IMPLEMENTATION OF PROTECTIVE ACTIONS
FOR RADIOLOGICAL INCIDENTS
AT OTHER THAN NUCLEAR POWER REACTORS
PROCEEDINGS OF A WORKSHOP
HELD AT THE
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF RADIATION PROGRAMS
NATIONAL AIR AND RADIATION ENVIRONMENTAL LABORATORY
MONTGOMERY, ALABAMA
SEPTEMBER 25-26, 1991
Office of Radiation Programs
U.S. Environmental Protection Agency
Washington, D.C. 20460
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PROCEEDINGS OF A WORKSHOP ON
IMPLEMENTATION OF PROTECTIVE ACTIONS FOR
RADIOLOGICAL INCIDENTS
AT OTHER THAN NUCLEAR POWER REACTORS
CONTENTS
Page
Introduction , 1
Workshop Participants 7
Workshop Working Group Assignments 11
Workshop Agenda 13
Speakers' Papers 17
Welcome and Introduction, by Sam Windham 19
Welcome, by Aubrey V. Godwin 21
Overview of the Workshop, by Allan C.B. Richardson 23
Lessons Learned from Emergency Planning at Hanford,
by Robert Mooney 27
The Relationship between Protective Action Guides and
Emergency Planning Zones, by Robert Trojanowski 31
The Basis for Protective Action Guides and Their Application to
Non-Reactor Source Terms, by Allan C.B. Richardson 37
Implementation of Protective Action Guides at a Large Plutonium
Processing Facility, by Philip C. Nyberg 45
Mixed Hazard Incidents (Chemical/Nuclear Incidents), by William Klutz 55
Arkansas' Titan II Experience, by Bernard Bevill 57
Review on the Basis of Guidance for Sheltering as a Protective
Action in a Plutonium Release Accident, by Bradley Nelson 63
ill
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Submitted Papers 73
Lessons Learned by the Illinois Department of Nuclear Safety
from Participation in FFE-2, by Gary N. Wright, Roy R. Wright
and Charles W. Miller 75
The Usefulness of Information Provided by Field Measurements
During Unplanned Releases into the Environment, by Robert W. Terry 79
Working Group Summaries 85
Working Group A
Differences in Modeling of Releases, Exposure Pathways, and Field
Monitoring, in REP at Nonreactor Nuclear Facilities Compared
to REP for Nuclear Power Plants 87
Working Group B
The Planning Basis and the Roles of Planning and Response Authorities 91
Working Group C
The Need for Specific Guidance on Dose Protection, Protective Actions,
Training, and Exercises for Implementing PAGs for Nuclear Incidents
at Nonreactor Nuclear Facilities 95
Working Group D
Integration of Emergency Response for Incidents in Which the Release
Includes Both Hazardous Chemical and Radiological Contaminants
(Mixed Incidents) 99
IV
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INTRODUCTION
The Workshop was held at the Environmental Protection Agency's (EPA) National
Air and Radiation Environmental Laboratory in Montgomery, Alabama on September 25-26,
1991. Hosted by the EPA's Office of Radiation Programs, the Workshop was attended by
State emergency response officials who have major nonreactor nuclear facilities in their
State, and by Federal officials responsible for developing guidance on emergency
preparedness.
The principal objective of the Workshop was to provide a forum for the States to
identify and discuss issues regarding implementation of protective actions following a
radiological accident involving a Federal or commercial nuclear facility, with emphasis on
source terms other than power reactors. EPA's impending issuance of revised Protective
Action Guides (PAGs) for evacuation and sheltering provided the key incentive for
conducting the Workshop at this time. Previous PAGs, which were applicable only to reactor
incidents, had been revised to be applicable to source terms from nonreactor incidents as
well. The dose quantities for expressing the PAGs were also revised so that they would
encompass all of the risk that may be avoided by the relevant protective action, and the
accompanying text was clarified to provide more complete guidance on the factors that
should or should not influence the choice between evacuation and sheltering.
The Workshop included two plenary sessions and one working group session in which
four working groups met to address different issues. In the first plenary session a variety
of speakers discussed State and Federal perspectives on the issues. This provided background
information for the working group sessions. The second plenary session consisted of
presentations and discussions from the four working groups. Although some key
organizations were not represented at the workshop, a great deal of information was
compiled that should be useful to those responsible for the development and exercising of
emergency response plans.
The purpose of this document is to provide a summary of the key issues based on the
formal presentations on specific topics, the associated discussions, and discussions of the
work that went on in the four working groups. Separate reports that summarize the results
of the deliberations of the working groups are provided later.
General Findings and Conclusions
Although several types of nuclear facilities other than power reactors were discussed,
there was general consensus that the most significant source terms at nonreactor nuclear
facilities for which detailed emergency planning is important are those associated with
Federal facilities; primarily those operated by or for the Department of Energy (DOE) and
Department of Defense (DOD).
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It was pointed out that emergency planning had been conducted by State officials and
facility operators at some of the Federal facilities, but in less detail than for nuclear power
facilities. In some cases facility emergency response plans have been exercised with State
participation. Also, Federal funds have been provided to some States to assist them in their
planning efforts, and some State officials have received DOE "Q" clearances to reduce
communication problems with facility operators.
Among the responsibilities of the Federal Emergency Management Agency (FEMA),
as chair of the Federal Radiological Preparedness Coordinating Committee (FRPCC), is the
following: "Establish policy and provide leadership via the FRPCC in the coordination of all
Federal assistance and guidance to State and local governments for developing, reviewing,
assessing and testing the State and local radiological emergency plans" (44 CFR Part
351.C.351.20). This same document requires the DOE and DOD to participate in these
planning activities for their contractor-operated facilities. However, none of the planning
activities mentioned above were carried out under the auspices of the FRPCC. Some
attendees were aware of a major effort begun several years ago by DOE and FEMA to
develop guidance for preparing and exercising State and local emergency response plans for
Federal nuclear facilities. This guidance would have been parallel to the guidance developed
for nuclear power plants. However, the effort was discontinued.
EPA discussed the proposed revisions to the "Manual of Protective Action Guides and
Protective Actions for Nuclear Incidents" (PAG Manual). Considerable discussion centered
around whether the revised PAGs for the early phase of response to a nuclear incident could
be reasonably applied for all types of nuclear incidents. No circumstances (except nuclear
war) could be identified that would require different PAG values, dose quantities, or time
periods for calculation of projected dose in order for the PAGs to be applied to nonreactor
incidents. It was concluded that the revised PAGs for the early phase could reasonably be
applied to any type of nuclear incident except nuclear war.
There are some positive indicators that progress is being made regarding emergency
response planning at Federal facilities. For example: 1) key officials in some states are
getting security clearances, 2) some Federal facility officials are meeting with State officials
regarding potential source term for incidents, and 3) some states are being funded
temporarily for emergency planning by DOE. The following summarizes the major issues
identified by attendees at the Workshop that require resolution with regard to planning for
response to incidents at nonreactor nuclear facilities. Additional issues are identified in the
individual reports of the four Working Groups.
Conclusions from Initial Presentations
1. The lack of regulatory oversight for planning at Federal facilities is a major problem.
Regulatory oversight similar to that provided for emergency planning activities at
commercial nuclear power facilities is needed for nonreactor nuclear facilities.
Resolution of many of the other issues identified at the Workshop is dependent on
resolving this issue.
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2. A planning basis is needed for nonreactor facilities. The planning basis for nuclear
power facilities dealt with size of the planning area, time frame for response, and
radionuclides to plan for. Due to the variability among sites and source terms for
Federal nuclear facilities, a different basis may be appropriate for each facility.
Guidance is needed on how to develop a planning basis.
3. Nuclear power facilities are a source of stable long-term funding for emergency
planning by State and local agencies. Similar funding is needed for State and local
planning at Federal facilities. In some cases funding has been provided, but it is
neither stable nor long-term.
4, At some facilities, arrangements are needed for communication between the facility
operator and offsite officials regarding classified information. Clearances for key
offsite individuals have been useful to facilitate communication in instances where
they have been implemented.
5. After emergency response plans are developed, exercises and training programs are
needed. Training programs already developed in support of response to nuclear power
plant accidents and transportation accidents are not totally adequate for response to
accidents at Federal nuclear facilities.
Key Issues Identified During Exercises at Federal Facilities
1. At some facilities, States were not considered to be an equal partner with the facility
operator. For example:
Communications were generally ineffective. This was because communications
at the facility were through a third party to a responsible party offsite.
No debate or justification of recommendations on protective actions was
provided to offsite officials.
The technical expertise of the State was not recognized.
2. Accident classification was confusing because of the lack of a standard set of
classifications.
3. Public information was ineffective. This was sometimes a result of facility rules that
did not allow discussions of onsite activities with outsiders.
4. The distinction between recommendations and decisions on protective actions was
sometimes not clear.
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Key Lessons Learned from the Titan II Incident in 1980
1. The impossible can occur.
2. Emergency plans should allow for flexibility so that the response can be tailored to
the situation.
3. Special monitoring equipment related to the potential source term is needed. This
relates primarily to the need to monitor for alpha radiation.
4. Training programs are needed in relation to specific source terms applicable to
nonreactor facilities.
5. An accident does a lot to improve emergency planning. Some results were:
Communication between State and Air Force was improved.
Emergency plans were developed.
Communication with citizens was improved.
Key Conclusions from Working Groups
1. Regardless of the nature of the tools to be used to assess offsite radiological
consequences, it is an inherent responsibility of the facility operator to develop these
tools and make them available to offsite agencies.
2. The absence of gamma-emitting radionuclides in releases from incidents at several
categories of nuclear facilities will require acquisition of expensive field and laboratory
instrumentation not currently available to offsite response organizations. Such
instrumentation will be needed to verify the presence or absence of an airborne
plume.
3. More important than the instrumentation itself, are the procedures and training
required to prepare samples and use the equipment. The analysis of transuranics and
mixed chemical/radiological sources were identified in particular as areas where
training is needed.
4. Far too little information is currently available to offsite planning agencies regarding
the nature of the hazards at many of the Federal facilities. Some may present mixed
chemical/radiological hazards. It was concluded that the current implementation
procedures for evacuation and sheltering will require expansion to address these
different types of hazards. An assessment of the potential for accidental release of
mixed source terms at Federal facilities was identified as a project that should be
completed as soon as possible.
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5. The responsibility for developing information and models for characterizing hazards
of accidental releases should fall to the owner/operator of facilities, whereas the
responsibility to expand current implementation procedures should rest with EPA, in
coordination with FEMA, DOE, and NEC. The development of standards for alpha
contamination was specifically identified as an area requiring the attention of EPA.
6. Due to the difficulty in collecting field monitoring data in a timely fashion, it will be
necessary to make early decisions on the need for protective actions based on facility
status. Emergency action levels and corresponding source terms in potential releases
are needed to support these early decisions.
7. Agreements between nuclear facility operators and offsite response officials should be
developed as needed for security clearances to facilitate communication during
emergencies.
8. Concern was expressed that radiological professionals would tend to overlook chemical
hazards during an event involving a mixed chemical/radiological release thus posing
a threat to themselves and others. Cross training between the chemical and
radiological personnel was recommended.
9. The Federal government should continue to streamline and consolidate authority to
aid States in knowing who is in charge for incidents involving mixed releases.
10. The Federal agencies should participate realistically during exercises at Federal
nuclear facilities by including all the resources that would actually be used in an
emergency.
The consensus of attendees at the Workshop was that it was a success. They
indicated that the information developed would be helpful to those preparing guidance for
the development of emergency plans and exercises as well as to those required to develop
such plans and exercises. EPA was encouraged to proceed with publication of the revised
PAGs, and EPA and FEMA were encouraged to follow through on the development of
additional guidance applicable to emergency preparedness at nonreactor nuclear faculties.
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WORKSHOP ON IMPLEMENTATION OF PROTECTIVE ACTIONS
FOR RADIOLOGICAL INCIDENTS
AT OTHER THAN NUCLEAR POWER REACTORS
PARTICIPANTS
Mr. Robert Baumgartner
Radiological Defense Officer
Idaho State Bureau of Disaster Services
650 West State Street
Boise, ID 83720
(208) 334-3460
Mr. Bernard Bevill
Health Physicist Supervisor
Nuclear & Environmental Safety Section
Division of Radiation Control and
Emergency Management
Arkansas Department of Health
4815 West Markham Street, Slot 30
Little Rock, AR 72205-3867
(501) 661-2301
Mr. Clarence L. Born
Manager, Emergency Response
Planning Program
Bureau of Radiation Control
Texas Department of Health
1100 West 49th Street
Austin, TX 78756
(512) 835-7000
Mr. Gary W. Butner
Senior Health Physicist
Department of Health Services
Nuclear Emergency Response
Environmental Management Branch
714 P Street, Room 616
Sacramento, CA 95814
(916) 323-5027
Mr. William Condon
Chief, Environmental Radiation Section
New York State Department of Health
Bureau of Environmental
Radiation Protection
2 University Place, Room 325
Albany, NY 12203
(518) 458-6495
Mr. Kevin Driesbach
Health Physics Supervisor
Ohio Department of Health
Post Office Box 118
Columbus, OH 43266-0118
(614) 644-2727
Mr. Leslie P. Foldesi
Director, Virginia Department of Health
Bureau of Radiological Health
Main Street Station
1500 East Main Street
Richmond, VA 23219
(804) 786-5932
S.W. (Felix) Fong, Ph.D.
Chief, Nuclear Facilities &
Environmental Radiation
Surveillance Section
North Carolina Division of
Radiation Protection
Department of Environment,
Health & Natural Resources
Post Office Box 27687
Raleigh, NC 27611-7687
(919) 571-4141
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Mr. Eloy A. Garcia Jr.
Water Resources Specialist II
New Mexico Health and
Environment Department
1190 St. Francis Drive (N2300)
Post Office Box 26110
Santa Fe, NM 87502
(505) 827-2935
Mr. Aubrey V. Godwin
Director, Division of Radiation Control
State Department of Public Health
State Office Building
Montgomery, AL 36130-1701
(205) 242-5315
Mr. James C. Hardeman Jr.
Manager, Environmental Radiation
Program
Department of Natural Resources
4244 International Parkway, Suite 114
Atlanta, GA 30354
(404) 362-2675
Mr. John C. Heard
Chief, Technological Hazards Branch
Federal Emergency Management Agency
Region IV
1371 Peachtree Street, NE, Suite 700
Atlanta, GA 30309-3108
(404) 853-4468
Mr. Larry Jensen
Office of Radiation Programs
(5AT26), Region V
Environmental Protection Agency
230 South Dearborn Street
Chicago, IL 60604
(312) 886-5026
Mr. Harlan W. Keaton
Manager, Environmental Radiation
Control
Florida Department of Health and
Rehabilitative Services
Office of Radiation Control
Post Office Box 680069
Orlando, FL 32868-0069
(407) 297-2095
Mr. William Klutz
On-Scene Coordinator, OSWER
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 347-3931
Mr. Joe Logsdon
Consultant
Scientific and Commercial Systems Corp.
4651 King Street, Suite 200
Alexandria, VA 22302
(703) 824-8240
Ms. Cheryl L. Malina
Emergency Programs Specialist
Office of Radiation Programs (ANR-460)
Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
(202) 260-1518
Mr. Stanley R. Marshall
Supervisor, Radiological Health Section
Health Division
Department of Human Resources
505 East King Street
Carson City, NV 89710
(702) 687-5394
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Mr. Robert Mooney
Supervisor, Nuclear Safety Section
Division of Radiation Protection
Department of Health
217 Pine Street, Suite 220
Seattle, WA 98101
(206) 464-7274
Mr. Bradley Nelson
Office of Radiation Programs (ANR-460)
Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
(202) 260-9620
Mr. Jim Rabb
Emergency Response Coordinator
Centers for Disease Control
1600 Clifton Road, N.E.
Atlanta, GA 30084
(404) 639-0615
Mr. Thomas Reavey
Environmental Chemist
Office of Radiation Programs (ANR-460)
Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
(202) 260-9620
Mr. Philip C. Nyberg
Environmental Protection Agency
Region VIII
Suite 500 (8ART-RP)
999 18th Street
Denver, CO 80202-2405
(303) 293-1709
Mr. Jon Richards
Nuclear Engineer
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 347-3907
Ms. Colleen F. Petullo
Office of Radiation Programs
Environmental Protection Agency
Post Office Box 98517
Las Vegas, NV 89193-8517
(702) 798-2446
Mr. William Phillips
Certified Health Physicist
EMSL-LV
Environmental Protection Agency
Post Office Box 93478
Las Vegas, NV 89193
(702) 798-2326
Mr. Allan C.B. Richardson
Chief, Guides & Criteria Branch
Office of Radiation Programs (ANR-460)
Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
(202) 260-9620
Mr. Felix Rogers
Health Scientist
Centers for Disease Control
1600 Clifton Road, MS:F28
Atlanta, GA 30333
(404) 488-4613
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Ms. Debra Shults
Environmental Specialist V
Division of Radiological Health
TERRA Building, 6th Floor
150 9th Avenue, North
Nashville, TN 37243-1532
(615) 741-7812
Dr. John A. Volpe
Ph.D., Manager, Radiation Control
Branch
Kentucky Cabinet for Human Resources
275 East Main Street
Frankfort, KY 40621
(502) 564-3700
Mr. Marlow J. Stangler
Federal Emergency Management Agency
SLPS-OTH-RP
500 C Street, S.W., Room 633
Washington, DC 20472
(202) 646-2856
Mr. Robert W. Terry
Senior Health Physicist
Radiation Control Division
Colorado Dept. of Health
4210 East llth Avenue, Room 54
Denver, CO 80220-3716
(303) 331-4816
Mr. Paul Wagner
Radiological Health Officer
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 347-3907
Mr. Vern Wingert
Chief, Policy Development Branch
Federal Emergency Management Agency
500 C Street, S.W., Room 633
Washington, DC 20472
(202) 646-2872
Ms. Sandra J. Threatt
Radiological Emergency Planning
Coordinator
South Carolina Department of Health
and Environmental Control
Bureau of Radiological Health
2600 Bull Street
Columbia, SC 29201
(803) 734-4629
Mr. Robert Trojanowski
Regional/State Liaison Officer
Nuclear Regulatory Commission
Region II, Suite 2900
101 Marietta Street, N.W.
Atlanta, GA 30323
(404) 331-5599
Mr. Gary N. Wright
Senior Nuclear Engineer
Illinois Department of Nuclear Safety
1035 Outer Park Drive
Springfield, IL 62704
(217) 785-9867
Mr. Sam Windham
Director, National Air and Radiation
Environmental Laboratory
Environmental Protection Agency
1504 Avenue A
Montgomery, AL 36115-2601
(205) 270-3401
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WORKSHOP ON IMPLEMENTATION OF PROTECTIVE ACTIONS
FOR RADIOLOGICAL INCIDENTS
AT OTHER THAN NUCLEAR POWER REACTORS
WORKING GROUP ASSIGNMENTS
Working Group A
James C. Hardeman Jr. (GA), Leader
Harlan W. Keaton (FL)
Bernard Bevill (AR)
Leslie P. Foldesi (VA)
S.W. (Felix) Fong (NC)
Jon Richards (EPA, Region IV)
Felix Rogers (CDC)
Marlow J. Stangler (FEMA)
Working Group B
Stanley R. Marshall (NV), Leader
Sandra J. Threatt (SC)
Robert Mooney (WA)
Gary W. Butner (CA)
Paul Wagner (EPA, Region IV)
Bradley Nelson (EPA, ORP)
Philip C. Nyberg (EPA, Region VIII)
Vern Wingert (FEMA)
Robert Trojanowski (NRC, Region II)
William Phillips (EPA, EMSL-LV)
Working Group G
Gary N. Wright (IL), Leader
William Condon (NY)
Robert Baumgartner (ID)
Robert W. Terry (CO)
John A. Volpe (KY)
Cheryl L. Malina (EPA, ORP)
Larry Jensen (EPA, Region V)
Working Group D
Debra Shults (TN), Leader
Kevin Driesbach (OH)
Aubrey V. Godwin (AL)
Eloy A. Garcia Jr. (NM)
Clarence L. Born (TX)
Jim Rabb (CDC)
Thomas Reavey (EPA, ORP)
John C. Heard (FEMA, Region IV)
Colleen F. Petullo (EPA, ORP/LVF)
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WORKSHOP ON IMPLEMENTATION OF PROTECTIVE ACTIONS
FOR RADIOLOGICAL INCIDENTS
AT OTHER THAN NUCLEAR POWER REACTORS
U.S. Environmental Protection Agency
Office of Radiation Programs
National Air and Radiation Environmental Laboratory
1504 Avenue A
Montgomery, Alabama
September 25-26, 1991
AGENDA
Workshop Objective
The principal objective is to provide a forum for the States to identify and discuss issues
regarding implementation of protective actions following a radiological accident involving a
Federal or Commercial Facility, with emphasis on source terms other than power reactors.
It is not expected that issues will be resolved or guidance developed at this workshop.
September 25, 1991
8:00 to 8:30 a.m. Registration
Cheryl L. Malina, Bradley Nelson, Thomas Reavey (EPA, ORP)
Plenary Session
Moderator: Allan C.B. Richardson (EPA, ORP)
8:30 a.m. Welcome and Introduction
Sam Windham (EPA, NAREL)
Welcome
Aubrey V. Godwin (AL)
8:50 a.m. Overview of the Workshop
Allan C.B. Richardson (EPA, ORP)
9:10 a.m. Lessons Learned From Emergency Planning at Hanford
Robert Mooney (WA)
9:30 a.m. Generic Nonreactor Source Terms: Transuranics, Tritium, Other
Possibilities
To be Announced (DOE/DOD)
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Agenda
September 25, 1991 (Continued)
9:50 a.m. The Relationship Between Protective Action Guides and Emergency
Planning Zones
Robert Trojanowski (NRG, Region II)
10:10 a.m. The Basis for Protective Action Guides and Their Application to Non-
reactor Source Terms
Allan C.B. Richardson (EPA, ORP)
10:30 a.m. Break
10:45 a.m. Implementation of Protection Action Guides at a Large Plutonium
Processing Facility
Philip C. Nyberg (EPA, Region VIII)
11:05 a.m. Mixed Hazard Incidents (Chemical/Nuclear Incidents)
William Klutz (EPA, Region IV)
11:25 a.m. Arkansas' Titan II Experience
Bernard Bevill (AR)
11:45 a.m. Review on the Basis of Guidance for Sheltering as a Protective Action in
a Plutonium Release Accident
Bradley Nelson (EPA, ORP)
12:05 p.m. Lunch
1:10 p.m. Tour of Lab
Working Group Sessions
Working Group A Leader: James C. Hardeman Jr. (GA)
Working Group B Leader: Stanley R. Marshall (NV)
Working Group C Leader: Gary N. Wright (IL)
Working Group D Leader: Debra Shults (TN)
2:00 p.m. Organization of Working Groups
Allan C.B. Richardson (EPA, ORP)
2:15 p.m. to Working Group Discussions and Drafting of Summary Reports
5:30 p.m.
8:30 a.m. to Working Groups Meet to Organize Presentations
10:00 a.m.
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Agenda
September 26, 1991
Plenary Session
Moderator: Aubrey V. Godwin (AL)
10:00 a.m. Working Group A Presentation and Discussion
10:45 a.m. Break
11:00 a.m. Working Group B Presentation and Discussion
11:45 a.m. Working Group C Presentation and Discussion
12:30 p.m. Lunch
1:30 p.m. Working Group D Presentation and Discussion
2:15 p.m. Audience Discussion and Review of the Most Important Issues
Aubrey V. Godwin (AL)
3:00 p.m. Closing Remarks and Adjournment
Allan C.B. Richardson (EPA, ORP)
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SPEAKERS' PAPERS
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WELCOME AND INTRODUCTION
Sam Windham
National Air and Radiation Environmental Laboratory
Office of Radiation Programs
U.S. Environmental Protection Agency
Montgomery, Alabama
As director of the National Air and Radiation Environmental Laboratory (NAREL),
I would like to welcome you here for this important meeting. Cheryl Malina and Allan
Richardson from the Office of Radiation Programs (ORP), and Dr. Charles Petko, from the
laboratory, have worked to assure the meeting is a success and that the time you spend here
is productive and pleasant.
For those of you who may not be familiar with the NAREL, we are an environmental
radiation laboratory, a part of the ORP. The laboratory was first established in 1959 in
support of the Bureau of Radiological Health, and when the Environmental Protection
Agency (EPA) was formed in 1970, we were transferred to EPA. Not only do we work
closely with our ORP headquarters organization, but we also support EPA regional offices
and other federal and state government agencies in environmental radiation related projects.
The laboratory has a staff of 39 federal employees and about 30 other employees who are
contractors, co-op students, etc.
About 18 months ago, we moved into our new facility, a 65,000 square foot modern
laboratory, of which we are very proud. We have set aside a time during this meeting to
take you on a tour of the facility.
We have arranged to have lunch each day at the Gunter Air Force Base Club adjacent
to the lab. There is a room reserved to accommodate our group. Our receptionist will
handle messages for you during the meeting. Please check with her at the front desk at each
break. Again, welcome to the NAREL, we are glad you are attending the PAG workshop.
If there is anything the NAREL staff or I can do to assist you during your visit, please let
us know.
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WELCOME
Aubrey V. Godwin
Division of Radiation Control
Department of Public Health
Montgomery, Alabama
On behalf of Governor Hunt, welcome to Alabama. We anticipate a good meeting on
the PAGs, I hope you found the accommodations in good order. This is a fine facility, and
I am sure the Environmental Protection Agency (EPA) will want to show you around as
their guests.
This workshop is to discuss the problems of implementing the PAGs for federal
facilities. The Guides are out and are not being discussed at this workshop. The results of
this workshop will be used by the federal agencies to identify problems and to develop policy
regarding those problems. So, now is your opportunity to affect the National policies which
may be developed.
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OVERVIEW OF THE WORKSHOP
Allan C.B. Richardson
Guides and Criteria Branch
Office of Radiation Programs
U.S. Environmental Protection Agency
Washington, D.C.
Introduction
Welcome to this Workshop on Implementation of Protective Actions for Radiological
Incidents at Other Than Nuclear Power Reactors. (I will elaborate on the slight change in
emphasis represented by the current versus the previously announced title later.) The
planning group has put forth considerable effort to bring this workshop together, and it is
our hope that the information developed here will be of great value in identifying any new
guidance needed for the host of different situations that the Protective Action Guides (PAGs)
now address, in contrast to their original focus — commercial nuclear power reactors.
We hosted a similar workshop two years ago on Protective Action Guides for
Accidentally Contaminated Food and Water in Washington, D.C. The purpose of that
workshop was to identify issues and relevant experience that should be considered in the
development of PAGs for water and food. It was, I believe, a clear success and helpful to
those responsible for the development of PAGs for ingestion. Several of you participated in
that workshop and I want to thank you again for your assistance. You will be familiar with
the process today and tomorrow, since it will be very similar.
We are also taking advantage of the opportunity provided by this workshop to show
off our new laboratory, which has been open for less than two years. We believe this to be
the best environmental radiation laboratory in the country, and possibly in the world, and
are quite proud of it. The Environmental Protection Agency (EPA) is in great debt to
Charlie Porter, whom I am sure many of you know, for conceiving the idea of a new
laboratory and for pushing it through the bureaucracy to completion over a period of several
decades. Charlie retired last year and Sam Windham, who has been involved in management
at the EPA Radiation Facility in Montgomery for many years and who participated in the
design of this new facility, is the new Laboratory Director. He has agreed to conduct a tour
this afternoon for all of the workshop participants.
Participants and Roles
Co-sponsors of this workshop are the EPA, the Federal Emergency Management
Agency (FEMA), the Department of Agriculture (USDA), the Food and Drug Administration
(FDA), and the Conference of Radiation Control Program Directors, Inc., (CRCPD). Our
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Planning Committee for the workshop included Aubrey Godwin (AL-CRCPD), Marlow
Stangler (FEMA), Janet Quissel (USDA), Donald Thompson (FDA), Jim Rabb, Centers for
Disease Control (CDC), Rosemary Hogan, Nuclear Regulatory Commission (NRG), Jim
Fairobent, Department of Energy (DOE), Michael Schaeffer (DNA) and myself from EPA.
We are responsible for the organization of the workshop, including development of the
agenda. Cheryl Malina (EPA) has been responsible for the administrative effort required to
make everything happen. Joe Logsdon, formerly of EPA, did most of the work on suggested
issues for the working groups. The CRCPD arranged for invitations to State representatives
who have major nonreactor nuclear facilities in their State. The CRCPD has also agreed to
manage the publication of the proceedings document.
EPA recommended PAGs for the early phase in 1975 (and revised them in 1980).
These PAGs applied to planning and carrying out radiological emergency response at
commercial nuclear power facilities. The 1975 (and 1980) PAGs addressed the need for
evacuation or sheltering, based on projected doses to the whole body from external gamma
radiation and to the thyroid from inhalation of radioiodine. Inhalation of particulate
materials and exposure of the skin to beta emitters were not considered. Thus, emergency
response planners have had no PAGs for evacuation and sheltering for source terms where
neither whole body exposure to gamma radiation nor inhalation of radioiodines are the
leading exposure pathways.
In response to this need, EPA has now developed revised PAGs for evacuation and
sheltering that apply to all types of nuclear incidents (except, of course, nuclear war). Last
year we issued similar PAGs for relocation. Since states are responsible for implementing
PAGs, and have extensive experience in implementing them during exercises of emergency
response plans for commercial nuclear power facilities, we thought it would be useful to
provide an opportunity for the states to collectively identify and evaluate potential problems
associated with implementation of these new PAGs at nonreactor nuclear facilities. We
have, therefore, organized this workshop and invited emergency preparedness officials from
all of the states that have major nonreactor nuclear facilities. We have also invited
representatives from the Federal agencies that would provide assistance in the event of a
radiological incident with potential offsite consequences.
I noted the change in the workshop title earlier. We have expanded the scope of this
meeting from incidents at Federal facilities to any incident not caused by a commercial
power reactor. We made this change, in response to suggestions from DOE, the Department
of Defense (DOD), and FEMA, because we believe it makes good sense. The new PAGs now
apply to any nonreactor source term, not just those at Federal facilities, the nonreactor
sources that most readily come to mind. Other examples now covered by the PAGs include,
among others, fuel cycle facilities licensed by the NRG, satellites using nuclear power
sources, and radiopharmaceutical manufacturers. You may also have noticed the absence
of DOE and DOD as co-sponsors. We regret this. They were invited. They have advised us
that they do not feel comfortable with this sort of meeting at this time, and do not believe
it would be productive. I hope we will prove their apprehensions wrong on both counts. It
is not our intention to focus on possible past inadequacies, but on what we need to do in the
future. In any case, the results of this workshop will be available to all in published form.
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The purpose of this workshop, then, is to provide a forum for State and Federal
officials to identify and evaluate the issues and problems associated with implementation of
the new PAGs in the event of an incident at a nonreaetor nuclear facility. However, since
there is so much experience in planning and exercising of plans for incidents at commercial
nuclear power plants, we should make a particular effort to evaluate the extent to which
plans and procedures for nonreaetor facilities can be the same as, as well as where they
should differ from, those developed for power plants. For incidents at some of these
facilities, it will also be appropriate to consider the issues and problems associated with
response to incidents involving simultaneous releases of chemically toxic and radioactive
materials (mixed releases), and we have included a special working group to focus on this
problem.
Format for the Workshop
As you can see from the agenda, the workshop will consist of two plenary sessions and
one working group session. This first plenary session is intended to provide background
information that may stimulate you to identify issues or problems that should be discussed
by the working groups. Each presentation in this session is scheduled for 15 minutes, with
an additional 5 minutes for questions. Although there is limited time, I plan to be somewhat
flexible with regard to individual presentations. In other words, we do not want to miss
important information because of a time constraint, but, on the other hand, speakers, please
do not feel obligated to use all of your allotted time. If questions and discussions tend to be
lengthy, they will be deferred to the appropriate working group in the afternoon session.
A second plenary session will be convened tomorrow morning to hear and discuss the
deliberations of the working groups. Then, tomorrow afternoon, we will attempt to sum up
what we have learned.
Working Groups
The planning group prepared a list of topics that included all of the relevant issues
that we could identify. After categorizing them into four topic areas (one for each working
group), they were sent to each of you with a request to identify your first, second, and third
choices for working group assignments. We have reviewed your selections and have assigned
each of you to a working group as shown on one of the handouts. Noone has been given his
third choice, although a few of you did not get assigned to your first choice. I will make
additional assignments, if necessary, and provide additional suggestions regarding operation
of the working groups when they are convened this afternoon. If anyone is not happy with
their assignment please see me during lunch.
Use of Workshop Results
We do not expect this workshop to produce consensus solutions or recommendations.
However, we encourage individuals to express opinions or to make recommendations on any
relevant issues. Also, if consensus opinions can be developed on what the outstanding needs
are, we will welcome their presentation.
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The proceedings of the workshop will include the papers that were presented in the
plenary session plus any others that were submitted for use or consideration by the working
groups. It will also include summaries prepared by each of the four working groups. The
document will then be distributed to all of you, to relevant Federal agencies, and to any
other interested parties. Most importantly, I hope it will be a useful resource for identifying
any additional guidance and for identifying any special plans or procedures needed for
emergency response based on these new PAGs.
Thank you for coming. I hope that when you leave you will feel that your time has
been well spent. If you have any questions about the workshop, either now or later, please
do not hesitate to ask either me or any of the other EPA staff members present.
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LESSONS LEARNED FROM EMERGENCY PLANNING AT HANFORD
Robert Mooney
Nuclear Safety Section
Division of Radiation Protection
Department of Health
Seattle, Washington
Introduction
Thank you for the opportunity to speak at this workshop. My involvement with the
Environmental Protection Agency (EPA) and Protective Action Guides (PAGs) dates back
to the 1970's. I am pleased we are finally bringing federal facilities into the emergency
planning process. My remarks will not cover the technical aspects of PAGs. The working
groups provide the forum for us to do that. Instead I will deal with two main concepts which
are poorly understood in emergency planning. Since they are so poorly understood, when
it comes time to implement protective actions, the parties involved experience both grief and
consternation. These two concepts are Guidance versus Legal Authority and
Recommendations versus Decisions. Following a discussion of these two concepts, I will
elaborate on lessons learned from our experience at Hanford.
Guidance versus Legal Authority
Usually overlooked in the application of PAGs is the fact that they are exactly that,
Guides. Quoting from the Federal Register of October 22, 1982, "these recommendations are
voluntary guidance to State and local agencies." (1) The legal authority for protecting public
health and safety rests with the state and/or local government. Therefore, when federal
guidance becomes "official," the process is not over. It has just begun. Failure to address this
key point sets up recurring pitfalls in implementing PAGs.
Recommendations versus Decisions
The Legal Authority issue leads directly to the Recommendations versus Decision
issue. Once an accident occurs at a nuclear facility, facility operators are responsible to
provide Recommendations to the offsite agencies responsible for public health and safety.
The agency with the legal authority then must make a Decision and implement it. Buried
in the emergency planning trees, we often forget that the purpose of the forest is to make
the process between the start of the accident and implementation of a protective action
decision fast, smooth and effective. The offsite decisions must range from NO ACTION
(minor accident) to AUTOMATIC EVACUATION (major accident).
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There is a big gray area between these two extremes. For adequate public health
protection to occur when we find ourselves in the gray area, trust and credibility must be
strong and communications must be flawless. For nuclear power plants, over ten years of
planning and exercises have brought us a long way down that road. For Federal exercises,
we have barely begun the journey. Also, Federal facilities start with a major credibility
problem. Because of this, one would expect Federal officials to spend major efforts on
effective communications. Yet the opposite is happening.
At recent Federal exercises I have evaluated, the entire communications with offsite
agencies is shunted to a third party "communicator." No one-to-one conversations occur
between onsite and offsite decision makers. This problem of poor personal communications
is well documented in a report titled, Human Factors of an Emergency Response Center by
Moray, Sanderson, and Vicente. (2) The report identifies three inputs required for effective
decision making:
(1) Status data from the facility.
(2) Data on meteorology and health physics.
(3) Data on the status of offsite agencies.
It is this third area where serious inertia exists. Progress cannot really begin until Federal
officials see offsite agencies as equal partners in the joint mission of protecting public health
and safety.
Once this equal partnership framework is established, major technical differences
must be resolved. I call this the Fix Fatal Flaws process. The Flaws we are striving to
fix at Hanford are:
o Planning Basis
o Planning Zones
o Long Term Stable Funding
o Independent Regulatory Oversight
Planning Basis
It is ironic that emergency planning at Hanford has begun after all major facilities
have been shut down. At one time, Hanford included fuel fabrication, nine production
reactors, plutonium extraction, and waste storage. Thus the entire nuclear fuel cycle, except
for enrichment and uranium milling was represented at Hanford. Now the only operating
facility is the FFTF breeder reactor, and it is expected to shut down soon. So what accidents
are left that we might have to respond to? There are two major sources of significant
radionuclide inventory: spent fuel from the last years of N reactor operations, and over 100
tanks of high level radioactive waste. The tanks have been identified as having potential for
significant explosions due to ferrocyanide and hydrogen gas. What Safety Analysis Reports
(SARs) do exist have been shown to be inadequate (3). Thus no technical basis exists that
defines the maximum credible accidents which could occur at Hanford.
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Planning Zones
In the absence of a sound technical basis for planning, the establishment of
appropriate planning zones sits in limbo. The State's position has been to use the nuclear
power plant 10- and 50-mile planning zones as a default until adequate SARs can justify
something else. Rather than a 10 mile planning zone for the plume pathway, the U.S.
Department of Energy (DOE) uses a 4.5 mile zone for their spent fuel storage facility.
Ironically, the 4.5 mile zone magically stops just short of the Hanford boundary. DOE has
been unresponsive to the State's efforts to resolve this issue.
Long Term Stable Funding
Washington's position on emergency response funding is that the facility pays the
costs of state and local agency planning efforts. In 1981, Governor Spellman of Washington
wrote to DOE requesting funding support for emergency planning at Hanford. Nine years
later, in March 1990, the state received the first funds from DOE to begin emergency
planning at Hanford. In accepting these funds, the state documented that the initial funding
was inadequate, and laid out a three year budget that was consistent with our ten year old
planning program for nuclear power plants. Eighteen months later, we are still negotiating
with DOE for adequate funding.
Independent Regulatory Oversight
Presently, emergency planning at federal facilities is done on a voluntary basis. Thus
the criteria at Hanford are established by DOE in a vacuum. The Conference of Radiation
Control Program Directors, Inc. (CRCPD) went on record this year to bring federal facilities
under the same regulatory umbrella as private industry. This is a key milestone in bringing
credibility and a sound technical basis to emergency planning at Hanford.
The State of Washington has partial regulatory authority over Hanford operations.
This includes authority over chemical and toxic wastes, waste clean-up operations, and air
emissions of radionuclides. Neither Washington nor any other state or federal agency has
authority to require emergency planning.
In closing, two conditions need to be established at Hanford to effectively implement
PAGs:
Equal Partnership
Fix Fatal Flaws
These conditions require a major cultural change to occur on the part of DOE, and major
state and federal legislative actions. In the meantime, state and local officials have begun
the process of emergency planning. In the event the accident happens "today", we aim to fee
as prepared as resources allow.
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REFERENCES
1. Food and Drug Administration, Accidental Radioactive Contamination of Human Food
and Animal Feeds: Recommendations for State and Local Agencies, Federal Register.
Vol. 47, No. 205, October 22, 1982, p. 47074.
2. Moray, N., Sanderson, P., and Vicente, K., Human Factors of an Emergency Response
Center: A Field Study, Third Topical Meeting on Emergency Preparedness and
Response, April 17, 1991, Chicago, Illinois.
3. General Accounting Office, Consequences of Explosion ofHanford's Single-Shell Tanks
Are Understated, October 1990.
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THE RELATIONSHIP BETWEEN PROTECTIVE ACTION GUIDES
AND EMERGENCY PLANNING ZONES
Robert Trojanowski
U.S. Nuclear Regulatory Commission
Region II
Atlanta, Georgia
Introduction
Good morning. The Nuclear Regulatory Commission (NRG) is pleased to participate
in this interesting and important workshop.
In order to discuss the relationship between the Protective Action Guides (PAGs) and
the Emergency Planning Zones (EPZs), it is important to take a brief historical perspective
as to the basis for the development of each of these concepts. The PAGs and the EPZs,
which as you know, have been subsequently implemented as "guidance tools" and "planning
mechanisms," respectively. Also, it is important to historically review the Federal
regulations and guidance as related to emergency preparedness, both prior to and after the
accident at the Three Mile Island (TMI) facility, in order to fully understand how we got to
where we are from where we were in the early days of the commercial nuclear power
industry.
These are some of the things I would like to discuss with you today, and then during
the workshop phase of this program, we can hopefully have a thorough discussion of how
these concepts can be applied to radiological incidents involving Federal faculties.
Unfortunately, I understand that the representatives from the Department of Energy (DOE),
Department of Defense (DOD), and the National Aeronautical and Space Administration
(NASA) who were expected to participate in this workshop will not be joining us today.
The Period Before the Incident at TMI
Yankee Rowe, located in Western Massachusetts was the first licensed nuclear power
reactor to go on-line and began commercial operation in July 1961. Others were licensed
and came on-line shortly thereafter. During this early period of the commercial nuclear
power industry, emergency planning considerations were initially set forth in Title 10,
Department of Energy, Code of Federal Regulations, Part 100 (10 CFR 100), Reactor Siting
Criteria, which was published in 1962. These 10 CFR 100 criteria specified that for each
reactor site an exclusion zone (EZ), low population zone (LPZ), and a population center be
established and identified. By definition, the utility operator was required to have total
control over the EZ, which essentially meant that this area was company-owned property.
Its exact size was determined through accident analyses consistent with the criteria specified
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in 10 CFR 100 which required that an individual located on any boundary point of the EZ
for a two-hour period immediately following a fission product release from the reactor
coolant would not receive a total radiation dose of 25 rem whole body or 300 rem to the
thyroid from plume exposures.
The size of the LPZ was similarly defined such that an individual located on any point
of its outer boundary continuously over a thirty day period would not receive a total
radiation dose in excess of 25 rem whole body or 300 rem thyroid from fission product plume
exposures. Additionally, the utility operator was required to demonstrate that there was a
reasonable probability that appropriate protective measures, including evacuation, could be
taken to protect the LPZ populace in the event of an accident. LPZs were generally defined
at distances of two to three miles from the site. Regarding the designated population center,
no dose guidance values were given, but were assumed to be lower than those values
associated with the LPZ. Population centers were generally defined as the areas within fifty
miles of the site, and the utility operator was required to demographically characterize these
areas. Not a great deal of concern was given to the need for implementing protective
measures in the designated population centers, since the dose criteria established for the EZ
and LPZ were considered to be extremely conservative based on the site-specific calculated
doses over a broad range of design-basis accidents.
This general philosophy prevailed during the decade, and although in a traditional
sense the state and local governments are responsible for public health and safety, these
entities did not play a large role in emergency planning around commercial nuclear power
plants. The risks from these facilities were generally considered to be consistent with the
risks associated with other industrial facilities such as steel making plants, chemical plants,
etc., and the utility operators were bound by the regulations specified in 10 CFR 100. In this
regard, engineered safeguards were designed and put in place to mitigate the consequences
of all identified design-basis accidents. Hence, the general thinking was that the public
domain was not at risk even for the class 9 accident, i.e., core melt or containment failure.
While the occurrence of a class 9 accident was plausible, the probability of it happening was
thought to be so small that no special emergency planning requirements were considered to
be necessary.
In 1970, 10 CFR 50, Appendix E was published which did contain explicit
requirements for dealing with emergencies; however, these requirements were again directed
to the utility operators, and required them to include provisions in their emergency plans
for participation of offsite governmental authorities or outside groups. The obvious dilemma
which developed is that the Federal Government did not have statutory authority over the
states and local governments with regard to emergency planning, yet the utility operators
were required to incorporate governmental participation into their emergency planning
process. At best, this could only be accomplished on a cooperative basis but raised questions
of effectiveness and legal liability.
During the period of the early to mid seventies not only was there an increase in the
number of power plants coming on-line commercially, but the reactor core inventories were
being substantially increased. Consequently, both the states and Federal Government began
to raise concerns regarding the potential offsite consequences to the general public as a
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result of a major accident. Additionally, the Federal Government also questioned the
capability of state and local governments in responding to a major nuclear incident,
particularly in light of the Federal regulations which required the utility operators to
coordinate state and local government participation into the overall response effort.
Consistent with these concerns, the NRG published the WASH-1400, Reactor Safety Study,
in 1975; and, the Environmental Protection Agency (EPA) developed and published the
Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, also in
1975. In 1976, the Conference of Radiation Control Program Directors, Inc. (CRCPD)
petitioned the Federal Government to identify the offsite threat, and to assist in the
development of state and local emergency plans. In response to these requests, NRC
published NUREG-75/111, Guide and Checklist for Development and Evaluation of State and
Local Government Radiological Emergency Response Plans in Support of Fixed Nuclear
Facilities. Regarding the identification of the offsite threat, a joint NRG/EPA Task Force
on emergency planning was formed and its findings were published in NUREG-0396/
EPA-520/1-78-016, dated December 1978, Planning Basis for the Development of State and
Local Government Radiological Emergency Response Plans in Support of Light Water
Nuclear Power Plants. These actions gave rise to the Regional Advisory Committees (RACs)
which were originally chaired by NRC, and the joint Task Force findings established the
concept of the 10-mile plume EPZ and the 50-mile ingestion EPZ. Initially, the RAG
program was strictly voluntary for the states and the Federal Committees assisted in the
development of state emergency plans, to include testing these plans in exercises. The RACs
had no statutory jurisdiction and consequently, the state plans were not "approved" by the
RACs, but rather the Committee simply granted a statement of "concurrence." This
statement of concurrence acknowledged that the plan was developed in accordance with the
NUREG-75/111 guidance criteria, concurred in by the RAG, and successfully tested by means
of a demonstration exercise.
The joint NRC/EPA findings concluded that the major threat for design-basis accidents
to be in the range of 2 to 5 miles, and out to ten miles, and possibly beyond, for the class 9
accident. The relationship between EPA PAGs of 1 rem to 5 rem whole body, and 5 rem to
25 rem thyroid, and the establishment of a ten mile EPZ is an extremely conservative
approach to emergency response. The Task Force concluded that incident response generally
would not involve taking response actions in the entire ten mile EPZ, but if necessary, the
detailed essential planning mechanisms would be in place.
The Period After the Incident at TMI
As you know, after the accident at the TMI facility, greater emphasis was placed on
emergency preparedness concerns. The NUREG-75/111 guidance criteria became the
foundation for NUREG-0654/FEMA-REP-l, which placed more emphasis on defining
emergency organizations, communications, notifications, alert and notification systems, etc.
Additionally, the ten and fifty mile EPZ concepts which were derived in the joint NRC/EPA
Task Force study were also incorporated into NUREG-0654. Federal Emergency
Management Agency (FEMA), through Executive order, was given responsibility for offsite
emergency preparedness. Consequently, the Chair of the RACs was transferred to FEMA
from NRC, while NRC retained regulatory jurisdiction for emergency preparedness onsite.
NRC also revised its regulation in 10 CFR 50, Appendix E to incorporate the planning
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standards in NUREG-0654.
Although the NRG did not have statutory authority over the state and local
governments, its regulations authorized the operation of commercial nuclear power plants
only in those states which have implemented a FEMA-approved emergency plan. Hence, the
RAC program which heretofore was advisory and voluntary, shifted to a more formal
program and became somewhat regulatory. This basically brings us to where we are today,
and I assume that most of you are familiar with FEMA's plan review and approval process,
as well as their program for evaluating exercises.
Emergency Planning Requirements for Fuel Processing Facilities
In contrast to the emergency preparedness requirements for reactors, I want to briefly
comment on the NRG regulations governing fuel processing facilities. These regulations are
contained in 10 CFR 70.22. Based on worst case accident analyses, which show that 1 rem
effective dose at the site boundary will not be exceeded, there are no established EPZs for
NRG licensed fuel processing facilities. Also, the regulations were revised to eliminate the
"Unusual Event" and "General Emergency" classifications. I only mention these regulations
to show that the risk to the public is based on the source term activity and potential offsite
effect, and that the concept of EPZs is really only a planning mechanism, i.e., worst case
accident analyses may indicate that the delineation of a specific EPZ is not necessary to
protect public health and safety.
Relationship Between PAGs and EPZs
The PAGs were developed and published by EPA in 1975. As you know, they are
expressed over a range for whole body exposures and exposures to a child's thyroid. EPA
intends that the PAGs be utilized as guidance for triggering appropriate protective actions
in order to protect public health and safety and to minimize exposures to the general public
and emergency workers. The PAGs should not be viewed as acceptable dose limits; and,
although the PAGs and EPZs complement each other, they should not be utilized to
determine the size of an EPZ, i.e., the boundary at which the whole body PAG is exceeded
should not be the EPZ demarcation boundary.
EPZs are planning mechanisms which, for any given facility, are based on a whole
range of accidents and other variables such as population demographics, meteorological data,
terrain, ingress and egress routes, etc. They should be developed and defined in a
conservative manner such that in the event of an accident, incident response will not involve
the entire EPZ, but if necessary, appropriate emergency plans are in place. Incident
response beyond the EPZ, if necessary, will have to be developed on an ad-hoc basis at the
time; however, if the EPZ is properly defined, such actions will be unlikely.
As I previously mentioned during our discussion of NRG licensed fuel processing
facilities, if an EPA PAG cannot be exceeded at the facility boundary, there should be no
need to develop and define an EPZ for such a facility.
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Before closing, I would like to briefly discuss the current philosophy within the NRC
regarding evacuation relative to power reactor incidents. Presently, at the declaration of
general emergency, the NRC regulatory scheme requires that, at a minimum, licensees
recommend that sheltering be implemented in the area encompassing the 0 - 2 mile radius
of the plant. However, the current thinking, as noted by some of you as expressed in NEC's
Response Technical Manual 91 (RTM-91), calls for the automatic evacuation of the 0-2 mile
sector at the declaration of a general emergency. Currently, actions are under way within
the NRC to adapt this scheme as a regulatory requirement. Please note that this evacuation
may be based solely on plant conditions in the absence of an actual radiological release, and
obviously, prior to reaching an EPA PAG trigger level.
I would be happy to respond to any questions you may have.
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THE BASIS FOR PROTECTIVE ACTION GUIDES
AND THEIR APPLICATION TO NON-REACTOR SOURCE TERMS
Allan C.B. Richardson
Guides and Criteria Branch
Office of Radiation Programs
U.S. Environmental Protection Agency
Washington, B.C.
Overview
The Protective Action Guides (PAGs) for decisions on evacuation and sheltering (also
known as the PAGs for the early phase) were first published in the Environmental
Protection Agency (EPA) Manual of Protective Action Guides and Protective Actions for
Nuclear Incidents in 1975, and were reissued in slightly revised form in 1980. In 1990, we
added PAGs for relocation as well as the 1982 recommendations of the Food and Drug
Administration (FDA) on PAGs for food. As you know, EPA has been in the process of
revising the PAGs for the early phase since early in the 1980s. My discussion today will
focus primarily on the reasons why the PAGs required revision and the considerations that
have led to the new PAGs. I will also touch on implementation guidance that we have
developed for these new PAGs, including examples of some recent situations to which they
have been applied.
There are three types of problems that led to the decision to update the 1975 PAGs
for the early phase of a nuclear incident. First, the scope of the PAGs was inadequate; e.g.,
some important exposure pathways were not covered and the source term did not include
long-lived materials. Second, we needed to consider new radiation risk projections. Finally,
implementing guidance for use of the range and the choice between evacuation and
sheltering had been occasionally misinterpreted and required clarification.
The PAGs Were Limited in Scope
a) Limited Source Term
The old PAGs for the early phase were adequate for protection of the general
public from a reactor accident, but they did not apply to other nuclear
incidents, unless the principal exposure was from radioactive noble gases or
radioiodines. This is the case because these PAGs were developed specifically
for atmospheric releases from power reactors, for which the leading pathway,
in terms of health effects, is either whole body exposure to gamma radiation
from the plume (plume shine), or thyroid exposure from inhalation of
radioiodines. The deficiency is most noticeable in planning for incidents
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involving releases of participates when radioiodine is not a major component.
To put the matter succinctly, we needed to generalize the PAGs so they would
apply to the dose from any combination of radionuclides. The new PAGs solve
this problem simply; they are now expressed in terms of effective dose, rather
than whole body or organ dose. This assures that dose to any organ is
accounted for, regardless of the radionuelide or pathway. We have also
developed dose conversion factors for 141 radionuclides that cover almost any
conceivable incident; these have been added to the implementation guidance.
However, there were other problems.
b) Long Term Exposure
Whole body dose from exposure to a plume only accumulates while the plume
is present. And, due to the short half-lives of most radioiodines, thyroid dose
from short-term inhalation of radioiodines also accumulates over a short period
of time. However, inhalation of long-lived particulates results in doses that
accumulate over a long period, in some cases for a lifetime. Similarly, surface
deposits of long-lived particulate materials can result in long-term exposure due
to inhalation of resuspended materials. Since, as we will see later, risk of
delayed health effects from radiation dose is the primary basis for selection of
the PAGs, all of these doses should be considered for decisions on protective
actions.
The PAGs that have already been developed for relocation take into account
long-term exposure to deposited materials during the intermediate phase, both
direct whole body exposure and inhalation of resuspended materials, because
they are expressed in terms of the committed dose, rather than annual dose.
However, long-term internal dose from inhalation of particulate materials from
the plume were not addressed by the 1975 PAGs for evacuation and sheltering.
This deficiency has been solved by expressing these PAGs in terms of the
committed dose as well.
Thus, we have now adopted, for emergency response, both of the improvements
introduced by ICRP-26 in 1977 and in use now for a number of years in
regulation of occupational exposure and exposure of the public to routine
releases, the concepts of effective and of committed dose.
c) Additional Exposure Pathways
Two exposure pathways not included in the old PAGs were, (a) exposure of the
skin from beta radiation from an airborne plume and from materials deposited
on the skin, and (b) whole body exposure to gamma radiation from radioactive
materials deposited on surfaces (ground shine). For an airborne plume of
beta/gamma emitters, calculations indicate that the health risk from skin dose
will almost always be secondary to the risk from other doses, but only if
exposed persons wash and change clothes within several hours after exposure
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of the skin begins. Therefore, since skin dose is not included in the summation
over organs represented by effective dose, there may be situations where
guidance is needed for evacuation or sheltering based on skin dose. Likewise,
whole body dose from ground shine could be a major exposure pathway if
relocation PAGs are not implemented within a few days after exposure begins.
These deficiencies were solved by adding separate guidance for skin and by
adding short-term exposure to ground shine to the dose included in the PAG
for evacuation and sheltering.
Risk Estimates Have Changed
In 1975, the International Commission on Radiation Protection (ICRP) assumed that
the risk of fatal cancer from low level exposure was approximately 1 x 10~4 rem"1. At that
time, EPA assumed a risk of about 2 x 10~4 rem"1. Now, fifteen years later; these risk
estimates have increased approximately 5-fold. The 1991 risk estimates published by the
National Academy of Sciences correspond, for total radiogenic cancer incidence to 5 to 10 x
10'4 rem"1, depending on the rate at which the dose is delivered.
We have addressed these increased risk estimates in two ways. First, we have taken
a new look at the PAGs in terms of the basic principles for their selection. Second, we have
reviewed experience on how the old PAGs were implemented, to make sure that they are
applied in a manner consistent with our judgments on risk.
The four principles that EPA has selected as the basis for choosing PAG values are
shown in Table 1. Principles 1, 3, and 4 are similar to those recommended by the ICRP in
Publication 40 and in the recently published Publication 60. We have added Principle 2 and
a similar consideration has been recognized by the International Atomic Energy Agency in
its recently re-issued Publication 72.
Principles 1 and 2 limit the risk to health of individuals from radiation independently
of other considerations. The first calls for avoiding dose that exceeds the threshold for
prompt health effects; the second calls for keeping the risk of delayed health effects to
reasonably low levels.
We assume that there is a threshold dose below which prompt effects are not expected
to occur, and that threshold is much higher (50 to 300 rads) than any PAG that would
satisfy the remaining three principles. Thus, Principle 1 has no effect on the choice of the
PAG level. However, there is no threshold associated with delayed effects, and, therefore,
the choice of PAGs based on the second principle is not so simple.
a) Risk of Delayed Effects
Since there is no threshold dose for delayed health effects, the determination
of a dose value that is "adequately protective of public health under emergency
conditions" requires one to select an acceptable risk value and relate it to the
corresponding dose. One approach is to compare risk levels commonly used by
EPA in setting standards for other carcinogens. These levels fall in the range
39
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of lifetime risks of death of 10"4 to 10"6; that is, EPA almost always chooses its
standards to reduce the Lifetime risk of fatal cancer to less than 1 in 10,000,
and rarely establishes a standard requiring a risk level less than 1 in 1,000,000.
This implies a maximum dose in the range of 100 to 200 millirem. This
maximum risk applies to standards for normal releases. Although there is no
clear precedent for choosing different acceptable risks for normal versus
emergency conditions, we concluded that a factor of 5 to 10 is not
unreasonable. This leads us to the conclusion that a projected dose of 1 rem
would satisfy Principle 2.
b) Cost of a Protective Action
Principle 3 requires that we carry out any further reduction of risk that is
achievable at acceptable cost, and thus it acts as a supplement to Principle 2.
That is, if the risk level established under Principle 2 can be reduced by cost-
effective measures, then the PAG should reflect this. A recent landmark court
decision under the Clean Air Act directed EPA not to set environmental
standards on the basis of cost unless the risks are lower than those found to be
"safe" without consideration of cost. This criterion has since been applied to
other standards set by EPA, including PAGs. Using our conclusion for
Principle 2 of 1 rem as the definition of "safe," under this criterion cost of
implementation cannot be used to justify a higher dose, but it can be used to
drive the risk to a lower value. Our analyses of cost of evacuation for several
combinations of reactor accident categories, meteorology, and evacuation
models indicates that the cost-effectiveness of avoiding the risk associated with
1 rem by evacuation is well within the range considered acceptable by the EPA,
but not so low as to warrant a further reduction in the PAG. Since power
reactors probably represent the worst case we can reasonably conjecture, we
take this as a general conclusion. Therefore, cost was not an influencing factor
in establishing the PAGs for the early phase.
c) Risk from the Protective Action
Principle 4 is simply an exercise in the application of common sense. It says
that one should never apply a protective action if the risk from the action itself
is greater than the risk that would be avoided.
In evaluating the risk from evacuation, the principle risk, for the average
member of the population under normal circumstances, is that from the
associated transportation. An additional potentially significant, but
unquantifiable, risk is the psychological risk from evacuation. However, this
risk may be offset by the psychological risk to those who would be concerned
about not being evacuated. The risk from transportation associated with
evacuation for ambulatory persons and under normal environmental conditions
was calculated to correspond to the risk associated with a dose of about 30
mrem. This is, of course, small compared to 1 rem. However, if evacuation
involves persons who are at much more than the normal risk from evacuation,
40
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or if the environment is more risky than normal, then evacuation at a dose of
1 rem could result in more risk from the evacuation itself than would be caused
by the radiation. To avoid this situation, sheltering provides an alternative to
evacuation. The PAGs provide for substituting evacuation, therefore, up to a
dose 5 times higher than the recommended level for evacuation under normal
circumstances for situations where evacuation carries a high risk. There may
be other reasons, such as physical constraints to evacuation, or special source
term characteristics that argue for sheltering. The new guidance also provides
that sheltering should be substituted for evacuation for any situation where
sheltering will provide equal or greater protection. But, caution is advised
regarding possible shelter failure mechanisms for situations where the projected
dose exceeds 10 times the PAG level for evacuation under normal
circumstances (1 rem).
TABLE 1
Principles for Establishing PAGs
1. Acute effects on health (those that would be observable within a short period of
time and which have a dose threshold below which such effects are not likely to
occur) should be avoided.
2. The risk of delayed effects on health (primarily cancer and genetic effects for
which linear nonthreshold relationships to dose are assumed) should not exceed
upper bounds that are judged to be adequately protective of public health under
emergency conditions, and are reasonably achievable.
3. PAGs should not be higher than justified on the basis of optimization of cost
and the collective risk of effects on health. That is, any reduction of risk to
public health achievable at acceptable cost should be carried out.
4. Regardless of the above principles, the risk to health from a protective action
should not itself exceed the risk to health from the dose that would be avoided.
PAGs Have Been Misinterpreted
An additional problem associated with the old PAGs for evacuation and sheltering was
their frequent misinterpretation with regard to whether evacuation was the protective action
of choice at 1 rem in the absence of other risk factors or constraints, or was only
recommended for consideration at this level. The intent of the guidance was that evacuation
was normally to be the protective action of choice at 1 rem, but some portions of the
published guidance on implementation were capable of multiple interpretations. This was
further complicated by the absence of a published rationale. Both of these problems have
been corrected in the revised guidance through detailed explanations and examples of the
41
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intended implementation of the PAGs, and by including background information on the
process used to develop them.
Implementation Guidance is Based on Postulated Source Terms
During the early phase of an incident when dose, or dose commitment, can be
accumulated rapidly, there is an urgent need to implement decisions for protective action
promptly. For reactor incidents, potential source terms have been defined for different
combinations of emergency plant conditions and meteorological conditions so that
recommendations for evacuation/sheltering can be made early for close-in populations, and
generally prior to a major release. The new guidance encourages this process for all fixed
nuclear facilities that require radiological emergency response plans.
a) Short-Term versus Long-Term Dose
Before getting into guidance on dose projection, I want to discuss a common
misunderstanding regarding the period of time over which dose is calculated to
evaluate risk of health effects. Since deterministic health effects occur within
a short time (usually within two months), dose received after this period is of
no importance for evaluating whether a threshold level of concern has been
exceeded. Therefore, dose calculations for these effects usually include only
prompt external exposure to plus the dose that would accumulate over about
30 days from long-term exposure pathways such as inhalation of particulate
materials. Some dose models calculate these short-term doses, and some
emergency planners make the mistake of comparing these doses to PAGs for
purposes of decisions on protective actions. However, the primary risk of
concern for PAGs is the risk of cancer, for which there is no threshold and for
which the risk continues to accrue from chronic doses received over many
years. Therefore, a dose model is required that takes these longer term doses
into account. In short, the dose of relevance is the entire committed dose, not
the annual, or any other shorter term dose.
b) Projection of Effective Dose
"Effective dose" is a new dose quantity for PAGs. This quantity allows us to
include all of the significant exposure pathways: direct gamma, inhalation, and
ground shine. The first two will generally predominate. The component from
ground shine may continue over many years, depending on the half life of the
deposited materials. However, since relocation PAGs may be implemented to
protect the public from long-term exposure to ground shine following
evacuation, the only dose from ground shine to be considered for decisions on
evacuation is the portion that would be accrued prior to the implementation of
relocation. Based on experience with exercises, we have concluded that 4 days
is sufficient time, in most cases, to collect sufficient information to implement
relocation, if necessary.
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Some concern has been expressed regarding the difficulty in calculating
effective dose, in comparison to calculating whole body dose, as required for the
current PAGs. In fact, it is no more difficult to calculate effective dose. It is
just a matter of using different dose conversion factors. Chapter Five of the
new guidance includes a single dose conversion factor for each of 141
radionuclides that can be used to calculate effective dose from the three
exposure pathways combined (plume shine, inhalation, and 4 days of ground
shine). These 141 dose factors should accommodate any reasonably conceivable
source term.
Application Experience
The revised PAGs for the early phase have been implemented successfully for some
special applications. The most notable were for the standby emergency responses for the
launch of Galileo and Ulysses spacecrafts, which carried large quantities of Pu-238 as an on-
board power source. In these cases, the limited road system was inadequate for timely
evacuation of the large temporary population that would be there to view the launch. For
this reason sheltering was considered and, since it provided the greatest exposure reduction,
and could be implemented within the guidelines, was the recommended protective action.
Another special application was developed for potential reentry into the atmosphere
over the United States land mass of Cosmos 1900 in 1988. This spacecraft was powered by
a fission reactor similar to one that crashed in a sparsely populated area of northern Canada
in 1978 and contaminated a large area with widely dispersed, highly radioactive, small "hot
particles." In preparation for possible similar consequences if Cosmos 1900 crashed in the
United States, it was necessary to develop procedures for monitoring and for calculating
projected dose from widely dispersed hot particles, so that the projected dose could be
compared to the PAGs for purposes of decisions on evacuation and relocation. These
procedures were on standby when reentry occurred (over the ocean, fortunately). These two
examples provide an indication that the new PAGs are flexible and that it is possible to
develop special implementation procedures for defined accident source terms and conditions.
In summary then, the new PAGs now apply to any source term, the dose units in
which they are expressed encompass all of the risk that may be avoided by the relevant
protective action, and the accompanying text has been clarified to provide more complete
guidance on the factors that should or should not influence the choice between evacuation
and sheltering.
I hope this discussion will be helpful to you in your workshop deliberations this
afternoon and tomorrow. I will be around if needed to further discuss any of these points,
as will Joe Logsdon who participated in development of the PAGs and the implementation
procedures.
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IMPLEMENTATION OF PROTECTIVE ACTION GUIDES
AT A LARGE PLUTONIUM PROCESSING FACILITY
Philip C. Nyberg
U.S. Environmental Protection Agency
Region VIII
Denver, Colorado
Introduction
The State of Colorado, with the assistance of the U.S. Department of Energy (DOE),
has developed a Radiological Emergency Response Plan for the DOE Rocky Flats Plant.
Several serious accidents at the plant in the past caused the Governor of Colorado to require
an emergency response plan equivalent to that required for a commercial nuclear power
plant. That planning process began in 1977 and has continued to the present. The planning
basis since 1980 has been the maximum credible accident (MCA), which was defined for the
plant as the maximum airborne release of plutonium which could occur with a frequency of
more than once in ten million years. The State chose to use the MCA as the bounding
accident for planning purposec, although it acknowledges that this is different than the
planning basis currently required by the Nuclear Regulatory Commission (NRC) for
commercial nuclear power reactors. The State developed protective action guides (PAGs)
based on the Environmental Protection Agency (EPA) guidance available in 1980 as well as
other information relevant to limiting lung dose, believed to be the most serious hazard for
an airborne release of plutonium particles. A review of the MCA and the emergency
planning zones (EPZs) for the plant was initiated in 1988 and continues to the present.
Phase II of that effort, the development of information to assist the State in revising its plan
on an interim basis, was recently completed. The observations in this paper are drawn from
the Phase II EPZ Project.
The Rocky Flats Plant is a major plutonium processing and fabrication facility owned
by DOE and located on 384 acres of land about 16 miles from downtown Denver, Colorado,
as shown in Figure 1. The facility itself is centered within a 6,550-acre buffer zone which
extends to a radius of roughly 2 miles from the center of the plant site in all directions.
EPZs have been established, and federal, state and local agencies have participated in
exercises which have tested the efficacy of the offsite emergency plan.
Changes in the operations at the plant, particularly the cessation of transuranic
radioactive waste shipments, caused the Governor of Colorado in 1988 to request a review
of the plan to assure its continued validity in the face of increasing waste volumes stored on
the site. DOE committed its operating contractor, then Rockwell International and now
EG&G/Rocky Flats, Inc., to provide Task Teams that would develop the necessary technical
information to validate the MCA and to update and improve the emergency plan. That
45
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information would be reviewed and evaluated by an oversight committee consisting of
representatives from the Colorado Division of Disaster and Emergency Services (DODES),
the Colorado Department of Health (CDH), DOE (Rocky Flats Area Office), and EPA (Region
VIII Office).
Recognizing the magnitude of the task, it was decided to divide it into four time-
sequenced phases, each of which would provide the State with a summary of the technical
information developed in that phase. Phase I was a revalidation of the MCA, while Phase
II was an interim analysis of the EPZs for a radiological accident. Phases III and IV would
develop more complete information on a spectrum of radiological and non-radioactive
hazardous material accidents. The activities of Phase II form the basis for this paper.
Background
According to A.J. Hazle (Ref. 1), Colorado has used a MCA as its bounding accident
for planning purposes. The assumption is that, by basing its plan on such a relatively
improbable event, the State would be prepared to handle more probable but less severe
events as well. It was not considered a prudent expenditure of State funds to develop a plan
for more severe, less probable accidents, although the current plan certainly provides a
sound basis for response in that unlikely event.
The MCA currently defined for the plant is the airborne release of 100 grams of
plutonium (primarily Pu-239, -240 with some Am-241 ingrowth). The scenario developed
in the Rocky Flats Plant Final Environmental Impact Statement (Ref. 2) was that of a large
airliner crashing into a plutonium production building, with the resultant penetration of the
building and jet-fueled fire providing the mechanism and driving energy for the release.
Release fractions for burning plutonium were taken from the available literature, and worst-
case meteorological conditions were assumed to maximize the off-site impact in the FEIS
analysis.
When the current emergency plan was developed in 1977-80, the State considered the
then-available EPA PAGs to be only partially appropriate for the Rocky Flats situation, as
they recommended action based on either whole body or thyroid radiation dose. The doses
expected from the Rocky Flats MCA would come primarily from inhalation of airborne
plutonium particles. This would result in a dose to the lung that would have a relatively
long commitment period because of the long half life of plutonium and its relative immobility
when deposited in the lung (although the doses to the liver and gonads were also
considered). The State chose to use the recommendations of the British Medical Research
Council (Ref. 3) to take protective action to avoid doses exceeding twice the maximum
permissible annual dose for radiation workers. By the standards of the day, this PAG
translated to a projected lung dose of 30 rem, a bone dose of 10 rem, and a gonadal dose of
5 rem. Calculations quickly revealed that the lung dose would be the controlling factor, i.e.,
if the lung dose were maintained below the guideline, the other doses would also be well
below their respective guides as well.
Using the expected worst-case meteorology, dose versus distance curves were
developed for an airborne release of 100 grams of plutonium, and three zones were defined
46
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corresponding to the EPA Category I, II, and III protective actions. They were: Category I,
projected dose greater than 30 rem (lung), consider evacuation/sheltering; Category II,
projected dose between 6 and 30 rem (lung), sheltering; and Category III, projected dose less
than 6 rem (lung), confirmatory sampling. The corresponding distances were 0 to 4 miles,
4 to 10 miles, and greater than 10 miles, as illustrated in Figure 1.
1988 Phase II Review
The current review, begun in late 1988, was conducted to ensure that the
accumulation of transuranic waste at the Rocky Flats Plant had not created a situation in
which the assumed MCA, i.e., the "credible" release of 100 grams of plutonium, could be
exceeded, and to update and revise the existing EPZs by considering more recent
developments in dosimetry and PAGs.
Dosimetry
Consistent with the recommendations in the International Commission on
Radiological Protection (ICRP) Publications 26 and 30 (Ref. 4 and 5), the State had
decided at the outset to use the "committed effective dose equivalent" concept as its
primary measure of radiation risk. This necessitated substantial changes from the
"organ dose" concept employed in the existing plan. Furthermore, the previous dose
calculations had been based on an assumed particle size distribution of 0.3 /xm
(AMAD: activity median aerodynamic diameter) and a dose commitment period of 70
years. For consistency with national and international practice, it was agreed to
change the assumptions to a particle size distribution of 1 ptm (AMAD) and a dose
commitment period of 50 years in the Phase II revision.
Protective Action Guides
PAGs are recommended levels of projected radiation dose at which actions to
protect the public should be taken following an accident at a nuclear facility involving
an actual or potential release of radioactive material. They are response guidelines,
rather than mandatory levels at which actions must be taken. State or local
government agencies may take actions at other projected doses or based upon
conditions at the facility. They may also refrain from taking protective action if that
action would result in a higher immediate risk to the public than the radiation risk
avoided by the action.
PAGs have been issued by the EPA (Ref. 6 and 7) for the United States, and
the ICRP has provided similar guidance internationally (Ref. 8). These two groups
espouse similar, though not identical, principles for their recommendations, and the
action levels are somewhat different. EPA recommendations are given in Table 1
while ICRP recommendations are given in Table 2. In reviewing the use of PAGs
world wide, the task team found significant variations among facilities, states, and
countries. The EPA recommendations employ the lowest action levels in common use,
and are presented in units of "committed effective dose equivalent" (CEDE). The
ICRP action levels are somewhat greater, and there is some ambiguity concerning
47
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which dosimetry units are intended. The task team noted five possible PAG options
for the State's consideration, including:
* EPA PAGs, December 1990 draft
* EPA PAGs, 1980 (revised 1988) draft
* ICRP Publication 40 PAGs
Modify current State PAGs for the Rocky Flats Plant to incorporate CEDE
Develop new PAGs specifically for this site
TABLE 1
EPA PAGs FOR THE EARLY PHASE OF A NUCLEAR INCIDENT
*
*
Protective Action
PAG (Projected Dose)
Comments
Evacuation (or sheltering8)
1-5 remb
Evacuation (or, for some
situations, sheltering8)
should normally be
initiated at 1 rem. For
further guidance, see Ref.
7.
Administration of
Stable Iodine
25 remc
Requires approval of State
Medical Officials.
"Sheltering may be the preferred protective action when it will provide protection equal to or greater than
evacuation, based on consideration of factors such as source term characteristics, and temporal or other
site-specific conditions.
bThe sum of the effective dose equivalent resulting from exposure to external sources and the committed
effective dose equivalent incurred from all significant inhalation pathways during the early phase.
Committed dose equivalents to the thyroid and to the skin may be 5 and 50 times larger, respectively.
""Committed dose equivalent to the thyroid from radioiodine.
Emergency Planning Zones
EPZs are areas surrounding a nuclear facility within which local and state
authorities have developed specific plans to protect the public in the event of an actual
or potential release of radioactivity at that facility. For nuclear power reactors, the
two zones are areas within a 10-mile radius of the plant (of greatest concern during
the early phase of an accident) and areas from 10 to 50 miles in radial distance (of
concern in the intermediate and late phases of an accident). At Rocky Flats, there are
effectively three zones as previously indicated, differentiated by the maximum
expected dose and type of protective action. These zones were originally defined by
projected doses relative to the PAGs at various distances resulting from the MCA.
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TABLE 2
ICRP GUIDANCE ON INTERVENTION LEVELS
Critical Organ Dose Equivalent (rem)
Countermeasure
Sheltering and Stable
Iodine Administration
upper dose level
lower dose level
Evacuation
upper dose level
lower dose level
Control of Foodstuffs
upper dose limit
lower dose limit
Relocation
upper dose limit
lower dose limit
Whole Body
5
0.5
50
5
50
5
50
5
Individual Organ
(including lung & thyroid)
50
5
500
50
50
5
Not Anticipated
(Extracted from ICRP Publication 40 (Ref. 8), Tables Cl and C2)
Current thinking at both EPA and NRC disavows such a specific linkage
between EPZs and PAGs. Both agencies agree that EPZs should be large enough to
include all areas where the MCA might cause exposures sufficient to produce acute
health effects, and also large enough to provide an adequate planning area for
implementing the PAGs (plus a basis for expansion if doses are predicted to exceed
the PAGs beyond the EPZ). The dilemma at Rocky Flats, as well as many other non-
reactor nuclear facilities, is defining an EPZ large enough for protection and small
enough for effective planning.
The distance from the plant to which a PAG would be exceeded in the event of
a MCA is an important component of EPZ development. This protective action
distance can be determined by comparing the dose versus distance relationship
calculated for the MCA and some assumed meteorology to PAG thresholds. This
distance can be highly variable, however, depending upon the selected wind speed and
atmospheric stability. In the case of Rocky Flats, several years of meteorological
observations are available from which to characterize these parameters in terms of
their probability of occurrence, although only one year was used in this analysis in
order to comply with strict data quality guidelines.
Three annual meteorological probabilities were chosen as illustrative of the
complete distribution. The median meteorology was chosen to represent "typical"
49
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conditions at the plant, reflecting an annual meteorological probability of 0.5 (50% of
the time it would be more favorable, 50% less favorable). A meteorological probability
of 0.05 was chosen to represent the "worst case" - the level used in previous analyses
at the Rocky Flats Plant. This level implies that only 5% of the time in one year
would the conditions be less favorable than this. The third meteorological probability
chosen for illustration was 0.005, corresponding to the "extreme worst case" conditions
defined in NRG Regulatory Guide 1.145 (Ref. 9). This implies that only 0.5% of the
time in one year would conditions be less favorable than this.
Figure 2 illustrates the effect of increasingly conservative meteorological
assumptions on the distance at which any given PAG would be exceeded for the
assumed MCA at the Rocky Flats Plant. For example, for the same accident scenario,
a dose of 1 rem might be exceeded at distances ranging from less than 6 to greater
than 80 kilometers (less than 4 to greater than 50 miles), depending on the chosen
meteorology. What is an appropriate assumption in this case? As a guide, it may be
appropriate to remember the compounding of probabilities. If the MCA has a
probability of one in ten million (1 x 10"7) per year, then the probability of achieving
the dose-distance curve from the median meteorology is the product of the two
probabilities, or 5 x 10"8 per year. Similarly, the probability of achieving the extreme
worst case curve is 5 x 10"10 per year. Is it appropriate to utilize such extremely small
probabilities in the emergency planning process? This is less a technical than a policy
question for the particular planning agency.
Summary
A technical review of the information needed by the Colorado emergency planning
agency to revise and update the radiological emergency response plan for the DOE Rocky
Flats Plant was conducted by a multi-agency oversight committee. This information may
be used by the State to redefine the EPZs. The choice of PAGs plays an important but not
definitive role in determining the most appropriate EPZ boundaries. The assumptions
underlying the MCA, the meteorological probability, and several other factors will also affect
the EPZ determination. Future activities contemplated for this project include investigation
of more realistic meteorological models than the straight-line Gaussian model used in this
analysis, analysis of a spectrum of possible accident probabilities and outcomes, and the
incorporation of procedures for coping with non-radioactive hazardous material accidents
which could have off-site consequences.
Acknowledgements
The effort described above is not mine but is the combined achievement of many
individuals working together often under difficult circumstances and with short deadlines.
Special acknowledgements go to the PAG Task Team, and to the entire Oversight
Committee, who have furthered my education in the emergency planning process.
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FIGURE 1
U.S. DOE Rocky Flats Plant and Vicinity
Approximate Boundaries for Colorado Emergency Response Plan
and "Area of Concern for Housing"
Adapted by EPA Region VIII Radiation Program - Revised 1985
PLUTONIUM - 239
CONTOURS (mC/km2)
GRAPHIC SCALE
(MILES)
Adapted from P.W, Krey and E.P. Hardy, Plutonium in soil around the Rocky Flats Plant, US AEC
Report HASL-23S, (1970)
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FIGURE 2
NRG Guide 1.145 Dose Calculations
PROJECTED
DOSE (RE|V], CEDE)
2
o Q
O
GO COZ>
mnjr
m
x
HO
m-
2;
o
CO
CO
m
r\:
o
CD
52
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REFERENCES
1. Personal communication, A.J. Hazle (Colorado Department of Health), March 25,
1991.
2. U.S. Department of Energy, Final Environmental Impact Statement for the Rocky
Flats Plant Site, DOE/EIS-0064 (3 volumes), April 1980.
3. United Kingdom Medical Research Council, Criteria for Controlling Radiation Doses
to the Public After Accidental Escape of Radioactive Material, HMSO, London
(England), 1975.
4. International Commission on Radiological Protection, Recommendations of the
International Commission on Radiological Protection, ICRP Publication 26, Pergamon
Press, Oxford (England), 1977.
5. International Commission on Radiological Protection, Limits for Intakes of
Radionuclides by Workers, ICRP Publication 30, Pergamon Press, Oxford (England),
1978.
6. U.S. Environmental Protection Agency, Manual of Protective Action Guides and
Protective Actions for Nuclear Incidents, EPA 520/1-75-001, Draft 1975, Revised 1988.
7. U.S. Environmental Protection Agency, Manual of Protective Action Guides and
Protective Actions for Nuclear Incidents, EPA 520/1-75-001, Revised 1991.
8. International Commission on Radiological Protection, Protection of the Public in the
Event of Major Radiation Accidents: Principles for Planning, ICRP Publication 40,
Pergamon Press, Oxford (England), 1984.
9. U.S. Nuclear Regulatory Commission, Atmospheric Dispersion Models For Potential
Accident Consequence Assessments at Nuclear Power Plants, Revision 1, Regulatory
Guide 1.145, February 1983.
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MIXED HAZARD INCIDENTS
(CHEMICAL/NUCLEAR INCIDENTS)
William Klutz
OSWER
U.S. Environmental Protection Agency
Region IV
Atlanta, Georgia
Emergency Response Capabilities to an Incident Involving Radioactive Materials
or Mixed Hazardous and Radioactive Materials
Emergency response to a release of radiation or a release of hazardous and radioactive
materials will be the responsibility of the Environmental Protection Agency (EPA) Region
IV, Emergency Response and Removal Branch. This Branch maintains a 24-hour duty
officer who will receive the information directly and will determine whether the Regional
first responder, an On-Scene Coordinator (OSC), should respond to the release. EPA
receives notifications through the National Response Center (NRC) in Washington D.C.,
which is the national clearinghouse for reporting spills or releases of CERCLA 101 listed
hazardous substances or the releases of oil. The listed hazardous substances includes
hazardous waste, hazardous air pollutants, hazardous substances, and the Title III list of
extremely hazardous substances as well as all radionuclides. All of the hazardous substances
have an associated reportable quantities, which is the minimum quantity which determines
whether the spill must be reported to either EPA or the Nuclear Regulatory Commission
(NRC). The reportable quantities are reported in pounds for hazardous substances and in
curies for radioactive materials.
After notification of a spill or release, the regional duty officer assesses the quantity
and hazard, and then determines whether to send an EPA OSC, or to utilize the capabilities
of our Technical Assistance Team (TAT) contractor, or in the case of major spills, both EPA
and TAT. Response to a spill of radioactive or mixed material would, at a minimum, require
the use of TAT for immediate monitoring for radiation. If additional radiation monitoring
is necessary or an extensive cleanup was required, the OSC has the capability and
contracting authority to utilize the Emergency Response Contract Services (ERGS)
contractor to perform a cleanup. Through either TAT or ERGS contractor, specialty
contractors for radiation monitoring, health physics and radioactive materials emergency
response cleanup could be obtained within 24 hours in an extreme emergency. In the case
where a viable responsible party is present, EPA OSC has the authority to issue immediate
cleanup orders.
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Region IV has used the services of Chem-Nuclear, Westinghouse, and Numanco as
subcontractors on removal actions which involved the removal or stabilization of radioactive
or mixed waste. Through TAT, EPA could procure all the necessary laboratory services for
both mixed waste or radioactive materials. The capability of EPA to respond is also
enhanced by being able to use the services of the EPA Emergency Response Team (ERT) and
its contractor services. The ERT has the capability for radiation monitoring or would be
able to procure specialized equipment.
In addition to the ability to procure contractor services, Region TV has a mobile
command post, satellite and cellular communications capabilities, which can be mobilized
immediately. We also have the ability to use the services of the U. S. Coast Guard Strike
Team and all of their resources, including level A personnel protection.
EPA Region IV OSC has the ability to procure up to $50,000 on-scene during an
emergency. If additional funds are necessary for a response action, the regional contracting
officer could approve an additional $200,000, and in the case of a catastrophic release up to
$2,000,000 in funds could be made available.
In summary, in the case of a radioactive or mixed waste release, EPA Region IV or
any Region could and would have the necessary funds, equipment and necessary personnel
on-scene within minimal time. We would have available the latest in communication
equipment, monitoring equipment and would be able to procure any needed specialty
services or equipment.
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ARKANSAS' TITAN II EXPERIENCE
Bernard Bevill
Nuclear and Environmental Safety Section
Division of Radiation Control and Emergency Management
Department of Health
Little Rock, Arkansas
Introduction
A Flash....a deafening Blast ushered in a dawn of a new Day. The unplanned, the
unthinkable, the IMPOSSIBLE had occurred. An American nuclear warhead had been
propelled from an underground missile silo. Its final target was not a Russian city or a
Soviet military complex thousands of miles away. It was on American soil within 1000 feet
from its Titan II silo. As the warhead lay near the edge of the silo complex grounds in the
dark of the early morning, state and local government officials were also in the dark. Due
to U.S. Air Force policy, the existence of this nuclear device and its final destination could
not be discussed with civilians. This, of course, lead to political and public relation
nightmares for all. Without adequate coordination with the Department of Defense (DOD),
state and local governments each worked separately. In some cases, alarming false data
surfaced, creating panic among our major administrators. I will in my talk today:
* Review the specific details of this Titan II missile incident near
Damascus, Arkansas, and
* Discuss an overview of activities that came after this incident to
better protect the health and safety of the citizens.
Background
In 1980, the American land based Intercontinental Ballistic Missile (ICBM) nuclear
arsenal consisted of 1000, what was then considered, "Modern" Minuteman missiles and a
few aged Titan II missiles. At that time, 54 Titans were sited in underground silos within
Arkansas, Kansas, and Arizona.
As their name implied these were large missiles capable of delivering large megaton
warheads. (In fact, these 54 made % of the land based U.S. megatonage). They had been
deployed in 1963. Seventeen years later their existence may have been poker chips in the
Arms reduction game.
These "geriatric giants" began to create problems for the Air Force in the field. As
they aged, liquid fuel leakage problems became more numerous, dangerous and on occasion
fatal. Between 1975 and 1980, 125 leaks had been reported with the Titans. In 1978, two
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leaks had occurred where two airmen had been killed. Another 29 were injured.
One such Titan II missile and its nine megaton thermonuclear warhead was sited in
a 146 foot underground silo near Damascus, Arkansas. This is a small town approximately
60 miles north - northeast of Little Rock. Two years earlier (in 1978) problems with leakage
at the silo had occurred. Liquid vapors had leaked into the air and seven people from the
Damascus area required hospitalization.
The Incident
On Thursday, September 18, 1980, routine maintenance was being performed on the
103 foot Titan missile. An Air Force technician dropped a 3 pound wrench socket. After
falling 70 feet it punctured the first stage fuel tank (The missile's skin was thin.). Fuel
(Aerozine-5O) vapors began to escape. The workmen evacuated the silo.
The automatic sprinkler system was activated once a fire had started. With 100,000
gallons of water the fire was put out. Yet, the leak continued. Vapor concentrations
continued to rise. A two mile evacuation was ordered by the missile crew on site.
Approximately 6Vz hours after the initial accident a two member emergency team
entered the silo's access chamber to plug the leak. They found at that time vapor
concentrations were continuing to increase. As these concentrations increased so did the
probability of spontaneous combustion. Just as the team was leaving the access chamber
the vapor, and air mixture exploded. This ignited the remaining fuel. The 750 ton concrete
roof was demolished. It was hurled across the country side as aluminum foil discarded from
the weekend picnic. The nine megaton warhead was catapulted out of the silo approximately
200 yards.
One airman died of chemical pneumonia from inhaling fumes. Another was critically
injured. Twenty more were hurt. Approximately 1,400 people were evacuated from the area.
ADH's Response
In September 1980, the Department's Division of Environmental Health Protection
(now named Division of Radiation Control and Emergency Management) had a hazardous
Chemical Response group. This section was staffed with chemists who responded to a wide
range of hazardous material mishaps within the State of Arkansas. A variety of chemical
test equipment could be taken on to a Hazmat scene and preliminary measurements could
be made to assess the impact of the incident.
On Thursday September 18, 1980, at approximately 8 p.m., our director, E.F. (Frank)
Wilson, received notification that there was a fire at the missile silo complex near Damascus.
The supervisor of our Hazardous Material Chemists was contacted and instructed to
obtain test equipment and proceed to the missile complex. At the same time, the
Department's Mobile Command Headquarters was activated.
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This Mobile Command Post is a refurbished Kentucky trailer that years earlier had
been used as an x-ray van for the Tuberculous Examination Program. At that time, it was
pulled by a two-ton Dodge tractor.
Mr. Wilson arrived on the scene at 10:30 p.m. Upon arrival, he was briefed by the
local Office of Emergency Services (OES) coordinator who informed him that there was no
fire in the complex. However, there was a leak.
At 12:15 a.m., on the next morning (September 19) our Field Headquarters van
arrived on the scene. A briefing was provided. Then, the normal routine long wait as with
many responses began. But, at 3:01 a.m., the normal waiting was interrupted by the
explosion.
In world class speed and with physical feats of herculean magnitude, the mobile van
was loaded up. The Department personnel jumped in the Dodge tractor and their personal
vehicles. They floorboarded the accelerators. A mad dash similar to the land rush in the
movie "Oklahoma" was in progress. We were racing away from the site following blue Air
Force pickup trucks.
Minutes and miles later contact with our director was made. The van was directed
to go to Damascus. Meanwhile, Mr. Wilson went to the State Emergency Operations Center
in Conway, Arkansas (30 miles northwest of Little Rock). Notification of our Medical
Director, other state officials and our emergency radiation monitoring teams (Health
Physicists (HP)) were made.
By 6 a.m., our HP teams had arrived in Conway. One team was directed to go to the
Conway Memorial Hospital to monitor the Air Force personnel being treated for burns and
wounds. No alpha contamination was detected.
At 6:30 a.m., Mr. Wilson contacted the Department of Energy (DOE) to activate the
IRAP team. He was informed that the Air Force had already alerted the system via another
method. Since the Air Force had alerted them they could not respond to the Arkansas
request. However, later that day they did.
Mr. Wilson was referred to the Albuquerque Operations Office for further information.
Upon contact with that Operations Office, we were informed that a DOE team had
been initiated. From these discussions, it was indicated that the high explosives had gone
off or burned in a reported mushroom shaped cloud. It was thought that it was possible that
the warhead could be involved. The area should be monitored. (Keep in mind that at this
time the Air Force was not talking to civilians about this incident. Thus, we were in a near
vacuum desperate for any information).
By 7 a.m., two ADH monitoring teams were dispatched to the Damascus area.
One team was deployed to a paved county road a few miles west of the silo. While
traveling down the road one of the novice HP's stuck his Eberline alpha probe out of the
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window of the vehicle. Due to internal instrument noise and perhaps faulty connections a
reading was obtained. Before followup readings and a plausible explanation could be made,
the erroneous reading was called in.
A pound of lead sunk through the GI tract of those within the State Emergency
Operations Center. (This report became one of our Medical Health Officer's most
unforgettable moments in his brief career with the Department).
The other HP team was quickly deployed to this area. Both teams were able to
confirm the existence of no alpha contamination. The EOC staff was informed of these
findings. Relieved, this staff was able to coordinate activities between the various state
agencies, answer questions and talk on the telephone.
Around 11:30 a.m., members of the DOE IRAP team arrived. They toured the area
around the silo. By early afternoon it was apparent that the Air Force had found their
wayward child and had safely secured it. No alpha contamination had been detected.
Finally, we were stationed at the missile complex gate. The remainder of the
afternoon was spent standing and sitting in the late summer sun discussing the days events,
speculating and watching a wide variety of military helicopters fly over.
By 5 p.m., we were sent back to our duty stations in Little Rock. Meanwhile,
Damascus, Arkansas enjoyed it's brief moment of fame as the lead-in story for all the major
networks and print media.
The Aftermath
From this Titan experience a new Dawn was figuratively ushered in. Better
communications between the Military (DOD), and the state and local government was
established.
From the standpoint of relationships between Arkansas officials and DOD, it was a
major catalyst in the Titan program. The following were results of this event:
* A Memorandum of Understanding between the U.S. Air Force and
the State of Arkansas was negotiated.
* Detailed emergency plans were developed.
* Canister masks could be made available for personnel protection.
* Periodic exercises of the Emergency Plans were performed with
the Air Force.
State agencies were kept informed of movement of missile propellants. This was
especially true as the Titan IPs were phased out within the next 6 years.
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Lessons Learned
Of course, many lessons were learned.
* First we must continually realize that the unplanned, the
unthinkable and even the impossible can and will occur. Our
mode of thinking must not rule these out. Here, we do not
necessarily have to plan for the possibility of every potential
event. Yet, our response policies and procedures must not be
rigid. Flexibility must be the standing order of the day.
* Adequate monitoring equipment must be available. After this
event, the Division was able to vastly update and upgrade it's
radiation detection equipment inventory.
* Adequate staff training must also be provided. A routine training
program was established. Both in-house and outside training is
now provided to our staff. Even today, various survey equipment
and techniques not normally encountered are covered in the rare
event they must be employed.
Conclusions
Today, I have reviewed with you what I hope was a very interesting chapter in
American Emergency Response history. Hopefully, we have gleaned lessons as to how we
may respond to the unplanned. The need for communication between DOD and the state
and local officials can not be over emphasized.
I believe that this workshop is a giant step toward a mutual working partnership.
I will be glad to answer any questions.
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REVIEW ON THE BASIS OF GUIDANCE FOR SHELTERING AS A
PROTECTIVE ACTION IN A PLUTONIUM RELEASE ACCIDENT
Bradley Nelson
Office of Radiation Programs
U.S. Environmental Protection Agency
Washington, B.C.
Introduction
Hazard
Briefly, I'll review the hazard from plutonium. For Pu-239, inhalation of
contamination in a cloud gives a dose of 5.2 x 108 rem per jiCi cm"3 h. Ground shine
from deposited contamination is 1.5 x 10°, and direct skin exposure from immersion
in a cloud is 4.7 x 102. Clearly, inhalation is the pathway of concern.1
Air Exchange
Protective action is based on the inhalation pathway. Evacuation removes the public
from the plume, breathing uncontaminated air at another location. Sheltering keeps
the public indoors breathing air which does not reach equilibrium with the plume.
In this discussion shelter means any building: a home, a school, a factory, an office
building, a hospital, or any other building of opportunity. The discussion is weighted
toward homes because, on average, only 40 hours of a 168 hour week are spent at
work. The effectiveness of a shelter is a function of the number of exchanges of clean
inside air with contaminated outside air. Shelter, in this case, is unrelated to
shielding. Please note that this is very different than Civil Defense (CD) fallout
sheltering. Shelter here means air-tight.
Three Areas of Consideration
The number of contaminated air exchanges depends on three things: (1) the tightness
or air exchange rate of the shelter, (2) the nature of the plume at the shelter, and
(3) the understanding of the public in sheltering techniques.
Tightness of the Shelter
Typical Exchange Rates
Typical air exchange rates vary from 0.07 to 4.0 complete air changes per hour.2 Even
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for a specific building, air exchange rate or tightness varies with a number of factors,
one of the largest being the weather.
Weather Variance
Indoor/outdoor temperature differences cause density differences which cause pressure
differences that drive infiltration.3 Wind also causes a driving pressure that produces
natural ventilation.4 Exchange rate more than doubles for a doubling of wind speed
above 6 mph.
Figures 1 and 2 show comparable wind driven and temperature driven infiltration
rates. One graph shows a "tight" house and the other shows a "loose" house.
Filtration
Air infiltrates through open windows and doors, cracks, and directly through solid
walls. These pathways essentially do not filter the incoming air. An entrained 2 ym
particle of plutonium will not be removed.5
Dose Reduction Factor (DRF) is the ratio of the time-integrated concentration of
contaminants inside the shelter to that outdoors. This means that a DRF close to
zero is desired and that a DRF of 1.0 offers no protection. The graph of the DRF of
a shelter immersed in a plume takes the form of 1 - e"m. This is shown in Figure 3.
Some buildings draw in outside air directly and filter it as it comes in, other buildings
filter recirculating air, and some do neither. If air is filtered at any step of the
process, the equilibrium contamination ratio of indoor to outdoor air will be less than
one.
The types of heating and cooling systems also affect the tightness of the building. For
instance a radiant heating system such as hydronic will affect infiltration differently
than a forced air system. A combustion based heating system will cause more
infiltration than an electric based system. An air conditioning system which uses
evaporative coolers rather than refrigerant coolers may have an indoor/outdoor
equilibrium contamination ratio of greater than one.6
Overall Estimate
There really is not a good ballpark number to use for air-exchange rate or DRF in an
emergency. If sheltering is to be considered as a protective action, emergency
response plans must evaluate buildings on a case-by-case basis. In very general terms,
modern homes built since the energy-conscious mid 70's seem to offer the most
protection. Industrial buildings offer the least protection and other buildings fall
somewhere in between. Again, for any real sense of sheltering effectiveness, specific
buildings in the area must be evaluated in advance.
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Plume Considerations
Duration
The nature of the plume itself also obviously affects indoor air contamination
concentration. For a long duration release, a shelter's indoor air contamination
concentration value will more closely approach equilibrium. A shelter subject to five
air changes inside the plume has nearly achieved equilibrium. Based on a range of
0.07 - 4.0 air changes per hour this is anywhere from 1.25 to 71 hours. The
Environmental Protection Agency (EPA) guidance on implementing Protective Action
Guides (PAGs) is that sheltering is usually not appropriate for exposure lasting more
than two air exchanges of the shelter.7 This translates to 1/2 to 29 hours.
Concentration
The shelter's location in the plume is a self evident concern. What is the
concentration? Is it low enough that the increment of protection afforded by
sheltering reduces projected concentration below the PAG Derived Response Levels?
Sheltering Technique
Sealing the Shelter
The third area of concern is public understanding. A shelter is a device which must
be operated properly to be effective.
Ventilation must be secured. Heating and air conditioning (HAG) in general is worth
0.33 +_ 0.37 air changes per hour.8 Note that Figures 1 and 2 are given with the
assumption that HAC is turned off.
Operation of kitchen and bathroom exhaust fans will also increase infiltration by the
amount of air being exhausted. This makes sense intuitively. If air is being removed
from the house at one point, then air must be coming into the house at another.
Otherwise the exhaust fans would draw a vacuum on the house and a person's ears
would pop as they walked outside (or they would pass out as all the air was removed
from the house.) Attic fans also greatly increase infiltration by creating pressure
differences. See Figure 4.
Post Plume Ventilation
Not to be overlooked is the dose received from contaminated air trapped indoors after
the plume has passed. A shelter must be aired-out. Otherwise, the indoor
contamination concentration will be an exponential die-off (e"8*) based on the same air
exchange rate.
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Summary
Highlights have been presented here. For planning purposes, thorough discussions
should be consulted in the EPA PAG Manual, Chapter 5 and the Department of
Energy (DOE) publication Effectiveness of Sheltering in Buildings and Vehicles for
Plutonium DOE/EH-0159T UC-160. Experienced Heating, Ventilation and Air
Conditioning (HVAC) engineers familiar with American Society of Heating,
Refrigeration, and Air Conditioning Engineers (ASHRAE) Fundamentals and local
building customs should be consulted about building tightness and infiltration.
CD sheltering considerations are very different than those presented here. Reliance
on CD plans and techniques could very well be worse than useless in a plutonium
release accident.
Three Areas of Concern
In a plutonium release accident, sheltering does provide some protection for the
airborne pathway, the pathway of concern. To rely on sheltering as a protective
action, three major considerations must be evaluated in advance: 1) air-tightness of
available shelters, 2) duration and concentration of the plume, and 3) public
understanding of sheltering technique.
U.S Environmental Protection Agency (EPA); Manual of Protective Actions for Nuclear
Incidents. Draft. Tables 5-3, 5-4, and 5-5; 1991.
2Engelmann, R.; Effectiveness of Sheltering in Buildings and Vehicles for Plutonium.
DOE/EH-0159T UC-160. U.S. Department of Energy (DOE), p.23; 1990.
3American Society of Heating, Refrigeration, and Air Conditioning Engineers (ASHRAE);
Fundamentals, p.22-3; 1985.
4Ibid., p.22.2.
5Engelmann; p.8.
6Ibid., p.9.
7EPA; p.5-29.
8Engelmann; p.26.
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HELTERING CONSIDERATION:
1. Building Tightness
2. Plume Concentration and
Duration
3. Sheltering Technique
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o
h-t
fa
00
CD
6
* 10 12
WIND (MPH)
14
18
Fig. l Exchange rate for closed homes of modern construction
and good insulation, with furnace and fans off. The number of
air exchanges per hour are presented as a function of the indoor-
outdoor temperature difference and the wind speed.
-------
o
20 -
10
o
M
to
8 10 12
WIND (MPH)
Fig. 2 Exchange rate for closed homes of older construction and
poor insulation with furnace and fans off. The number of air
exchanges per hour are presented as a function of the indoor-
outdoor temperature difference and the wind speed.
-------
1.0
0.8
(fR/R*)=l/0=1.0
1
2
3
4
5
R*T
6
7
8
9
Fig. 3 The Dose Reduction Factor (DRF) as a function of the air
exchange rate, R, time, T, fraction of the contaminant that pene-
trates the shelter's structure, f, and the virtual air exchange
rate, R . At large values of R T, the DRF approaches the equi-
librium ratio of indoor and outdoor concentrations, I/O.
-------
FIGURE 4
d
* 0
d
0
o
0
» L° v 0 G A °
0
S 0
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SUBMITTED PAPERS
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LESSONS LEARNED
BY THE ILLINOIS DEPARTMENT OF NUCLEAR SAFETY
FROM PARTICIPATION IN FFE-2
Gary N. Wright, Roy R. Wight and Charles W. Miller
Illinois Department of Nuclear Safety
Springfield, Illinois
The second Federal Radiological Emergency Response Plan (FRERP) (Ref. 1) Federal
Field Exercise (FFE-2) was conducted June 23-25, 1987, at the Commonwealth Edison
Company's (CECo) Zion Nuclear Power Station (NFS) in Zion, Illinois. The first day of this
three-day exercise was the biennial regulatory exercise involving CECo, the States of Illinois
and Wisconsin, the U.S. Nuclear Regulatory Commission (NRC), and Lake (IL) and Kenosha
(WI) counties. On the second day, these participants were joined by the Federal Emergency
Management Agency (FEMA), the U.S. Department of Energy (DOE), the U.S.
Environmental Protection Agency (EPA), and other Federal agencies. The time line of the
exercise was advanced seven days at the end of day two, so that day three of the exercise
corresponded to day ten of the simulated accident. Altogether, over 1,000 players at 30
different locations and over 150 controller/evaluators took part in FFE-2. In addition, there
were 130 foreign visitors from 17 countries, and 126 official U.S. visitors who visited the
exercise emergency response facilities in the Zion area.
The Illinois Department of Nuclear Safety (IDNS) played a key role in FFE-2. Under
the Illinois Plan for Radiological Accidents (IPRA), IDNS is responsible for providing
technical support for emergency response activities in the event of a nuclear power plant
accident in the State of Illinois. During FFE-2, IDNS activated approximately 100 persons
during day one, and then maintained the level of activity in cooperation with Federal
personnel during days two and three. IDNS shifted its primary technical functions from
Springfield on day one to the Federal Radiological Monitoring and Assessment Center
(FRMAC) for days two and three. IDNS also participated in the management leadership of
the FRMAC to ensure that it supported the needs of the states.
All agencies involved in FFE-2 learned many valuable lessons as a result of their
participation in this exercise. The purpose of this paper is to present some of the major
lessons learned by IDNS as a result of participating in FFE-2.
The lessons learned from an activity usually refer to actions that need to be taken in
the future to improve what is being done. While that is certainly the case with FFE-2, it is
important to begin by pointing out an important general conclusion; that is, the State of
Illinois did demonstrate an ability to protect the health and safety of its citizens in the event
of a nuclear reactor accident similar in scope to the accident simulated for FFE-2. If an
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actual release had occurred under the conditions of the exercise, no members of the general
public would have received significant doses from this accident. State and local government
agencies worked together closely and effectively to implement IPRA, and there was good
coordination with the key Federal agencies.
An important factor in the success of FFE-2 was the extensive planning that took
place prior to the actual exercise. This planning began 18 months before the June 1987
exercise. It included two practice drills that took place before the full exercise: a Tabletop
exercise in January, 1987; and in May, about six weeks before the exercise, a Dry Run at
Zion where many of the players assembled and participated in a dress rehearsal. In addition,
there were many smaller groups of players that held extensive planning meetings. For
example, the field monitoring staff of the FRMAC held meetings to identify potential
problems and solve them before they could occur during the exercise.
The reason these meetings and all this planning were so important was that Federal
agencies seldom participated fully in normal regulatory exercises. As a result, the meetings
that were held prior to FFE-2 were important for improving communication links and
settling questions of responsibility and capability. "What do you do?" was the typical kind
of question that was asked and answered. Recently, NRC has participated more frequently
in exercises, and we feel that is a very positive sign.
One of the insights gained from this exercise and planning process is that Federal
guidance with regard to protective action recommendations is currently in a period of
transition. The official guidance from the NRC suggests that dose assessment be used to
evaluate various protective action decisions such as sheltering versus evacuation (Ref. 2).
During the Dry Run, however, the staff of the NRC Incident Response Center demonstrated
a different approach to decision making. Their procedure calls for making protective action
decisions on the basis of in-plant parameters wherever possible, not dose assessments, and
evacuation before a release starts is the preferred protective action (Ref. 3). Although this
is an approach preferred by IDNS, it represents a change in philosophy on the part of NRC,
and it initially caused some confusion between CECo, state and local officials, and NRC.
Discussions prior to FFE-2 removed this confusion from the exercise itself. However, it is
interesting to point out that this philosophy has neither been universally accepted by the
technical community nor formally promulgated as NRC guidance to licensees. Further, the,
two licensees in the State of Illinois and IDNS are still concerned about just what would
happen in the event of a real accident, despite NRC's position that there is no conflict.
The integration of the capabilities of IDNS with those of the various Federal agencies
also needs further studying. In a large-scale radiological emergency, the Federal government
would be asked to augment the technical capabilities of the state. During FFE-2, Federal
agencies did supply extensive resources, including equipment, technical manpower, and
facilities. However, the integration of the state's and Federal resources was not always
smooth. For example, during FFE-2 the start-up of the various facilities was often
unrealistically staged. At the end of day one, the Federal facilities were not yet operational.
At the beginning of day two, however, they were suddenly all in place and fully functional.
Expectations from the Federal facilities were not always realized either. For example, dose
assessments were not produced at the FRMAC as rapidly as many expected. This led to
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delays in production of useful information from the FRMAC. Finally, the management of
the Federal facilities to meet the state's needs was not always as effective as it should have
been.
An important conclusion from FFE-2 is that realistic exercises involving Federal
capabilities need to be continued and must be frequent enough to retain the joint capabilities
developed during FFE-2 (Ref. 4). For example, recovery and re-entry following the release
were important considerations during the third day of the exercise. As the Chernobyl
accident illustrated, these would be important concerns following a severe nuclear reactor
accident. Time does not allow sufficient demonstration of these activities during normal
regulatory exercises, which generally run from 8:00 in the morning until 3:00 or so in the
afternoon. During FFE-2, a multi-agency re-entry and recovery group was formed to support
the states. Staff from IDNS provided direction for this group, and the output of the group
was in fact very useful to decision makers, but more work needs to be done in this area. The
recovery and re-entry group needs to be better defined and formalized, and special exercises
to consider decontamination and re-entry questions need to be conducted. Furthermore, if
these re-entry exercises are going to be effective, they must include Federal participation.
FFE-2 also served as a proving ground for many of the technical tools that have been
developed by IDNS. For example, IDNS normally receives about 1,000 operating parameters
from each of the 13 nuclear reactors in Illinois on a near real-time basis. Simulated
parameters for Zion NFS were provided during FFE-2. A full set for Zion was not available,
but enough data were provided to test IDNS's computerized analysis software under
simulated accident conditions. Such data are desirable for all exercises, but they are not
always available during regulatory exercises because of the time, money, and effort required
to develop consistent values for all of these parameters.
A new PC-based radiological dose assessment model was used for the first time during
FFE-2 (Ref. 5). This model allows for very rapid dose projections to be performed. It can
also generate a picture of the radioactive plume and the pattern of the ground deposition,
and can incorporate radiological dose measurements gathered by the field teams to augment
model calculations. These and other IDNS tools have been modified and improved as a
result of the experience gained from FFE-2.
Finally, one of the most important lessons confirmed by IDNS from FFE-2 is the fact
that final protective action recommendations are based on more than technical and
operational considerations. Under IPRA, the Governor of the State of Illinois is the final
decision maker with regard to protective action recommendations for the general public.
The Governor or his designee makes this decision on the basis of a variety of considerations.
There are technical considerations such as the plant conditions, and operational factors such
as the availability of evacuation routes. However, there are also other concerns to be taken
into account. During the Chernobyl accident, for example, governmental agencies in Europe
often made protective action recommendations that were more conservative than the
recommendations of the technical experts they consulted. During FFE-2, the Governor's
designee recommended evacuation of certain areas before receiving such a recommendation
from IDNS. It is clear that in a severe nuclear reactor incident political considerations
would likely play a key role in protective action decision making. Those involved in the
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technical aspects of emergency planning need to remain aware of this fact at all times.
In conclusion, FFE-2 was a good learning experience for IDNS. IDNS also firmly
believes that Federal agencies need to participate in emergency exercises on a more regular
basis, and some of the Federal agencies seem to concur (Ref. 4). Most importantly, however,
Illinois did demonstrate the ability to carry out its responsibilities to protect the health and
safety of its citizens in the event of a nuclear power plant accident similar in scope to the
accident simulated in this exercise.
REFERENCES
1. Federal Emergency Management Agency (FEMA). 1985. Federal radiological
emergency response plan, concurrency by all 12 Federal agencies and publication as
an operational plan. Federal Register 50(217): 46542-46570 (November 8, 1985).
2. U.S. Nuclear Regulatory Commission (NRC). 1980. Criteria for preparation and
evaluation of radiological emergency response plans and preparedness in support of
nuclear power plants. NRC Report NUREG-0654 (FEMA-REP-1), Rev. 1.
3. U.S. Nuclear Regulatory Commission (NRC). 1987. Pilot program: NRC severe reactor
accident incident response training manual. NRC Report NUREG-1210, Vol. 1-5.
4. Baker, G., 1987. NRC says changes are needed in Federal emergency response plan.
Inside NRC, December 7, 1987.
5. Impell. 1987. User's Manual, MESOREM, Jr. Atmospheric dispersion and dose
assessment system. Impell Corporation, Lincolnshire, Illinois.
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THE USEFULNESS OF INFORMATION PROVIDED
BY FIELD MEASUREMENTS DURING UNPLANNED RELEASES
INTO THE ENVIRONMENT
Robert W. Terry
Radiation Control Division
Department of Health
Denver, Colorado
The emergency response manager is required to rapidly evaluate minimal amounts
of information in order to decide whether or not to implement protective measures as an
incident develops. Alarming effluent monitors will likely provide the only measurements of
material actually released into the environment. For hours, or even days, after a release
event it may be impossible to obtain good information about the quantities and
concentrations of material at receptor locations. Therefore, the emergency response
manager will place heavy reliance on modeling of releases. In preparing for unplanned
releases, emphasis should be placed on realistic expectations of survey instrument
measurements, of the time required to collect and analyze samples from the field, and of the
type of information that can be provided. This report provides specific examples that
illustrate both the limitations and strengths of measurement information in managing an
emergency response.
Decision making under uncertain conditions is a difficult challenge, and emergency
situations that can affect the immediate or future well-being of a large segment of the
population present challenges that only a few people have the temperament to accept. Good,
thorough planning can help to achieve the best outcomes for such unfavorable situations,
and may even lead to design or procedure modifications that keep hazards to a minimum.
Basic Preparation for Unplanned Releases
The time required to evaluate a release of material into the environment, to make
decisions regarding protective actions, and to implement those decisions, will usually
determine the effectiveness of the response. Environmental sample collection can only
evaluate releases after they have reached their receptor locations; therefore, they will be
useless to the emergency response manager in the initial stages of the response.
The emergency response manager will rely primarily on modeling techniques to
project the seriousness of the hazard to the public and make decisions regarding protective
actions. Ordinarily, models should be incorporated into computer programs as part of the
planning and preparation processes, in order to assure that calculations are made as rapidly,
and accurately, as possible.
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The computer programs should be interactive and friendly, with default values clearly
provided to users as an option. In this way, if the first experts who are available to evaluate
releases lack proficiency with the specific models employed, useful information can still be
obtained.
Primary responsibility for developing the models should lie with the facility, but state
and local government personnel will participate in their development and should be skilled
in their use and interpretation. In the event that a release does occur, diversity of opinion
among experts should be encouraged — provided that the cadre of experts who advise the
emergency response manager will produce a succinct consensus opinion, with a realistic
assessment of their uncertainty.
All models must be based on site-specific information; default values for the models
will be based on worst-case scenarios for design-based releases. The site-specific information
will be used to project off-site concentrations and radiation doses. Relevant information
about target organs will follow naturally from the dosimetry calculations. All other things
being equal, reactor releases will require the most complicated models because the relative
quantities of the various radionuclides will depend heavily on the recent operating history
of the reactor.
Releases to the Air and the Inhalation Pathway
The fastest pathway to receptors is the airborne release. Airborne releases can reach
the downwind population in a matter of minutes. Protective actions will invariably be
initiated before monitoring teams can even reach the field.
Since the uncertainty about the on-site situation, together with the uncertainty in the
model projections, is so great, extreme caution should be exercised when deploying
monitoring teams to the field.
Consider the release of 100 grams (6.13 curies, or 227 GBq) of Pu-239 into the air and
assume that it all falls to the ground, evenly distributed over a 25 square mile (65 km2) area.
The resulting surface contamination would be about 2000 dpm/100 cm2. Of course, not all
of the material will fall on the ground in such a small area, and it will not be evenly
distributed. At the facility boundary it is unlikely, even in the event of such a catastrophe,
that any measurable radioactivity will be found on the ground with a survey meter,
assuming a detection limit of 20 dpm/100 cm2.
Air sampling poses equally intractable problems for both gross alpha and gross beta
analysis. Both alpha- and beta-emitting decay products of radon and thoron in outdoor air
pose a sufficiently great interference in the measurement that the sample will have to be
held for five to 24 hours before an accurate measurement can be made. Sample preparation
for alpha spectrometric analysis would delay the measurement even more. Gamma
spectrometric analysis is also time-consuming and will also be subject to interference from
short-lived naturally-occurring material. Nonradioactive contaminants will typically require
elaborate and time-consuming sample preparation prior to measurement, as well.
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Air sampling can provide a very accurate evaluation of airborne contaminant
concentrations, but only after the fact of the release. Therefore, air sampling will be useful
only for reconstruction of the incident's impact after the initial and most critical phase of
the incident has passed.
If airborne concentrations are to be accurately evaluated, reliance will have to be
placed on continuous air samplers that are used for routine surveillance. Placement of air
sampling devices after an incident has begun probably will not be timely and creates an
unnecessary hazard for field personnel.
The best short-term evaluation of the airborne release will rely on monitoring
outbound vehicles at traffic control points, coupled with preprinted questionnaires about the
passengers' traverse of the plume, that can be filled out and mailed in at leisure. Law
enforcement personnel cannot be expected to carry survey meters and questionnaires in their
cars in anticipation of an unlikely event; however, this activity may be the most effective use
of field teams in the early stages of airborne release event.
Releases to the air, which result in deposition on the ground, will also result in
deposition on the surface of open reservoirs, lakes and rivers. While the ingestion pathway
through drinking water and fisheries from an airborne plume will ordinarily be a relatively
minor hazard to the public, it will require evaluation; protective actions should not be
overlooked. The techniques for coping with this hazard will be similar to those for releases
directly into the water, with the exception that the reservoir cannot be closed off from the
source.
Releases to Surface Water and the Ingestion Pathway
With a little bit of luck, downstream reservoirs usually can be closed off before
contaminated water reaches them, provided a mechanism is in place to warn the affected
water supplies immediately, and that plants have adequate control over the intakes to stop
the flow into the reservoir. In many locations reservoir intakes are several miles
downstream from the release point, but at the Rocky Flats Plant in Colorado one large
municipal water system has an intake directly across the street from the Plant, only about
one mile from the release point.
The Rocky Flats Plant experience also points out another problem. In 1973 a release
of tritium into the stream, and subsequently into the water supply, occurred for several
weeks before it was discovered by state public health personnel; it was actually several
months before Rocky Flats Plant personnel accepted the validity of the measurements and
identified the cause. Fortunately, the radiation dose to the affected population was only
about five millirem (0.05 mSv), but experiences of this type should emphasize that even a
well-developed emergency response program can be thoroughly defeated if the operating
conditions at the subject facility are not adequately monitored.
Initially, both the intake to the reservoir and the intake to the water treatment plant
should be closed off, until good information about the release can support a decision to
reopen them with confidence.
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Analysis of alpha emitters will require very elaborate and time-consuming analysis;
considering sample preparation time, a minimum of eight hours will be required to obtain
the first gross alpha/gross beta radioactivity measurement. Alpha spectrometric, liquid
scintillation, and gamma spectrometric analysis will require still more time, even before the
first sample analysis is complete.
Contamination of Crops, Feed, and Livestock, and the Ingestion Pathway
Contamination of crops, feed, and Livestock will ordinarily follow an airborne release.
The Workshop on Protective Action Guides (PAGs) for Contaminated Water and Food, held
in Washington, D.C., on September 13-14, 1989, resulted in several helpful recommendations
for establishing PAGs and implementing protective actions. The Codex Alimentarius
Commission, a joint body of the World Health Organization (WHO) and the Food and
Agriculture Organization (FAO), held in Geneva, Switzerland, from July 3-12, 1989, resulted
in several recommendations based on lessons learned from the Chernobyl incident.
Both of these groups focussed primarily on the Chernobyl experience, a disaster that
produced off-site contamination on such an enormous scale that extreme actions, and
extreme compromises to the quality of food as well, had to be considered.
Most of the scenarios that are Likely to occur will not produce such widespread and
extreme contamination.
The most perishable agricultural products, dairy products, will require the highest
priority for assessment. Emergency response managers should always consider isolation of
dairy products in the affected areas until conclusive measurements can be performed.
If a release occurs immediately before planting time, or immediately before harvesting
time, the priority for evaluation of pathways through crops should be elevated.
Ranchers and herdsmen will consider moving their livestock out of the area, or
substituting feed. Public health and agricultural experts should be prepared to quickly
provide accurate and authoritative information to this group. Plans should also be made to
assist in the orderly removal of livestock if ranchers and herdsmen so desire, whether or not
the situation warrants such action.
Contamination of fisheries is another issue, but is only mentioned here as an item that
warrants additional planning.
Public Expectation and Measurement and Surveillance Requirements
PAGs generally are based on the assumption that evacuation or other protective
measures will affect large populations, or that such a large portion of the food and water
supplies will be affected that alternative supplies will not be adequate to meet the
population's needs.
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As experts in this area we have a fairly realistic understanding of the hazards
involved, and realistic estimates of the effect that intermediate radiation doses will produce.
Ordinary, reasonable citizens have rather different expectations. They will ordinarily
wish to leave an affected area, no matter how small the actual hazard, unless they can be
highly motivated to stay in place. And in this country of bountiful resources, tainted food
and water, no matter how small the contaminant concentration is, will be unacceptable,
particularly where alternative sources are available. The marketability of agricultural
produce can be destroyed unless there is public confidence that every item in the grocery
store is absolutely free of contamination from industrial releases.
We, therefore, should consider emergency response plans that are based on a realistic
evaluation of public expectation. Law enforcement agencies should be prepared to facilitate
citizen-initiated evacuation. Water supplies should make every effort to keep their reservoirs
isolated until the quality of their product can be confirmed. Similarly, all food sources
should be held in quarantine after a release event until confirmation is obtained that they
are absolutely free of contamination.
By "free of contamination" we must agree that the laboratory must measure
contamination with extreme sensitivity, not just to the concentrations established by PAGs.
Good surveillance programs at each facility should consolidate preoperational measurements
into a complete and thorough summary, and should evaluate contamination during normal
operations. This evaluation should not be made to meet minimum regulatory requirements
that are established by standards for protection under ordinary circumstances; this
evaluation should exploit all available detector time and other excess capacity in the
laboratory, after basic regulatory requirements have been met. Then, in the aftermath of
a release to the environment, every effort should be made to duplicate the sensitivity of the
baseline measurements.
Continuous air sampling devices should be placed at each point of the compass, and
maintained to evaluate plumes in the event that releases do occur. Streams, lakes and every
conceivable food pathway should be measured. All coefficients that are used in dosimetry
analysis should be reviewed and updated as insight is gained into their site-specific
application.
Measurement Equipment Needs
The TABLETOP Exercise in Baton Rouge, Louisiana, conducted on August 28 and
September 18, 1990, concluded, among other things, that on-site, state, and local personnel
have the expertise to address the problems of implementing PAGs, but that physical
resources are limited. The report of lessons learned from that exercise recommended that
the Federal government should keep available large amounts of equipment that can be
deployed on short notice. While there are limitations on the usefulness of such equipment,
anything will be a help.
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Conclusions and Recommendations
The greatest obstacle to measurement of contamination following a release event is
the quantity of very expensive and sophisticated equipment that is required. A good gamma
spectrometry system, employing a single detector, costs a minimum of $75,000. A single
detector system can only analyze one sample at a time.
Following a release event the demands for detailed analysis will consume all the
capacity of an analytical laboratory, no matter how well equipped it is. Effective emergency
planning will consider a variety of release scenarios and establish a sampling plan that will
provide optimum use of scarce, identifiable resources. Some allowance should be made for
discretionary analysis, but strict discipline should be enforced to adhere to the analysis
priorities that are established in advance. In that way the emergency response manager can
follow a realistic timetable for the receipt of measurement reports.
Finally, the models employed in making projections of hazards from releases should
use reasonable coefficients. Models should not build conservatism into projections. Every
effort should be made to make the most accurate estimates possible, and then provide the
emergency response manager with a clear understanding of the uncertainty involved. It is,
after all, the emergency response manager's responsibility to exercise caution when needed.
If the projected hazards lack credibility, decisions will place little or no reliance on
information that could have been the best basis for a decision available. And if the projected
hazards are overly cautious, resources may be squandered at a time when they can never be
adequate to meet all the demands of the situation.
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WORKING GROUP SUMMARIES
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SUMMARY REPORT OF WORKING GROUP A
Leader: James C. Hardeman Jr., Georgia
ISSUE: Differences in Modeling of Releases, Exposure Pathways, and Field Monitoring,
in REP at Nonreactor Nuclear Facilities Compared to REP for Nuclear Power
Plants
1. Are State REP officials aware of the potential source terms that may require
offsite monitoring capability at nonreactor nuclear facilities in their State?
What additional source term information is needed?
In addressing this question, the working group members outlined categories of
facilities and/or potential incidents which would meet the above criterion. Facilities
considered by the working group include: DOE production and/or test reactors; other
DOE facilities, DOD facilities; research reactors; NASA facilities; transportation
incidents; and the general category of NRC & state licensees, which specifically
includes nuclear fuel cycle facilities and nuclear laundries.
The working group indicated a general knowledge of the radionuclides present in
possible source terms from faculties in each of these categories. The working group
members had lesser knowledge concerning the quantities of these materials available
for release.
2. What release scenarios, if any, could require early lifesaving efforts?
The working group was unable to conclude that radiological releases from any of the
facilities outlined above would require early lifesaving efforts. The working group did
note, however, that non-radiological aspects of incidents at certain types of facilities
(e.g., enrichment facilities, weapons-related incidents, etc.) might require lifesaving
efforts.
3. What computer codes or other standard formats (e.g., predetermined
isopleths) are needed to project dose for incidents at nonreactor nuclear
facilities? Who should develop them?
The working group unanimously agreed that regardless of the nature of the tools to
be used to assess offsite radiological consequences, it is an inherent responsibility of
the facility operator to develop these tools and to make them available to offsite
agencies. The working group discussed this matter at some length, and arrived at no
clear consensus as to the "ideal" tool to be used to consequence assessment. The
members of the working group did display a preference for the use of computer codes,
given sufficient meteorological and effluent monitoring data to permit their use.
Several of the group members drew attention to the NRC Response Technical Manual
(RTM-91), and particularly to the accompanying pocket cards. Among other
information related to commercial reactor incidents, these cards present "order of
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magnitude" dose estimates for 1 curie releases of a variety of radioactive materials,
and also for releases from 1 curie quantities of radioactive materials involved in a fire.
The presentation of this data in the pocket card format appears to be very useful.
4. What important differences are there between monitoring the ingestion
exposure pathway for incidents at nonreactor nuclear facilities compared
to similar monitoring at nuclear power plants?
Working group members noted that releases from several categories of facilities may
consist only of beta-emitting or alpha-emitting radionuclides. The absence of
gamma-emitting radionuclides will require both different field instrumentation and
laboratory instrumentation to assess the concentrations of radionuclides in food and
water. DOE airborne monitoring resources, which will be critical to the rapid
assessment of deposited radionuclides as a result of a reactor accident, appear to have
limited utility for releases from certain nonreactor facilities. The consensus among
the working group members was that more time would be required to monitor such
releases than releases from reactor facilities.
5. What important lessons regarding exposure pathways and field monitoring
have been learned from exercises at nonreactor nuclear facilities?
The working group members had little experience in exercises with nonreactor
facilities, and thus few "lessons learned" could be gleaned from this source. Based on
previous presentations and other experiences of the working group members, it was
agreed that airborne pathways would almost always be dose-dominant, and that at
least in the short term, inhalation would be the controlling pathway.
6. What problems would be encountered in monitoring an airborne plume of
pure alpha emitters or pure beta emitters? Is time a serious constraint for
choosing protective actions? What effect, if any, should the time required
to verify such airborne plumes have on the choice of the basis for taking
protective actions?
The working group members agreed that current equipment available to offsite
agencies would not permit a "real-time" indication of airborne concentrations of alpha-
and beta-emitting radionuclides, as a Geiger counter or a pressurized ion chamber
would for gamma-emitting radionuclides. Current technology would be limited to
collection of an air sample and subsequent analysis either in the field or at a
radiochemical laboratory, yielding monitoring results minutes to hours after collection
of a sample.
Members of the working group noted a trend among operators of commercial nuclear
facilities and offsite agencies to recommend and implement measures for the
protection of the general public based solely on plant status - regardless of the
existence of a radioactive materials release. In these instances, the protective
measures are based on the potential for a release of radioactive materials. Working
group members urged the use of facility status in the determination of protective
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measures, particularly for those facilities where "real-time" monitoring of released
radioactive materials would be difficult or impossible.
Several members of the working group indicated that an instrument such as a
field-portable continuous air monitor (CAM) would be useful in providing a limited
real-time indication of airborne plumes of alpha- and/or beta-emitting radionuclides.
Fixed CAM systems are used in a variety of facilities to continuously sample and
analyze air for the presence of radioactive materials.
Members of the working group also noted that field monitoring and laboratory
procedures and laboratory equipment may not be adequate to verify the presence of
an airborne plume of alpha- and/or beta-emitting radionuclides. The working group
indicated a need for guidance and training in this area.
7. What additional monitoring equipment will be needed by state and local
responders for incidents at nonreactor nuclear facilities? Consider:
* emergency response teams
* off-site personnel
* contamination on food and other surfaces
* minimum detection levels compared to derived response levels
As mentioned above, the working group recognized a need for field-portable
instrumentation to provide a real-time indication of the presence of airborne alpha-
and/or beta-emitting radionuclides. For contamination monitoring, the working group
indicated that alpha scintillators and Fidler probes would probably be adequate for
alpha-emitters, and that existing beta-gamma instruments may be adequate for
high-energy beta-emitters.
Monitoring for the presence of low-energy beta-emitters (e.g., H-3, C-14, etc.) would
require either additional equipment or the services of a radiochemical laboratory.
8. What early monitoring services can be implemented by nonreactor nuclear
facility operators? Should a list of these services and methods for accessing
them be identified in state plans?
The members of the working group recognized that facility operators are uniquely
qualified and equipped to deal with radionuclides used at their facilities. More
importantly, they are familiar with the systems in use at their facilities to detect the
presence of abnormal conditions. At major facilities, these systems may include
real-time effluent or environmental radiation monitoring systems and/or vehicles
specifically equipped to monitor for radioactive materials. The facility operators
should provide for, and the state plan should identify the methods for state personnel
to obtain access to monitoring data gathered by the facility operator. This system
should also allow for the facility operator to access monitoring data gathered by offsite
response agencies.
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9. Are there any types of special laboratory analytical equipment that are not
available to states that would be necessary for monitoring in the event of an
accident at a nonreactor nuclear facility?
The major laboratory analytical systems required for monitoring releases from
nonreactor facilities (i.e., liquid scintillation (LS) counters, alpha-beta counters, alpha
spectrometry systems) are likely to be already in place and in use by state
radiochemical laboratories, with the possible exception of alpha spectrometry
capability. The working group members did note, however, that most states would
be ill-equipped to handle a large number of samples under "emergency" conditions
with these systems. More important than the equipment itself are the procedures and
training required to prepare samples for analysis by these systems. Working group
members identified a specific need for training, particularly in the area of analysis for
transuranics.
10. What problems can be identified regarding the use of the dose limits for
workers performing emergency services as prescribed in the revised PAG
manual?
The most obvious problem identified by the working group is the inability to monitor
radiation doses delivered to radiation workers in real time when dealing only with
alpha- and beta-emitting radionuclides. This problem led the members of the working
group to conclude that the performance of monitoring activities would likely require
the use of respiratory protection. In order to conclusively determine internal
radiation doses, offsite agencies would need a bioassay program, including baseline
bioassay data.
11. How should the inability to accurately project dose from an accident at a
nonreactor nuclear facility affect decisions to take protective actions?
The language of the question implies that we have the ability to "accurately project"
dose from accidents at reactor facilities. Members of the working group suggested
replacing the phrase "accurate project" with "estimate," highlighting the inherent
uncertainties in the assessment of offsite consequences from releases of radioactive
materials.
The inability to estimate offsite radiation doses, coupled with the inability to monitor
for airborne alpha- and beta-emitting radionuclides in real time, should drive facility
operators and offsite responders to base protective action decisions on the status of
systems required for the protection of the public (plant status). The inability to
rapidly confirm radiological status may cause offsite agencies to "err on the side of
public health and safety," basing protective action decisions on assumptions which
may later prove to be substantially conservative.
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SUMMARY REPORT OF WORKSHOP B
Leader: Stanley R. Marshall, Nevada
TOPIC: The Planning Basis and the Roles of Planning and Response Authorities
As a result of the group discussions, group consensus supported a general discussion
with the full group, addressing the general questions when appropriate but without
specifically using the questions to deliver our summary to the full group.
The group members also voted that I should lead the Group B discussion with the full
group so I entitled the Group B discussion remarks, Raindrops, Dogpaddling and PAGs:
What Do They Have In Common ?. The title, with some qualification, seemed appropriate
to me because the general emergency planning issue must also be qualified to describe
parameters by which emergency response planning is conducted. You may recall that I
referenced Aubrey Godwin's story about a 6-inch rain. Was the rain 6 inches deep or were
the raindrops 6 inches apart? Whether discussing rain or PAGs, perspective is important.
I have attempted to organize the group comments in order of the questions for
purposes of similar reporting by the other groups:
1. What should be the basis for the size and shape of the Emergency Planning
Zones (EPZs)?
The group decided that the following minimum issues should be addressed in order
to develop appropriate nonreactor EPZ size and shape:
1. characterize the radiation source term.
2. characterize EPZs and other pathways.
3. identify population demographics.
4. characterize maximum "credible" accident (do not devote resources to
"incredible" accident scenario).
2. How should probability of incident severity figure into selecting the size of
the EPZ?
The group again agreed that the parameters in Issue 1 must be considered to
determine emergency action levels (EALs).
3. How would the time frame of release, notification, or response for incidents
at Federal facilities differ from those at nuclear power plants?
Release time, notification and response time will differ by significance of the
parameters in Issue 1.
Education of planning agencies and obligation by a facility operator to provide
information allows planning agencies to develop response plans.
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4. How should size of the site affect the size of the EPZ?
Group B participants agreed that onsite circumstances might not translate well to
offsite areas. Issue 1 answer indicates onsite parameters that have to be addressed
in the effort to determine size of EPZ and degree of implementation of PAG activities.
Some may not be appropriate based on onsite parameters.
5. What conditions at a Federal facility would indicate that an offsite
emergency response plan or an EPZ is not needed?
Again, Issue 1 answer parameters provide the minimum conditions to determine
whether an EPZ is needed.
1. characterize the radiation source term.
2. characterize EPZs and other pathways.
3. identify population demographics.
4. characterize maximum "credible" accident (do not devote resources to
"incredible" accident scenario).
6. How much information is available to State REP officials regarding source
term type, magnitude, and probability of occurrence: Is it adequate? What
(if any) additional information is needed?
The group recognized that some Federal information restrictions would prevent some
information from being available to state and local planners. Available onsite
information may also not be in a form that is directly usable by state or local
planners. It is essential that state and local planners be provided opportunities to
meet with onsite personnel to understand information that is pertinent to emergency
planning.
7. What revisions to NUREG-0654 are necessary to make it a satisfactory
outline for the development of State and local REP plans for Federal
facilities?
Revision of NUREG-0654 should require development of a well defined source term
to make it a satisfactory outline for state and local nonreactor plans.
8. To what degree should the Regional Advisory Committee (RAC) be used for
Federal facility REP plans and exercises?
Group B did not believe that RACs have any authority for peacetime response
activities. Typically, state legislation provides for state and/or local agency response
designation without regard to federal agency organization or resources that may stand
ready to respond.
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9. What roles should FEMA and other Federal agencies have in revising State
and local plans to include response to incidents at Federal facilities?
Group B did not believe that FEMA has authority for peacetime response activities.
Typically, state legislation provides for state and/or local agency response designation
without regard to federal agency organization or resources that may stand ready to
respond.
10. What role should FEMA and other Federal agencies play in exercising at
Federal facilities?
Consider planning, scheduling, scenario development, controlling, playing, evaluating,
documenting findings, and concurring in the adequacy of response. Group B did not
believe that FEMA has authority for peacetime response activities, therefore, FEMA
should play only a supporting role to state and local agencies in exercise scenarios at
state and local request.
11. What agreements for planning, exercising and/or response need to be made
between Federal facility operators and state and local officials?
Consider site access, classified areas, data, etc. Again, the degree of agreements
between facilities and state/local agencies will be dependent on the parameters in
Issue 1. The agreements will also depend on facility operation restrictions that may
exist that provide state and local leverage for obtaining information, assistance and
cooperation from the facility management/ownership.
12. What restrictions are appropriate for public information releases from other
Federal agencies and state and local governments? Are pre-prepared news
releases appropriate?
The Federal government should never provide any press release unless the response
information concerns a Federal facility. State and local government press releases are
usually dependent on state/local administrative procedures that are developed. Issues
concerning terrorism or national security would require coordinated press releases
from federal, state and local agencies.
13. How will security restrictions at nonreactor facilities affect state and local
officials in planning, exercising, training and response? What are potential
solutions?
Group B participants who represented state agencies did not think that security
restrictions at nonreactor facilities were a problem. Comments during some open
discussion indicated that states felt they needed clearance for Federal facilities; others
indicated they could implement adequate emergency plans without any level of
Federal clearance.
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SUMMARY REPORT OF WORKING GROUP C
Leader: Gary N. Wright, Illinois
ISSUE: The Need for Specific Guidance on Dose Projection, Protective Actions,
Training, and Exercises for Implementing PAGs for Nuclear Incidents at
Nonreactor Nuclear Facilities
1. Do implementation procedures in the PAG manual for evacuation and
relocation (Chapters 5 and 7) require expansion to apply to nuclear
incidents at nonreactor nuclear facilities? If so, who should develop them?
The group recognized that far too little information is currently available to offsite
planning agencies regarding the nature of the hazards at many of these facilities.
However, based on what is known, many of these facilities may present hazards
somewhat different in nature than those presented by commercial nuclear reactor
facilities. For example, some may present mixed chemical/radiological hazards.
Therefore, the group felt that it is likely that the current implementation procedures
for evacuation and relocation will likely require expansion to address these different
types of hazards.
The group felt that the responsibility for developing the necessary information and
models to characterize hazards should fall to the owner/operator of these faculties.
The responsibility to expand current implementation procedures should likely rest
with the U.S. Environmental Protection Agency (EPA), in coordination with FEMA,
U.S. Department of Energy (DOE), and U.S. Nuclear Regulatory Commission (NRC).
2. What important lessons regarding dose projection, protective actions,
training, and exercises have been learned from exercises at nonreactor
nuclear facilities?
Although the group's experience in such exercises was limited, the group felt strongly
that the level of planning, training, and exercises for some facilities should be at a
level equivalent to that for commercial nuclear power plants. However, they felt that
dose projection may be different in some cases than those for power reactors. The
level of knowledge and training for offsite responders for such facilities should be
similar to that for power reactors. All hazards at such facilities should be fully
evaluated and exercises should include combinations of such hazards, e.g. mixed
chemical/radiological hazards.
3. How will security restrictions affect planning, exercises, training, and
response? What agreements are appropriate during the planning phase to
avoid problems during response?
The group felt that any security restrictions which limit offsite planner's and
responder's knowledge of source term, dispersion characteristics, and site access could
severely hamper response. Therefore, the group felt that agreements should be
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developed to alleviate such problems. A generic format for such agreements should
be negotiated at the highest levels, e.g. the National Governor's Association and
appropriate federal agencies, to ensure some degree of uniformity throughout the U.S.
These agreements might very well include provisions for key offsite planning and
response personnel to obtain security clearances to ensure access to necessary
information and the site.
4. What special planning in the areas of dose projection, protective actions,
and training is needed to deal with possible broken arrows?
The group decided that some training is needed for all States since such an event
could occur anywhere. The unique nature of such devices requires training on the
nature of the source term, possible dispersal characteristics, and monitoring
instrumentation and techniques.
5. What special training will be needed by offsite responders to nuclear
incidents at nonreactor nuclear facilities that is different from the training
currently offered for planners and responders to incidents at nuclear power
plants?
Information regarding source term and dispersal modes for many of these facilities is
not readily available to offsite responders, which makes it difficult to fully address this
question. However, the group agreed that most States have Limited capabilities for
field monitoring for alpha contamination. In addition, the need for training in dealing
with mixed hazards will be necessary for response to some facilities.
6. What additional guidance is needed regarding deposited radioactive
material on persons and other surfaces from nuclear incidents at nonreactor
nuclear facilities? Who should develop it?
The group decided that the EPA should give additional attention to alpha surface
contamination levels.
7. How does the State's responsibility to protect its citizens relate to the
sometimes large, onsite, non-worker populations at some nonreactor nuclear
facilities? Is it different from its responsibility at commercial nuclear power
plants?
The group decided that the owner/operators of such facilities has the primary
responsibility for protection of non-worker populations. However, their procedures
should be developed in consultation with state and local governments.
8. What substantive revisions to State and local REP plans, if any, are
necessary to accommodate response to nuclear incidents at nonreactor
nuclear facilities?
The group felt that for some facilities detailed site specific planning, similar to that
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for power reactors, will be necessary.
9. What additional guidance is needed on planning and conducting exercises
for nuclear incidents at nonreactor nuclear facilities?
Additional guidance will be needed to deal with the different nature of some of the
source terms and modes of dispersal presented by some nonreactor facilities.
10. Can circumstances be identified in which telephone drills or table-top
exercises could be used to reduce the magnitude and cost of field exercises
at nonreactor nuclear facilities without reducing preparedness? If so, who
should develop and implement such drills or exercises?
The group could not identify any specific circumstances. However, they felt that there
are probably instances where telephone drills and tabletops could be used. However,
these should not be used to eliminate full exercises which will be needed at some
agreed-upon frequency.
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SUMMARY REPORT OF WORKING GROUP D
Leader: Debra Shults, Tennessee
ISSUE: Integration of Emergency Response for Incidents in Which the Release Includes
Both Hazardous Chemical and Radiological Contaminants (Mixed Incidents)
Eleven issues under this topic were provided to the group for discussion. Although
there were differing opinions on almost all the issues, the consensus of the group was that
the basic planning criteria and fundamental guidance needed for mixed incidents were so
closely related to those of a radiation incident that planning and exercising for these mixed
incidents could be accomplished.
The group's discussions can be outlined in four major areas:
1. Risk Evaluation
2. Planning
3. Exercising
4. Federal Assistance
1. Risk Evaluation
Our experience involving mixed incidents to date has indicated that the chemical
hazard is usually the greatest hazard involved but not necessarily the one that
receives the most attention from the media or those involved in responding to the
incident. There should be a mechanism in place to compare risk levels between
chemicals and radioactive materials. If there were a philosophy or structure in place
to compare the two, it would need to be placed into a guidance document. In
comparing these risks, studies should be performed concerning the synergistic effects
of the combinations of chemicals and radioactive materials. An assessment of the
actual mixed source terms at Federal facilities should be made as soon as possible.
2. Planning
Most states are aware of the potential for mixed incidents at facilities which they or
the NRC regulate. However, most states are not aware of the potential at Federal
facilities which they do not regulate. In planning for these incidents, expertise from
all areas involved should be considered. At both the state and Federal level, different
response structures are often used for chemical versus radiological response. In order
to provide adequate response, it is essential that there be communication between
these groups, an understanding of the command structure, and as much integration
of the systems as possible.
There is no need to write a separate plan for every possible mixed incident. Planning
should be done for the concept, not to each mixed hazard. Many states have separate
written procedures for chemical and radiological incidents. These states might
reference a "mixed" incident in their existing plans.
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3. Exercising
There was a real division among the group regarding the need for exercising mixed
incidents. Most believed states should exercise a mixed incident scenario if there is
a possibility that one may occur at a facility within their state or in transit within
their state's borders. Several states have included a chemical incident during a
nuclear power plant exercise, but did not actually incorporate a mixed incident during
these scenarios. There was concern expressed by the group that radiological
professionals would tend to overlook chemical hazards during a real event thus posing
a threat to themselves and others. The group believed that more cross training
between the chemical and radiological personnel should occur.
4. Federal Assistance
The Federal government should continue to streamline and consolidate authority to
aid states in knowing "who's in charge?" during a mixed incident. The responsible
parties could compare the relative risks of both hazards and advise the decision
makers. The Federal agencies also should participate realistically during these
exercises by including all the resources that would actually be used in an emergency.
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