimes**
                   Co-Chairmen of Task Force
                        F. Galpin***
                   Senior EPA Representative
                Manuscript Completed: November 1978
                     Date Published: December 1978
                    *Off ice of State Programs
               * "Office of Nuclear Reactor Regulation
                U. S. Nuclear Regulatory Commission
                    Washington, D.C. 20555
                 ***Office of Radiation Programs
               U. S. Environmental Protection Agency
                    Washington, D. C. 20460

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                                FOREWORD

The purpose of this report is to provide a basis for Federal, State and
local government emergency preparedness organizations to determine the
appropriate degree of emergency response planning efforts in the environs
of nuclear power plants.  The report is the product of a Task Force of
NRC and EPA representatives formed in 1976 to address this issue.  The
Task Force hopes that the guidance provided here will be used to supplement
the extensive emergency planning guidance already published by NRC and
EPA.

This report introduces the concept of generic Emergency Planning Zones
as a basis for the planning of response actions which would result in
dose savings in the environs of nuclear facilities  in the event of a
serious power reactor accident.  Application of the Task Force guidance
should result in the development of more uniform emergency plans from
site to site but should not result in a large incremental increase in
the resources required to implement the existing planning elements.
This is particularly true of recently licensed plants where planning
elements have been implemented at substantial distances from reactor
sites.

This report represents a consensus view of the Task Force on the
planning basis guidance and on a number of important  Issues  related
to emergency planning which were considered  in the  development  of
                                 i

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the guidance.  As of the publication date of this report, these
recommendations had not been formally adopted by the NRC or EPA and
therefore represent only Task Force views.  However, the concept of
a generic area in which to plan has received general acceptance by the
variety of groups commenting on drafts of this report.  If adopted by
the NRC, the Task Force expects that the key elements of the guidance
would be incorporated in the NRC's primary emergency planning guidance
publication for States and their local governments (NUREG-75/111) and
therefore used by Federal agencies as a part of the basis for concurrence
in State and local government Radiological Emergency Response Plans in
support of power reactor facilities.

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                         NRC/EPA TASK FORCE
                                 ON
                         EMERGENCY PLANNING


 Membership on the Task Force on Emergency Planning was drawn from both
 the United States Nuclear Regulatory Commission and the United  States
 Environmental Protection Agency and is listed below.

                             Co-Chairmen

 Harold E. Collins, Assistant Director for Emergency Preparedness, Office
   of State Programs, NRC
 Brian K. Grimes, Assistant Director for Engineering and Projects, Division
   of Operating Reactors, Office of Nuclear Reactor Regulation,  NRC


                      Senior EPA Representative

 Floyd L. Galpin, Director, Environmental Analysis Division,  Office of
   Radiation Programs, EPA


                               Members

*Roger M. Blond, Senior Risk Analyst,  Probabilistic Analysis  Staff, Office of
   Nuclear Regulatory Research, NRC
 Harry W. Calley, Chief, Protective Action Planning and Investigation
   Branch, Office of Radiation Programs, EPA
 Leo B.  Higginbotham, Acting Director, Division of Fuel Facilities and
   Materials Safety & Inspection, Office of Inspection and Enforcement,  NRC
 C. Vernon Hodge, Transportation Specialist, Transportation  Branch, Office
   of Nuclear Material Safety & Safeguards, NRC
 Michael  T. Jamgochian, Nuclear Engineer, Site Designation Standards Branch,
   Office of Standards Development, NRC
 Joe Logsdon, Health Physicist, Protective Action Planning and Investigation
   Branch, Office of Radiation Programs, EPA
 James A. Martin, Reactor Safety Engineer, Accident Analysis Branch, Office
   of Nuclear Reactor Regulation, NRC
 Jerry Swift, Environmental  Engineer (Radiation), Technology Assessment
   Division, Office of Radiation Programs, EPA


                    Consultants to the Task Force

 Fredric  D. Anderson, Senior Nuclear Safety Engineer,  Site Designation
   Standards Branch, Office of Standards Development,  NRC
 Delbert  F. Bunch,  Director, Program Support Staff, Office of Nuclear
   Reactor Regulation, NRC
 R. Wayne Houston,  Chief, Accident Analysis Branch, Office of Nuclear
   Reactor Regulation, NRC

            Legal Consultants Acquired by the Task Force
 Joseph Scinto, Deputy Director, Hearing Division, Office of Executive Legal
   Director, NRC
 Royal J.  Voegeli,  Attorney, Office of the Executive Legal Director, NRC

 *  Replaced Ian B.  Wall, Office of Nuclear Regulatory Research effective
   May 15, 1978.
                                  iii

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                           ACKNOWLEDGEMENT
 Two major  versions  of  this Task  Force  report  have  been  reviewed by
 interested Federal  agencies,  and a  limited number  of State and
 local government  emergency preparedness representatives.  Many written
 comments and  suggestions were received on the two  major draft versions
 and all of the  comments were  carefully considered  in preparing the
 final version of  this  report.  The  report was significantly improved
 as a result of  the  comments and  suggestions.

 The Task Force  wishes  to thank all  of those who provided comments and
 critiques  of the  report during the  two year period of its development
 and in particular the  Interorganizational Advisory Committee on
 Radiological Emergency Response  Planning and Preparedness, of the
 Conference of (State) Radiation  Control Program Directors.
Members  of the committee also included representatives of the National
Association of State Directors for  Disaster Preparedness and the U.S.
Civil  Defense Council.
                                iv

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                          TABLE OF OCMltHTS
  I.  Introduction                                            1
      Accident Considerations                                 4
 II.  Planning Needs                                          7
III.  Rsoonmended Planning Basis                             11
          Emergency Planning Zones    — ^/^               11
          Size of the Emergency Planning Zone —&.fA        15  — r/l*
    f C.  Time Factors Associated with Releases              18
 1 0i^, it
"  [D.  Radiological Characteristics of Releases           20
 IV.  Conclusions                                            24
      References                                             25
      Glossary                                               26
      Appendix I - Rationale for the Planning Basis         1-1
         A.   General Considerations                         1-1
         B.   Consequence Considerations                     1-4
             1.  Design Basis Accidents                     1-4
             2.  Class 9 Accidents                          1-6
         C.   Probability Considerations                     1-7
         D.   Emergency Planning Considerations Derived
             from Siting, Meteorological Models, and
             Licensing Criteria                            1-12
             1.  Siting                                    1-12
             2.  Meteorological Considerations             1-20
             3.  Licensing Considerations                  1-26
         E.   Emergency Planning Considerations Derived
             fron the Reactor Safety StuSy (ttASH-1400)      1-36
         F.   Examination of Offsite Emergency Protection
             Measures for Core Melt Accidents              1-44
      References                                           1-53

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                 TABLE OF CONTENTS (Ccn't.)
Appendix II - Background Concerning the Report      II-l

   A.  NRC Reactor Siting and Emergency Planning
       Regulations                                  II-l

   B.  Federal Guidance Effort                      II-3

   C.  Reactor Accident Considerations              II-8

   D.  Establishment of the Task Force             11-13

References                                         11-15

Appendix III - Related Issues Considered By
               the Task Force                      III-l

   A.  Issue:  Whether and to what extent, so-
       called "Class 9" events having consequences
       beyond the most serious design basis
       accidents analyzed for siting purposes,
       should be considered in developing emergency
       plans                                       III-l

   B.  Issue:  Is there a need to plan beyond the
       low Population Zone?                        III-5

   C.  Issue:  Whether there is a conflict between
       Protective Action Guides for plums exposures
       and dose criteria for siting and design of
       nuclear power facilities                    III-8

   D.  Issue:  Whether the guidance in this document
       for offsite emergency planning can be
       separated from siting considerations in the
       NRC licensing process                      111-12

References                                        111-17
                         VI

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                      TABLE OF OONTENTS (Con't.)


                           List of Tables

  Table ft

  1.  Guidance en Size of the Emergency Planning Zone      17

  2.  Guidance on Initiation and Duration of Release       20

  3.  Radionuclides with Significant Contributions to
      Dominant Exposure Modes                              23

1-1.  Relation of Turbulence Types to Weather
      Conditions                                         1-15

1-2.  Upper Bound Plume Exposure Pathway Projected
      Doses Based on 10 CFR Part 100.11 Values           1-17

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                        TftBIE OF CONTENTS (Oon't.)


                             list of Figures

    Figure #

    1.   Concept of Emergency Planning Zones                  12

  1-1.   Dose Falloff with Distance                         1-18

  1-2.   Crosswind versus Downwind Distances                1-21

  1-3.   Wind Persistence (22 1/2° sector)                   1-23

  1-4.   Wind Persistence (67 1/2° sector)                   1-24

  1-5.   Example of Time-Dose-Distance Relationships
        for Worst Case DBA Thyroid Dose  (Inhalation) -
        Plume Exposure Pathway                             1-29

  1-6.   Thyroid Dose Versus Distance (DBA-HX&)             1-30

  1-7.   Cumulative Frequency of Thyroid Dose at
        10 miles                                           1-31

  1-8.   Whole Body Dose Versus Distance  (DBA-LOCA)          1-32

  1-9.   Cumulative Frequency of Whole Body Dose at
        10 miles                                           1-33

1-10.   Thyroid Ihgestion Dose Versus Distance              1-35

1-11.   Conditional Probability of Whole Body Dose
        Versus  Distance given Core Melt                     1-38

1-12.   Conditional Probability of Lung Dose Versus
        Distance given Core Melt                            1-39

1-13.   Conditional Probability of Thyroid Dose Versus
        Distance given Core Melt                            1-40

1-14.  Conditional Probability of Thyroid Ingestim
       Dose Versus  Distance given Core Melt               1-42

1-15.  Conditional Probability of Exceeding PflGs
       given PWR "melt-through" releases                   1-46

1-16.  Conditional Probability of Exceeding PAGs
       given PWR "atmospheric" releases                    1-46
                              viil

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                       TRBIE OF CONTENTS (OOn't.)


                       List of Figures (Con't.)
   Figure #
1-17.  Early Fatalities for Selected Protective
       Actions-                                            1-48

1-18.  Early Injuries for Selected Protective Actions     1-48
                                IX

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I.   INTRODUCTION
    Nuclear facility licensees are required by NRC regulations  to  develop
    emergency response plans^   .   Portions of these regulations require
    the licensees to coordinate their plans with State and local  agencies.
                              (2  3)
    Published Federal  guidancev ' ' recommends that State and local
    governments formalize their emergency response plans in support  of
    these facilities to protect public health and safety in the unlikely
    event of a significant release of radioactive material from a nuclear
    facility to the environment.
    Present Federal  guidance* suggests the use of a spectrum of accidents as
    a basis for developing emergency response plans.  For various reasons,*
    in 1976 an ad hoc Task Force of the Conference of (State) Radiation
    Control Program Directors passed a resolution requesting NRC to "make
    a determination of the most severe accident basis for which radiological
    emergency response plans should be developed by offsite agencies".
    Additionally, the NRC and EPA received other comments from State and
    local  governments relating to this recommendation.
    *See Appendix II.

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                                    - 2 -
In November 1976, a Task Force consisting of NRC and EPA representatives
was convened to address this Conference request and related issues.
The Task Force reviewed what is currently being done in terms of
emergency planning for newly licensed plants and found that substantial
efforts were being made both in on-site and off-site planning.  It
also reviewed current guidance from Federal Agencies regarding emergency
                  (2 3 4)
response planningv * * ' and concluded that adequate guidance was
available or was  being developed with regard to the elements of a
plan.  While the  previous guidance has not precisely specified distances
to which planning elements should be applied, the actual current
application of previous guidance on a case basis during the licensing
process has in practice extended to substantial distances from
reactor sites, i.e., independent of specific Low Population Zone
distances used for siting purposes.  However, information regarding
the consequences  and characteristics of the accident situation for
which planning was being recommended had not been fully defined.

The Task Force accepts the principle noted in existing NRC and EPA
        (2  3)
guidancev  *  ' that acceptable values for emergency doses to the
public under the actual  conditions of a nuclear accident cannot be
predetermined.  The emergency actions taken in any individual  case

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                                   - 3 -
must be based on the actual conditions that exist and are projected
at the time of an accident.  For very serious accidents, predetermined
protective actions would be taken if projected doses, at any place and
time during an actual accident, appeared to be at or above the appli-
cable proposed Protective Action Guides (PAGs), based on information
readily available in the reactor control room, i.e., at predetermined
                       (A)
emergency action levelsv   .  Of course, ad hoc actions, based on
plant or environmental measurements, could be taken at any time.
The concept of Protective Action Guides was introduced to radiologi-
cal emergency response planning to assist public health and other
governmental authorities in deciding how much of a  radiation  hazard
in the environment constitutes a basis  for initiating emergency
protective actions.  These guides (PAGs) are  expressed  in units
of radiation dose (rem) and represent trigger or initiation levels,
which warrant pre-selected protective actions for the public  if
the projected (future) dose received by an individual in the
absence of a protective action exceeds  the PAG.  PAGs are defined
or definable for all  pathways  of radiation exposure to  man  and
are proposed as guidance to be used  as  a basis  for  taking action
to minimize the impact on  individuals.

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                                 - 4 -
The nature of PAGs is such that they cannot be used to assure that
a given level of exposure to individuals in the population is
prevented.   In any particular response situation, a range of
doses may be experienced, principally depending on the distance
from the point of release.  Some of these doses may be well in
excess of the PAG levels and clearly warrant the initiation of
any feasible protective actions.  This does not mean, however,
that doses above PAG levels can be prevented or that emergency
response plans should have as their objective preventing doses
above PAG levels.  Furthermore, PAGs represent only trigger levels
and are not  intended to represent acceptable dose levels.  PAGs are
tools to be  used as a decision aid in the actual response situation.
Methods for  the implementation of Protective Action Guides are an
essential element of emergency planning.  These include the pre-
determination of emergency conditions for which planned protective
actions such as shelter and/or evacuation would be implemented
offsite.  Details of these methods are being provided as separate
        (3 4)
guidancev '  ' and are not included in this report.

Accident Considerations

After considerable discussion, the Task Force concluded that there
was no specific accident sequence that could be isolated as the
one for which to plan, because each accident could have different

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                                - 5 -
consequences, both in nature and degree.   Further,  the range of
possible selections for a planning basis  is very large, starting
with a zero point of requiring no planning at all  because signifi-
cant offsite radiological accident consequences are unlikely to occur,
to planning for the worst physically possible accident regardless
of its extremely low likelihood.  As an alternative to attempting
to define a specific accident sequence, the Task Force decided to
identify the bounds of the parameters for which planning is
recommended based upon a knowledge of the potential consequences,
timing, and release characteristics of a spectrum of accidents.
The Task Force recognized that more specific guidance with respect
to accidents whose consequences would be more severe than the design
basis accidents explicitly considered in the licensing process was
appropriate.  Additional discussions regarding the need to plan for
consequences of such accidents  (commonly known as Class 9 accidents*)
may be found in Appendix III.

The Task Force concluded that the objective of emergency response plans
should be to provide dose savings for a spectrum of accidents that
could produce offsite doses in  excess of the PAGs.  Although the selected
 throughout thTs report, "Class 9 accidents" will refer to those accidents
 in which there is melting of the core and/or containment failure.

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                                      -  6  -
 planning  basis  is  independent  of  a  specific  accident  sequence, a number

 of  accident  descriptions were  reviewed  including the  design basis accidents

 with  various  active engineered safety features, and the accident release

 categories of the  Reactor Safety  Study*^  '.


 Additional information regarding  the rationale for the recommended planning

 basis,the background of Federal emergency planning efforts, the Task Force

 deliberations on Class 9 accidents, the relationship between emergency

 planning and  siting criteria, and the difference between PAGs and dose

 criteria used for  siting can be found in the appendices to this report.
*The Task Force has used information in the RSS as a basis to perform
 calculations which illustrate the likelihood of certain offsite dose
 levels given a core melt accident.  Various aspects of the study have
 been debated by reviewers and additional  programs are underway to extend
 or refine the study.  While the RSS is considered by the Task Force to
 have limited use in dealing with plant/site specific factors, it provides
 the best currently available source of information on the relative
 likelihood of large accidental  releases of radioactivity given a core
 melt event.   The results derived from the RSS-based work served to
 confirm the  Task Force judgment that offsite planning for a generic
 distance around nuclear power plants is prudent and useful.

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                                        -  7  -
II.   PLANNING NEEDS
     The Task Force reviewed the types of information that  State  and
     local  governments need to develop emergency response plans and
     determined that the information fell  into two categories;  site
     specific and generic.   The site specific information such  as
     population distribution and topography must be available to  State
     and local officials as part of the planning process.   Such informa-
     tion is summarized in  Environmental  Reports and Safety Analysis
     Reports prepared by applicants for a permit to construct and
     operate a nuclear power facility and is useful for emergency
     planning purposes.  Some generic information related  to the
                                                                  (2 3 4)
     planning effort is already being provided by Federal  agencies  '    .
     The Federal generic guidance provided includes the topics which should
     be addressed in an emergency plan^ '  , protective action guides   ,
     the types of protective action appropriate^ ' and emergency instru-
     mentation considerations^  ' ' '.

     If it were possible to identify a single accident on which to base
     emergency response planning, one could use the release characteristics
     of that  single accident in connection with site specific characteristics
     and other generic information to specify the planning effort.  Having
     determined that a single specific accident sequence for a light water

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                               - 8 -
reactor nuclear power plant cannot be identified as a planning basis,
the Task Force chose to provide recommendations in terms of the conse-
quences or characteristics of accidents that would be important in
determining the extent of the planning effort.  The planning basis
elements needed to scope the planning effort were determined to be:
     1.  The distance to which planning for the initiation of
         predetermined protective actions is warranted.
     2.  The time dependent characteristics of potential releases
         and exposures.
     3.  The kinds of radioactive materials that can potentially
         be released to the environment.
The most important guidance for planning officials is the distance
from the nuclear facility which defines the area over which planning
for predetermined actions should be'carried out.  The other elements
of guidance provide supporting information for planning and preparedness.

The need for specification of distance for the major exposure
pathways is evident.  The location of the population for whom actions
may be needed, responsible authorities who would carry out these
actions and the means of communication to these authorities are all
dependent on the size of the planning area.

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                                  - 9 -
Information on the time frames of the accidents is also important.
The time between the initial  recognition at the nuclear facility
that a serious accident is in progress and the beginning of the
radioactive release to the surrounding environment is critical  in
determining the type of protective actions which are feasible
immediately following an accident.  Likewise, knowledge of the
potential duration of release and the time available before
exposures are expected several miles offsite is important in
determining what specific instructions can be given to the public.

A knowledge of kinds of radioactive materials potentially released
is necessary to decide the characteristics of monitoring instru-
mentation, to develop tools for estimating projected doses, and to
identify the most important exposure pathways.

In this report, emergency preparedness is related to two predominant
exposure pathways.  They are:
1.  Plume exposure pathway — The principal exposure sources from
    this pathway are (a) whole body external exposure to gamma
    radiation from the plume and from deposited material and
    (b) inhalation exposure from the passing radioactive plume.
    The time of potential exposure could range from hours to
    days.

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                                  - 10 -

2«  Ingest ion exposure pathway — The principal  exposure from
    this pathway would be from ingestion of contaminated water
    or foods such as milk or fresh vegetables.  The time of
    potential exposure could range in length from hours to
    months.
The Task Force has provided separate guidance for these two exposure
pathways, although a single emergency plan would include elements
common to assessing or taking protective actions for both pathways.

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                                       -  11 -
III.   RECOMMENDED  PLANNING  BASIS
      A.   Emergency Planning Zones
          With regard to the area over which  planning  efforts should be
          carried  out, the  Task Force recommends  that  "Emergency Planning
          Zones" (EPZs) about each  nuclear facility  be defined  both for
          the short term "plume exposure pathway" and  for  the longer term
          "ingestion exposure pathways."  The Emergency Planning Zone
          concept  is illustrated  in figure 1.  EPZs  are designated  as
          the areas for which planning  is recommended  to assure that prompt
          and effective actions can be  taken  to protect the public  in  the
          event of an accident.   Responsible  government officials  should
                                                                    (2\
          apply the applicable planning items listed in NUREG-75/llr  '
          in the development of radiological  emergency response plans.
          The following are example planning elements considered appro-
          priate for the EPZs:

          (1)   Identify responsible onsite and offsite emergency response
                organizations and the mechanisms for activating their
                services,
          (2)   Establish effective communication networks to promptly
                notify  cognizant authorities  and the public,
          (3)   Designate pre-determined  actions'as

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           PLANNING ZONE
EXCLUSION AREA
                                                                                                   EXAMPLE
                                                                                                   RESPONSE
                                                                                                   AREAS
                                                                                                   PLUME
                                                                                                   TRAVEL
                                                                                                   DIRECTION
ro
I
                                                                                                   TRANSPORT OF
                                                                                                   MILK TO DAIRY
                                                                                                   PROCESSING CENTER
                                         Figure 1 Concept of Emergency Planning Zones

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                               -  13  -

(4)   Develop procedures  for use by emergency workers,
(5)   Identify applicable radiation measurement  equipment,
(6)   Identify emergency  operations centers  and  alternate
     locations,  assembly points,  and radiation  monitoring
     locations,
(7)   Implement training  programs for emergency  workers  as
     appropriate, and
(8)   Develop test procedures for emergency  response plans.
Emergency planning should predetermine appropriate emergency
responses within the EPZ as a function of population groups,
environmental conditions^  , plant  conditions     and time
available to respond.  For the plume exposure  phase, shelter
and/or evacuation would likely be the principal immediate
protective actions to be recommended for the general public
within the EPZ.  The ability to best reduce exposure should
determine the appropriate response.   The key to effective
planning is good communication to authorities who know what
they are going to do under pre-determined conditions.
For the ingest ion exposure Emergency Planning Zone, the
planning effort  involves the  identification of major exposure
pathways from contaminated food  and water and the associated

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                                 - 14 -

 control  points and mechanisms.   The ingestion pathway exposures
 in general  would represent  a longer term problem,  although  some  early
 protective  actions to  minimize  subsequent contamination  of  milk  or
 other supplies should  be  initiated (e.g., put cows on stored  feed).
 It is expected that judgment of the planner will be used in
 determining the precise size and shape of the EPZs considering
 local  conditions such  as  demography,  topography and land use
 characteristics, access routes,  jurisdictional boundaries,  and
 arrangements with the  nuclear facility operator for notification
 and response assistance.

 The EPZ  guidance does  not change the  requirements  for emergency
 planning, it only sets bounds on the  planning problem.   The Task
 Force  does  not  recommend that massive  emergency preparedness  programs
 be  established  around  all nuclear power stations.   The following
 examples are given  to  further clarify  the Task Force  guidance on
 EPZs:

No special  local  decontamination  provisions for the general public
 (e.g., blankets,  changes of  clothing,  food, special showers)

No stockpiles of  anti-contamination equipment  for  the general
public
No construction of specially equipped fallout  shelters

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                                    - 15 -

    No  special  radiological medical  provisions for the general public
    No  new construction  of  special  public facilities for emergency
    use
    No  special  stockpiles of  emergency animal feed
    No  special  decontamination  equipment  for property and  equipment
    No  participation by  the general  public  in test  exercises  of
    emergency plans.
    Some capabilities in these  areas,  of course, already exist under
    the general emergency plans of Federal  and  State agencies.
B.  Size of the Emergency Planning Zone
    Several possible rationales were considered for establishing the
    size of the EPZs.  These included risk, probability, cost
    effectiveness and accident consequence spectrum.  After reviewing
    these alternatives, the Task Force chose to base the rationale
    on a full  spectrum of accidents and corresponding consequences
    tempered by probability considerations.  These rationales are
    discussed  more  fully in Appendix I.
    The Task Force  agreed that emergency response plans should be
    useful for responding to any  accident  that  would produce  offsite
    doses  in excess of  the PAGs.   This would include the  more severe
    design basis  accidents and the accident spectrum analyzed in  the
    RSS.  After  reviewing  the  potential  consequences associated with

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                                - 16 -
these types of accidents, it was the concensus of the Task Force
that emergency plans could be based upon a generic distance out
to which predetermined actions would provide dose savings for any
such accidents.  Bevond this qeneric distance it was concluded that
actions could be taken on an ad hoc basis using the same considerations
that went into the initial action determinations.
The Task Force judgment on the extent of the Emergency Planning Zone
is derived from the characteristics of design basis and Class 9
accident consequences.  Based on the information provided in Appendix
I and the applicable PAGs a radius of about 10 miles was selected
for the plume exposure pathway and a radius of about 50 miles was
selected for the ingestion exposure pathway, as shown in table 1.
Although the radius for the EPZ implies a circular area, the actual
shape would depend upon the characteristics of a particular site.
The circular or other defined area would be for planning whereas
initial response would likely involve only a portion of the total area.

The EPZ recommended is of sufficient size to provide dose savings to
the population in areas where the projected dose from design basis
accidents could be expected to exceed the applicable PAGs under
unfavorable atmospheric conditions.  As illustrated in Appendix I,
consequences of less severe Class 9 accidents would not exceed the

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                                    -  17  -



    PAG levels  outside the  recommended EPZ  distance.   In addition, the

    EPZ is of sufficient  size to  provide  for  substantial reduction in

    early severe health effects  (injuries or  deaths)  in the event of the

    more severe Class 9 accidents.



         Table 1.  Guidance on Size of the  Emergency  Planning  Zone
Accident Phase
Plume Exposure
  Pathway
Ingestion Pathway**
  Critical  Organ and
   Exposure Pathway
Whole body (external)

Thyroid (inhalation)

Other organs (inhalation)

Thyroid, whole body,
bone marrow (ingestion)
   EPZ Radius
about 10 mile radius*
about 50 mile radius***
*  Judgment should be used in adopting this distance based upon considerations
   of local conditions such as demography, topography, land characteristics,
   access routes, and local jurisdictional boundaries.

** Processing plants for milk produced within the EPZ should be included in
   the emergency response plans regardless of their location.

***The recommended size of the ingestion exposure EPZ is based on an expected
   revision of milk pathway Protective Action Guides based on FDA-Bureau of
   Radiological Health recommendations.  The Task Force understands that
   measures such as placing dairy cows on stored feed will be recommended
   for projected exposure levels as low as about 1.5 rem to the infant
   thyroid.  Should the current FRC guidelines, 10 rem'8), be maintained,
   an EPZ of about 25 miles would achieve the objectives of the Task Force.

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                                     - 18 -
C.  Time Factors Associated with Releases
    The planning time frames are based on design basis accident
    considerations and the results of Cerlculdttws reported in ttve
    Reactor Safety Study'  '.  The guidance cannot be very specific
    because of the wide range of time frames  associated with the
    spectrum of accidents  considered.   Therefore, it will  be
    necessary for planners to consider the possible different
    time periods between the initiating event  and arrival  of the
    plume and possible time periods  of releases  in relationship to
    time needed to implement protective actions.   The Reactor Safety
    Study indicates,  for example,  that major  releases may  begin in  the
    range of one-half hour to as much  as 30 hours after an initiating
    event and that the duration  of the releases  may range  from one-
    half hour to several days with the major  portion of the  release
    occurring well  within  the first  day.   In  addition,  significant  plume
    travel  times are  associated  with the most  adverse meteorological
    conditions that might  result in  large potential  exposures  far
    from the  site.  For example,  under poor dispersion conditions
    associated with low windspeeds,  two hours  or  more might  be required
    for  the plume  to  travel  a distance of five miles.   Higher  wind-
    speeds would result  in  shorter travel  times but  would  provide
    more  dispersion,  making  high exposures at  long  distances much
    less  likely.  Therefore,  in most cases, significant  advance warning

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                                -  19 -
                                                                fl 4)
of high concentrations should be available since NRC regulationsv  '
require early notification of offsite authorities for major releases
of radioactive material.  The warning time could be somewhat different
for reactors with different containment characteristics than those
analyzed in the Reactor Safety Study.  The range of times, however,
is judged suitably representative for the purpose of developing
emergency plans.  Shorter release initiation times are typically
associated with design basis events of much smaller potential
consequences or with the more severe Reactor Safety Study accident
sequences.

The planning basis for the time dependence of a release is expressed
as a range of time values in which to  implement protective action.
This range of values prior to the start of a major  release is of
the order of one-half hour to several  hours.  The subsequent time
period over which radioactive material may be expected to be released
is of the order of one-half  hour {short-term release) to a few days
(continuous release).  Table 2  summarizes the Task  Force guidance
on the time of the release.

The time available for  action  is strongly related to  the time
consumed in notification  that  conditions exist  that could cause a
major release or that a major  release  is occurring.   Development
and periodic testing  of procedures  for rapid notification  are  encouraged.

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                                    - 20 -
         Table 2 - Guidance on Initiation and Duration of Release
Time from the Initiating event
to start of atmospheric release

Time period over which radioactive
material may be continuously
released

Time at which major portion of
release may occur

Travel time for release to
exposure point
(time after release)
0.5 hours to one day
0.5 hours to several  days
0.5 hours to 1  day after
start of release
5 miles  — 0.5 to 2 hours
10 miles — 1  to 4 hours
D.  Radiological Characteristics of Releases

    To specify the characteristics of monitoring instrumentation,* develop

    decisional aids to estimate projected doses, and identify critical

    exposure modes, planners will need information on the characteristics

    of potential radioactivity releases.  For atmospheric releases from

    nuclear power facilities, three dominant exposure modes have been

    identified.  These are (1) whole body (bone marrow) exposure from

    external gamma radiation and from ingestion of radioactive material;

    (2) thyroid exposure from inhalation or ingestion of radiodines; and
*An Interagency Task Force on Emergency Instrumentation (offsite) is now
 preparing guidance^) on the type and quantity of instruments needed
 for the various exposure pathways.  Federal agencies represented on the
 Instrumentation Task Force include NRC, EPA, DCPA, HEW, and DOE.

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                                -  21  -

(3) exposure of other organs (e.g.,  lung)  from inhalation or
ingest ion of radioactive materials.   Any of these exposure modes
could dominate (i.e., result in the  largest exposures)  depending
upon the relative quantities of various isotopes released.
Radioactive materials produced in the operation of nuclear reactors
include fission products and transuranics generated within the
fuel material itself and activation products generated by neutron
exposure of the structural and other materials within and immediately
around the reactor core.  The fission products consist of a very
large number of different kinds of isotopes (nuclides),  almost all
of which are initially radioactive.  The amounts of these fission
products and their potential for  escape from their normal places
of confinement represent the dominant  potential  for consequences
to the public.  Radioactive fission  products exist in a  variety of
physical and chemical forms of  varied  volatility.  Virtually  all
activation  products  and transuranics exist  as  non-volatile  solids.
The  characteristics  of  these materials shows  quite clearly  that
the  potential  for releases  to  the environment  decreases  dramatically
in this  order:   (1)  gaseous materials; (2)  volatile solids; and
(3)  non-volatile  solids.   For  this  reason,  guidance for  source
terms representing hypothetical  fission product activity within

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                                - 22 -
a nuclear power plant containment structure emphasizes the development
of plans relating to the release of noble gases and of volatiles such
as iodine.  However, consideration of particulate materials should not
be completely neglected.  For example, capability to determine the
presence or absence of key particulate radionuclides will be needed
to identify requirements for additional  resources.

Table 3 provides a list of key radionuclides that might be expected
to be dominant for each exposure pathway.   More detailed lists of core
inventories are presented in Chapter 15  of recent Safety Analysis
Reports and in Appendix V of the Reactor Safety Study.   Both of these
sources give details on the time histories of the release fractions
for a spectrum of postulated accidents.

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                                          Table 3

          RADIONUCLIDES WITH SIGNIFICANT CONTRIBUTION TO DOMINANT EXPOSURE MODES
 Radionuclides  with  Significant
 Contribution to  Thyroid Exposure
Radionuclides with Significant
Contribution to Whole Body Exposure
Radionuclides with Significant
Contribution to Lung Exposure*
(Lung only controlling when
thyroid dose is reduced by iodine
blocking or there is a long delay
prior to releases).
Radionuclide
1-131
1-132
1-133
1-134
1-135
Te-132
Kr-88




Half Life
(days)
8.05
0.0858
0.875
0.0366
.028
3.25
0.117




Radionuclide
1-131
Te-132
Xe-133
1-133
Xe-135
1-135
Cs-134
Kr-88
Cs-137


Half Life
(days)
8.05
3.25
5,28
0.875
0,384
,028
750
0.117
11,000


Radionuclide
1-131
1-132
1-133
1-134
1-135
Cs-134
Kr-88
Cs-137
Ru-106
Te-132
Ce-144
Half Life
(days)
8.05
0.0858
0.875
0.0366
.028 ,
,750 es
0.117 '
11,000
365
3.25
284
*Derived from the more probable Reactor Safety Study fuel melt  categories and  from postulated  design basis

 accident releases.

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                                        - 24 -
IV.   CONCLUSIONS
     In summary, the Task Force concludes that:

          .  A spectrum of accidents (not  the source term from a  single
            accident sequence)  should be  considered in developing  a
            basis for emergency planning.

          .  The establishment of Emergency Planning Zones of about 10
            miles for the plume exposure  pathway  and about 50 miles  for
            the ingest ion pathway is  sufficient to  scope the areas in
            which planning for  the initiation  of  predetermined protective
            action is warranted for any given  nuclear power plant.

          .  The establishment of time frames and  radiological  characteristics
            of  releases  provides supporting  information  for planning and
            preparedness.

          .  If  previous  consideration has  been given to  the basic  planning
                                                             (2  3  4)
            elements put  forth  in existing guidance documents^ '     ,
            the establishment of Emergency Planning Zones should not
            result  in large  incremental increases in required  planning
            and preparedness resources.

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                               -  25  -

                             REFERENCES

 1.   10  CFR  Part  50,  Licensing  of Production and Utilization Facility.
     Appendix  E,  U. S.  Nuclear  Regulatory Commission, Washington, D. C.

 2.   Guide and Check  List  for the Development and Evaluation of State
     and Local Government  Radiological Emergency Response Plans in Support
     of  Fixed  Nuclear Facilities. NUREG-75/111, Dec. 1974, U.S. Nuclear
     Regulatory Commission.

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

 4.   Emergency Planning for  Nuclear Power Plants, Regulatory Guide  1.101,
     Mar.  1977.U.S. Nuclear Regulatory Commission, Washington, D. C.

 5.   Reactor Safety Study:   An  Assessment of Accident Risks in U.S.
     Commercial Nuclear Power Plants.  (NUREG-75/014), October  1975,
     WASH-1400, U.S.  Nuclear Regulatory  Commission.

 6.   Instrumentation  for Light-Water-Cooled Nuclear  Power  Plants to Assess
     Plant Conditions During and Following an  Accident,  Regulatory  Guide  1.97.
     Dec.  1975, U.S.  Nuclear Regulatory  Commission,  Washington, D.  C.

 7.   Interim Guidance on Offsite Radiation Measurement  Systems, A Report  to
     Developers of State Radiological  Emergency Response Plans by the
     Federal Interagency Task Force on  (offsite)  Emergency Instrumentation
     for Nuclear  Incidents at Fixed Facilities, August  1977, U.S. Nuclear
     Regulatory Commission,  Washington,  D. C.

 8.   Federal Radiation Council  Staff  Report No. 5,  July 1964;  Staff Report
     No. 7,  May 1965.!

 9.   Federal Response Plan for  Peacetime Nuclear Emergencies  (Interim  Guidance)
     April 1977,  Federal Preparedness Agency,  General  Services Administration.

10.   Disaster Operations,  A Handbook  for Local  Governments (CPG  1-6)  July
     1972, & Change No. 1, June 1974, Defense  Civil  Preparedness Agency.

11.   Radiological Incident Emergency  Response  Planning, Fixed  Facilities  and
     Transportation:    Interagency  Responsibilities,  Federal  Preparedness  Agency
     General Services Administration, Federal  Register Notice, Vol. 40,
     No. 248 December 24,  1975.

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                                 - 26 -
Class 9 Accident
Consequences
Core Melt Accident
GLOSSARY
An accident considered to be so low in
probability as not to require specific
additional provisions in the design of
a reactor facility.  Such accidents would
involve sequences of successive failures
more severe than those postulated for
the purpose of establishing the design
basis for protective systems and engineered
safety features.  (Class 9 event sequences
include those leading to total core melt
and consequent degradation of the contain-
ment boundary and those leading to gross
fuel clad failure or partial melt with
independent failures of the containment
boundary).
The results or effects (especially projected
dose rates) of a release of radioactive
material to the environment.

A postulated reactor accident in which the
fuel melts because of overheating.

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                                      - 27 -
Emergency Planning Zone (EPZ)
Ingestlon Exposure Pathway
Planning Basis
A generic area defined about a nuclear
facility to facilitate emergency planning
offsite.  It is defined for the plume and
ingestion exposure pathways.  In relation
to emergency response an EPZ is an area in
which best effort is performed making use
of existing emergency plans and is not an
area in which particular criteria must be
met.

The principal exposure from this pathway
would be from ingestion of contaminated
water or foods such as milk or fresh
vegetables.  The time of potential
exposure could range in length from
hours* to months.

Guidance in terms of (1) Size of Planning
Area (Distance); (2) Time Dependence of
Release; and (3) Radiological Characteristics
of Releases.

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                                      - 28 -
Plume Exposure Pathway
Projected Dose
Protective Action
Protective Action Guide
Source Term
The principal exposure sources from this
pathway are:  (a) whole body external
exposure to gamma radiation from the plume
and from deposited materials and (b)
inhalation exposure from the passing
radioactive plume.  The time of potential
exposure could range in length from
hours to days.
An estimate of the radiation dose which
affected population groups could potentially
receive if protective actions are not taken.

An action taken to avoid or reduce a
projected dose. (Sometimes referred to
as protective measure).
Projected absorbed dose to individuals in
the general population which warrants
protective action following a contaminating
event.
Radioisotope inventory of the reactor core,
or radioisotope release to the environment,
often as a function of time.

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                       APPENDIX  I

             RATIONALE FOR THE PLANNING BASIS
A.  General Considerations
    The Task  Force considered various rationales for establishing
    a  planning basis;   including risk, probability.
    cost effectiveness, and consequence spectrum.
    After  studying the various approaches discussed below, the
    Task Force chose  to  base  the  rationale for  the planning basis
    on a spectrum of  consequences,  tempered  by  probability consider-
    ations.

    With respect to  the  risk* rationale.such an approach would
    establish "planning  guidance" that could be compared with
     the risks associated with non-nuclear accidents.  This
     rationale would  seemingly give a uniform basis  for emergency
     planning and would clearly indicate the  level  of risk that
    could  be mitigated by advanced planning.   However,  emergency
    planning for non-nuclear hazards is not  based upon  quantified
     risk  analyses.   Risk  is not  generally thought of in  terms of
     probaDilities and consequences, rather  it  is an intuitive feeling
     of the threat posed to the public.  Reactors are unique  in  this
     regard:  radiation  tends to  be perceived as more dangerous  than
     other hazards because the nature of radiation effects are less commonly
*Risk is defined as accident consequences times the probability of
 accident occurrence.

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                         1-2
  understood  and the  public generally  associates  radiation
  effects with  the  fear  of nuclear weapons effects.   In  addition,
  a risk-related rationale  might imply the  determination of an
  acceptable  level  of risk which is  outside  the  scope  of the Task
  Force effort.  Choosing a risk comparable  to non-nuclear  events,
  therefore,  was not  directly  used as  the rationale  for  an  emergency
  planning  basis.
  With  respect  to  a  probability  rationale, one could arrive at
  "planning guidance" by selecting an accident probability
  below which development of an  emergency plan could not be
  justified.  Factors favoring using this rationale center around
  providing a quantitative probability basis, which could be
  compared with the  probabilities of other types of emergencies
  for which plans are prepared.

  Factors arguing against the probability rationale are similar
  to those against the risk approach.  Emergency planning is  not
  based upon quantified probabilities of  incidents or accidents.  On
 the basis of the accident probabilities presented  in  the  Reactor
 Safety Study  (nuclear  and  non-nuclear)  society  tolerates  much  more
 probable non-nuclear events with similar consequence spectrum*
without  any specific Planning.  Radiological emergency planning is
not based upon probabilities, but on public perceptions of the
problem and what could be done to protect health and safety.    In
essence, it is a matter of prudence rather than necessity.

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                      1-3
 Ageneric "probability of an event" appropriate for planning  has
 many implications felt to be outside the scope of the Task Force
 objective.  However,  the concept of accident probability  is important
 and does  have  a  place in terms of  evaluatinq the  ranae of the
 consequences of accident  sequences and setting some reasonable
 bounds on the  planning basis.  The probability rationale was used
 by  the Task Force to  gain additional perspective  on the planning
 basis finally  chosen.

With respect to a cost-effectiveness rationale, the level  of
emergency planning effort would be based on an analysis of
what it costs to develop different levels of such a plan and
the potential  consequences that could be averted by that degree
of development.  The factor favoring the cost-effectiveness
rationale is that an  emergency plan could be developed on the
basis of cost per potential health effect averted.  Factors
arguing against the cost-effectiveness rationale are the dif-
ficulty in arriving at costs of plan development and maintenance
and considerations that general and radiological emergency
 response plans have already been developed.  In addition,absent
 an  actual accident,  it would  be very difficult to assign  a dollar
 value to  the effectiveness  of the  plan  in  terms  of health effects
 averted.
 Lastly, the calculated consequences from  a  spectrum of postulated
 accidents was  considered  as the rationale  for  the planning basis.

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                           1-4
    Such a rationale could be used to help identify desirable
    planning elements and establish bounds on the planning effort.
    Further, a planning basis could be easily stated and understood
    in terms of the areas or distances, time frames and radio-
    logical characteristics that would correspond to the conse-
    quences from a range of possible accidents. Consequence oriented
    guidance would also provide a consistency and uniformity in
    the amount of planning recommended to State and local
    governments.   The Task Force therefore judged that the conse-
    quences of a spectrum of accidents should be the principal
    rationale behind the planning basis.

B.   Consequence Considerations
    The Task Force considered the complete spectrum of accidents
    postulated for various purposes,  including  those discussed
    in  environmental  reports  (i.e.  best estimate Class  1 through
    8 accidents),  accidents postulated for purposes  of  evaluating
    plant designs  (e.g.  the DBA/LOCA), and the  spectrum of
    accidents  assessed  by  the Reactor  Safety  Study.  The Task Force
    concluded  that the environmental report discussions (Class  1-8)
    were too  limited  in  scope and detail to be  useful in emergency
    planning.

    1.   Design Basis Accidents
   Under NRC Regulations, the site/reactor design combination must
   be such that the consequences of design basis accidents are

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                        1-5

below the plume exposure guidelines  of 10 CFR Part 100.  The
design basis loss-of-coolant accident (DBA-LOCA)  has  been
typically the most severe design basis accident  in that  it
results in the largest calculated offsite doses  of any accident
in this class.  The DBA-LOCA is not  a realistic  accident
scenario in that the release magnitudes are much more severe  than
would be realistically expected and  may exceed that of some core-
melt type accidents.  A best estimate assessment of the  release
following a LOCA would be significantly smaller than the DBA-LOCA
used for siting purposes.  An analysis of this accident  has been
performed for most of the power plants licensed or under review
by NRC to determine the dose/distance relationships as  computed
by traditionally conservative assumptions used under 10  CFR Part
100 requirements.  Results of this study are presented later in
this appendix.  The study concluded that the higher PAG  plume
exposures of 25 rem (thyroid) and 5 rem (whole body) would not
be exceeded beyond 10 miles for any site analyzed.  Even under
the most restrictive PAG plume exposure values of 5 rem to the
thyroid and 1 rem whole body, over 70 percent of the plants would
not require any consideration of emergency responses beyond 10
miles.  It should be noted that even for the DBA-LOCA, the lower
range of the plume PAGs would likely not be exceeded outside the
low population zone (LPZ) for average meteorological conditions.

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                       1-6

 For the ingestion pathways,  under the same DBA-LOCA conditions,
 the downwind range within which a PAG of 1.5 rem thyroid  could
 be exceeded would be limited to within 50 miles  even
 under the conservative 10 CFR 100 assumptions.   The 50 mile
 distance is also justified as a maximum planning distance
 because of likely significant wind shifts within this  distance
 that would further restrict  the radius  of the spread of radioactive
 material.

 2.   Class  9 Accidents
 "Class  9"  accidents  cover a  full  spectrum of releases  which range
 from those accidents which are of the same  order as  the DBA-LOCA
 type of releases;  i.e., doses  on  the  order  of PAGs within 10 miles;
 to  those accidents which  release  significant fractions  of the
 available  radioactive materials  in  the  reactor to the  atmosphere,
 thus  having  potential for  life-threatening  doses.  The  lower
 range of the spectrum would  include accidents in which  a core
 "melt-through" of  the containment would occur.  As in  the DBA-LOCA
 class,  the  doses from "melt-through"  releases (involving
 thousands of curies) generally would  not exceed even the most
 restrictive PAG beyond about 10 miles from a power plant.   The
upper range of the core-melt accidents is categorized by those
 in which the containment catastrophically fails and releases large
quantities of radioactive materials directly to the atmosphere
because of over-pressurization or a steam explosion.  These

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                            1-7
     accidents  have  the  potential  to release very large quantities
     (hundreds  of millions  of curies) of radioactive materials.  There
     is a full  spectrum  of  releases between the lower and upper range
     with all of these releases  involving some combination of atmospheric
     and melt-through  accidents.   These very severe accidents have the
     potential  for causing  serious injuries and deaths.  Therefore,
     emergency  response  for these  conditions must have as its first
     priority the reduction of early severe health effects.  Studies*6' '
     have been  performed which indicate tnat if emergency actions sucn
     as sheltering or  evacuation were taken within about lu miles of a
     power plant, there  would be significant savings  of early  injuries
     ana deatns from even the most "severe" atmospneric releases.
     For the ingestion pathways, (due to  the airborne releases   and
     under Class 9 accident conditions),  the downwind range within
     which significant contamination could occur would generally be
     limited to about  50 miles from a power plant, because of  wind
     shifts during  the release and travel  periods.  There may  also be
     conversion of  iodine in the atmosphere  (for  long time periods)
     to chemical forms which do  not readily enter  the ingestion  pathway.
     Additionally, much  of  the particulate materials  in a cloud  would
     have been  deposited on the  ground  within  about  50 miles.

C.  Probability Considerations
     An additional  perspective  can be  gained  when the planning basis
     is considered  in  terms of  the likelihood (probability)  of
     accidents  which could  require some emergency response.

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                                   1-8
           Probabilities can be used to give a perspective to the
           emergency planner by comparing the chance of a reactor accident
           to other emergencies for which plans and action may be required.
           This consideration forms an additional basis upon which the
           Task Force selected the planning basis.  The Reactor Safety
           Study (RSS) estimated the probabilities*  of various severe
           accidents occurring at nuclear power plants.  The probability of
           a loss-of-coolant accident (LOCA) from a large pipe break was
           estimated to be approximately one chance in 10,000 (1x10" ) of
           occurring per reactor-year.   LOCA accidents would not necessarily
           lead to the melting of the reactor core since emergency core
           cooling systems (ECCS)  are designed to protect the core in
           such an event.   In fact, other accident initiating events such
           as the loss-of-coolant accident from a small pipe break or
           transient events have a higher chance of leading  to core-melting
           than do large LOCA accidents.   Core-melt type accidents were
           calculated to have a probability of about one chance in 20,000
           of occurring  per reactor-year.  There  is  a significant  degree
           of uncertainty associated with both of the above probability
           estimates.
Use of the RSS probability estimates, in the context of emergency planning,
has been thoroughly examined.  It is recognized that there is a large range
of uncertainties in these numbers (as indicated in,the Risk Assessment
Review Group Report, NUREG/CR-0400). but the perspective gained when con-
sidering the probabilities is important in making a rational decision
concerning a basis for emergency planning.

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                                  1-9

          The degree of uncertainty is  such  that  no  differentiation can
          be confidently made,  on a probabilistic basis,  between  the
          DBA/LOCA and the releases associated  with  less  severe core-melt
          categories.

          As discussed in Appendix III, the  Task  Force has  concluded  that
          both the design basis accidents and less severe core-melt accidents
          should be considered  when selecting a basis for planning pre-
          determined protective actions and  that  certain  features of  the
          more severe core-melt accidents should  be considered in planning
          to assure that some capability exists to  reduce  the consequences
          of even the most severe accidents.  The low probabilities  associated
          with core-melt reactor accidents (e.g.  one chance in 20,000 or
                -5
          5 x 10   per reactor-year) are not easy to comprehend and  additional
          perspectives are useful.  Within the nex
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                       1-10

 100.   To restate this, there is about a 1% chance of  emergency
 plans being activated in the U.S.  beyond the recommended  EPZs
 within the next few years.   For a  single State,  this  probability
 drops appreciably.   For a State with ten reactors within  or
 adjacent to its borders, the probability of exceeding PAGs
 outside the planning basis  radius  for the plume  exposure  pathway
                  -5
 is  about 1.5 x 10  x 10 or  about one chance in 6000 per year
 according to the Reactor Safety Study analysis.

 For perspective, a  comparison between reactor accidents and
 other emergency situations  can be  made.   Considerations of
 emergency planning  for reactor accidents are quite similar
 to  many other emergencies;  floods,  for example,  have  many
 characteristics which  are comparable.   Timing, response
 measures  and potential  consequences,  such as property
 damage  are  similar  for  both  events.

 Flood risk  analysis  has  been  carried  out by  the  Flood
 Insurance Program of the  Department of Housing and Urban
 Development and  the  Corps of  Engineers.   Flood plains have
 been designated  for  all areas of the  country by computing
 the probability  of being flooded within  a certain period
of time; ie., the 100-year flood plain designates those
areas which can  be expected to be under water when .the worst
flood in a century occurs.  Even with this relatively high
probability of severe flood occurrence there are no explicit
requirements for emergency response planning.

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                       1-11
 Hurricanes  and  tornadoes  are  two potential threats for which some
 emergency planning  is  required.  Approximately  2  hurricanes
 per year may be expected  to hit the Atlantic  coastal  States
 which require emergency response.   For individual  States,  the
 hurricane frequency ranges  from 0.01 to 0.65  per  year.
 Tornadoes have  a very  high  probability of occurrence per year.
 A severe tornado can be characterized by wind speeds of
 over 200 miles  per hour.   Such tornadoes are  capable of
 lifting cars off the ground,  tearing roofs and walls
 off frame houses, overturning trains, and uprooting  or
 snapping most trees.  Emergency actions would probably be
 taken for such  tornadoes.  The frequency of severe tornadoes
 for individual  States, ranges from about 0.1  to 4 per year.
Severe reactor accidents are at least 100 times less likely to
occur than these other disasters requiring emergency response.
Me nevertheless believe, that 1t 1s appropriate to develop
flexible emergency response capabilities which will assure that
consequences from nuclear reactor accidents are minimized.

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                         1-12
D.   Emergency Planning Considerations Derived from Siting,
    Meteorological Models and Licensing Criteria

    1. Siting
    As indicated in 10 CFR Part 100 (Siting Criteria),
    an applicant for a construction permit to build a nuclear
    power plant must designate an exclusion area,  a low population
    zone  (LPZ)  and a population center based upon  consideration
    of population distribution.   The exclusion area must be  of such.
    a  size  that^an individual  located at  any point on its boundary
    for two hours immediately  following the onset  of a  postulated
    design  basis  accident  fission product release  from  the reactor
    plant would not receive  a  total  radiation  dose to the whole body
    of 25 rem or  300  rem to  the  thyroid from radioactive plume exposure
    The LPZ must  be of such  a  size  that an Individual located at any
    point on  its  outer  boundary  who  is exposed  to  the radioactive
    cloud during  its entire period  (30 days) of passage would not
    receive a total  radiation  dose  to  the  whole body  of  25 rem or 300
    rem thyroid.   Calculated doses  are usually  substantially less
    than  these  doses.   Protective measures  are  not
   assumed to be taken to avoid or mitigate these doses during
   the denoted time periods.  In addition, site related requirements
   are placed on the exclusion area and the LPZ.   The licensee must
   have authority over all activities within the exclusion  area,
   which normally requires ownership of the area.  There must

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                       1-13

 be a reasonable probability that appropriate protective
 measures,  Including evacuation, could be taken for the
 residents  in the LPZ in the event of a serious accident.
 Dose guideline values are not given for the population
 center, although the expected doses would be less than within the
 LPZ.   Demographic characteristics within 50 miles of sites
 are discussed in detail in Environmental Reports and in
 Chapter 2  of Safety Analysis Reports for each nuclear power
 plant  and  in Reference 1.

Assumptions used by the NRC staff to assess  conformance
with these regulations  are contained in various  Regulatory
Guides le.g. Regulatory Guides 1.3 and 1.4)  and  the NRC staff's
Standard Review Plans for Chapter 15 of Safety Analysis
Reports submitted by applicants for construction permits and
operating licenses.   Although various assumptions are utilized
in this guidance, certain common features are shared:  systems
containing potentially significant quantities of radio-'
nuclides are postulated to fail for an unspecified reason,
releasing all  or substantial  fractions of their inventories
from their normal location to the reactor plant containment
structure;* various installed safety systems in the contain-
ment designed to mitigate the consequences of the postulated
release, are assumed to be inoperable at the time of the event,
*In particular, for the worst case DBA/LOCA postulated for contain-
ment design, 100% of the noble gases and 50% of the radioiodines in
the reactbr core are presumed to be released from the core and primary
pressure boundary to the containment, which is assumed to isolate
and leak at a specified volumetric leak rate.

-------
                       1-14
 or  are  assumed  to  be  operating  in a degraded mode, or combin-
 ations  thereof;  the resulting fractional release to the
 atmosphere  is assumed to occur  at ground level under extremely
 unfavorable dispersion conditions, i.e., under conditions
 such that the calculated dose for the given fractional release
 would not be exceeded more than five percent of the time at the
 site under review; and dose models which overestimate the dose
 on a plume center line for the given release fraction are used in
 the dose calculation.   For all of these postulated, simultaneously
 occurring circumstances, 10 CFR Part 100 dose guideline values
must not be exceeded  at the specified distances from the site.

 Perspective on the implications of these 10 CFR 100 reactor
 siting criteria for emergency planning can be obtained by
 relating the calculated doses to the EPA PAGs, to guidelines
 for milk ingestion, and to certain meteorological aspects
of dispersion in the atmosphere.  For ground level  releases,
without a wind shift,  dose decreases with downwind  distance (r)
in proportion to r"a,  where a_ is between 1.5 and 3, depending on
                                           (2)
the  stability class prevailing at the time.  '(Stability classes
 are measures of atmospheric dispersion and are classified
 by the letters A through G, with A denoting extremely dispersive
conditions (see Table 1-1)^).  For the NRC staff assumption
 conditions (e.g., class F conditions with low wind

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          Table r-i — RELATION OF TURBULENCE TYPES
                      TO WEATHER CONDITIONS

 A—Extremely unstable conditions     D—Neutral conditions*
 B—Moderately unstable conditions    E—Slightly stable conditions
 C—Slightly unstable conditions        F— Moderately stable conditions

                                               Nighttime conditions
                   ~  ...    .    ,  ,.         Thin overcast
0  f     .  .        Daytime insolation
Surface wind    - - -
                                                or
 speed, m/sec   Strong   Moderate   Slight    cloudinesst    cloudiness
<2
2
4
6
>6
A
A-B
B
C
C
A-B
B
B-C
C-D
D
B
C
C
D
D

E
D
D
D

F
E
D
D
   * Applicable to heavy overcast, day or night.
   tThe degree of cloudiness is  defined as that fraction of the sky above
the local apparent horizon which is covered by clouds.

REF:  flETEOROLOGY AND ATOMIC ENERGY - 1968

-------
                         1-16
 speed) and for "average" dispersion conditions (e.g.,  class
 D stability), a value of a_= 1.5 provides a qood approxi-
 mation for purposes of projecting dose rates with distance
 from an exclusion area boundary.  Table 1-2 and figure 1-1
 illustrate this dose rate decrease.  For illustrative  purposes,
 figure 1-1  also shows the decrease for values of a_ equal to
 1  and 2.   Except for stability class  A,  which seldom
 occurs, dose  rate should decrease with distance within the
 1/r and 1/r  curves in this  figure, barring a significant
 wind shift during a release  period.

 For purposes  of this  discussion, dose ^s_ distance extrapola-
 tions of  the  exclusion radius  dose rate  for LWR accidents
 are of the  greatest interest.   Table  1-2  presents projected
 upper bound (no wind  shift)  values of 2  hour whole body and
 thyroid doses at  various  distances given  a  25 rem and  300 rem
 dose level  at an  exclusion radius  (rQ).   For a  site with an
 exclusion  radius  of one mile,  the  upper  limits  of the  proposed
 EPA PAGs for    plume  exposures  would  be  exceeded  within 3
 miles  (whole body PAG) and 5 miles (thyroid  PAG)  of the reactor
 plant  containment structure; the lower limits could  be exceeded
 within  8 miles  (whole  body) and  15 miles  (thyroid)  of  the reactor
 plant  containment  structure.   For  a site with an  exclusion radius
of 0.5 miles (about the median for currently licensed plants),

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                              1-17



                            TABLE  1-2


                UPPER BOUND PLUME EXPOSURE PATHWAY

                     PROJECTED DOSES BASED ON

                     10 CFR PART 100.11 VALUES
r/rr
1.
1.5
2
3
4
5
6
8
10
15
20
(r/rv)
                        -1.5
 1.
 0.54
 0.35
 0.19
 0.13
 0.089
 0.068
 0.044
 0.032
 0.017
 0.011
0 to 2 HR DOSE LIMIT (REM)
Whole Body      THYROID
    25
    14
    8.8
    4.8
    3.3
    2.2
    1.7
    1.1
    0.8
    0.43
    0.28
300
162
105
57
39
27
20
13
9.6
5.2
3.3
ETA
(hrs)

0.5
0.75
1
1.5
2
2.5
3
4
5
7.5
10
NOTES:  (1)  Dose = Dose commitment on plume center!Ine.
        (2)
= Exclusion area boundary, or exclusion radius
  for a given site; r/r  = multiple of exclusion
  radius; lefthand column can be read as miles if
                    rQ = 1 mile.
        (3)  Presumes 100% of noble gases and 50$ of radioidines
             in core inventory released to containment, constant
             volumetric leak rate from containment, "five percentile"
             meteorology, straight line of sight travel of the plume,
             and conservative dose factors for plume exposure.

        (4)  ETA = Estimated time of arrival of plume front based on
             ro = 1 mile and 2 mph wind speed.  Higher wind speeds
             reduce travel times and calculated doses.

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                         DOSE FALLOFF WITH  DISTANCE
                               (ALONG ACTUAL PLUME TRACK)
          1.0 r-
          0.8  -
Relative   0.6
 Dose
 Rate
         0.4 -
         0.2 -
                  0.5     1
            0      1
2            3
 Distance (Miles)
 r/r0 (Any Units)
             6
                                           £7)
                                           70
                                                                                       cc
                                                                  8
10

-------
                           1-19
       these  limits  could  be exceeded within half the denoted distances.
       Calculated  course-of-accident doses could be several times
       larger than the  above values.

       A  second perspective from which to peruse the data in table 1-2
       is that of  the thyroid PAGs for the milk ingestion pathway.
       The  ratio of  thyroid dose commitment factor (related to air
       concentration) for  the milk pathway to the inhalation (plume
       exposure) pathway is of the order of 300 for 1-131.* From
       this perspective it is clear that, without a wind shift during
       the  release period, potential dose commitments via  the milk
       pathway could exceed the  ingestion PAG for tens  of
       miles  from  the reactor site for the presumed conditions, given
       the  presence of  dairy herds and pasture  in the downwind direc*
       tion.   Clearly,  wherever  there  is a potential to exceed a
       plume  exposure PAG  for the thyroid, there  is a much greater
       potential  to exceed the milk  pathway  thyroid PAG.   Alternately,
       much lower releases of radioiodine could result  in  projected
       doses  in  excess  of  the  ingestion  PAG  without there  being a
       potential  to exceed plume exposure PAGs.
*For a core release, 1-131 activity would be about one eighth the total
 radioiodine activity.  Initially (for a day or so) 1-133 or 1-135
 activities would be dominant.  Thus, although 1-131 would dominate the
 projected dose commitment rate, the key early indicators for monitoring
 purposes would be the hard (1-2 MeV) gamma emissions from 1-135.

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                            1-20
2.  Meteorological  Considerations
    Although actual  atmospheric diffusion is  unlikely  to  behave
    as simple theory would suggest,  initial projections of
    dose during an  incident would most likely be  based  in part
    on the simple,  theoretical, gaussian  plume model (i.e.,  Pasquill
    diffusion).  Shown  in  figure 1-2  are  theoretical "widths" of
    gaussian shaped  plumes^  '  (the concentration  of a pollutant
    at the selected  width  of the plume is  about 1% of the center-
    line concentration).   Travel  times of  plume fronts for different
    wind speeds  are  also illustrated  in figure 1-2. Stability
    class,  wind  speed and  wind  direction might be considerably
    different at the same  time  at  different locations in the vicin-
    ity  of  a site and local  topography could  significantly influ-
    ence wind patterns.  Nevertheless,  the information displayed
    in figure 1-2 could be useful  for  scoping  initial emergency
    response actions, especially for those areas within a couple
    of miles of  a site.   For example, for a wind speed of 2
    miles per hour and class F stability  ( corresponding
    roughly to the meteorological conditions assumed for the worst
    case (5%)  design  basis  accident considered for purposes of con-
    tainment design), a plume front would not arrive at a location
    two miles downwind for almost one  hour.  For this hypothetical
    case, given  timely warning, and using crosswind travel,  an
    individual could, barring any obstacles, walk out of the poten-
   tially impacted area before the plume front extends to two miles,

-------
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-------
                         1-22
  since  the  individual would have to travel for about six
  minutes to do  so.  Generally, higher wind speeds result
  in lower dose  rates for a given release fraction (source
  term), but time of arrival of a plume front at a specific
  distance is shorter.

  In  the foregoing,  on several occasions note was made of the possible
  influence of a wind shift.  Clearly,  upon a wind shift the
  plume exposure dose commitment rate of persons in the original
 downwind direction, due to the passage of a plume,  would
 end,  and a  different population  dose  commitment rate would
 begin in the new downwind  direction.
NOA/r ' has analyzed National Weather Station meteorological
data across the United States and has presented results in
the  form of graphical displays of the probability of hours of
wind persistence in 22.5° and 67.5° sectors. (Figure'I-3   and  1-4).
The  study  concludes  that  there  is an even  chance  of  a  sig-
nificant wind  shift  occurring in the next  two  to  four  hours  at
any  given  location in  the United States.   A few general observations
are of import to emergency planning  and/or response:
". .  .  the higher the wind speed,  the greater is
the tendency for the wind  to remain in a given direction.  Con-
versely, it is  in the  lowest wind speed categories of  calm
and 1 to 5 mph  that the least direction persistence  is found."

-------
REF.  I. VAN DER HOVEN. WIND PERSITENCE PROBABILITY.
      ERLTM-ARL-10.  NOAA AIR RESOURCES LABORATORY.
      SILVER SPRING, MD. 20910
         Highest 50-percent  probability  of  hours of wind persistence in a 22^u sector centered on the
         indicated direction*-.
                                                                                                                      ro
                                                  Figure I-3.
                                                                                                      USNRC   12/75

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       3.9
                                                                                              4.2'
REF.  «. VAN DER HOVEN.  WIND PERSISTENCE PROBABILITY.
      ERLTM-ARL-10. NOAA AIR RESOURCES LABORATORY.
      SILVER SPRING, MD.  20910
         Highest 50-percent probability of hours of wind persistence in a 67%  sector centered on the  indicated
         directions.
                                                    Figure 1-4.
USNRC   12/75

-------
                       1-25
and  "... wind roses (frequency) that favor a particular
sector will also tend to persist in that sector."

Three caveats to the meteoroloaical  discussion are worth  noting.  The
first has to do with precipitation.   Rainfall  could occur either  at
the time of a radioactive release or some time during transport,
possibly many miles away from the source of the release.   Rainfall
is  usually  a  very  efficient  scavenger  of particles in  the
atmosphere.   Should a radioactive release  to  the  atmosphere
occur  during  rainfall,  one should expect to find  relatively
greater  ground deposition  close  to  the source of  the release,
independent of the height  of the release,  than one would find
during clear  weather.  Under rainy conditions, relatively less
air and ground concentrations of radioactive  material  should
 be found at greater distances from  the source of the release.
 On the other hand, a release could  occur during  dry weather
 yet the release could intercept a rainfall at some distance
 away;  at this distance particles could be deposited on the
 earth, vegetation, structures, water,  etc., very efficiently.
 In a strong rainfall a substantial  fraction of deposited
 radioactive material could even be  washed away.   Rainfall
 interception could be the most important meteorological
 phenomena of concern for the case of a strongly elevated
 release, such as due to plume rise of a thermally hot
 release which is probable with larger accidents.

-------
                                 1-26
    The  second caveat concerns real world meteorology.  As noted
    earlier, plumes or puffs do  not normally follow straight lines,
    especially in  low wind speed conditions.  Nor do they maintain
    a constant windspeed and stability.  Puffs can double back and
    return from where they came  and slow down or speed up.  Clearly,
    the  track of a major radioactive release would be of great interest
    and  concern.  As illustrated in Figure 7.15 of reference (3),
    radiation signals well above natural background should be observed
    even miles away from a plume at the center of which the dose rate
    is as low as one rem per hour, and even less.  Such plumes could
    be tracked using aircraft and generally available instrumentation
    such as Geiger counters and "cutie pies."
    It is also important to realize that a substantial  amount of energy
    could be associated with major releases.  This energy will  tend to
    lift the radioactive material off of the ground and form a cloud
    or plume.  If this occurs,  tracking of the material could be much
    more difficult since the wind direction can change dramatically
    with attitude.

3.  Licensing Considerations
    NRC regulation  require applicants  for licenses to construct and
    operate nuclear power facilities to make accident dose calculations.
    Such calculations  take into consideration plant designs and site
    characteristics.   They are  based in part on the DBA-LOCA accident
    scenario.
    Inherent  in  the consequence calculations for the postulated
    DBA-LOCA  is  the presumption of  "five percentile" meteorology,
    i.e., the presumption  that  atmospheric  dispersion  at a site

-------
                      1-27
at the time of the postulated accident should be more favorable
(leading to lower doses) ninety-five percent of the time.
Alternately, given the postulated accident,  the odds are at
least twenty to one against the doses being  as large as
calculated for the DBA-LOCA.  This "five-percentile" meteoro-
logy is derived from measurements made at the site during, or
previous to, the construction period.  It can nominally  be
characterized by class F stability and very low wind speeds
(e.g., 2 miles/hour or less), i.e., the very conditions
for which a wind shift is most likely.  These data are presented
in Chapter 2 of current Safety Analysis Reports for each nuclear
power facility and are given as funcions of elapsed time and
distance.

The results of the conservative licensing calculations for the
DBA-LOCA vary from plant-to-plant because of plant design and
variation in meteorology.  For this reason a large number plants
were analyzed in order to report the likely range of the con-
servative DBA-LOCA doses.  Data from seventy safety analysis
reports were collected and used for this purpose.  The seventy
plants consisted of 129 separate nuclear units.  The resulting
distribution of DBA-LOCA doses calculated for these facilities are
indicative of plants that are now operating and plants that  will
be operating in the near future.

An example of the results of such calculations  is  shown in

-------
                       1-28
 figure  1-5.  As  is  seen  in the figure, the major portion of the
 radioactive material will be released in the first few hours,
 after the accident.  Fortunately, for release durations of more
 than  a couple of hours there will be significant wind shifts
 and cloud meander (especially associated with the 5% to meteor-
 ological conditions postulated).   Therefore, for purposes of these
 calculations it was assumed that  the dose of any individual
would be limited to that of the first two hours after the accident.

 The results of the analysis are depicted in figures 1-6 through
 1-9.  Figure 1-6 shows the 2 hour thyroid dose versus distance
 for the 50 percentile and 10 percentile cases.  The 50 percentile
 curve is the median dose for all  129 units; thus half of the
 units had doses less than that indicated and the other half
 had greater doses.  The 10 percentile curve means that 10% of
 the units had doses greater than that indicated.  This figure
 also shows a rapid decrease in thyroid dose out to almost 10 miles
with a leveling off at greater distances.  It shows that at ten
miles, the 2 hour thyroid dose would be typically about 4 rem
and that in a few cases it may exceed 10 rem.  Figure^I-7 takes
the same data but plots the dose at 10 miles against the cumulative
frequency of reactor units.   It can be seen that the DBA-LOCA
doses were calculated to exceed the lower PAG range for only
30% of the units.

Figure 1-8 and 1-9 provide similar plots for the whole body

-------
h-

tu
<

h
CC
in
<

tt

—    1
Of
     10
       -1
                      1   i   i  i  i 111         I     i   r  r i IN
                                                                               I    I  I  1 I I
                           25 REM
                            5 REM
                       I   i   i  I  I  i I-1	[	I   I  I  I I I ll	1	1—I   Mill
                                    103
                                                                                             10'
                                            DISTANCE (METERS)
          Figure 1-5. Example of Time-Dose-Distance Relationships for Thyroid Inhalation Dose

                      From DBA/LOCA (5% Meteorology and Straightline Plume Trajectory)

-------
                                         1-30
            2
            iii
            cc
            CO
            O
            cc
                80
                70
                60
50
                40
                30
                20
                10
                                          2 HOUR THYROID DOSE
                      50%
                               10            20


                                      DISTANCE (MILES)
                                          30
40
I
0
I
5
I
10
I
15
I
20
                          APPROX. TIME OF CLOUD ARRIVAL (HOURS)
Figure I-6.  Centerline Dose Versus Distance for Licensing Calculation of DBA/LOCA at 2 Hours

           Assuming 5 Percentile Meteorology and Straight Line Plume Trajectory.

           50% Curve is Median of 67 Actual Site Calculations

           10% Curve is Highest 10% of Calculations

-------
                                         r-31
                    100
                    80
z

u.
O

U

UJ  o
3  X
o  Qi.
                    60
                    40
               3
               s

               O
                    20
                                           2 HOUR THYROID DOSE
                                    10     15     20     25

                                    X - THYROID DOSE (REM)
                                                30
Figure I-7.  Cumulative Frequency of Units Versus Dose at 10 Miles for Licensing Calculation of
           DBA/LOCA at 2 Hours Assuming 5 Percentile Meteorology and Straight Line
           Trajectory.

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                                        1-32
                                          2 HOUR WHOLE BODY DOSE
                                I
                                             20            30
                                      DISTANCE (MILES)
I
                                5            10           15
                           APPROX. TIME OF CLOUD ARRIVAL (HOURS)
                          20
Figure I-8.  Centerline Dose Versus Distance for Licensing Calculation of DBA/LOCA at 2 Hours
           Assuming 5 Percentile Meteorology and Straight Line Plume Trajectory.
           50% Curve is Median of 67 Actual Site Calculations
           10% Curve is Highest 10% of Calculations

-------
                                        1-33
                   100
              15
              CO
u.
O

O

^ -™*

O A
UJ
cc
              D
              O
                    80
                             1	1	1	T
                                        2 HOUR WHOLE BODY DOSE
                    60 ~
                    40 -
                    20  -
                      0.0
               0.2    0.4    0.6    0.8    1.0     1.2


                     X - WHOLE BODY DOSE (REM)
                                                                       1.4
Figure I-9.  Cumulative Frequency of Units Versus Dose at 10 Miles for Licensing Calculation of
           DBA/LOCA at 2 Hours Assuming 5 Percentile Meteorology and Straight Line

           Trajectory.

-------
                        1-34
  dose case.   The results are similar to the thyroid  case.
  The dose is seen to sharply decrease within 10 miles  and  to
 decrease  slowly  at  greater  distances.  At  10 miles the
 whole body  dose  for the median plant was about  1/10 of a rem
 and  very few plants had doses in excess of 1/2 rem whole  body.

  From these  results, the Task Force concluded that about a
  10 mile Emergency Planning Zone  for the plume exposure pathway
 was justified  to assure that predetermined actions  would  be
 planned in  those areas  where PAGs  could  be exceeded in the
 event of  a  release  comparable to a  design  basis accident.

 For the  ingestion pathway,  figure J-10 was  developed showing
 a  distance relationship  of  potential dose to an infant's
 thyroid  from milk consumption. As  was done for the  plume
 exposure,  conservative calculational techniques were used  to
 attempt  to bound  the results of the ingestion exposure.  For
 example, the straight line  trajectory was used  with  no credit
 taken for  wind  shifts.   All  of the  assumptions  of  the  Reactor
 Safety Study for  the calculation of  thyroid  dose from  milk
 ingestion  were  used  for  this  analysis.  The  results of
-figure 1-10  show that for the  DBA-LOCA,ingestion doses  above
 PAG's are  unlikely to occur  beyond about 50 miles  from power plants,

-------
                                     1-35
       50
       40
       30
   UJ
   cc
   u.
   2
   Ul
   oo
   8
   O
   uj  20
   Z
   O
   O
   cc
   X
       10
                      10
20           30
DISTANCE (MILES)
             40
50
                       I
 I
I
                       1234
                        APPROX. TIME OF CLOUD ARRIVAL (HOURS)
Figure 1-10. Maximum Thyroid Dose (Milk Pathway) to Infant Versus Distance, From 1-131,
           for DBA/LOCA Assuming Worst Possible Meteorology and Straight Line
           Trajectory.

-------
                          1-36
E.   Emergency Planning Consideration Derived from
    The Reactor Safety Study (HASH-14QQ)

    The Reactor Safety Study (RSS)  attempts  to  provide  a  detailed
    quantitative assessment of the  probability  and  consequences of
    "Class  9"  accidents.   The  study concluded that  the  public risk
    from nuclear reactor  accidents  was  dominated  by accidents in
    which there was  substantial damage  to the reactor core and
    that the probabilities  of  such  accidents were very  small.*
    Since emergency  planners are encouraged  to  develop  response plans
    which will  be flexible  enough to respond to most accident
    situations,  some understanding  of "Class 9" accidents and the
    relationships between them and  emergency planning is needed.

    The  Reactor Safety Study developed the mathematical techniques
    and  data base to provide an understanding of  these relationships.
   To obtain an appreciation for the distances to which or areas
   within which emergency planning might be required, a perspective
   on the relative probabilities of certain critical  doses as
   a function of distance from the power plant for these accidents
 *Probability of a  "core-melt"  accident was estimated to be approxi-
  mately  1  in 20,000 (5 x 10"b)  per  reactor year.  There  is a
  large uncertainty  on  this number.

-------
                     1-37
is needed.   A set of such curves  has  been prepared for all
of the RSS accident release categories  (figure  1-11).  These
curves include both Pressurized  and Boiling  Water Reactor  (PWR
& BWR) accidents.  Doses are given for  the critical  values
for which emergency planners should be  concerned.  One and
five rem whole body doses correspond  to the  lower range  of the
PAGs; 50 rem whole body corresponds to  the dosage at which
early illnesses start to occur;  and 200 rem  whole  body  is  the
dose at which significant early  injuries start to  occur.  As
can be seen from figure 1-11, core melt accidents  can be
severe, but the probability of large doses  drops off substanti-
ally at about 10 miles from the  reactor.  Similar  conclusions
can be reached by evaluating the other critical organs of
lung and thyroid shown in figures 1-12 and 1-13, respectively.
For the lung, the doses of 5, 25, 300 and 3000 rem were plotted
as a function of distance and probability of occurence.   For
the thyroid, the reference doses of  5, 25,  300 rem, which
correspond to the  lower and upper PAG levels, and the guide-
line exposure used for siting purposes are presented.

Given a core melt  accident, there is about a 70% chance of
exceeding the PAG  doses at 2 miles, a 40% chance at 5 miles,
and a 30% chance at  10 miles from a power plant.  That  is,
the probability  of exceeding PAG  doses at 10 miles  is 1.5  x  10~5

-------
                                           1-38
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Figure 1-11.  Conditional Probability of Exceeding Whole Body Dose Versus Distance. Probabilities

            are Conditional on a Core Melt Accident (5 x 10"5).

            Whole body dose calculated includes:  external dose to the whole body due to the

            passing cloud, exposure to radionuclides on ground, and the dose to the whole body
            from inhaled radionuclides.

            Dose calculations assumed no protective actions taken, and straight line plume
            trajectory.

-------
                                          1-39
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Figure 1-12.   Conditional Probability of Exceeding Lung Doses Versus Distance. Probabilities are

             Conditional on a Core Melt Accident (5 x 10'5).

             Lung dose calculated includes:  external dose to the lung due to the passing cloud,

             exposure to radionuclides on ground, and the dose to the lung from inhaled

             radionuclides within 1 year.

             Dose calculations assumed no protective actions taken, and straight line trajectory.

-------
                                          1-40
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Figure 1-13.   Conditional Probability of Exceeding Thyroid Doses Versus Distance. Probabilities
             are Conditional on a Core Melt Accident (5 x 1Q-5).

             Thyroid dose calculated includes:  external dose to the thyroid due to the passing
             cloud, exposure to radionuclides on ground, and the dose to the thyroid from
             inhaled radionuclides.

             Dose calculations assumed no protective actions taken, and straight line trajectory.

-------
                           1-41
   per reactor year* (one chance in 50,000 per reactor-year)  from
   the Reactor Safety Study analysis.

   Based in part upon the above information the Task Force judged
   that a 10 mile plume EPZ would be appropriate  to deal with
   core melt accidents.

   Potential ingestion doses to the  thyroid (through the cow/milk
   pathway) from core melt accidents are given in'"figure  1-14.
   The distance for which emergency  planning  is needed is not easily
   determined from the information given in the figure.  It  is
   evident  that doses can potentially  be quite high out to
   considerable distances.

   The current  PAG for milk  ingestion  is  30 rem thyroid to an
    individual and 10  rem  thyroid  to  a  suitable sample  of the
    population  (usually calculated on the  basis of an  infant's
    thyroid).  Given a core melt accident,  there is a  near
    100%  chance  of exceeding  the 10 rem thyroid PAG from milk
    ingestion  at 1 mile,  about  an  80% chance at 10 miles and  a  40%
    chance  at  25 miles from  a power plant.  A  planning  basis
    for milk ingestion on  the order of 25  miles would  therefore
    approximately correspond to the 10 mile plume  exposure  distance
*There is a large uncertainty on this number.

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                                          1-42
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                                               1000
Figure M4.   Conditional Probability of Exceeding Thyroid Dose to an Infant Versus Distance.
             Probabilities are Conditional on a Core Melt Accident (5 x 10~5).

             Thyroid dose calculated is due solely to radionuclide ingestion through the milk
             consumption pathway.

             Dose calculations assumed no  protective actions taken, and straight line trajectory.

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                           1-43


     if current FRC guidance were used.   However,  because the

     Task Force is aware that revision of the FRC  guides

     may result in recommendations for certain types of pre-

     ventive measures (such as putting cows on stored feed)

     at projected doses substantially below these  levels,*

     the Task Force chose an ingestion pathway EPZ on the order

     of 50 miles.
*The recommended size of the ingesticn exposure ERZ is based on an expected
revision of milk pathway Protective Action Guidelines by FDA-Bureau of
Radiological Health.  The Task Force understands that measures such as
placing dairy cows on stored feed will be recommended for projected
exposure levels as low as about 1.5 rem to the infant thyroid.  Should
the current FRC guidelines be maintained,an EPZ of about 25 miles would
be(recommended by the Task Force.

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                           1-44
F.   Examination of Off site Emergency Prnt.PrtivP Mpasnres for
    Core Melt Accidents
    A recent study (6, 7)  has been published which is  of general
    use to those responsible for emergency response planning for
    reactor accidents  in understanding  the "Class  9" accident
    relationships  and  specifically the  core "melt-through"  and
    "atmospheric"  accident classes.   This  study was undertaken  to
    evaluate,  in terms  of  public radiation exposure and  health
    effects,  the relative  merits of possible offsite emergency
    protective measures for response to potential  nuclear reactor
    accidents  involving serious  reactor accidents.   Three types of
    protective measures were examined and  compared:  evacuation;
    sheltering followed by population relocation,  and  medical
    (iodine) prophylaxis.   This  study was  based  upon the  Reactor
    Safety  Study results and methodologies.   The conclusions  of
    the  study  not  only  give a perspective  on  the relative merits
    of £ given protective  measure,  the  conclusions  also confirm
    the Task Force recommendations on the  distances  and times
    for which  planning  is  appropriate.

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                          1-45
   Figures1 "I5 and L16 give the additional  perspective of the
   study on the probabilities and needs for emergency planning
   in terms of the core "melt-through" and "atmospheric" categories
   and a range of expected emergency actions.  Figure I-ISshows
   the probabilities of exceeding thyroid and whole body PAGs
   versus distance from the reactor, conditional on the  occurrence
   of a'Vielt-through" release.  The probabilities are calculated
   for an individual located outdoors, and are presented for
   both lower  and upper PAG levels for each organ. A similar curve
   is shown in figure  I-l&for the"atmospherid1 releases.

   The figure  indicates that both whole body and  thyroid
   PAGs are likely to  be  exceeded at  very large distances*
   from the reactor  (and  correspondingly  over very large areas)
   if an  "atmospheric"  accident  were  to occur.  Doses  in excess
   of threshold  levels for  early health effects are  confined to
   smaller  areas much  closer  to  the reactor.  Therefore, in the
   unlikely event that an accident of this magnitude were  to occur,
   responsible authorities  might choose to direct their available
*Caution must be used in interpreting the large distances indicated.
 The RSS consequence model assumes an invariant wind direction following
 the release of radioactive material.  However, because of the time
 required by the cloud to travel large distances, it is likely that the
 wind directions will, in fact, shift and that the predicted dose levels
 would not be observed at the reported radial distance.  Rather, the
 distance applies more closely to the trajectory of the released cloud.

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    DISTANCE  (MILES)
Figure 1-15.  Conditional Probability of  Exceeding Thyroid and Nhole Body Protective Action
              Guides (PAGs)  Versus Distance  for an Individual Located Outdoors.8
              Probabilities  are Conditional  on a WK "Melt-Through" Release (PHP 6 and 7).


              Yielding factor for airborne radionuclides » 1.0.  Shielding factor for
               radionoclides deposited on ground > 0.7.  1-day exposure to radionuclides on
               ground.

              bV*iole body (thyroid) dose  calculated includes:  external dose to the whole
               body (thyroid)  due  to the  passing cloud and 1-day exposure to radionuclides
               on ground, and  the  dose to the whole body (thyroid) from inhaled radionuclides
               within 1  year.
                                                                Figure 1-16.  Conditional Probability of Exceeding Thyroid and Whole Body Protective Action
                                                                              Guides (PAGs)  Versus Distance for an Individual Located Outdoors.3  Probabilities
                                                                              are Conditional on  a PHR 'Atmospheric" telease 
-------
                           1-47
     resources  towards  limiting  the  life-  and  injury-threatening
     doses  to  individuals  in  those closer  areas.  Then, if sufficient
     resources  are  available,  protective measures might also be
     implemented  for  individuals at  larger distances for whom PAGs
     are, or are  likely to be, exceeded.

     Mean** numbers of  projected early  fatalities and  injuries
     within selected  radial  intervals,  conditional  on  an '^atmos-
     pheric" release, are  compared for  evacuation and  sheltering
     strategies in  figures 1-17  and   1-18. Seven strategies are
     included,  as defined  in  the key to these  figures.  Strategy
     1  assumes  that no  immediate protective  actions are taken.
     2,  3,  and  4  are  selected  sheltering  strategies.   Strategies
     3  and  4 represent  sheltering for regions  in which a large
     fraction  of  homes  have basements.  Effective exposure
     durations  to ground contamination  for these two strategics
     are 1  day  and  6  hours,  respectively.  Strategy 2  repre-
     sents  sheltering for  regions in which most homes  do not
     have basements,  with    6  hours  of  effective exposure to ground
     contamination.   Strategies  5, 6, and  7  represent  evacuation
     with 5, 3  and  1  hours of  delay  time,  respectively.  The results
     presented  in ftgures  1-17 and   H8 assume a uniform population
     density of 100 people   per  square  mile.   The corresponding
** The mean refers to the average of 91 stratified weather sequences
  -which were used to calculate a frequency distribution of early
  public health effects.

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RADIAL INTERVAL  (MILES)
15-25
0-5
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Figure t-17.  Mean ttatxc of Ptojected Baily Fatalities Within selected  Radial
              Intervals for Bracuation and Shelterinj Stcateqiss, Giwen  a  MR
              •Atnuspheric" delease (£Wt 1-5).  A Uniform l*pulation tensity
              of 100 Persona per Square Nile is Assured.
                       Figure 1-18.  Mean Number of Projected Early Injuries Within Selected  Radial
                                     Intervals for evacuation and 3wlterin; Strategies,  Given a fW
                                     "Atmospheric- Release |WR 1-5).  A Uniform ftmulation Dnv.ity
                                     ot 100 Persons per Square lile is Assured.
              Key;                                                b
              1,  No imnediate protective action, SF's  (0.75, 0.33).   1-day exposure
                  to radionuclides on ground.
              2.  Sheltering, SF's (0.75, 0-3J),  6-hour exposure to cadionuclides on
                  ground.
              3.  Sheltering, SF's (0.5, 0.08),  1-day exposure to radionucUdes on  •
                  ground.
              4.  Sheltering, SF's (0.5, 0.08),  6-hour exposure to radiomjclvtes on
                  ground.
              5.  Evacuation, 5 hour delay tine, 10 MPB.
              6.  evacuation, 3 hour delay time, 10 «PH.
              7.  evacuation, 1 hour delay time, 10 WH.


  aShielding factors (airborne radionuclides, ground contamination).

  bShielding factors for no protective action were chosen  to be the sane as for
   sheltering  in areas where rost  homes do not have  basements  (see reference 6).
                                     1.   No imnediate protective action, SF's" (0.75, 0.53),   1-day exposure
                                         to radionuclides on ground.
                                     2.   Sheltering, SF's !O.T>, 0.33). 6-hour exposure to radionuclides On
                                         ground.
                                     3.   Sheltering, SF's (0.5, 0.08), 1-day exposure to radionuclides on
                                         ground.
                                     4.   Sheltering, SF's (0.5, 0.08), 5-hour exposure to raUonuclides on
                                         ground.
                                     5.   Evacuation, 5 hour delay time, 10 "PH.
                                     6.   Evacuation, 3 hour delay time, 10 WH.
                                     7,   evacuation, 1 hour delay time, 10 WH.


                          Shielding factors (airborne radionucliHes, ground contamination).

                         "shielding factors for  no protective acliin were chosen to he the same a",  for
                          shelterirvi in areas where most hones do not  have HiSMient? (see reference f).

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                           1-49
    number  of projected early fatalities and injuries for any par-
    ticular site would depend on the actual population distri-
    bution  surrounding the  site.  Nevertheless, the relative com-
    parison of  numbers for  the  strategies  indicated is nearly
    independent of  the population distribution within a given
    interval.
    Several  observations can be drawn from the results
    presented  in  figures 1-17 and   1-18. Most  early fatalities
    resulting  from  "atmospheric" accidents  are projected  to
    occur within  approximately  10 miles  of the reactor, while early
    injuries are  likely  out  to  somewhat  larger distances.*
    Within 5 miles  of the reactor,  evacuation  appears to  be  more
    effective  in  reducing the number of  early  health effects
    than sheltering,  as  long as the delay  time and nonparticipating
    segment of the  population are  kept sufficiently small.
    This distinction  is  not  as  apparent  in the 5 to 10 mile
    interval.   Throughout both  of  the intervals from 0 to 10 miles,
    the importance  of a  rapid and  efficient implementation of
    either evacuation or sheltering is evident (small delay
    times for  evacuation, small ground exposure times for sheltering)
*Projected early fatalities and injuries in the 15 to 25 mile
interval arejiigher than for the 10-15 mile interval because
the interval *is twice as wide.

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                       1-50
 Note that evacuation  (i.e.,  removal  of population from
 hazardous area)  with   delay  times of 1 hour or less will
 reduce  the projected  number  early public health effects
 to  roughly 0  in  any radial interval,  and will always be
 the most  effective response  measure  for a severe accident,
 if  it can be  achieved.   In the  intervals beyond 10 miles,
 there is  little  apparent distinction  between the effective-
 ness  of evacuation and sheltering strategies in terms of
 projected early  fatalities or injuries.  The mean number of
 early fatalities is 0  in both of these intervals, and projected
 early injuries,  although not 0, are greatly reduced for each
 of  the protective strategies investigated.

 Several important conclusions about the relative effective-
 ness  of the protective measures examined, the distances to
 which or  areas within which they might be required, and
 the time  available for their implementation, were drawn by
 the study  from the results provided by these analyses.  For
 the "melt-through" class, projected whole body and thyroid
 doses in  excess of PAGs for those organs are, for all practical
 purposes,  confined to areas within 10 miles of the reactor.
 Emergency  response planning for this type of accident should
 therefore  be primarily directed towards limiting the dose to
 those individuals located within that distance.   Evacuation
appears to provide the greatest benefit«of any protective measure.

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                          I- 51
    However,  sheltering, particularly in areas where most homes
    have  basements, also offers substantial benefit* and may in
    many  cases offer an acceptable alternative to evacuation.  Iodine
    prophylaxis,  if administered in sufficient time, could also
    offer substantial  reduction in the projected dose to the
    thyroid.

    'Atmospheric"  accidents could result in the occurrence of sig-
    nificant  numbers of early  fatalities and  injuries.  However, doses
    in  excess of  threshold levels for significant early health
    effects  (about 200 rem whole body) are generally confined
    to  areas  much closer to  the reactor.  Therefore, given an
    "atmospheric" accident, responsible authorities  should concentrate
    their immediately  available resources on  limiting the life-
    and injury-threatening doses to  individuals  in  those closer
    areas.* Within 5 miles of  the reactor, evacuation appears  to be
    more  effective than sheltering in reducing the  number of early
    health effects,  as long  as the delay  time and  nonparticipating
    fraction  of  the  population can be  kept sufficiently small.
    Between  5 and 10 miles,  this  distinction  is  not as apparent,
    and sheltering  in  areas  where  basements are  widely available
    (followed by rapid relocation) may  be as  effective as
    evacuation with  relatively small delay times.    For all  affected
*Then, when time permits, protective measures might be implemented
 for individuals at larger distances for whom PAGs are, or are
 likely to be, exceeded.

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                      1-52

areas within approximately 10 miles of the reactor, the speed
and efficiency with which either evacuation or sheltering
and relocation are implemented strongly influence the number
of projected early health effects.  For areas beyond 10 miles,
there is little apparent distinction between the effectiveness
of evacuation and sheltering strategies in terms of projected
early fatalities or injuries.   Therefore,  although protective
actions  may be required  for individuals located in areas fur-
ther than 10 miles from  the reactor for an "atmospheric"
release, the actual  measures used and how rapidly or efficiently
they are implemented, will  not strongly influence the number
of projected early health effects.

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                      REFERENCES FOR APPENDIX I


(1)   D.  Bunch,  K. Murphy and J. Reyes.
     Demographic  Statistics Pertaining  to  Nuclear  Power Reactor
     Sites.  (Draft)  NUREG-0348.  USNRC  Washington, D. C.  20555
     Dec.  1977

(2)   D.  Bruce Turner.  Workbook of Atmospheric  Dispersion Estimates.
     AP-26.   USEPA  Office  of Air Programs,  Research  Triangle  Park,
     NC   27711.  1970  Revision.

(3)   USAEC.   Meteorology and Atomic  Energy -  1968.   D. Slade,  ed
     TID-24190.  National  Technical  Information Service, Springfield, Va.
     22151

(4)   J.  A. Martin,  Jr.  Doses While Traveling  Under Well Established
      Plumes.  Health  Physics  Jr.  V.  32,  n.4,  pp. 305-307, April  1977.

(5)   I.  Van der Hoven. Wind  Persistence Probability.   ERLTM-ARL-10.
     NOAA Air Resources Laboratory,  Silver Spring, MD  20910


(6)  Aldrich, D.  C., Examination of Offsite Radiological Emergency
     Protective Measures  For Nuclear Reactor Accidents Involving
     Core Melt, MIT, Department of Nuclear Engineering,  March, 1978.

(7)  Aldrich, D.  C., et al, "Examination of Offsite Emergency Protective
     Measures For Core Melt Accidents," American Nuclear Society Topical
     Meeting, Newocrt  Beach,  Ca.,  May, 1978.                        K

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                              APPENDIX II

                   BACKGROUND CONCERNING THIS REPORT
The commercial nuclear power industry has expanded greatly in the last
several years and is expected to grow even larger in the years ahead  as
more plants go into operation.  The industry to date has had an excellent
safety record.  The Federal government recognizes this excellent safety
record and the efforts by the nuclear industry to continue to reduce  even
further the likelihood of accidents.  It also recognizes, however, that
the probability of an accident involving a significant release of radio-
active material, although small, is not zero.  It has been and continues
to be Federal policy to adopt a cautious attitude with respect to the
potential of these facilities for the release of radioactive materials
in hazardous quantities.  Such emergency situations are the focus of
attention of Federal radiological emergency preparedness activities.

A.  NRC Reactor Siting and Emergency Planning Regulations

    The U. S. NRC, as the agency with the principal regulatory authority
    for the construction and operation of nuclear power plants, has
    long recognized that emergencies could arise in the operation of
    such plants.  One of its regulations, Reactor Site Criteria  (10 CFR
    Part 100  published  in 1962'  ')  states that a capability for taking
    protective measures on behalf of the public  in the event  of  a serious
                                    II-l

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 accident should be established within a region called  the  low
 population zone (LPZ)  surrounding  a  nuclear power  plant  site.
 Whether a specific number of people  can,  for example,  be evacuated
 from  a  specific area,  or instructed  to take shelter, on  a  timely
 basis will  depend  on many factors  such as:   egress  routes, availa-
 bility  of sheltering,  the scope  and  extent  of advance  planning,
 and the actual  distribution  of residents  within the area.
 In 1970,  explicit  requirements  for plans  to cope with  emergencies
 were  published  in  10 CFR  50,  Appendix E.  In accordance  with
 provisions  of the  Atomic  Energy Act  of 1954,  these  requirements
 are directed to  applicants who apply  for  licenses to operate these
 facilities  rather  than to State or local  governments.  With respect
 to a  planning basis, NRC  regulations  in 10  CFR 50,  Appendix E, do
 not provide explicit guidance as to the character or magnitude of
 accidental  releases to the environment which  should be considered
 in the  development of nuclear facility or State and local government
emergency plans.  The Appendix E regulations  also do not include
any explicit references to the low population zone  or other
particular geographical areas other than "within and outside
the site boundary".  They do, however, require that applicants
for construction permits for these facilities provide sufficient
                           II-2

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    information to "assure compatibility of proposed (facility) emergency
    plans with facility design features, site layout, and site location
    with respect to such considerations as access routes, surrounding
    population distributions, and land use".

    Neither the NRC nor the other Federal  agencies have statutory authority
    over State and local governments with respect to emergency planning
    related to nuclear facilities.  In the regulation of nuclear power
    plants, however, NRC requires licensees to develop an emergency
    response plan which contains provisions for the protection of the
    public.  The implementation of any protective actions offsite,
    however, is necessarily the responsibility of offsite organizations.
    The NRC requires that the licensee develop procedures for notifying
    local, State and Federal  agencies.  NRC also requires that licensees'
    emergency plans contain agreements reached with local, State and
    Federal agencies which provide for the early warning of the public
    and the implementation of any appropriate protective actions.
B.  Federal Guidance Effort

    The legal  authority and responsibility of local, State and Federal
    governments for offsite response was recognized when 10 CFR 50,
    Appendix E was published.  NRC regulations require licensees to
                                 II-3

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 incorporate  provisions  for  participation  by  offsite  authorities
 or  organizations whose  assistance may be  required  in the  event of
 a radiological  emergency  in periodic drills  to test  response plans.
 As  the NRC staff gained experience with these requirements, it
 became concerned with the abilities of State and local governments
 to  discharge their  responsibilities should the need  ever  arise.
 This concern in part gave rise to a Federal  Register Notice^ '
 which started an Interagency program for  providing radiological
 emergency response  planning guidance and  related training to
 State and local government  organizations.  NRC exercises  the
 lead role in this activity  and several Federal Agencies,  including
 EPA, participate.   Guidance has been published by NRC, EPA and other
 Federal agencies for use by State and local  governments in developing
 radiological  emergency  response plans.
 It  has been  Federal policy  to encourage planning for a variety of
 radiological  consequence situations "within  and outside the site
 boundary" and the Task  Force reemphasizes the necessity for
 emergency planners  to consider a wide spectrum of situations.
Existing Federal guidance documents are constructive in this
regard.   But  these  documents are not sufficiently definitive as
evidenced by'the continuing dialogue among Federal, State and
                               II-4

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local  agencies and licensees on this subject.   Existing Federal
guidance which bears on the basis for developing offsite emergency
plans is summarized below.

1.  1970 - "The licensee should give particular attention to
    protective measures that may be necessary for individuals
    within the low population zone ...n^3^

2.  1974 - The NRC staff's  acceptance criteria for preliminary
    planning at Preliminary Safety Analysis Report (PSAR) review
    stage refers to a basis of "calculated radiological dose
    consequences of an airborne release following the most
    serious design basis accident."^'

3.  1974 - The NRC's principal guidance document^ for State
    and local government emergency planners contains the following
    under an introductory heading of "Magnitude of the Accident:"
    "The evaluation of sites and plant designs, required testing
    programs, and quality assurance for the operation of such
    facilities all provide  substantial assurance that accidents
    with serious consequences to the public health and safety
    are not likely to occur.  Nevertheless, highly unlikely
    sequences of events are postulated and their potential
    consequences analyzed by the applicant in the Safety Analysis
    Report wtrtcti acuumpantes eauti apTJlicattorrand-by the {NRC-)
                               II-5

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 staff  in  its  Safety Evaluation Report  for each  plant.  The
 (NRC)  considers that  it  is reasonable, for purposes of
 emergency planning relative to nuclear facilities, to
 prepare for the potential consequences of accidents of
 severity  up to and including the most serious design basis
 accident  analyzed for siting purposes."

 ..."The (NRC) recognizes that accidents with more severe
 potential consequences than design basis accidents can be
 hypothesized.  However, the probability of such accidents
 is exceedingly low.  Emergency plans properly designed to
 cope with design basis accidents would also provide
 significant protection against more severe accidents, since
 such plans provide for all of the major elements and functions
 of emergency preparedness.  An added element of confidence
 can be gained, however, if States and local  governments
 assure that their plans for responding to radiological
 emergencies are coordinated with their plans for dealing
with floods, earthquakes, or other disaster situations which
might necessitate large scale displacement of people and the
 provision of shelter,  food, medical  aid,  and other emergency
services.   Communications, traffic control,  evacuation, public
notification and other emergency responses will  tend to be
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    the same whether or not the emergency involves  radiological
    considerations.  The (Department  of Energy's) Radiological
    Assistance Program (RAP),  the Federal Interagency Radiological
    Assistance Plan (IRAP) and other  Radiological Emergency
    Assistance Plans, which are a part of the Federal capability,
    provide significant additional  emergency resources in the event
    of a serious accident."

    This introductory text in  the "Guide and Checklist"^
    document was written for the express purpose of providing
    interpretive guidance to the meaning of the enumerated
    checklist elements in this document.

4.  1975 - With respect to evacuation as a protective measure,
    applicants are requested to provide "plots showing projected
    ground-level doses for stationary individuals,  — resulting
    from the most serious design basis accident analyzed in the
    Safety Analysis Report.  These should be based on the same
    isotopic release rates to the atmosphere and the same
    dispersion model as are acceptable for use in Chapter 15
    of the PSAR for the purpose of showing conformance to the
    siting dose criteria of 10 CFR Part
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    5.  1975 - With respect to the levels at which emergency actions
        should be initiated, EPA issued as Agency guidance, portions
        of the "Manual of Protective Action Guides and Protective
        Actions for Nuclear Incidents" which provided PAGs for plume
        exposure and application procedures for these PAGs.  '
        These bear on the areas or distances for which plans might be
        implemented.

    6.  1977 - "Planning and implementation of measures to cope with
        plant related emergencies outside the site boundary with
        particular emphasis on the low population zone should be a
        coordinated effort involving the licensee, and local, State,
                                                                /p\
        and Federal  agencies having emergency responsibilities.
C.  Reactor Accident Considerations

    Current NRC regulatory practice requires that events which may be
    anticipated to occur one or more times during the lifetime of a
    facility lead to no significant releases of radioactive material
    to the environment.  No design or mode of operation is, however,
    entirely risk free.   Despite the efforts made to prevent accidental
    releases of significant quantities of radioactive material, the
    possibility does in fact exist  that such accidents may occur.   Each
    application for  a  license is accompanied by a detailed assessment
                                     II-8

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of such postulated accidents, and NRC staff performs an independent
evaluation of these accidents before a nuclear facility license is
granted.

The NRC staff has provided guidance to applicants as to the type of
accidents to be considered in the design of nuclear power plants (see
for example, Sections 2.3 and 15 of Regulatory Guide 1.70^ and
particularly Table 15-1 of that guide).  The recommended approach
by the NRC staff is to organize the postulated accidents to ensure
that a broad spectrum of events have been considered and then to
categorize the events by type and expected frequency so that only
the limiting (i.e., more severe) cases in each group need to be
quantitatively analyzed.

NRC staff has categorized postulated accidents into four major
groups as follows:

     1.  Events of moderate frequency (anticipated operational
         occurrences) leading to no significant radioactive
         releases from the facility.

     2.  Events of low probability with potential for small
         radioactive release from the facility.
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         3.  Events of very low probability with potential for large
             radioactive releases from the facility and whose consequences
             are evaluated to establish the performance requirements
             of engineered safety features and to evaluate the accepta-
             bility of the reactor site.  These events, some of which
             assume unlikely failures or fission product releases are
             referred to as design basis accidents (DBAs).

         4.  A fourth group of accidents, the so-called "Class 9"*
             accidents, which include any situation not specifically
             included in the foregoing groups of events and which
             typically are represented by some combination of failures
             which lead to coremelting and/or containment failure.
             These larger events are generally considered in the
             regulatory process by reducing their probability of
             occurrence to acceptably low values through design
             of the plant and its engineered safety features.  This
             group includes external  events such as severe natural
             phenomena as well as accidents initiated within the
*The first three groups have also been divided into eight categories in some
 accident assessments.  The eight categories plus a "Class 9" category are
 defined in the proposed Annex to Appendix D to 10 CFR Part 50 dated
 December 1, 1971.  (Also listed in NUREG 0099, Regulatory Guide 4.2,
 Appendix I).

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         facility.   Unlike groups  1  through  3,  the  consequences
         of events  in group 4,  are not  specifically analyzed
         in most applications.

One design basis accident in the third  group routinely considered  in
the safety analysis performed by the staff is a loss-of-coolant  accident
(LOCA) where it is  assumed that a large fission product release  from
the containment also occurs.  The analysis of this accident is used in
connection with the site suitability evaluations done to establish
compliance with 10  CFR Part 100 of the NRC regulations by comparing
computed accident consequences with exposure guidelines given in the
regulations.

The Task Force considers the events described  in NRC Regulatory Guide
1.70 as a useful source of  information on the  type of events in
groups 1 through 3 above.   Each application will have detailed infor-
mation on these possible events, including  important  plant and site-
specific factors that affect the probability and consequences of
accidents.  Safety Analysis Reports submitted  by licensees are not
likely to include a discussion  of Class 9 accidents.  Other documents,
such as the Reactor Safety  Study^   \ discuss  the  Class 9  type
accidents and  their consequences.  The Task Force  believes that
the findings on types of  severe accidents reported in WASH-1400
provide a useful supplement to  the Safety Analysis Reports in
developing  a basis  for  emergency  planning.
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 The current version of NRC Regulatory Guide 1.70 requests  applicants
 to provide two separate analyses  of accident consequences:   one using
 conservative assumptions to verify  that  plant design  is  adequate
 and a second using best estimate  assumptions.  One  purpose for the
 latter assessment  is to illustrate  the margins of conservatism used
 in designing plant engineered  safety features.   This  provision is
 a  recent  addition  and consequently  there are few analyses  of this
 type actually available.   Therefore,  while  the nuclear facility
 Safety Analysis  Report  will  contain a great deal  of information
 on credible accidents and  how  they  are accommodated by design,
 there is  likely  to be little information provided on  the expected
 consequences  of  such initiating events.
 Best estimate consequences  of  a number of representative initiating
 events  are  addressed in the  staff's  environmental impact statements.
 The Task  Force has  reviewed  the summary  information on accident
 consequences  provided in connection with these  statements  and we
 conclude  that these  best estimate analyses  are  too  limited  in scope
 and detail  to be useful  in emergency  planning.   It  is apparent,
 however,  from these  analyses as well  as  from the  NRC  Regulatory
Guide  1.70  analyses,  that best estimate  consequences  are likely
to  be a factor of  10  or so smaller, from the  standpoint of
meteorological considerations  alone,  than the consequences of
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    accidents as typically presented  in  Safety Analysis Reports and
    in NRC staff safety evaluation reports  for the  purpose  of  site
    and plant design feature evaluation.

D.  Establishment of the Task Force

    To prepare adequate emergency response  procedures,  basic information
    regarding an accident, such as the time characteristics of an
    accident, the radioactive material release characteristics, and
    the extent of the area potentially impacted is required.  Past
    practice has been to use a spectrum of accidents, including
    design basis accidents for emergency response planning.  These
    accidents, however, were developed for the specific purposes of
    reactor  siting and the design of containment and engineered
    safety features.  Further, the description of the DBAs  in Safety
    Analysis Reports does not always contain the information needed
    for developing emergency response plans.  In addition,  since the
    publication  of the Reactor Safety Study in 1975, there  has been
    some  concern and confusion among State and local goverment
    emergency response planning  and preparedness organizations
    as to how the accidents described in the Reactor Safety Study
    relate to emergency  planning.

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As a result of some perceived confusion in how accident analyses
should relate to emergency planning, the Conference of (State)
Radiation Control Program Directors passed a resolution in 1976
requesting NRC to "make a determination of the most severe accident
basis for which radiological emergency response plans should be
developed by offsite agencies."  Additionally, the NRC and EPA
received correspondence from a few States, and local governments
in this regard.
In response to this dialogue, a Task Force consisting of NRC and
EPA representatives was assembled to address this Conference request
and related issues in November 1976.  The Task Force interpreted
the request as a charge to provide a clearer definition of the types
of radiological accidents for which States and local governments
should plan and develop preparedness programs.
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Appendix II
                                REFERENCES


1.   Title 10 Code of Federal  Regulations,  Part  100 Reactor Site
     Criteria.                                     	

2.   Radiological  Incident Emergency  Response  Planning. Fixed
     Facilities and Transportation:   Interagency ResponsYBTTTties
     Federal  Preparedness Agency,  General Services Administration'
     Federal  Register Notice,  Vol. 40,  No.  248,  December 24, 1975.'

3-   "Guides  to the Preparation  of Emergency Plans for Production and
     Utilization Facilities. December 1970. U. S. Atomic Energy	
     Commission.                                      '	

4.  "Standard Review Plan for  the  Review  of Safety Analysis Reports for
     Nuclear Power Plants." Section  13.3  -  Emergency Planning, NUREG 75/087
     September 1975, U.  S. Nuclear Regulatory  Commission.

5.   Guide and Check List for  the  Development  and Evaluation of State and
     Local Government Radiological Emergency Response Plans in Support of
     Fixed Nuclear Facilities. NUREG  75/111, Dec. 1974, II. 9. Nuclear	
     Regulatory Commission.

6-   "Standard Format and Content  of  Safety Analysis Reports for Nuclear
     Power Plants, LUR jgnion." section  l5.3  -  Emergpnry  Panning. NUREG
     75/094 (Rev.  2), September  1975, U.  S. Nuclear Regulatory Commission.

7.   Manual of Protective Action Guides and Protective Actions for Nuclear
     Incidents, EPA-520/1-75-D01.  September. 1975, u. s. Frnnrr»nmoPf:Q	
     Protection Agency.

8.   "Emergency Planning for Nuclear  Power  Plants." Regulatory Guide 1.101
      Rev. 1, March 1977.     ~~                "                        *

9.   "Standard Format and Content  of  Safety Analysis Reports for Nuclear
     Power Plants  LWR Edition." Regulatory Guide 1.70, RPV. ?  September
     7975, U. S. Nuclear Regulatory Commission.

10.  Reactor Safety Study: An Assessment of Accident Risks in U  S
     Commercial Nuclear Power  nants. (NUREG-75/014),  (WASH-1 Ann)
     October 19/5, U. S. Nuclear Regulatory Commission.
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                             APPENDIX III
              RELATED ISSUES CONSIDERED BY  THE  TASK  FORCE

Certain issues related to providing a more  definitive planning  basis
were considered by the Task Force.   These  issues were examined  in
the light of existing Federal guidance and  particularly in light of
guidance promulgated by the former AEC regulatory arm (Now the  NRC).
There are four principal issues:
     A.  Issue:  Whether and to what extent, so-called "Class 9"
         events having consequences beyond the most serious design
         basis accidents analyzed for siting purposes, should be
         considered in developing emergency plans.
         Commentary:

         The Task Force believes that States should be encouraged
         to develop a breadth, versatility and flexibility in
         emergency response preparations and capabilities - and
         that some consideration of Class 9 events  in emergency
         planning is consistent with this view.  Further, the
         potential consequences of  improbable but nevertheless
         severe power reactor accidents, while comparable in some
         sense to severe natural or man-made disasters which
         would trigger an ultimate protective measure such as
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 evacuation,  do require some specialized planning considerations.
 We do not suggest that these specialized planning considerations
 are or ought to be excessively burdensome.   Rather,  we recommend
 that they be considered and developed  as a  matter of prudence.

 The Task  Force recognized  from the  start that  there  is no
 specific  design basis  accident or Class 9 accident scenario
 which can be isolated  as the one for which  to  plan because
 each such accident would have different consequences,  both
 in nature and  degree.   It  is for this  reason that NRC  and EPA
 have encouraged State  and  local agencies to concentrate
 their efforts  on devising  response  preparations  and  capa-
 bilities  that  are versatile  and that also take  into  account
 the  unique aspects of  radiological  accidents.

 The  Reactor  Safety Study (RSS)^ provides  a detailed
 assessment of  the  probability  and consequences of Class 9
 accidents.   Various aspects  of that study have been  debated
 by reviewers.   Additional programs  are  underway  to extend
 or refine the  study.   It should be  noted  that the RSS  is
 based on  an  analysis of two  specific reactors, and the
 consequences presented are based on a spectrum of data
compiled from many sites.  The report therefore  is of
 limited use  in dealing with plant/site  specific  factors.

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Nonetheless, the RSS provides  the best  currently  available
source of information on this  subject.
The Task Force had to decide whether to place reliance on
general emergency plans for coping with the events of
Class 9 accidents for emergency planning purposes, or
whether to  recommend developing specific plans and organi-
zational capabilities to contend with such accidents.
The Task Force believes that  it  is not appropriate to
develop specific plans for the most severe and most
improbable  Class 9  events.  The  Task Force,  however,
does  believe that consideration  should be  given  to
the  characteristics of Class  9 events  in judging whether
emergency  plans  based  primarily  on smaller accidents
can  be expanded  to  cope with  larger events.   This is
a means of providing flexibility of response capability
and  at the same time giving reasonable assurance that
 some capability exists to minimize the impacts of even
 the  most severe accidents.

 For example, if we are dealing with a very large release
 of radioactive material,  the principal goal is to prevent
 serious adverse health effects to individuals.  The measures
 required to minimize health effects and to cope with
 secondary effects of a large accidental  release (such as

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 land or water contamination,  and  the  housing  and  feeding
 of any people required  to  be  relocated  for substantial
 time periods) would,  in all likelihood,  require the
 involvement  of Federal  agencies in  addition to State
 and local  governments.

 The planning basis  recommended by the Task  Force  therefore
 includes some of  the  key characteristics of very  large
 releases to  assure  that  site  specific capabilities could
 be  effectively augmented with general emergency preparedness
 (response) resources  of  the Federal government should the
 need  arise.

 NRC and other Federal agency emergency planning guidance
 has perhaps  been misinterpreted as reflecting a position
 that  no consideration should be given to so-called Class 9
 accidents for  emergency  planning  purposes.  The Task Force,
 after considering the published guidance and available
 documentation/ " ' concludes that Class 9 accidents
 have  been given some  consideration in emergency planning.
 It has been,  and continues to be  the Federal position that
 it is possible  (but exceedingly improbable) that accidents
could occur calling for  additional resources beyond those
that are identified in specific emergency plans developed
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to support specific Individual  nuclear facilities.   Further,
the NRC and Federal position has been and continues to be,
that as in other disaster situations, additional  resources
would be mobilized by State and Federal agencies.
        ll--thgrg__a_nee-d to. P^n beyond the Low Population Zone?
Commentary

The Low Population Zone (LPZ) is determined in accordance with
the requirements of NRC Reactor Siting Criteria, 10 CFR Part
    (5)
100V  ' .  While the consequences of postulated design basis
accidents would be expected to be substantially lower than
the guideline values of 10 CFR Part 100, there are three
reasons why  some planning beyond the LPZ is useful:

First,  if an accidental release were as severe as the design
basis releases analyzed for  purposes of 10 CFR Part 100,
doses could  be above the Protective Action Guide  (PAG)^
 levels beyond the  LPZ.   In this  instance, the responsible
 officials  should take  reasonable and  practical measures
 to reduce  exposures  to individuals  beyond the LPZ.
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 Second,  the  deposition  of  radioactivity,  and  its  subsequent
 uptake  in  foodstuffs  such  as  milk  products could  be significant
 beyond  the LPZ  even if  the plume exposure pathway doses did not
 exceed  the PAG  level  at the LPZ outer  boundary, because of
 the  reconcentration of  certain radionuclides  in the food
 chain.   Emergency  protective  measures  in  that situation
 should  be  taken to minimize exposures  from the food chain
 via  the  ingest ion  pathway.

 Third, there  is a  very  small  probability  that releases larger
 than those from design  basis  accidents used in evaluating the
 acceptability of the  reactor  stte could occur which could
 have consequences substantially in excess of the  PAG levels
 outside  the LPZ outer boundary.  As discussed in  Issue "A"
 the  Task Force  concluded that such larger accidents should
 be considered in developing the basis on which emergency
 plans are developed.

The  Task Force  considered these factors in establishing the
size of the emergency planning zone.  Two basic options were
considered.  One option was to develop site specific guidance
based on the low population zone (LPZ) with some modifications
to better assure that  actions could be extended beyond the LPZ
if needed.   The  second option was  the concept of a planning

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area completely independent of the LPZ.   The Task Force
recognized that the LPZ is included in NRC regulations for
siting of nuclear facilities, and is closely connected
to design basis accident consequences.  We also recognized
that actual emergency response actions would be based on
proposed Protective Action Guides.  Given these factors,
the Task Force concluded that the concept of Emergency
Planning Zones (EPZs) around each nuclear power facility
would best serve to scope the desired spectrum of situations
for which emergency planning should be accomplished.  EPZs
for both the "plume exposure pathway" and the "ingestion
exposure pathway"  are  proposed.  The  separation  of this
concept  from NRC siting  considerations is discussed  in
Issue 0.

While the  Task Force  recognizes  that  there  are  site-to-site
variations in  LPZs, due  in  part  to varying  features  of the
plant,  the Task  Force concluded  that  the size of the EPZs
need  not be site specific.   The  principal  reason for this
 is that the size of the LPZ is determined primarily  by the
type  and extent  of engineered safety  features installed in
 the reactor plant  and their response  to design basis accidents.
The loss of either some or all engineered safety features are

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    postulated in Class 9 accidents.   If the engineered safety
    features are lost during an accident, then the LPZ has  no
    meaning with regard to the size of the areas around the
    plant in which emergency response would be appropriate.
    A principal  aim in establishing EPZs is to foster a breadth,
    versatility  and flexibility in response preparation and
    capabilities in a systematic manner.   From the standpoint
    of general emergency planning guidance, emergency planning
    needs seem to be best served by adopting uniform Emergency
    Planning Zones for initial  planning studies for all light
    water reactors.

c-  Issue:  Whether there is a conflict between Protective  Action
    Guides for plume exposures and dose criteria for siting and
    design of nuclear power facilities.

    Commentary

    The Reactor  Site Criteria (10 CFR Part 100) require that an
    applicant identify an area surrounding a nuclear power  reactor,
    defined as a Low Population Zone  (LPZ).  The consequences of
    the most severe "design basis accidents" analyzed for siting
    purposes should not result  in exposures in excess of 300 rem
    to the thyroid from radioiodine exposure or 25 ren? to the whole
    body for an  individual  located at any point on the outer
    boundary of  the Low Population Zone (LPZ).

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Protective action guides (PAGs) for plume exposure have been
provided to State and local government agencies for use as
EPA agency guidance in developing State and local government
radioTogical emergency response plans for areas around
nuclear facilities.  One might reasonably ask whether it
is inconsistent for the Federal government to recommend
the development of plans to implement protective actions
at projected dose levels lower than the projected doses
associated with siting criteria.  The discussion that
follows reviews this  issue.

The dose  guideline values  in  10 CFR Part  100 do not  constitute
 acceptable limits  for emergency doses  to  the public  under
 accident  conditions.   The  numerical  values  of  25 rem whole
 body  and  300 rem thyroid can  be  considered values above
 which prevention of  serious health effects would be the
 paramount concern.   Good health  physics practice would
 indicate  that radiological exposures of these  magnitudes
 should not be allowed to take place if reasonable and
 practical measures can prevent such exposures.

 The assumptions used for siting purposes in calculating
 the doses that could result from design basis accidents
 are conservative.  The actual doses that would result

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from releases postulated to occur from a design basis
accident therefore would be expected to be much lower
than the dose guidelines of 10 CFR Part 100 under most
meteorological conditions.  The inhalation and direct
exposure doses from the releases postulated for design
basis accidents are not likely to exceed the PAG levels
beyond the LPZ under average meteorological conditions.
It has been, however, the NRC's position that a spectrum
of postulated conditions be considered in emergency planning
including adverse meteorological conditions.

Protective Action Guides were devised for purposes of dose
savings and are defined as the projected absorbed dose to
individuals in the general population that warrants protective
action following a contaminating event.  Emergency response
plans should include them as trigger values to aid in decisions
to implement protective actions, and responsible officials
should plan to implement protective actions if projected
doses exceed the PAGs.  The PAGs, which have numerical values
smaller than the 10 CFR Part 100 guidelines*, are decision
*The PAGs for the plume exposure pathway are expressed as a
 range of 1  to 5 rem whole body dose and 5 to 25 rem thyroid
 dose to individuals in the population.  PAGs for the ingestion
 exposure pathway have no parallel  in the 10 CFR Part 100
 guidelines.
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aids in devising best efforts, considering existing
constraints.  They have been set at levels below those
that would produce detectable short term biological effects
and at levels that would minimize long term biological
effects.  In the event of an accident they should be
considered as criteria against which available options
for various types of emergency actions can be weighed.
Officials responsible for implementing the protective
actions must take into account constraints that exist
at the time and use professional judgment in determining
the actions appropriate to protect the public.

The nature of PAGs is such that they cannot be used to
assure that a given exposure to individuals in the
population is prevented.  In any particular response
situation, a range of doses will be projected, principally
depending on the distance from the point  of the radioactive
release.  Some of these projected doses may be well in
excess of PAG levels and clearly warrant  the initiation
of any feasible protective actions.  This does not mean,
however, that doses above PAG levels can  be prevented,
or that emergency response plans should have as their
objective preventing exposures above PAG  levels.   Furthermore,
PAGs represent only trigger levels and are not intended to

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    represent acceptable dose levels.  PAGs are tools to be used
    as a decision aid in the actual response situation.
    As discussed above, PAGs and Part 100 dose guidelines
    serve distinctly separate functions.  The concept of
    Emergency Planning Zones (EPZs) introduced in this report
    is an attempt to provide guidance on the areas for which
    offsite officials should be prepared to make judgments using
    the PAGs, to initiate predetermined actions.
D.  Issue:  Whether the guidance in this document for offsite
    emergency planning can be separated from siting considerations
    in the NRC licensing process.
    Commentary

    The NRC siting criteria as related to accidental releases
    of radioactivity are given in 10 CFR Part 100 of the
    Federal regulations, and are supplemented by the Statement
    of Considerations published with this regulation in 1962
    and in various regulatory guides and standard review plans
    used by the NRC staff.  These criteria are used'in the
    review of applications for nuclear power plant construction
    permits, operating licenses and operating license amendments.
    The evaluation performed under 10 CFR 100 primarily involves;
    (1) assuring that possible effects of all relevant natural
    and man-made phenomena on the nuclear facility have been
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identified and expressed as design conditions for the
facility, (2) determining that adequate engineered safety
features have been provided to assure that postulated
releases of radioactivity resulting from design basis
accidents will not lead to radiological exposures that are
in excess of the numerical guidelines of 10 CFR Part 100
at specified offsite locations> even under adverse
meteorological conditions, (3) evaluating the distance
to the nearest densely populated area to allow calculation
of the offsite location at which certain of the Part 100
exposure guidelines must be met, and {4} evaluating the
general current and projected population density  around
the proposed  facility out to  about 30  miles.  The first
three evaluation areas  are reexamined  at the  operating
license  review stage and  occasionally  over the  plant
lifetime  as  facility or  site  conditions  change.   The
fourth  area  (population  density)  is  only evaluated in  a
prospective  manner  to assure  the  use of  low  population
density'sites when  such  are available  and  is  generally
not  reexamined.  The objective  of the  evaluations performed
during  the Part  100 siting review is to  assure that the
risk from any accident  (including  a  Class 9  accident)  is
low.

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The definition of the Low Population Zone (LPZ) in 10 CFR
Part 100 states that it is an area which contains residents,
the total number and density of which are such that there
is a reasonable probability that protective measures could
he taken, in their behalf in the event of serious accident.
The outer boundary of the LPZ is one of the locations at
which Part 100 exposure guidelines must be met.  The outer
boundary of the LPZ must also be less than a fixed fraction
of the distance to the nearest boundary of a densely populated
center containing more than about 25,000 residents.  These
are not in practice siting constraints because restrictions
on the 2 hour exposure from design basis accidents at the
site (exclusion area) boundary generally provide ample time
to take action within a few miles to cope with postulated
design basis releases and because additional engineered
safety features could be added to the facility design, at
some additional cost, to allow the outer boundary of the
LPZ to be as small as the site boundary.
The current NRC staff evaluation of emergency plans for a
particular facility is substantially independent of the
siting criteria.  The staff review includes facility
emergency plans and plans for at least the offsite area
referred to in 10 CFR Part 100 as the Low Population

                      .  111-14

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Zone (LPZ) and in current licensing reviews often extends
to substantially longer distances, particularly for the
ingestion pathway.  Emergency plans are reviewed by the
NRC staff during the construction permit and operating
license review stages and audited during the plant lifetime.

Emergency offsite response to large accidents may be less
effective for sites located in an area of general high
population density.  Such sites, which may have adequate
engineered safety features to meet the explicit criteria
of  10 CFR Part 100, tend to be eliminated  by the NRC staff
guidelines on the general population density around
prospective  sites.

We  recognize that there  would be a reduction in exposures
through  the  emergency  response  of the  facility staff  and
local  authorities even without  planning.   This is  based  on
experience  in coping with more  common  emergencies  such
as  those associated with large  chemical  releases or dam
failures.  It seems reasonable  that some additional
reduction in exposures may  be  obtained by certain planning
activities  related  to  emergency preparedness  at any
site.   However,  the reduction  in exposures from planned
 actions would be difficult  to  take into account in a
quantitative or qualitative way in siting reviews.

                         111-15

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In view of the above we conclude that although there is
an indirect relationship between siting and emergency
planning, the two can and should be considered separately
in the NRC licensing process.  Some clarification of the
NRC regulations may be desirable to make clear the separation
of these issues in the licensing process.
                        111-16

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Appendix III


                                REFERENCES

1•  Radiological  Incident Emergency Response  Planning, Fixed Facilities
    and^ Transportation: Tnteragency Responsibilities, Federal Preparedness
    Agency General  Services Administration, Federal Register Notice,
    Vol. 40, No.  248, December 24,  1975.

2.  Reactor Safety Study:  An Assessment  of Accident  Risks  In U.  S.
    Commercial Nuclear Power Plants, (NUREG-75/014fT"6ctober 1975,
    HASH-1400. U. S. Nuclear Regulatory Commission.

3.  Disaster Operations, A Handbook for Local Governments  (CPG 1-6)
    July 1972, & Change NoT 1, June 1974. Defense Civil  Preparedness
    Agency.

4.  Federal Response Plan for Peacetime Nuclear Emergencies (Interim
    Guidance) April 1977, Federal Preparedness Agency, General Services
    Administration.

5.  Title  10, Code of Federal Regulations, Part 100.  Reactor Site
    Criteria.

6.  Manual  of Protective Action Guides and Protective Actions for
    Nuclear Incidents. EPA-520/1-75-001,  September, 1975,  U. S.—
    Environmental Protection Agency.
                                    111-17

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 7. AUTHORS,  F. L.  Gal pin. EPA  -  Office of  Radiation Programing
H.  E.  Collins,  NRC  -  Office of  State Programs
ft.  K.  Grimes, NRP. - DffiVp nf Nnr1oar
 NRC FORM 335
 (7 77)
                 U.S. NUCLEAR REGULATORY COMMISSION

                  BIBLIOGRAPHIC DATA SHEET
4. TITLE AND SUBTITLE (Add Volume No., if appropriate)

PLANNING BASIS  FOR THE DEVELOPMENT OF  STATE AND LOCAL

GOVERNMENT RADIOLOGICAL EMERGENCY RESPONSE PLANS  IN

SUPPORT OF LIGHT WATER NUCLEAR POWER PLANTS
       '  "" ''•'••••            -	
1. HEPORT NUMBER (A«/<*»•


                                                         20. SECURITY CLASS (Th,spage)
               21  NO. Of PACil

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