Preparedness Directorate; Protective Action Guides for Radiological Dispersal Device (RDD) and Improvised Nuclear Device (IND) Incidents, 174-196 [05-24521]
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Federal Register / Vol. 71, No. 1 / Tuesday, January 3, 2006 / Notices
DEPARTMENT OF HOMELAND
SECURITY
Z–RIN 1660–ZA02
Preparedness Directorate; Protective
Action Guides for Radiological
Dispersal Device (RDD) and
Improvised Nuclear Device (IND)
Incidents
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AGENCY: Preparedness Directorate,
Department of Homeland Security.
ACTION: Notice of draft guidance for
interim use with request for comment.
SUMMARY: The Preparedness Directorate
of the Department of Homeland Security
(DHS) is issuing guidance entitled,
‘‘Application of Protective Action
Guides for Radiological Dispersal
Devices (RDD) and Improvised Nuclear
Device (IND) Incidents’’ for Federal
agencies, and as appropriate, State and
local governments, emergency
responders, and the general public who
may find it useful in planning and
responding to an RDD or IND incident.
The guidance recommends ‘‘protective
action guides’’ (PAGs) to support
decisions about actions that may need to
be taken to protect the public when
responding to or recovering from an
RDD or IND incident. It also outlines a
process to implement the
recommendations and discusses
operational guidelines that may be
useful in the implementation of the
PAGs. The full text of the document is
included in this Notice. This guidance
is provided for interim use and will be
revised based on comments received.
The Preparedness Directorate is seeking
input on the appropriateness,
implementability and completeness of
the guidance.
DATES: The draft guidance contained in
this notice is released for interim use
effective January 3, 2006. Comments on
this draft guidance should be received
on or before March 6, 2006.
ADDRESSES: You may submit comments,
identified by Docket Number DHS–
2004–0029 and Z–RIN 1660–ZA02, by
one of the following methods:
• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
• E-mail: FEMA-RULES@dhs.gov.
Include Docket Number DHS–2004–
0029 and Z–RIN 1660–ZA02 in the
subject line of the message.
• Fax: 202–646–4536.
• Mail/Hand Delivery/Courier: Rules
Docket Clerk, Office of the General
Counsel, Federal Emergency
Management Agency, Room 840, 500 C
Street, SW., Washington, DC 20472.
Instructions: All submissions received
must include the agency name and
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docket number (if available) or
Regulatory Information Number (RIN)
for this rulemaking. All comments
received will be posted without change
to https://www.regulations.gov, including
any personal information provided.
Docket: For access to the docket to
read background documents or
comments received, go to https://
www.regulations.gov. Submitted
comments may also be inspected at 500
C Street, SW., Room 840, Washington,
DC 20472.
FOR FURTHER INFORMATION CONTACT:
Craig Conklin, Chief, Nuclear and
Chemical Hazards Branch, Preparedness
Division, Department of Homeland
Security, NAC, Washington, DC 20528,
703–605–1228 (phone), 703–605–1198
(facsimile), or craig.conklin@dhs.gov (email.)
SUPPLEMENTARY INFORMATION:
(a) Introduction
(1) Background on the Guidance
Since the terrorist events in the
United States on September 11, 2001,
there has been increased worldwide
effort to avert and respond to terrorist
attacks. In addition, based on
intelligence information, the potential
for terrorist attacks in the United States
involving radiological materials or a
nuclear device has grown. The Federal
Government has responded with an
aggressive approach to planning and
preparedness, utilizing the resources
and expertise found in departments and
agencies across the government. Prior to
September 11, radiological emergencies
were considered bounded by potential
nuclear power plant accidents.
However, new terrorist scenarios have
emerged that offer new and different
response challenges.
In order to prepare for potential
attacks, DHS held a Federal interagency
‘‘dirty bomb’’ exercise as part of the Top
Officials–2 Exercise (TOPOFF–2) in
Seattle, Washington, May 12–16, 2003.
The exercise brought to light a number
of issues in Federal radiological
emergency response and recovery. One
of the most important issues raised was
how long-term site restoration and
cleanup would be accomplished
following an act of radiological
terrorism. This question was part of a
larger discussion of Federal Government
protective action recommendations
following acts of radiological or nuclear
terror. The Environmental Protection
Agency (EPA) published PAGs in the
‘‘Manual of Protective Action Guides
and Protective Actions for Nuclear
Incidents’’ (EPA 400–R–92–001, May
1992), in coordination with the Federal
Radiological Preparedness Coordinating
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Committee (FRPCC). However, the EPA
Manual, often called the PAG Manual,
was not developed to address response
actions following radiological or nuclear
terrorist incidents. Also, the PAG
Manual does not address long-term
cleanup.
In 2003, DHS tasked an interagency
working group to address these issues.
The working group consisted of senior
subject matter experts in radiological/
nuclear emergency preparedness,
response, and consequence
management. The following Federal
departments and agencies were
represented on the working group: DHS,
EPA, Department of Commerce (DOC),
Department of Energy (DOE),
Department of Defense (DOD),
Department of Labor (DOL), Department
of Health and Human Services (HHS),
and the Nuclear Regulatory Commission
(NRC).
The result of the interagency working
group process is the following Federal
consensus guidance entitled,
‘‘Application of Protective Action
Guides for Radiological Dispersal
Device (RDD) and Improvised Nuclear
Device (IND) Incidents.’’ (June 1, 2004).
In it, the Federal agencies support the
use of existing early and intermediate
phase PAGs, as found in the EPA PAG
Manual, for acts of radiological and
nuclear terrorism. The working group
also developed late phase guidance, also
contained in the consensus guidance,
for the cleanup and restoration of a site
following an act of radiological or
nuclear terrorism that is based on the
principle of site-specific optimization.
In developing this draft guidance,
DHS convened a focus group of
representatives from 13 State agencies
with expertise in radiological
emergency response and consequence
management. The State representatives
were asked to review the draft guidance
and provide detailed comments on its
content, structure, and presentation.
DHS was particularly interested in how
States would make use of the guidance
and how well the guidance would serve
to facilitate Federal and State (or local)
government interactions during a
radiological terrorism response. Overall,
the State representatives responded very
positively to the guidance. A number of
improvements suggested by the States
were incorporated into the draft
guidance being published today.
The purpose of this guidance is to aid
Federal decision makers in protecting
the public and emergency responders
from the effects of radiation during an
emergency and to provide guidelines
and a process for site cleanup and
recovery following an RDD or IND
incident. This guidance is designed to
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be compatible with the National
Incident Management System (NIMS)
and the National Response Plan (NRP).
This guidance presents levels of
radiation exposure at which the Federal
Government recommends that actions
be considered to avoid or reduce
radiation dose to the public from an
RDD or IND incident. The intended
audience for this document is
principally Federal Government
emergency response planners and
officials; however, this document
should also be useful to State and local
governments for response planning. The
protective action guides incorporate
guidance and regulations published by
the EPA, the Food and Drug
Administration (FDA), and the
Occupational Safety and Health
Administration (OSHA), and address
key health protection questions faced in
the various phases (early, intermediate,
and late) of response to an incident.
These PAGs are not absolute
standards and are not intended to define
‘‘safe’’ or ‘‘unsafe’’ levels of exposure or
contamination. Rather, they represent
the approximate levels at which the
associated protective actions are
recommended. This guidance may also
be used by State and local decision
makers, and provides flexibility to be
more or less restrictive as deemed
appropriate based on the unique
characteristics of the incident and local
considerations.
This guidance is not intended for use
at site cleanups occurring under other
statutory authorities such as EPA’s
Superfund program, the NRC’s
decommissioning program, or other
Federal or State cleanup programs. In
addition, the scope of this guidance
does not include situations involving
United States nuclear weapons
accidents.
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(2) Characteristics of RDD and IND
Incidents
An RDD is any device that causes the
purposeful dissemination of radioactive
material across an area without a
nuclear detonation. The mode of
dispersal typically described as an RDD
is an explosive device coupled with
radioactive material. An RDD poses a
threat to public health and safety and
the environment through the spread of
radioactive materials, and any explosive
device presents an added immediate
threat to human life and property. Other
means of dispersal, both passive and
active, may be employed. Dissemination
of radioactive material not carried out
via a device would still be treated like
an RDD by responders and decision
makers.
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There is a wide range of possible
consequences that may result from an
RDD depending upon the type and size
of the device, the type and quantity of
radioactive material, and how
dispersion is achieved. The
consequences of an RDD may range
from a small, localized area (e.g., a
street, single building or city block) to
large areas, conceivably several square
miles. However, most experts agree that
the likelihood of a large impacted area
is low. In most plausible scenarios, the
radioactive material would not result in
acutely harmful radiation doses and the
public health concern from the
radioactive materials would likely focus
on the chronic risk of developing cancer
among exposed individuals. Hazards
from fire, smoke, shock, shrapnel (from
an explosion), industrial chemicals and
other chemical or biological agents may
also be present.
An IND is an illicit nuclear weapon
bought, stolen, or otherwise originating
from a nuclear State, or a weapon
fabricated by a terrorist group from
illegally obtained fissile nuclear
weapons material that produces a
nuclear explosion. The guidance does
not apply to acts of war between nationstates involving nuclear weapons. The
nuclear yield achieved by an IND
produces extreme heat, powerful
shockwaves, and prompt radiation that
would be acutely lethal for a significant
distance. It also produces potentially
lethal radioactive fallout, which may
spread far downwind and deposit over
very large areas. An IND would result in
catastrophic loss of life, destruction of
infrastructure and contamination of a
very large area. If nuclear yield is not
achieved, the result would likely
resemble an RDD in which fissile
weapons material was dispersed locally.
(3) RDD and IND Incidents v. Accidents
Acts of radiological and nuclear
terrorism differ from radiological and
nuclear accidents in several key ways.
Accidents occur almost exclusively at
well-characterized fixed facilities, or
along prescribed transit routes. Facility
operators have a good understanding of
the kinds of radiological incidents that
may occur, and have developed
safeguards, plans, and procedures to
deal with them. Exercises are regularly
held to practice emergency plans and
procedures, and improvements are
made where necessary. Local
communities, such as those around
nuclear power plants (NPPs) or weapons
production facilities, are informed and
involved in emergency planning,
including development of public
communication strategies, practicing
shelter-in-place, and orderly evacuation
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along prescribed routes. Accidents may
also occur along transit routes, but these
are relatively rare and substantial
contingency planning and exercising
occurs for transportation accidents as
well.
Acts of radiological and nuclear
terrorism, on the other hand, may occur
virtually anywhere. Major cities are
potential targets of such incidents. The
number of potential targets and the
diverse circumstances of potential
attacks make focused response planning
almost impossible. Even a rural setting
could fall victim, if for example, a
device were to go off prematurely. Most
nuclear facilities are located in semirural settings around which the number
of people affected would be less and the
amount of critical infrastructure
impacted is likely to be less.
The scope of potential accidents is
limited and fairly well understood.
Facilities tend to have fixed quantities
of licensed radioisotopes or well
characterized types of radionuclides on
site that may be released in an accident.
The number of ways accidents can
occur (within reason) is limited, making
possible effective contingency planning
and improved safety. Accidents of any
magnitude are limited to a relatively
small number of facilities, and these
tend to have highly trained personnel,
advanced security, advanced process
designs with the most rigorous
safeguards and back-up systems, and the
most aggressive contingency planning.
The design of commercial nuclear
power reactors in the United States, for
example, precludes a Chernobyl-type of
nuclear accident. Smaller facilities, such
as radiopharmaceutical or radiation
source manufacturers, generally possess
much less radioactive material (or only
short half-life materials) that may be
involved in an accidental release.
Finally, an RDD or IND incident may
be initiated without any advance
warning and the release would likely
have a relatively short duration. With a
major NPP accident, the most severe
type of incident previously considered,
there is likely to be several hours or
days of warning before the release starts
and the release may be drawn out over
many hours. The benefit of time is
critical. Advance notice affords time to
make appropriate decisions,
communicate to the public, and execute
orderly evacuation, if necessary, or
other protective actions. This difference
means that most early and some
intermediate phase protective actions
must be made more quickly and with
less information in an RDD or IND
incident if they are to be effective.
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(4) Phases of Response
Typically, the response to an
emergency can be divided into three
time phases. Although these phases
cannot be represented by precise time
periods and may overlap, they provide
a useful framework for the
considerations involved in emergency
response planning. The early phase (or
emergency phase) is the period at the
beginning of the incident when the
source (e.g., fire or contaminated plume)
at the incident is active, field
measurement data are limited or not
available, and immediate protective
action decisions are required. Exposure
to the radioactive plume, short-term
exposure to deposited materials and
inhalation of radioactive material are
generally included when considering
protective actions for the early phase of
a radiological emergency. The response
during the early phase includes the
initial emergency response actions to
retrieve and care for victims, stabilize
the scene, and public health protective
actions (such as sheltering-in-place or
evacuation) in the short term. Lifesaving and first aid actions should be
given priority.
In general, early phase protective
actions need to be made very quickly,
and the protective action decisions can
be modified later as more information
becomes available. If an explosive RDD
is deployed without warning, there may
be no time to take protective actions to
reduce plume exposure. In the event of
a covert dispersal, discovery or
detection may not occur for days or
weeks, allowing contamination to be
dispersed broadly by foot, vehicular
traffic, wind, rain or other forces. If an
IND explodes, there would only be time
to make early phase protective action
recommendations to protect against
exposure from fallout in areas miles
downwind from the explosion.
The intermediate phase of the
response may follow the early phase
response within as little as a few hours,
up to several days. The intermediate
phase of the response is usually
assumed to begin after the incident
source and releases have been brought
under control and protective action
decisions can be made based on some
field measurements of exposure and
radioactive materials. Activities in this
phase typically overlap with early and
late phase activities, and may continue
for weeks to many months until
protective actions are terminated.
During the intermediate phase,
decisions must be made on the initial
actions needed to begin recovery from
the incident, reopen transportation
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systems and critical infrastructure, and
return to some state of normal activities.
The late phase is the period when
recovery and cleanup actions designed
to reduce radiation levels in the
environment to acceptable levels
commence and ends when all the
recovery actions have been completed.
In the late phase, decision makers will
have more time and information to
allow for better data collection and
options analyses. In this respect, the late
phase is no longer a response to an
‘‘emergency situation,’’ as in the early
and intermediate phases, and is better
viewed in terms of the long-term
objectives of cleanup and restoration of
the site to meet the needs and desires of
the community and region. With the
additional time and increased
understanding of the situation, there
will be opportunities to involve key
stakeholders in providing sound, costeffective recommendations.
(5) Protective Action Guides
A PAG is the projected dose to a
reference individual from an accidental
or deliberate release of radioactive
material at which a specific protective
action to reduce or avoid that dose is
recommended. Thus, protective actions,
such as evacuation or sheltering-inplace, should normally be taken before
the anticipated dose is realized. The
PAG Manual, published by EPA in
coordination with the FRPCC, provides
the basis for this proposed guidance and
may be referred to for additional details.
The EPA PAGs achieve the following
criteria and goals: (1) Prevent acute
effects, (2) reduce risk of chronic effects
and, (3) require optimization to balance
protection with other important factors
and ensure that actions taken cause
more benefit than harm.
The PAG Manual was written to
address the kinds of nuclear or
radiological incidents deemed likely to
occur. While intended to be applicable
to any radiological release, the PAGs
were designed principally to meet the
needs of commercial nuclear power
plant accidents, the worst type of
incident under consideration in the
PAGs. This is important for two reasons:
commercial nuclear power plant
accidents are almost always signaled by
preceding events, giving plant managers
time (hours or days) to make decisions,
and local emergency managers time to
communicate with the public and
initiate evacuations if necessary; and,
the suite of radionuclides is wellknown, and is dominated by relatively
short-lived isotopes. As a result of
September 11, the Federal Government
has reevaluated the PAGs for their
applicability to RDD and IND incidents.
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The PAGs are non-regulatory, and are
meant to provide a flexible basis for
decisions under varying emergency
circumstances. Many factors should be
considered when deciding whether or
not to order an action based on the
projected dose to a population. For
example, evacuation of a population is
much more difficult and costly as the
size of the subject population increases.
Further, there is a statistical increase in
casualties directly related to the size of
the population evacuated that must be
taken into consideration. Thus,
considering incident-specific factors
like these, actual projected doses at
which action is recommended may vary
up or down.
(b) Developing the Proposed Guidance
(1) Use of Existing PAGs
In deriving the recommendations
contained in this guidance, new types of
incidents and scenarios that could lead
to environmental radiological
contamination were considered. The
working group determined that the
existing PAGs for the early and
intermediate phases, including worker
protection guides, published in the EPA
PAG Manual, are also appropriate for
use in RDD and IND incidents. The
proposed recommendations are
provided in Table 1 in Section D.3 of
the following guidance. Appendix 1 of
the following guidance provides
additional details regarding worker
protection recommendations and
includes additional Response Worker
Guidelines in Table 1B.
(2) Guidance for Late Phase Site
Cleanup and Restoration
The working group evaluated existing
Federal dose and risk-based standards,
guidance and benchmarks for site
cleanup and restoration as possible
guidance for use after an RDD or IND.
Standards considered included those of
the EPA under the Comprehensive
Environmental Response,
Compensation, and Liability Act
(CERCLA), and DOE and NRC standards
under the Atomic Energy Act of 1954,
as amended. In addition, cleanup
guidance and benchmarks issued by
national and international radiation
advisory bodies (such as the
International Commission on
Radiological Protection and the
International Atomic Energy Agency)
were considered.
The working group also examined
variations of these standards, guidance
and benchmarks by explicitly
considering the possibility of achieving
more or less stringent risk or dose
levels, and by using target ranges.
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The working group determined that
the nature of potential impacts from
radiological and nuclear terror incidents
was extremely broad. Because of the
broad range of potential impacts that
may occur from RDDs and INDs ranging,
for example, from light contamination of
a street or building, to widespread
destruction of a major metropolitan
area, a pre-established numeric
guideline was not recommended as best
serving the needs of decision makers in
the late phase. Rather, a site-specific
process is recommended for
determining the societal objectives for
expected land uses and the options and
approaches available to address RDD or
IND contamination. For example, if the
incident is an RDD of limited size, such
that the impacted area is small, then it
might reasonably be expected that a
complete return to normal conditions
can be achieved within a short period of
time. However, if the impacted area is
very large, then achieving even very low
criteria for remediation of the entire area
and/or maintaining existing land uses
may not be practicable.
The process recommended in the
guidance was based on the risk
management framework discussed in
Appendix 2. This process may be
implemented through engaging
knowledgeable technical experts and
key stakeholders to provide decision
makers with advice on the options, costs
and implications of various courses of
action. The guidance recommends that
the level of effort and resources invested
be scaled to the significance of the
incident, scope of contamination,
potential severity of economic impact,
technical feasibility, and resource
constraints. This process should result
in the selection of the most appropriate
solution that is sensitive to the range of
involved stakeholders. Such a process
where multiple factors are considered in
developing options and deciding on
action is often referred to as
optimization.
Optimization is a concept that is
common to many State, Federal and
international risk management programs
that address radionuclides and
chemicals, although it is not always
referred to as such. Broadly speaking,
optimization is a flexible, multiattribute decision process that seeks to
consider and balance many factors.
Optimization analyses are quantitative
and qualitative assessments applied at
each stage of site restoration
decisionmaking, from evaluation of
remedial options, to implementation of
the chosen alternative. The evaluation
of cleanup alternatives, for example,
should factor all relevant variables,
including; areas impacted (e.g., size,
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location relative to population), types of
contamination (chemical, biological,
and radioactive), human health, public
welfare, technical feasibility, costs and
available resources to implement and
maintain remedial options, long-term
effectiveness, timeliness, public
acceptability, and economic effects (e.g.,
on residents, tourism, business, and
industry).
The optimization process is an
approach that may accommodate a
variety of dose and/or risk benchmarks
identified from State, Federal or other
sources (e.g., national and international
advisory organizations) as goals or
starting points in the analysis of
remediation options. These benchmarks
may be useful for analysis of
remediation options and levels may
move up or down depending on the sitespecific circumstances and balancing of
other relevant factors.
(3) Implementation of Site Cleanup and
Restoration
The guidance presents an
implementation plan for long-term site
cleanup and restoration analysis and
decisionmaking that is described in
detail in Appendix 3 of the guidance.
The implementation plan was designed
principally to describe Federal
interactions with State and local
governments and public stakeholder
representatives. For purposes of this
guidance, it is assumed that the RDD or
IND incident is significant in size and
scope of contamination and that the
Federal Government will be the primary
source of funding for site cleanup and
restoration. This plan is compatible
with NIMS and the NRP, and should be
seen as a framework for assessing a site,
evaluating technologies and remediation
options, assessing costs and timeframes,
and incorporating local input on current
and future land uses so that site cleanup
and restoration may be approached in a
fair and open manner.
The plan describes a collaborative and
iterative approach in which two work
groups, one of stakeholders and one of
technical subject matter experts, interact
to develop cleanup options for the site
under the supervision and oversight of
a team of senior local, State and Federal
management officials. The stakeholder
workgroup would represent local
interests, and relate local land use
preferences and public health and
welfare concerns. The technical work
group would perform analyses, evaluate
technologies and options, assess costeffectiveness, and estimate timelines for
completion. Ongoing discussions
between the groups should result in a
remediation solution and cleanup
criteria for site restoration that are
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generally acceptable to involved
stakeholders. The options and
recommended decision would be
forwarded up to decisionmakers for
final approval so that cleanup can
commence.
The constitution of the groups and the
interactions among them may be shaped
to meet specific local needs and
concerns. For example, larger, more
complex incidents may require a
number of technical experts with
specific skills and knowledge, and the
location may warrant varying
stakeholder group composition. The
implementation plan is scalable to the
situation.
The goal of the whole process is to
reach an agreed upon approach to site
cleanup and restoration within a
reasonable timeframe that is effective,
achievable, and meets the needs of local
stakeholders. The final decision must be
approved by local, State and Federal
decision makers.
(c) Tools and Guidelines To Support
Application of the PAGs
The need for protective action will be
based on a determination of whether
PAGs will be exceeded. To facilitate
first responder activities and the use of
PAGs in the field, operational
guidelines are needed which can be
readily used by local decision makers
and by responders. Radiation doses are
not directly measurable and must be
calculated based on measurable
quantities such as exposure rates,
radiation count rates or decays per unit
surface area, or radioactivity per unit
volume. Operational guidelines are
levels of radioactivity or concentrations
of radionuclides that can be accurately
measured by radiation detection and
monitoring equipment and related or
compared to the dose-based PAGs to
quickly determine if protective actions
need to be implemented. Appendix 4 of
the guidance provides examples of
existing operational guidelines, and
those being developed.
Federal Government agencies are
continuing development of the
operational guidelines to support the
application of the protective action
guides in this document, as well as tools
that will help in the development of
incident-specific operational guidelines
when they are needed. As the Federal
agencies develop these guidelines and
tools, they will be made available for
review on the internet at the DOE’s Web
site at https://www.ogcms.energy.gov.
This webpage will provide the status of
operation guideline development and
contain or provide a link to
downloadable documents and tools
related to the guidelines.
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(d) Specific Questions for Reviewers
The Preparedness Directorate/DHS
welcomes any comments and
suggestions regarding the subject
document. However, we would
appreciate if reviewers specifically
address the following issues:
• Is the presentation and format of the
document useful and appropriate for its
intended purpose? If not, why not and
how should it be changed?
• Is the implementation process in
Appendix 3 of the proposed guidance
clear and appropriate for its intended
purpose? Are roles and responsibilities
sufficiently defined in the document?
• Does the guidance provide the
appropriate balance between (a) public
health and environmental protection
goals; and (b) the flexibility needed for
the decision makers to conduct
emergency response actions and address
public welfare needs, costs and benefits,
technical feasibility and societal
interests during response to and
recovery from an incident? If not, how
should the guidance be changed to
provide the appropriate balance?
• Are the proposed PAGs for the early
and intermediate phases
implementable? Are they appropriate? If
not, why not and what alternatives do
you recommend?
• Is the discussion on worker
protection and response worker
protection helpful? Does Appendix 1 of
the proposed guidance provide an
adequate discussion of expectations and
the use of the alternate response worker
guidelines for life and property saving
situations? If not, what additional
information is needed to make the
discussion adequate?
• Are the operational guidelines
being developed and discussed in
Appendix 4 of the proposed guidance
useful? Are the groupings clear and
appropriate? Are there additional
operational guides that should be
developed?
• Is the optimization process
proposed for late phase site restoration
and cleanup reasonable and sufficiently
flexible to address RDD and IND
situations? If not, what changes need to
be made to improve the process?
• Is a flexible process without preestablished limits an appropriate
method for site recovery? Would a
flexible process with goals, ranges or
limits be more appropriate?
• What other guidance or tools are
needed to assist in the implementation
of the recommendations?
(e) References
‘‘National Response Plan’’ (NRP),
January 2005.
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‘‘National Incident Management Plan’’
(NIMS), March 1, 2004
‘‘Manual of Protective Action Guides
and Protective Actions for Nuclear
Incidents’’ (EPA PAG) EPA 400–R–92–
001, May 1992.
Complete Text of the Guidance
Application of Protective Action Guides
for Radiological Dispersal Device (RDD)
and Improvised Nuclear Device (IND)
Incidents
Prepared by the Department of
Homeland Security in coordination with
the Department of Commerce,
Department of Defense, Department of
Energy, Department of Labor,
Department of Health and Human
Services, Environmental Protection
Agency, Nuclear Regulatory
Commission.
Table of Contents
(a) Introduction
(b) Characteristics of RDD and IND Incidents
(1) Radiological Dispersal Device
(2) Improvised Nuclear Device
(3) Differences Between Acts of Terror and
Accidents
(c) Phases of Response
(1) Early Phase
(2) Intermediate Phase
(3) Late Phase
(d) Protective Actions and Protective Action
Guides for RDD and IND Incidents
(1) Protective Actions
(2) Protective Action Guides
(3) Protective Action Guides for RDD and
IND Incidents
(i) Early Phase PAGs
(ii) Intermediate Phase PAGs
(iii) Late Phase PAGs
(e) Federal Implementation
(f) Operational Guidelines
Appendix 1. Radiation Protection for the
Responder and Planning for
Implementation of the Protective Action
Guides
Appendix 2. Risk Management Framework
for RDD and IND Incident Planning
Appendix 3. Federal Implementation
Appendix 4. Operational Guidelines for
Implementation of the PAGs During RDD
or IND Events
Appendix 5. Acronyms/Glossary
Preface
Homeland Security Presidential
Directive 5 (HSPD–5), Management of
Domestic Incidents, states, ‘‘to prevent,
prepare for, respond to and recover from
terrorist attacks, major disasters, and
other emergencies, the United States
Government shall establish a single,
comprehensive approach to domestic
incident management.’’ It also assigns
the Secretary of the Department of
Homeland Security (DHS) the role of
Principal Federal Official for domestic
incident management.
DHS coordinated the development of
this document in order to address the
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critical issues of protective actions and
protective action guides (PAGs) to
mitigate the effects caused by terrorist
use of a Radiological Dispersal Device
(RDD) or Improvised Nuclear Device
(IND). This document was developed to
provide guidance for site cleanup and
recovery following an RDD or IND
incident and affirms the applicability of
existing PAGs for radiological
emergencies. The intended audience of
this document is Federal radiological
emergency response and consequence
management officials. In addition, State
and local governments may find this
document useful in response and
consequence management planning.
These guides are not intended for use at
site cleanups occurring under other
statutory authorities such as the
Environmental Protection Agency (EPA)
Superfund program, the Nuclear
Regulatory Commission’s
decommissioning program, or other
Federal and State cleanup programs. In
addition, the scope of this document
does not include situations involving
United States nuclear weapons
accidents.
Underlying the development and
implementation of the
recommendations in the report is a risk
management framework for making
decisions to provide for public safety
and welfare. Appendix 2 provides a
summary of the framework based upon
the report, ‘‘Framework for
Environmental Health Risk
Management,’’ published in 1997 by the
Commission on Risk Assessment and
Risk Management. The stages in this
framework—(1) Defining the problem
and putting it into context, (2) analyzing
the risks, (3) examining the options, (4)
making decisions about which options
to implement, (5) taking action, and (6)
conducting an evaluation of the
results—are applicable to each of the
stages of response to an RDD or IND
incident. However, the recommended
guidelines for early and intermediate
phase actions already incorporate
consideration of the first four stages, so
that action can be taken immediately to
respond to the incident. All of the stages
of the risk management framework will
be applicable in the process of
establishing the criteria for the late
phase of the response, as described later
in this report, because each situation
will have its own unique problems,
risks, options, and decisions.
The Consequence Management, Site
Restoration/Cleanup and
Decontamination (CMS) Subgroup of the
DHS RDD/IND Working Group
accomplished this effort. The CMS
Subgroup consists of subject matter
experts in radiological/nuclear
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emergency preparedness and response.
In addition to DHS, the following
departments and agencies contributed to
this effort: Department of Commerce
(DOC), Department of Defense (DoD),
Department of Energy (DOE),
Department of Labor (DOL), Department
of Health and Human Services (HHS),
Environmental Protection Agency
(EPA), and Nuclear Regulatory
Commission (NRC).
(a) Introduction
For the early and intermediate phases
of response, this document presents
levels of radiation exposure at which
the Federal Government recommends
that actions be considered to avoid or
reduce adverse public health
consequences from an RDD or IND
incident. These PAGs incorporate
guidance and regulations published by
the EPA, Food and Drug Administration
(FDA), and the Occupational Safety and
Health Administration (OSHA). For the
late phase of the response, this
document presents a process to
establish appropriate levels based on
site-specific circumstances. This
document addresses the key questions
at each stage of an incident (early,
intermediate, and late) and constitutes
advice by DHS to Federal, State, and
local decision makers.
The objectives of the guides are to aid
decision makers in protecting the
public, first responders, and other
workers from the effects of radiation,
while balancing the adverse social and
economic impacts following an RDD or
IND incident. Restoring the normal
operation of critical infrastructure,
services, industries, business, and
public activities as soon as possible can
minimize adverse social and economic
impacts.
These guides for RDD and IND
incidents are not absolute standards.
The guides are not intended to define
‘‘safe’’ or ‘‘unsafe’’ levels of exposure or
contamination, but rather they represent
the approximate levels at which the
associated protective actions are
justified. The guides give State and local
decision makers the flexibility to be
more or less restrictive as deemed
appropriate based on the unique
characteristics of the incident and local
considerations.
The PAGs can be used to select
actions to prepare for, respond to, and
recover from the adverse effects that
may exist during any phase of a terrorist
incident—the early (emergency) phase,
the intermediate phase, or the late
phase. There may be an urgent need to
evacuate people; there may also be an
urgent need to restore the services of
critical infrastructure (e.g., roads, rail
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lines, airports, electric power, water,
sewage, medical facilities, and
businesses) in the hours and days
following the incident—thus, some
response decisions must be made
quickly. If the decisions on the recovery
of critical infrastructure are not made
quickly, the disruption and harm caused
by the incident could be inadvertently
and unnecessarily increased. Failure to
restore important services rapidly could
result in additional adverse public
health and welfare impacts that could
be more significant than the direct
radiological impacts.
(b) Characteristics of RDD and IND
Incidents
A radiological incident is defined as
an event or series of events, deliberate
or accidental, leading to the release, or
potential release, into the environment
of radioactive material in sufficient
quantity to warrant consideration of
protective actions. Use of an RDD or
IND is an act of terror that produces a
radiological incident.
(1) Radiological Dispersal Device
An RDD poses a threat to public
health and safety through the spread of
radioactive materials by some means of
dispersion. The mode of dispersal
typically conceived as an RDD is an
explosive device coupled with
radioactive material. The explosion
adds an immediate threat to human life
and property. Other means of dispersal,
both passive and active, may be
employed.
There is a wide range of possible
consequences that may result from an
RDD, depending on the type and size of
the device, and how dispersal is
achieved. The consequences of an RDD
may range from a small, localized area,
such as a single building or city block,
to large areas, conceivably many square
miles. However, most experts agree that
the likelihood of impacting a large area
is low. In most plausible scenarios, the
radioactive material would not cause
acutely harmful radiation doses, and the
primary public health concern from
those materials would be chronic risk of
cancer to exposed individuals. Hazards
from fire, smoke, shock (physical,
electrical or thermal), shrapnel (from an
explosion), industrial chemicals, and
other chemical or biological agents may
also be present.
(2) Improvised Nuclear Device
An IND is a nuclear weapon
originating from an adversary State or
fabricated by a terrorist group from
illicit special nuclear material that
produces a nuclear explosion. The
nuclear yield achieved by an IND
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179
produces extreme heat, powerful
shockwaves, and prompt radiation that
would be acutely lethal for a significant
distance. It also produces radioactive
fallout, which may spread far
downwind and deposit over very large
areas. If nuclear yield is not achieved,
the result would likely resemble an RDD
in which fissile weapons material was
utilized.
(3) Differences Between Acts of Terror
and Accidents
Most radiological emergency planning
has been conducted to respond to
potential nuclear power plant accidents.
RDD and IND incidents may differ from
a nuclear power plant accident in
several ways, and response planning
should take these differences into
account. First, the severity of an IND
incident would be dramatically greater
than any nuclear power plant accident
(although an RDD would likely be on
the same order of magnitude as a
nuclear power plant accident). An IND
would have vastly greater radiation
levels and would create a large radius of
severe damage from blast and heat,
which could not occur in a nuclear
power plant accident.
Second, the release from an RDD or
IND may start without any advance
warning and would likely have a
relatively short release duration. With a
major nuclear power plant accident
there is likely to be several hours of
warning before the release starts, and
the release is likely to be drawn out over
many hours. This difference means that
most early, and some intermediate
phase, protective action decisions must
be made more quickly (and with less
information) in an RDD or IND incident
if they are to be effective.
Third, an RDD or IND incident is
more likely to occur in a major city with
a large population. Because of the rural
setting in which many nuclear facilities
are located, the number of people
affected by a nuclear power plant
incident may be less and the amount of
critical infrastructure impacted is also
likely to be smaller.
Fourth, large nuclear facilities have
detailed emergency plans that are
periodically exercised, including
specified protective action sectors,
evacuation routes, and methods to
quickly warn the public on the
protective actions to take. This would
not be the case in an RDD or IND
incident. This level of radiological
emergency planning typically does not
exist for most cities and towns without
nuclear facilities.
Fifth, the type of radioactive material
involved could and probably will be
different from what is potentially
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released for a nuclear power plant
incident.
(c) Phases of Response
Typically, the response to an RDD or
IND incident can be divided into three
time phases—the early phase, the
intermediate phase, and the late phase—
that are generally accepted as being
common to all nuclear incidents.
Although these phases cannot be
represented by precise time periods and
may overlap, they provide a useful
framework for the considerations
involved in emergency response
planning.
(1) Early Phase
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The early phase (or emergency phase)
is the period at the beginning of the
incident when immediate decisions for
effective use of protective actions are
required and actual field measurement
data is generally not available. Exposure
to the radioactive plume, short-term
exposure to deposited materials, and
inhalation of radioactive material are
generally included when considering
protective actions for the early phase.
The response during the early phase
includes initial emergency response
actions to protect public health and
welfare in the short term. Priority
should be given to lifesaving and firstaid actions.
In general, early phase protective
actions should be taken very quickly,
and the protective action decisions can
be modified later as more information
becomes available. If an explosive RDD
is deployed without warning, there may
be no time to take protective actions to
reduce plume exposure. In the event of
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a covert dispersal, discovery or
detection may not occur for days or
weeks, allowing contamination to be
dispersed broadly by foot, vehicular
traffic, wind, rain, or other forces. If an
IND explodes, there would only be time
to make early phase, protective action
recommendations to protect against
exposure from fallout in areas many
miles downwind from the explosion.
factors that must be balanced by local
officials. For example, it can be
expected that hospitals and their access
roads will need to remain open or be
reopened quickly. These interim
decisions can often be made with the
acknowledgement that further work may
be needed as time progresses.
(2) Intermediate Phase
The late phase is the period when
recovery and cleanup actions designed
to reduce radiation levels in the
environment to acceptable levels are
commenced, and it ends when all the
recovery actions have been completed.
With the additional time and increased
understanding of the situation, there
will be opportunities to involve key
stakeholders in providing sound, costeffective recommendations. Generally,
early (or emergency) phase decisions
will be made directly by elected public
officials, or their designees, with limited
stakeholder involvement due to the
need to act within a short timeframe.
Long-term decisions should be made
with stakeholder involvement, and can
also include incident-specific technical
working groups to provide expert advice
to decision makers on impacts, costs,
and alternatives.
The intermediate phase of the
response may follow the early phase
response within as little as a few hours.
The intermediate phase of the response
is usually assumed to begin after the
source and releases have been brought
under control and protective action
decisions can be made based on
measurements of exposure and
radioactive materials that have been
deposited as a result of the incident.
Activities in this phase typically overlap
with early and late phase activities, and
may continue for weeks to many
months, until protective actions are
terminated.
During the intermediate phase,
decisions must be made on the initial
actions needed to recover from the
incident, reopen critical infrastructures,
and return to a general state of normal
activity. In general, intermediate phase
decisions should consider late phase
response objectives. However, some
intermediate phase decisions will need
to be made quickly (i.e., within hours)
and should not be delayed by
discussions on what the more desirable
permanent decisions will be. All of
these decisions must take into account
the health, welfare, economic, and other
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(3) Late Phase
The relationship between typical
protective actions and the phases of the
incident response are outlined in Figure
1. Plainly, there is overlap between the
phases, and this framework should be
used to support a timely
decisionmaking process, irrespective of
the perception of which incident phase
might be applicable.
BILLING CODE 9110–21–P
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(d) Protective Actions and Protective
Action Guides for RDD and IND
Incidents
(1) Protective Actions
Protective actions are activities that
may be conducted in response to an
RDD or IND incident in order to reduce
or eliminate exposure to members of the
public to radiation or other hazards.
These actions are generic and are
applicable to RDDs and INDs. The
principal protective action decisions for
consideration in the early and
intermediate phases of an emergency are
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whether to shelter-in-place, evacuate, or
relocate affected or potentially affected
populations. Secondary actions include
administration of prophylactic drugs,
decontamination, use of access
restrictions, and use of restrictions on
food and water. In some situations, only
one protective action needs to be
implemented, while in others,
numerous protective actions should be
implemented.
material at which a specific protective
action to reduce or avoid that dose is
recommended. Thus, protective actions
are designed to be taken before the
anticipated dose is realized. The
‘‘Manual of Protective Action Guides
and Protective Actions for Nuclear
Incidents’’ 1 published by the EPA (also
known as the EPA PAG Manual)
provides a significant part of the basis
(2) Protective Action Guides
PAGs are the projected dose to a
reference individual, from an accidental
or deliberate release of radioactive
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1 ‘‘Manual of Protective Action Guides and
Protective Actions for Nuclear Incidents,’’ U.S.
Environmental Protection Agency, May 1992, EPA–
400–R–92–001.
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of this document and may be referred to
for additional details.
The existing PAGs meet the following
principle criteria and goals: (1) Prevent
acute effects, (2) reduce risk of chronic
effects, and (3) require optimization to
balance protection with other important
factors and ensure that actions taken
cause more benefit than harm.
In this document, PAGs are generic
criteria based on balancing public
health and welfare with the risk of
alternatives applied in each of the
phases of an RDD or IND incident. The
PAGs are specific for radiation and
radioactive materials, and must be
considered in the context of other
chemical or biological hazards that may
also be present. Though the PAGs are
values of dose avoided, published dose
conversion factors and derived response
levels may be utilized in estimating
doses, and for choosing and
implementing protective actions. Other
quantitative measures and derived
concentration values may be useful in
emergency situations; for example, for
the release of goods and property from
contaminated zones, and to control
access in and out of contaminated areas.
Because of the short time frames
required for emergency response
decisions, it is likely there will not be
opportunities for local decision makers
to consult with a variety of stakeholders
before taking actions. Therefore, the
early and intermediate phase EPA PAGs
have been based on the significant body
of work done in the general context of
radiological emergency response
planning, and represent the results of
public comment, drills, exercises, and a
consensus at the Federal level for
appropriate emergency action.
In order to use the PAGs to make
decisions about appropriate protective
actions, decision makers will need
information on suspected radionuclides;
projected plume movement and
depositions; and/or actual measurement
data or, during the period initially
following the release, expert advice in
the absence of good information.
Sources of such information include:
on-scene responders as well as
monitoring, assessment, and modeling
centers.
(3) Protective Action Guides for RDD
and IND Incidents
The PAGs for RDD and IND incidents
are generally based on the following
sources: the PAGs developed by EPA in
coordination with other Federal
agencies through the Protective Action
Guide Subcommittee of the Federal
Radiological Preparedness Coordinating
Committee; guidance developed by the
FDA for food and food products and the
distribution of potassium iodide; and
OSHA regulations.
In order to use this guide, there may
be a need to compare the PAG to the
results of a risk assessment or dose
projection. It should be emphasized
that, in general, when making radiation
dose projections, realistic assumptions
should be used so the final results are
representative of actual conditions.
Table 1 provides a summary of the
key actions and suggested PAGs for an
RDD or IND incident.
TABLE 1.—PROTECTIVE ACTION GUIDES FOR RDD OR IND INCIDENTS
Phase
Protective action
Protective action guide
Early ............................
Limit Emergency Worker Exposure.
Sheltering of Public ......................
Evacuation of Public .....................
Administration of Prophylactic
Drugs.
Limit Worker Exposure .................
Relocation of General Public ........
5 rem (or greater under exceptional circumstances1.
1 to 5 rems projected dose2 ...........................
1 to 5 rems projected dose3 ...........................
For potassium iodide, FDA Guidance dose
values4 5.
5 rem/yr ...........................................................
2 rems, projected dose first year Subsequent
years: 500 mrem/yr projected dose.
500 mrem/yr projected dose ...........................
500 mrem/yr dose ...........................................
Late phase PAG based on optimization.
Intermediate .................
Late ..............................
Food Interdiction ...........................
Drinking Water Interdiction ...........
Final Cleanup Actions ..................
Reference
EPA PAG Manual.
EPA PAG Manual.
EPA PAG Manual.
FDA Guidance 6.
See Appendix 1.
EPA PAG Manual.
FDA Guidance 7.
EPA guidance in development.
1 In cases when radiation control options are not available or, due to the magnitude of the incident, are not sufficient, doses above 5 rems may
be unavoidable. For further discussion see Appendix 1.
2 Should normally begin at 1 rem; however, sheltering may begin at lower levels if advantageous.
3 Should normally begin at 1 rem.
4 Provides protection from radioactive iodine only.
5 For other information on medical prophylactics and treatment please refer to https://www.fda.gov/cder/drugprepare/default.htm or https://
www.bt.cdc.gov/radiation/index/asp or https://www.orau.gov/reacts.
6 ‘‘Potassium Iodide as a Thyroid Blocking Agent in Radiation Emergencies,’’ December 2001, Center Drug Evaluation and Research, FDA,
HHS (https://www.fda.gov/cder/guidance/5386fnl.htm).
7 ‘‘Accidental Radioactive Contamination of Human Food and Animal Feeds: Recommendations for State and Local Agencies,’’ August 13,
1998, Office of Health and Industry Programs, Center for Devices and Radiological Health, FDA, HHS (https://www.fda.gov/cdhr/dmqrp/84.html).
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(i) Early Phase PAGs
For the early phase, the existing PAGs
for evacuation, sheltering, relocation,
and protection of emergency workers
are appropriate for RDD and IND
incidents. FDA guidance on the
administration of stable iodine is also
considered appropriate (only useful for
an IND or NPP incident involving
radioiodine release). The administration
of other prophylactic drugs should be
evaluated on a case-by-case basis and
depend on the nature of the event and
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radioisotopes involved. It can be
expected that an initial zone will be
established and controlled around the
site of the incident, as is the case for
other crime scenes and hazards. These
guides allow for the refinement of that
area if the presence of radiation or
radioactive material warrants such
action.
The response during the early phase
includes initial emergency response
actions to protect public health and
welfare in the short term. Priority
should be given to lifesaving and first-
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aid actions. Incident commanders
should define and enforce an allowable
emergency dose limit in accordance
with the immediate risk situation.
Following IND detonation, the highest
priority missions will include
suppression of ignited fires to prevent
further loss of life. High radiation doses
to emergency personnel in IND
situations, substantially exceeding the
nominal occupational level of 5 rem
may be unavoidable. While every effort
to employ as low as reasonably
achievable (ALARA) principles after an
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IND event will be made, medically
significant exposures may also be
unavoidable (see Appendix 1, Section
E). Medical evaluation of emergency
response personnel after such exposure
is recommended.
(ii) Intermediate Phase PAGs
The decisions in the intermediate
phase will focus on the return of key
infrastructure and services, and the
rapid restoration of normal activities.
This will include decisions on allowing
use of roads, ports, waterways,
transportation systems (including
subways, trains, and airports), hospitals,
businesses, and residences. It will also
include responses to questions about
acceptable use and release of real and
personal property such as cars, clothes,
or equipment that may have been
impacted by the RDD or IND incident.
Many of the activities will be concerned
with materials and areas that were not
affected but for which members of the
public may have a concern. Thus, the
PAGs serve to guide decisions on
returning to impacted areas, leaving
impacted areas, and providing
assurance that an area or material was
not impacted. See Appendix 1 for a
discussion of occupational safety and
health standards.
For the intermediate phase, relocation
of the population is a protective action
that can be used to reduce dose.
Relocation is the removal or continued
exclusion of people (households) from
contaminated areas in order to avoid
chronic radiation exposure, and it is
meant to protect the general public. For
the intermediate phase, the existing
relocation PAGs of 2 rems in the first
year and 500 mrems in any year after
the first are considered appropriate for
RDD and IND incidents. However, for
some IND incidents, the area impacted
and the number of people that might be
subject to relocation could potentially
be very large and could exceed the
resources and infrastructure available.
For example, in making the relocation
decision, the availability of adequate
accommodations for relocated people
should be considered. Decision makers
may need to consider limiting action to
those most severely affected, and
phasing relocation implementation
based on the resources available.
The relocation PAG applies
principally to personal residences but
may impact other facilities as well. For
example, it could impact work
locations, hospitals, and park lands as
well as the use of highways and other
transportation facilities. For each type of
facility, the occupancy time of
individuals should be taken into
account to determine the criteria for
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using a facility or area. It might be
necessary to avoid continuous use of
homes in an area because radiation
levels are too high. However, a factory
or office building in the same area could
be used because occupancy times are
shorter. Similarly, a highway could be
used at higher contamination levels
because the exposure time of highway
users would be considerably less than
the time spent at home.
The intermediate phase PAGs for the
interdiction of food and water are set at
500 mrem/yr each for RDD and IND
incidents. These values are consistent
with those now used or being
considered as PAGs for other types of
nuclear incidents.
The use of simple dose reduction
techniques is recommended for personal
property and all potentially
contaminated areas that continue to be
occupied. This use is also consistent
with the PAGs developed for other types
of nuclear incidents. Examples of
simple dose reduction techniques
would be washing of all transportation
vehicles (e.g., automobiles, trains, ships,
and airplanes), personal clothing before
reuse, eating utensils, food preparation
surfaces before next use, and other
personal property, as practicable and
appropriate.
(iii) Late Phase PAGs
The late phase involves the final
cleanup of areas and property with
radioactive material present. Unlike the
early and intermediate phases of an
RDD or IND incident, decision makers
will have more time and information
during the late phase to allow for better
data collection, stakeholder
involvement, and options analysis. In
this respect, the late phase is no longer
a response to an ‘‘emergency situation,’’
and is better viewed in terms of the
objectives of site restoration and
cleanup.
Because of the extremely broad range
of potential impacts that may occur
from RDDs and INDs (e.g., ranging from
light contamination of one building to
widespread destruction of a major
metropolitan area), a pre-established
numeric guideline is not recommended
as best serving the needs of decision
makers in the late phase. Rather, a
process should be used to determine the
societal objectives for expected land
uses and the options and approaches
available, in order to select the most
acceptable criteria. For example, if the
incident is an RDD of limited size, such
that the impacted area is small, then it
might reasonably be expected that a
complete return to normal conditions
can be achieved within a short period of
time. However, if the impacted area is
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183
large, then achieving even low cleanup
levels for remediation of the entire area
and/or maintaining existing land uses
may not be practicable.
The Risk Management Framework
described in Appendix 2 provides such
a process and helps assure the
protection of public health and welfare.
Decisions should take health, safety,
technical, economic, and public policy
factors into account. Appendix 3
utilizes the framework to manage
Federal RDD and IND site cleanup and
restoration.
Optimization (broadly defined) is a
concept that is common to many State,
Federal, and international risk
management programs that address
radionuclides and chemicals, although
it is not always identified as such.
Optimization is a flexible approach
where a variety of dose and/or risk
benchmarks may be identified from
State, Federal, or other sources (e.g.,
national and international advisory
organizations). These benchmarks may
be useful for analysis of remediation
options and levels may move up or
down depending on the site-specific
circumstances and balancing of other
relevant factors.
Optimization activities are
quantitative and qualitative assessments
applied at each stage of site restoration
decisionmaking, from evaluation of
remedial options, to implementation of
the chosen alternative. The evaluation
of options for the late phase of recovery
after an RDD or IND incident should
balance all of the relevant factors,
including:
• Areas impacted (e.g., size, location
relative to population)
• Types of contamination (chemical,
biological, and radiological)
• Other hazards present
• Human health
• Public welfare
• Ecological risks
• Actions already taken during the
early and intermediate phases
• Projected land use
• Preservation or destruction of
places of historical, national, or regional
significance
• Technical feasibility
• Wastes generated and disposal
options and costs
• Costs and available resources to
implement and maintain remedial
options
• Potential adverse impacts (e.g., to
human health, the environment, and the
economy) of remedial options
• Long-term effectiveness
• Timeliness
• Public acceptability, including local
cultural sensitivities
• Economic effects (e.g., tourism,
business, and industry)
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The optimization process provides the
best opportunity for decision makers to
gain public confidence through the
involvement of stakeholders. This
process may begin during, and proceed
independently of, intermediate phase
protective actions.
The Recovery Management Team (see
Appendix 3) should develop a schedule
with milestones for conducting the
optimization process as soon as
practicable following the incident.
While the goal of the team should be to
complete the initial optimization
process within six months of the
incident, the schedule must take into
consideration incident-specific factors
that would affect successful
implementation. It should be recognized
that this schedule may need to represent
a phased approach to cleanup and is
subject to change as the cleanup
progresses.
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(e) Federal Implementation
This guidance describes the approach
the Federal Government will take in
making protective action
recommendations and provides
guidance for long-term site restoration
following radiological and nuclear terror
incidents. Appendix 3 provides
additional details on the process that
will be used to implement this
guidance, focusing on describing the
role of the Federal Government and how
it will integrate its activities with State
and local governments and the public.
In particular, Appendix 3 addresses the
scenario in which the Federal
Government is expected to be the
primary funding entity for cleanup and
restoration activities. It should be
recognized that for some radiological
terror incidents, States might take the
primary leadership role in cleanup and
contribute significant resources toward
restoration of the site. The appendix
does not address such a scenario.
(f) Operational Guidelines
Implementation of the PAGs is
supported by operational guidelines that
can be readily used by decision makers
and responders in the field. Operational
guidelines are levels of radiation or
concentrations of radionuclides that can
be accurately measured by radiation
detection and monitoring equipment,
and then related or compared to the
PAGs to quickly determine if protective
actions need to be implemented. Federal
agencies are continuing development of
operational guidelines to support the
application of protective action
recommendations in this document.
Some values already exist that could
potentially serve as operational
guidelines for RDD and IND recovery
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operations. However, there are many
more operational guidelines that need to
be developed or applied in order to
provide decision makers and responders
with the capability to quickly determine
that the suite of PAGs for RDDs and
INDs are being met. Appendix 4
presents a summary of the potential
types of operational guidelines likely
needed for RDD and IND response
operations.
Some examples of existing values that
could be used as operational guidelines
for RDD and IND response operations
include:
(i) Derived Response Levels
The PAG Manual published by the
EPA contains guidance and Derived
Response Levels (DRLs) for use with the
early phase PAGs. These values serve as
operational guidelines to readily
determine if protective actions
associated with the PAGs need to be
implemented. If concentrations of
radionuclides obtained through field
measurements are less than the DRLs,
the PAGs will not be exceeded and,
thus, a protective action may not need
to be taken.
(ii) Derived Intervention Levels for Food
The FDA has developed Derived
Intervention Levels (DILs) for
implementation of the PAGs for food.
These DILs establish levels of
contamination than can exist on crops
and in food products and still maintain
exposure levels below the food PAGs,
and could therefore be used as
operational guidelines for RDD and IND
events.
(iii) Radiation Levels for Control of
Access to Radiation Areas
Another example of an operational
guideline is a 2mR/hr radiation level
that can be established for control of
access to radiation areas during the
response. The rationale for this
operational guideline is that first
responders need an easily measurable
dose rate for restricting access to more
highly contaminated areas. The
operational guideline would not limit
access by emergency workers
performing duties such as rescuing
victims, but it would allow the
establishment of a hot zone boundary
for an area to which unnecessary access
should be prevented. While emergency
workers’ total doses would be
monitored and decisions made
accordingly, the 2mR/hr operational
guideline is also useful to control access
for non-emergency workers and
members of the public who are subject
to lower dose constraints. For example,
non-emergency workers may need
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limited access to infrastructure and
facilities within the contaminated zone,
and residents may need access to homes
for limited time periods.
Additional operational guidelines for
use with PAGs in each phase of
recovery will need to be developed for
a wide range of personal and real
property. Appropriations language from
House Report 108–076, Making
Emergency Wartime Supplemental
Appropriations for the Fiscal Year 2003,
and for Other Purposes, directs the DOE
‘‘to develop standards for the cleanup of
contamination resulting from a potential
RDD event.’’ Accordingly, DOE is
leading an effort to develop needed
standards, in the form of operational
guidelines, for a wide range of personal
(e.g., vehicles, equipment, personal
items, debris) and real (e.g., buildings,
roads, bridges, residential and
commercial areas, monuments) property
types likely to be impacted by an RDD
or IND incident. The work is being
coordinated with other Federal
agencies, and an inter-agency work
group has been established to foster
collaboration and acceptance of the
operational guidelines upon
completion. The goal is to arrive at the
needed set of operational guidelines that
can then be incorporated into
appropriate Federal response
documents and used by decision makers
and responders.
Appendix 1—Radiation Protection for
the Responder and Planning for
Implementation of the Protective Action
Guides
The purpose of this appendix is to discuss
the context for the PAGs and to provide
guidance for their application, particularly
for the protection of emergency responders.
Response organizations need to develop
plans and protocols that address radiation
protection during an RDD or IND incident
and that ensure appropriate training for
responders and decision makers. Although
this appendix discusses some of the
important issues and information that must
be communicated, it is not intended to
provide a comprehensive discussion of the
topic. Other detailed reports on radiation
risk, risk management decisionmaking,
training, and public communication should
be consulted in the development of plans,
protocols, and training materials.
Organizations that have published such
reports include the National Council on
Radiation Protection and Measurements, the
International Commission on Radiological
Protection, the International Atomic Energy
Agency, the American Nuclear Society, and
the Health Physics Society.
(a) The Protective Action Guides and
Operations Guidelines Into Perspective
The recommendations in this report were
developed to assist decision makers and
responders in planning for radiological
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emergencies, in particular, those related to
terrorist incidents using RDDs and INDs.
Decisions regarding protective actions for
workers and the public during such incidents
are risk management decisions, and the
recommendations in this report are provided
in that context. In all cases, all practical and
reasonable means should be used to reduce
or eliminate exposures that are not necessary
to protect public health and welfare.
(b) The Difference Between PAGs for
Emergencies and Other Operations
Worker and public protection guidance
and standards for normal operations are
typically developed through risk
management approaches and are documented
in Federal and State regulations (e.g., 10 CFR
part 20; 10 CFR part 835; 29 CFR 1910.1096).
However, many factors or decision criteria
differ during a radiological emergency versus
normal operations. Some of the key decision
criteria differences between emergency PAGs
and typical occupational and public
protection standards are shown in Table 1A.
Although there are times when
implementation of standards or guidelines
can cause or enhance other risks, these
secondary risks normally can be controlled.
Standards for normal operations provide a
185
margin of safety that is greater than that in
guidelines for emergency response because
that margin can be provided in a manner that
ensures no significant increase in public
health risk or detriment to the public welfare.
Currently, the development of standards and
guidelines for normal operations is done in
a manner that provides reasonable assurance
that implementation of the standards will not
cause more risk than it averts.
TABLE 1A.—DIFFERENT RISK MANAGEMENT CONSIDERATIONS FOR EMERGENCY AND NORMAL OPERATIONS
Normal operations
An adversary may attempt to create conditions that will cause high radiation exposures, widespread contamination, and mass disruption.
Actions must be taken as soon as possible to minimize exposures
even when information on the risks is incomplete.
Lack of action—due to unclear, overly complicated, or reactive guidelines—have a high possibility of causing unintended consequences.
During emergencies, the undesired consequences can be significant,
uncontrollable, and unpredictable.
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Emergency
Key elements to radiation protection are to contain radioactivity and
confine access to it.
There is adequate time to fully characterize situations and determine
risks and mitigating measures.
Inaction or delays may increase costs but rarely results in consequences that cannot be mitigated.
Consequences associated with implementation of the standard are well
characterized, considered, and controlled so as not to be of concern
from either a health or public welfare perspective.
During the early phase of an emergency
response, however, tradeoffs are not only
cost-related but may directly impact public
health and welfare. It is difficult to ensure
that implementation of recommendations
does not result in more harm than good.
Guidelines that prevent or restrict a
responder’s ability to provide medical
assistance based on an uncertain cancer risk
may result in loss of life of incident victims.
If the PAGs delay firefighters’ ability to
control fires, resulting property damage can
seriously affect overall public welfare or even
cause an increase to health risks associated
with the incident. The decision maker’s use
of public protection PAGs also must consider
secondary risks. Evacuation of the public
could result in loss of life and injury as a
result of the evacuation process that exceeds
the increased public risk should the
evacuations not occur. These and other
considerations require that the PAGs and
associated operational guides be developed
so that decisions can appropriately consider
risks, detriments, and costs associated with
an RDD or IND incident, as well as those
associated with implementation of the
protective action to, on balance, benefit the
public welfare.
Emergency response actions should be
carried out following a careful consideration
of both the benefits to be achieved by the
‘‘rescue’’ or response action (e.g., the
significance of the outcome to individuals,
populations, property, and the environment
at risk considering their likely impaired
status following an incident), and the
potential for additional health impacts to
those conducting the emergency response
operation. That is, in making an emergency
response decision, the potential for the
success of the response/rescue operation and
the significance of its benefits to the
community should be balanced against the
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potential for rescuers to be exposed to new
and significant health and safety risks.
Actions should be based on balancing risks
and benefits. Nothing in this guidance should
be construed to imply that appropriate steps
should not be taken to minimize dose to
workers and the public, consistent with the
ALARA principle applied to radiation
protection activities in the United States.
However, actions similarly should not
restrict lifesaving or property-saving actions
necessary for protection of public and public
welfare.
(c) Controlling Occupational Exposures and
Doses to First Responders
This section provides guidance for first
responders concerning occupational doses of
radiation, during an emergency response. In
many emergency situations, actual exposure
of workers, including first responders, may
be controlled to low doses when proper
precautions are taken. However, it is
important to recognize that conditions that
exist during an RDD or IND incident may
limit the effectiveness of these precautions
for some first responders. One of the major
radiation protection controls used for normal
operations is containment of the radioactive
material. Another is to keep people away
from the sources. However, during an RDD or
IND incident, use of these controls may not
be possible. As a result, radiation exposures,
particularly to first responders, may be
unavoidable and may have the potential to
exceed limits used for normal operations.
Nonetheless, every reasonable effort should
be made to control doses to levels that are as
low as practicable.
(d) Maintaining the ‘‘As Low As Reasonably
Achievable’’ Principle
To minimize the risks from exposure to
ionizing radiation, employers of first
responders should prepare emergency
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response plans and protocols in advance to
keep worker exposures as low as reasonably
achievable. These protocols should include,
to the extent they can be employed, the
following health physics and industrial
hygiene practices:
• Minimizing the time spent in the
contaminated area (e.g., rotation of workers);
• Maintaining the maximum distance from
sources of radiation;
• Shielding of the radiation source from
the receptor;
• Tailoring of hazard controls to the work
performed;
• Properly selecting and using respirators
and other personal protective equipment
(PPE) may be useful to prevent exposure to
internally deposited radioactive materials
(e.g., alpha and beta emitters); and
• Using prophylactic medications, where
medically appropriate, that either block the
uptake or reduce the retention time of
radioactive material in the body.
The incident commander should be
prepared to identify, to the extent possible,
all hazardous conditions or substances and to
perform appropriate site hazard analysis.
Emergency management plans should
include protocols to control worker
exposures, establish exposure guidelines in
advance, and outline procedures for worker
protection. All activities should be performed
in conjunction with emergency procedures
that include provisions for exposure
monitoring, worker training on the hazards
involved in response operations and ways to
control them, and medical monitoring.
(e) Understanding Dose and Risk
Relationships
Responders and incident commanders
should understand the risks associated with
radiation. PAG recommendations in this
document provide a guideline level of 5 rems
for worker protection and alternative
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response worker guidelines 2 (see Table 1B)
for certain activities where exposures below
5 rems cannot be maintained.
for certain activities where exposures below
5 rems cannot be maintained.
TABLE 1B.—RESPONSE WORKER GUIDELINES
Total effective date equivalent (TEDE) guideline
Activity
Condition
5 rems ..................................
All occupational exposures .............................................
10 rems * ..............................
Protecting valuable property necessary for public welfare (e.g., a power plant).
25 rems ** .............................
Lifesaving or protection of large populations ..................
All reasonably achievable actions have been taken to
minimize dose.
Exceeding 5 rems unavoidable and all appropriate actions taken to reduce dose. Monitoring available to
project or measure dose.
Exceeding 5 rems unavoidable and all appropriate actions taken to reduce dose. Monitoring available to
project or measure dose.
* For potential does >10 rems, special medical monitoring programs should be employed, and exposure should be tracked in terms of the unit
of absorbed dose (rad) rather than TEDE (rem).
** In the case of a very large incident such as an IND, incident commanders may need to consider raising the property and lifesaving response
worker guidelines in order to prevent further loss of life and massive spread of destruction.
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It is likely during most RDD incidents that
the radiation control measures discussed
above will be able to maintain doses below
the 5 rem occupational exposure PAG in
almost all situations, including fire fighting;
general emergency response; and transport
to, and medical treatment of, contaminated
victims at hospitals. However, in those
situations in which victims are injured or
trapped in high radiation areas or only be
reached via high radiation areas, exposure
control options may be unavailable or
insufficient, and doses above 5 rem may be
unavoidable.
Response decisions allowing actions that
could result in doses in excess of 5 rems can
only be made at the time of the incident,
under consideration of the actual situation.
In such situations, incident commanders and
other responders need to understand the risk
posed by such exposures in order to make
informed decisions. The Response Worker
Guidelines for life and property saving
activities in Table 1B are provided to assist
such decisions.
The catastrophic event represented by an
IND can cause other immediate widespread
physical hazards such as firestorm and
building instability; emergency intervention
will be integral to preventing further loss of
life and additional destruction. This
intervention may result in increased
exposure to emergency response personnel.
Exceeding the Response Worker Guidelines
in Table 1B in such an event may be
unavoidable.
Persons undertaking an emergency mission
covered under the alternative occupational
PAG levels should do so with full awareness
of the sub-chronic and chronic risks
involved, including knowledge of numerical
estimates of the risk of delayed effects, and
they should be given reasonable assurance
that normal controls cannot be utilized to
reduce doses below the general 5 rem
occupational exposure PAG. The 25 rem
lifesaving Response Worker Guidelines
provide assurance that exposures will not
result in detrimental deterministic health
effects (i.e., prompt or acute effects). If, due
to extensive public health and welfare
benefits (i.e., optimization considerations),
response actions are deemed necessary that
cause exposures that may exceed the 25 rem
alternative Response Worker Guideline, such
response actions should only be taken with
an understanding of the potential acute
effects of radiation to the exposed responder
(Table 1C) and based on the determination
that the benefits of the action clearly exceed
the associated risks.
2 Alternative response worker guidelines are
applicable only during emergency situations. They
typically apply during the early phase of the
emergency but may also be applicable in later
phases under emergency situations such as a fire or
a structure failure that puts life and property at risk.
In addition to the obvious life saving situation,
other examples of where the guidelines may be
applicable include situations where it is necessary
to access controls to prevent or mitigate explosions,
fires or other catastrophic events. The alternative
response worker guidelines are not applicable to
normal restoration or cleanup actions.
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The following paragraph is presented to
help illustrate how certain toxicity
information may be relevant in response
decisionmaking during emergencies. It is
important to note that the approach used
below to translate dose to risk in this
discussion is a simplistic approach useful in
developing rough estimates of risks for
comparative purposes given limited data.
However, other more realistic approaches are
often used in assessing risks for risk
management decisions (other than for
emergencies) when more complete
information about the contaminants and the
potential for human exposure is available.
These other approaches rely on radionuclidespecific risk factors (e.g., Federal Guidance
Report #13 3 and EPA Health Effects
Assessment Summary Tables).
The estimated risk of fatal cancer 4 for
workers exposed to 10 rem is 0.6 percent (six
cases per thousand exposed). Workers
exposed to 25 rem have an estimated risk of
fatal cancer of 1.5 percent (15 cases per
thousand exposed). Because of the latency
period of cancer, younger workers face a
larger risk of fatal cancer than older workers
(for example, when exposed to 25 rem,
twenty to 30 year-olds have a 9.1 per
thousand risk of premature death, while 40
3 ‘‘Risks from Low-Level Environmental Exposure
to Radionuclides,’’ Federal Guidance Report #13,
U.S. Environmental Protection Agency, January
1998, EPA 402–R–97–014.
4 Risk per dose of a fatal concern is assumed to
be about 6×10¥4 per rem. Cancer incidence is
assumed to be about 7×10¥4 per rem. (See Federal
Guidance Report #13.
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to 50 year-olds have a 5.3 per thousand risk
of premature death).5
(f) Incident Commanders and Responders
Need to Proper Training in Advance
When the 5-rem guideline is exceeded,
workers should be provided the following:
• Medical follow-up
• Training with respect to the risk
associated with exposure to ionizing
radiation
• A thorough explanation of the latent
risks associated with receiving exposures
greater than 5 rems.
In addition, these PAGs represent dose
constraint levels (e.g., when this level of dose
is accumulated, the responder should not
take part in the later stages of the response
that may significantly increase their dose). It
is assumed that doses acquired in response
to a radiological incident would be ‘‘once in
a lifetime’’ doses, and that future radiological
exposures would be substantially less.
Incident commanders and responders need
a thorough understanding of the worker
exposure guidelines for radiological
emergency response, including the associated
risks and specific worker protection
procedures. The reader is referred to the EPA
PAG Manual and Protective Actions for
Nuclear Incidents (May 1992), and the
Federal Radiological Monitoring and
Assessment Center (FRMAC) Radiological
Emergency Response Health and Safety
Manual (May 2001).6
5 Federal
Guidance Report #13.
at https://www.nv.doe.gov/programs/
frmac/DOCUMENTS.htm.
6 Available
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187
(g) Occupational Standards
Under the provisions of the Occupational
Safety and Health Act, and equivalent
statutes in the 26 States that operate OSHAapproved State plans, each employer is
responsible for the health and safety of its
employees. In accomplishing this, employers
are expected to comply with the
requirements of the Federal OSHA or State
plan occupational safety and health
standards applicable in the jurisdiction in
which they are working. States with State
plans enforce standards, under State law,
which are ‘‘at least as effective as’’ Federal
OSHA standards, and therefore may have
more stringent or supplemental
requirements. There are currently 22 States
and jurisdictions operating complete State
plans (covering both the private sector and
State and local government employees,
including State and local emergency
responders). Four of these State plans cover
public (State and local government)
employees only. Federal OSHA administers
the safety and health program for the private
sector in the remaining States and territories,
and also retains authority with regard to
safety and health conditions for Federal
employees throughout the nation, but it does
not have enforcement jurisdiction over State
and local government employees.
The primary occupational safety and
health standard for emergency response is
the Hazardous Waste Operations and
Emergency Response (HAZWOPER) standard
(29 CFR 1910.120). The EPA has a Worker
Protection (40 CFR 311) standard that applies
the HAZWOPER standard to State and local
workers in States that do not have their own
occupational safety and health program.
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For emergency response, the OSHA
standard (among many other requirements)
states that ‘‘the individual in charge of the
incident command system shall identify to
the extent possible, all hazardous substances
or conditions present and shall address as
appropriate site analysis, use of engineering
controls, maximum exposure limits,
hazardous substance handling procedures,
and use of any new technologies’’ (29 CFR
1910.120(q)). As part of emergency
preparedness activities, individuals
authorized as incident commanders should
receive the necessary training and planning
prior to the incident, use the hazard
information available, consult relevant
standards, and apply all feasible and useful
measures to minimize hazards to emergency
responders.
OSHA’s ionizing radiation standard (29
CFR 1910.1096), which may also apply in
certain circumstances, limits quarterly dose 7
and includes other requirements such as
monitoring, recordkeeping, training, and
reporting.
The worker exposure levels are not PAGs
but instead are regulatory limits that cannot
be exceeded except under certain conditions.
These occupational limits allow workers to
receive radiation exposure during the course
of performing their jobs. This limit offers the
possibility that industrial and manufacturing
facilities, critical infrastructures and other
business operations could be reopened
without having to be cleaned up, as long as
they are in compliance with the 5 rem dose
limit and other OSHA requirements found in
29 CFR 1910.1096. Otherwise, the relocation
PAGs could be used by decision makers to
protect their citizens.
DOE employees and contractors are subject
to DOE radiation protection regulations, and
requirements for worker protection from
radiation exposure are contained in 10 CFR
part 835. These requirements apply to all
DOE employees and contractors that may be
exposed to ionizing radiation as a result of
their work for DOE, including work relating
to emergency response activities. Section
835.3(d) indicates that nothing in the
regulation ‘‘shall be construed as limiting
actions that may be necessary to protect
health and safety.’’ This clause is intended to
recognize the fact that during emergencies,
lifesaving or property-saving actions may
necessitate actions that have the potential to
cause doses in excess of the Department’s
radiation dose limits. Subpart N of section
835 provides direction for emergency
exposure situations and indicates that:
• The risk of injury should be minimized.
• Actual and potential risks should be
weighed against benefits of such actions
causing exposures.
• No individual should be forced to
perform a rescue action that involves
substantial personal risk.
• Individuals authorized to perform
emergency actions that may result in
exposures exceeding DOE dose limits should
7 1.25 rems or rems if cumulative lifetime dose is
less than 5(n–18), where n is the worker’s age at the
last birthday, and adequate past and current
exposure records are maintained to show exposures
do not exceed the standard’s radiation levels (29
CFR 1910.1096).
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receive prior training and briefing on known
or anticipated hazards.
Under all circumstances, doses should be
maintained as low as is reasonably
achievable. Under DOE requirements,
emergency response doses are not included
with worker doses measured and calculated
to demonstrate compliance with 10 CFR Part
835 dose limits.
Requirements for the protection of NRC
employees are covered by NRC Management
Directive 10.131, ‘‘Protection of NRC
Employees Against Ionizing Radiation.’’
Section VI, Guidance for Emergency
Exposure Controls During Rescue and
Recovery Activities, deals specifically with
radiation exposure control during
emergencies. Section VI adopts the dose
limits in the EPA PAG Manual (EPA 400–R–
92–001) for exposure of NRC employees
during emergencies. Similarly, NRC and
Agreement State licensees have established
on-site exposure guidelines consistent with
EPA PAGs.
For an IND incident, the radiological
consequences could be so severe that many
workers would be exposed in activities, such
as emergency lifesaving functions, that
would result in doses in excess of the 5 rem
limit for normal occupational activities.
Appendix 2—Risk Management
Framework for RDD/IND Incident
Planning
This appendix contains a description of a
risk management framework for making
decisions to protect public health and
welfare in the context of cleanup and site
restoration following an RDD or IND
incident. The framework is based on the
report, ‘‘Framework for Environmental Health
Risk Management,’’ mandated by the 1990
Clean Air Act Amendments published by the
Commission on Risk Assessment and Risk
Management in 1997. This appendix
provides specific material for RDD and IND
incidents, and reference to the report is
encouraged for the details of the general
framework. Details of a plan for
implementing this framework for certain
RDD and IND incidents are provided in
Appendix 4.
The ‘‘Framework for Environmental Health
Risk Management’’ is considered generally
suitable for addressing the long-term
recovery issues for RDDs and INDs. Given the
time frames following an RDD or IND
incident, there is generally not sufficient time
in the early and intermediate phases to
conduct full risk assessment and get
stakeholder involvement. Therefore, in order
for the framework to be effective for these
phases, it must be used in planning and
preparing for a radiological or nuclear
incident. As a result, many of the principles
have already been incorporated into the
establishment of the PAGs for RDD and IND
incidents on a generic basis.
The framework is designed to help
decision makers make good risk management
decisions. The level of effort and resources
invested in using the framework should be
scaled to the importance of the problem, the
potential severity and economic impact of
the risk, the level of controversy surrounding
the problem, and resource constraints. In the
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context of an RDD or IND incident, the risk
management decisions involve responding to
the consequences of a particular incident.
The risks that must be considered are both
radiation risks and potentially chemical or
biological agents. Other factors to be
considered include the continued sense of
uncertainty and disruption in normal
activities; the loss of, or limited access to,
critical infrastructure and health care; and
general economic disruption.
The framework relies on the three key
principles of broad context, stakeholder
participation, and iteration. Broad context
refers to placing all of the health and
environmental issues in the real-world
context following an RDD or IND incident,
and is intended to assure that all public
welfare related factors and impacts are taken
into account. Stakeholder participation is
critical to making and successfully
implementing sound, cost-effective, riskinformed decisions. Iteration is the process of
continuing to refine the information
available, and therefore the decisions and
actions that can be taken at any point in time.
Together these principles outline a fair,
responsive approach to making the decisions
necessary to effectively respond to the
impacts of an RDD or IND incident.
Risk management is the process of
identifying, evaluating, selecting, and
implementing actions to reduce risk to public
health and the environment. The goal of risk
management is scientifically sound, costeffective, integrated actions that reduce or
prevent risks while taking into account
social, cultural, ethical, public policy, and
legal considerations. In order to accomplish
this goal, information will be needed on the
nature and magnitude of the risks present as
a result of the incident, the options for
reducing or eliminating the risks, and the
effectiveness and costs of those options.
Decision makers also consider the economic,
social, cultural, ethical, legal, and public
policy implications associated with
implementing each option, as well as the
unique safety and health hazards facing
emergency workers and community health,
or ecological hazards the cleanup actions
themselves may cause. Often a stakeholder
advisory group can provide the advice
needed to consider all of the relevant
information.
Stakeholders can provide valuable input to
decision makers during the long-term
recovery effort, and the key decision makers
should establish a process that provides for
appropriate stakeholder input. Identifying
which stakeholders need to be involved in
the process depends on the situation. In the
case of a site contaminated as a result of an
RDD or IND incident, stakeholders may
include those whose health, economic wellbeing, and quality of life are currently
affected or would be affected by the cleanup
and the site’s subsequent use. They may also
include those who are legally responsible for
the site’s contamination and cleanup, those
with regulatory responsibility, and those who
may speak on behalf of environmental
considerations or future generations.
Stakeholder input should be considered
throughout all stages of the framework as
appropriate, including analyzing the risks,
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identifying potential cleanup options,
evaluating options, selecting an approach,
and evaluating the effectiveness of the action
afterwards. Their input will assist decision
makers in providing a reasonable basis for
actions to be taken. Further information on
the importance and selection of stakeholders
can be found in the Framework for
Environmental Health Risk Management.
Decision makers can also benefit from the
use of working groups that can provide
expert technical advice regarding the
decisions that need to be made during the
long-term recovery process. Further
information on how to incorporate the use of
technical working groups is provided later in
this appendix.
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(a) The Stages of the Risk Management
Framework for Responding to RDD and IND
Incidents
The ‘‘Framework for Environmental Health
Risk Management’’ has six stages:
1. Define the problem and put it in context.
2. Analyze the risks associated with the
problem in context.
3. Examine options for addressing the
risks.
4. Make decisions about which options to
implement.
5. Take actions to implement the decisions.
6. Evaluate results of the actions taken.
Risk management decisions under this
framework should do the following:
• Clearly articulate all of the problems in
their public health and ecological contexts,
not just those associated with radiation.
• Emerge from a decisionmaking process
that elicits the views of those affected by the
decision.
• Be based on the best available scientific,
economic, and other technical evidence.
• Be implemented with stakeholder
support in a manner that is effective,
expeditious, and flexible.
• Be shown to have a significant impact on
the risks of concern.
• Be revised and changed when significant
new information becomes available.
• Account for their multi-source,
multimedia, multi-chemical, and multi-risk
contexts.
• Be feasible, with benefits reasonably
related to their costs.
• Give priority to preventing risks, not just
controlling them.
• Be sensitive to political, social, legal, and
cultural considerations.
(1) Define the Problems and Put Them in
Context
In the case of RDDs, the initial problem is
caused by the dispersal of radioactive
material. This dispersion may also result in
the release of other types of contaminants
(chemical or biological) or create other types
of public health hazards. Individuals exposed
may include workers and members of the
public, and there may be different associated
assumptions; for example, how long the
individuals will be exposed in the future.
The potential for future radiation exposure
must be considered within the context of the
societal objectives to be achieved, and must
examine the options in the context of all of
the other sources, hazards, and impacts the
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community faces. There may also be broader
public health or environmental issues that
local governments and public health agencies
have to confront and consider.
Understanding the context of a risk problem
is essential for effectively managing the risk.
The goals of the recovery will extend well
beyond the reduction of potential delayed
radiation health effects, and may include:
• Public health protection goals, including
acute hazards, long-term chronic issues, and
protection of children and other sensitive
populations.
• Social and economic goals, such as
minimizing disruption to communities and
businesses, maintaining property values, and
protecting historical or cultural landmarks or
resources.
• National security goals, such as
maintaining and normalizing use of critical
arteries, airports, or seaports for mass transit;
maintaining energy production; and
providing for critical communications.
• Public welfare goals, including
maintaining hospital capacity, water
treatment works, and sewerage systems for
protection of community health; assuring
adequate food, fuel, power, and other
essential resources; and providing for the
protection or recovery of personal property.
(2) Analyze the Risks
To make effective risk management
decisions, decision makers and other
stakeholders need to know what potential
harm a situation poses and how great is the
likelihood that people or the environment
will be harmed. The nature, extent, and focus
of a risk assessment should be guided by the
risk management goals. The results of a risk
assessment—along with information about
public values, statutory requirements, court
decisions, equity considerations, benefits,
and costs—are used to decide whether and
how to manage the risks.
Risk assessments can be controversial,
reflecting the important role that both science
and judgment play in drawing conclusions
about the likelihood of effects on public
health and the environment. It is important
that risk assessors respect the objective
scientific basis of risks and procedures for
making inferences in the absence of adequate
data. Risk assessors should provide decision
makers and other stakeholders with plausible
conclusions about risk that can be made on
the basis of the available information, along
with evaluations of the scientific support for
those conclusions, descriptions of major
sources of uncertainty, and alternative views.
Stakeholders’ perception of a risk can vary
substantially depending on such factors as
the extent to which the stakeholders are
directly affected, whether they have
voluntarily assumed the risk or had the risk
imposed on them, and whether they are
connected with the cause of the risk. For this
reason, risk assessments should characterize
the scientific aspects of a risk and note its
subjective, cultural, and comparative
dimensions. Stakeholders play an important
role in providing information that should be
used in risk assessments and in identifying
specific health and ecological concerns that
should be considered.
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(3) Examine the Options
This stage of the risk management process
involves identifying potential recovery
management options and evaluating their
effectiveness, feasibility, costs, benefits,
cultural or social impacts, and unintended
consequences. This process can begin
whenever appropriate, after defining the
problem and considering the context. It does
not have to wait until the risk analysis is
completed, although a risk analysis often will
provide important information for identifying
and evaluating risk management options. In
some cases, examining risk management
options may help refine a risk analysis. Risk
management goals may be redefined after
decision makers and stakeholders gain some
appreciation for what is feasible, what the
costs and benefits are, and what contribution
reducing exposures and risks can make
toward improving human and ecological
health.
Once potential options have been
identified, the effectiveness, feasibility,
benefits, detriments, and costs of each option
must be assessed to provide input into
selecting an option. Key questions include
determining (1) the expected benefits and
costs; (2) who gains the benefits and who
bears the costs; (3) the feasibility of the
option given the available time; resources;
and any legal, political, statutory, and
technology limitations; and (4) whether the
option increases certain risks while reducing
others. Other adverse consequences may be
cultural, political, social, or economic—such
as economic impacts on a community,
including reduced property values or loss of
jobs; environmental justice issues; and
harming the social fabric of a town or tribe
by relocating the people away from a
contaminated area.
Many risk management options may be
unfeasible for social, political, cultural, legal,
or economic reasons—or because they do not
reduce risks to the extent needed. For
example, removing all the soil from an entire
valley that is heavily contaminated with
radioactive material may be infeasible. On
the other hand, the costs of cleaning up an
elementary school may be considered
justified by their benefits: protecting children
and returning daily activities to a sense of
normalcy. Of course, the feasibility and costeffectiveness of an option may change in the
future as technology is improved or as
society’s values change.
(4) Make a Decision
A productive stakeholder involvement
process can generate important guidance for
decision makers. Thus, decisions may reflect
negotiation and compromise, as long as risk
management goals and intent are met. In
some cases, win-win solutions are available
that allow stakeholders with divergent views
to achieve their primary goals.
Decision makers must balance the value of
obtaining additional information against the
need for a decision, however uncertain.
Sometimes a decision must be made
primarily on a precautionary basis. Every
effort should be made to avoid ‘‘paralysis by
analysis,’’ in which the need for additional
information, or the inability to reach
consensus, is used as an excuse to avoid or
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postpone decisionmaking. When sufficient
information is available to make a risk
management decision, or when additional
information or analysis would not contribute
significantly to the quality of the decision,
the decision should not be postponed.
‘‘Value-of-information’’ techniques can be
used to provide perspective on the next steps
to be taken.
(5) Take Action To Implement Decision
When options have been evaluated and
decisions made, a plan for action should be
developed and implemented. Traditionally,
implementation of protective actions is
driven by decision makers’ responsibilities to
protect the public and the environment. State
and local officials, business leaders, private
industries, and the general public are
generally the implementers of these
protective actions. Actions may take
considerable time for completion, and
additional decisions may often be necessary
as the actions proceed.
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(6) Evaluate the Results
Decision makers and other stakeholders
must continue to review what risk
management actions have been implemented
and how effective these actions have been.
Evaluating effectiveness involves monitoring
and measuring, as well as comparing actual
benefits and costs to estimates made in the
decisionmaking stage. The effectiveness of
the process leading to implementation
should also be evaluated at this stage.
Evaluation provides important information
about: Whether the actions were successful;
whether they accomplished what was
intended; whether the predicted benefits and
costs were accurate; whether any
modifications are needed to the risk
management plan to improve success;
whether any critical information gaps
hindered success; whether any new
information has emerged that indicates a
decision or a stage of the framework should
be revisited; whether the process was
effective; how stakeholder involvement
contributed to the outcome; and what lessons
can be learned to guide future risk
management decisions or to improve the
decisionmaking process.
Evaluation is critical to accountability and
to ensure wise use of valuable but limited
resources. Tools for evaluation include
environmental and health monitoring,
research, disease surveillance, analyses of
costs and benefits, and discussions with
stakeholders.
(b) Technical Advisory Groups
Making decisions on the appropriate
cleanup approaches and levels following an
RDD or IND incident of any significant size
will undoubtedly be a challenging task for
decision makers. As already noted, the
technical issues may be complex, many
potentially competing factors will need to be
carefully weighed, and public anxiety can be
expected to be high in the face of a terrorist
act involving radioactive materials. In
addition, it is recognized that different
regulatory authorities and organizations
historically have taken different cleanup
approaches for radioactively contaminated
sites. Given this context, decision makers
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will need to determine how best to obtain the
necessary technical input to support these
decisions and demonstrate to the public that
the final decisions are credible and sound.
There are a variety of ways this approach
may be accomplished, and decision makers
will need to tailor a process best suited to
particular site circumstances. This section
describes one process that is available to
decision makers, which is based on the ‘‘ad
hoc’’ mechanisms used for coordinating
interagency expertise and assessing the
effectiveness in general of the cleanup in
response to the 2001 anthrax attacks. The
anthrax cleanup involved the use of two
technical groups that were used to advise key
decision makers: a technical working group
and a technical peer review advisory
committee. (Unlike the other steps described
in this appendix, these concepts are not
described in the 1997 framework and are
thus described in greater detail here.)
(1) Technical Working Group
Decision makers may choose to convene a
technical working group to provide multiagency, multi-disciplinary expert input to the
planning and implementation of the cleanup
effort, especially in setting appropriate
cleanup goals and developing strategies for
meeting them.
The group would be an ad hoc technical
advisory group, not a decisionmaking body.
It may include representatives from Federal,
State, local, and tribal agencies. It may also
include experts from the private sector or
universities. Inclusion of a qualified local
physician or health official also helps
enhance the credibility of the working group
within the community.
The composition of the group and the
scope of its charter will vary depending on
the needs of the situation and the nature of
the contamination. For example, expertise in
chemical or radiation toxicology will be
needed for attacks involving chemical or
radioactive agents. In some cases (e.g., where
there is simultaneous release of similar
contamination at numerous locations), one
working group may be charged with
providing national-level advice to be applied
locally at multiple individual sites. In other
cases (i.e., where contamination is minimal
or exposure is unlikely), a technical working
group may not be necessary.
A technical working group can provide
expert input in the form of cross-agency
coordination on technical issues, analysis of
relevant requirements and guidelines, review
of data and plans, and recommendations that
will aid in ensuring that cleanup will be
adequate. The group may also provide
technical information to the Joint Information
Center (JIC) to explain public health or
environmental impacts to the public and the
press. This group, like the advisory
committee discussed below, reports to the
decision maker, however, and not directly to
the public. A technical working group can
complement other ‘‘special teams’’ that may
assist in the recovery effort, and
representatives from these other special
teams may be members of the technical
working group.
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(2) Technical Peer Review Advisory
Committee
For significant decontamination efforts, the
key decision makers may choose to convene
an independent committee of technical
experts to conduct a deliberative and
comprehensive post-decontamination review.
The committee would evaluate the
effectiveness of the decontamination process
and make recommendations on whether the
decontaminated areas or items may be
reoccupied or reused. It is important to note
that although this review may enhance the
scientific credibility of the final outcome,
final cleanup decisions rest with decision
makers.
The committee may consist of experts from
the involved Federal agencies, State and
tribal public health and environmental
agencies, universities and private industry,
the local health department, and possibly
representatives of the employees and the
community. To maximize objectivity, the
committee would be an independent group
that will advise and report to the decision
makers, but not be a part of the
decisionmaking team.
The scientific expertise in the committee
should reflect the needs of the decision
makers in conducting a peer review of all
aspects of the decontamination process (e.g.,
environmental sampling, epidemiology, risk
assessment, industrial hygiene, statistics, and
engineering). Agencies on the committee may
also have representatives on the technical
working group, but in order to preserve the
objectivity of the committee, it is best to
designate different experts to serve on each
group. The chair and co-chair of the
committee should not be a part of the
decisionmaking group at the site.
The decision makers should develop a
charter for the committee, specifying the
tasks committee members are intended to
perform, the issues they are to consider, and
the process they will use in arriving at
conclusions and recommendations. The
charter should also specify whether the
individual members are expected to
represent the views of their respective
agencies or just their own opinions as
independent scientific experts. Consensus
among committee members is desirable but
may not be possible. If consensus cannot be
achieved, the charter should specify how
decision makers expect the full range of
opinions to be reflected in the final
committee report. All members of the
committee should agree to the terms of
charter and sign it before participating.
In general, the technical peer review
committee would evaluate pre- and postdecontamination sampling data, the
decontamination plan, and any other
information key to assessing the effectiveness
of the cleanup. Based on this evaluation, the
committee would make recommendations to
the decision makers on whether cleanup has
reduced contamination to acceptable levels,
or whether further actions are needed before
re-occupancy.
Appendix 3—Federal Implementation
This appendix provides an implementation
plan for the protective action
recommendations in the body of this
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document. It also describes how to
implement the risk management framework
for recovery after a radiological or nuclear
incident described in Appendix 2. This
implementation plan presents the Federal
role in long-term site restoration, and how
Federal departments and agencies will
interact with State and local government
counterparts and the public. The plan does
not attempt to provide detailed descriptions
of State and local roles and expertise. It is
assumed those details would be provided in
State-, area-, and local-level planning
documents that address radiological/nuclear
terrorism incidents.
This site cleanup implementation plan is
intended to function under the National
Response Plan (NRP) with Federal agencies
performing work consistent with their
established roles, responsibilities and
capabilities. Agencies should be tasked to
perform work under the appropriate
Emergency Support Function, as a primary or
support agency, as described in the NRP.
This plan is designed to be compatible
with the Incident Command/Unified
Command (IC/UC) structure embodied in the
National Incident Management System
(NIMS). The functional descriptions and
processes in this plan are provided to address
the specific needs and wide range of
potential impacts of an RDD or IND incident.
During the intermediate phase, site
restoration planners should begin the process
described below, in coordination with the
on-site IC/UC. Coordination of Federal
activities may organize along IC/UC
functional lines coordinating with the on-site
organization to avoid redundancy. After early
and intermediate phase activities have come
to conclusion, and only long-term cleanup
and site restoration activities are ongoing, the
IC/UC structure may continue to support
planning and decisionmaking for the longterm cleanup. The IC/UC may make
personnel changes and structural adaptations
to suit the needs of a lengthy, multifaceted
and highly visible remediation process. For
example, a less formal and structured
command, more focused on technical
analysis and stakeholder involvement, may
be preferable for site restoration than what is
required under emergency circumstances.
Some of the Teams described below, such as
the Decision Team or the Recovery
Management Team may be coordinated from,
or coincident with, functional portions of the
IC/UC at the site. Although the makeup of the
Teams may vary, the functions should
remain the same.
Radiological and nuclear terrorism
incidents cover a broad range of potential
scenarios and impacts. For the sake of this
appendix, it is assumed that the incident is
of sufficient size to trigger a State request for
Federal assistance, and that the Federal
Government is the primary funding agent for
site restoration. In particular the process,
described for the late phase in Section D.3.3
of this document, assumes an incident of
larger size. For smaller incidents, all of the
elements in this section may not be
warranted. The process should be tailored to
the circumstances of the particular incident.
It should be recognized that for some
radiological/nuclear terrorist incidents,
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States will take the primary leadership role
and contribute significant resources toward
restoration of the site. This section does not
address such a scenario.
As described earlier in the document,
radiological/nuclear emergency responses are
often divided roughly into three phases: (1)
The early phase, when the plume is active
and field data are lacking or not reliable; (2)
the intermediate phase, when the plume has
passed and field data are available for
assessment and analysis; and (3) the late
phase, when long-term issues are addressed,
such as restoration of the site. For purposes
of this appendix, the response to a
radiological or nuclear terrorism incident is
divided into two separate, but interrelated
and overlapping, processes. The first is
comprised of the early and intermediate
phases of response, which consist of the
immediate on-scene actions of State and local
first responders under Incident Command/
Unified Command (IC/UC), as well as those
of Federal teams and officials, to perform
incident stabilization, lifesaving activities,
access control and security, emergency
decontamination of persons and property,
‘‘hot spot’’ removal actions, dose reduction
actions for members of the public and
emergency responders, and resumption of
basic infrastructure functions.
The second process pertains to
environmental restoration, which is initiated
soon after the incident (during the
intermediate phase) and continues into the
late phase. The process starts with the
convening of stakeholders and technical
subject matter experts to begin identifying
and evaluating options for the restoration of
the site. The environmental restoration
process overlaps the intermediate phase
activities described above and should be
coordinated with those activities.
This implementation plan does not address
law enforcement coordination during
terrorism incident response, including how
the Federal Bureau of Investigation (FBI) and
DHS will manage on-scene actions
immediately following an act of terror. Also,
victim triage and other medical response
aspects are not addressed. The plan
presented in this appendix is not intended
for use at site cleanups occurring under other
statutory authorities such as EPA’s
Superfund program, the NRC’s
decommissioning program, or Stateadministered cleanup programs.
(a) Response and Recovery Activities
Overview
The following are actions expected to
occur according to existing plans, protocols,
and capabilities. These early activities are
primarily for context and are not intended to
be exhaustive. The major change from
current operating plans and protocols is the
assumption of Federal leadership by DHS.
The early phase of the response will be run
at the scene by State and local responders,
who are likely to make protective action
decisions for the protection of public health,
property, and environment early in the
incident based on judgment, protocol, and
what limited data are available. As Federal
response assets arrive on scene, they will be
incorporated into the on-scene incident
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command established by State and local
officials and then become part of the unified
command structure. Other Federal assets will
be located in the Joint Field Office (JFO), colocated with a State/local Emergency
Operations Center (EOC), if possible, to
support the local incident management
activities.
(1) Early Phase
0–3 hours.
• Local incident command established
• Radiation detected and a terrorism
incident recognized
• DHS Homeland Security Operations
Center (HSOC) notified of incident and
mobilized to provide support and
coordination until JFO is operational
• DHS determines if this incident is an
Incident of National Significance, as defined
in the NRP
• Initial protective actions ordered
(downwind shelter-in-place/evacuation)
Comments:
• Some Federal assets will self-deploy
under their own authority (HHS, FBI, OSHA,
EPA, DOE)
• Protective actions by locals likely to
occur before Federal assets arrive
6 hours.
• DHS designates a Principal Federal
Official (PFO)
• Nuclear Incident Response Team (NIRT)
activated by DHS (i.e. Radiological
Assistance Program (RAP), Aerial Measuring
System (AMS), FRMAC, Radiation
Emergency Assistance Center/Training Site
(REAC/TS), Radiological Emergency
Response Team (RERT))
• Initial dispersion plots developed, other
analyses done, and initial Federal protective
action recommendations may be provided
• Domestic Emergency Support Team
(DEST) deploys
Comments:
• An ‘‘Initial PFO’’ may be named until the
PFO can arrive at the site
• The PFO may deploy with the DEST
• The PFO is responsible for coordinating
Federal assets in collaboration with other
Federal officials
6–12 hours.
• Initial JFO established to include FBI
Joint Operations Center (JOC)
• Advance FRMAC stood up, field
measurements being taken
• AMS arrives, provides initial deposition
data to JFO
12–24 hours.
• JFO operational
• Federal teams in place (NIRT, DEST,
Advisory Team for Food and Health)
• PAG being provided by JFO to State and
local decision makers
• State requests, and is granted, a major
disaster or emergency declaration
Early phase activities are expected to
proceed as described under existing plans
and agreements. If DHS declares an Incident
of National Significance, the PFO will
coordinate Federal activities from the JFO
and integrate Federal activities in support of
the State and local response. A Robert T.
Stafford Disaster Relief and Emergency
Assistance Act declaration will facilitate
funding for public and individual assistance,
and for recovery operations.
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In general, the primary agencies expected
to be represented in the unified command for
an RDD or IND response incident are the
agencies with primary response authority
and include DHS, FBI, DOE, EPA, and other
Federal, State, and local government
agencies, as appropriate. Other Federal
agencies (e.g., NRC, OSHA, U.S. Army Corps
of Engineers, and DoD) will be requested to
support the response in accordance with the
NRP and NIMS.
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(2) Intermediate Phase
During the intermediate phase, actions
initiated in the early phase will continue as
needed, such as lifesaving, fire suppression,
perimeter security, and field data collection
and analysis. Preliminary shelter-in-place or
evacuation may occur within the first hours
at the order of local incident command, but
as data become available, Federal, State, and
local officials will have better information
with which to make protective action
decisions, assist emergency workers, and
inform the public.
Federal protective action recommendations
will be provided to State and local
governments on public dose constraints,
restrictions regarding consumption of food
and water, and dose reduction actions.
Intermediate phase actions may include
relocation, control of public access,
decontamination of persons,
decontamination/removal of ‘‘hot spots,’’
response worker dose monitoring, population
monitoring, food and water controls, and
clearance of personal property. Public
information and communication programs
should be implemented as soon as
practicable. Federal officials will work with
State and local officials to develop
information for the public in coordination
with the JIC. (See the ‘‘Application of PAGs
for RDD or IND Incidents’’ for more
information on intermediate phase protective
actions and recommendations.)
(3) Late Phase—Recovery and Site
Restoration Activities Process Overview
As noted earlier, the long-term recovery
process should be initiated during the
intermediate phase. This process is
interrelated with the ongoing intermediate
phase activities, and the intermediate phase
protective actions continue to apply through
the late phase until cleanup is complete.
However, the long-term recovery phase is
likely to involve separate individuals who
can focus on long-term restoration issues
while others continue working on
intermediate phase activities.
Cleanup planning and discussions should
begin as soon as practicable after an incident
to allow for selection of key stakeholders and
subject matter experts, planning, analyses,
contractual processes, and cleanup activities.
States may choose to pre-determine
stakeholders. These activities should proceed
in parallel with ongoing intermediate phase
activities, and coordination between these
sets of activities should be maintained.
Preliminary remediation activities carried out
during the intermediate phase—such as
emergency removals, decontamination,
resumption of basic infrastructure function,
and some return to normalcy in accordance
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with intermediate phase guidelines—should
not be delayed for the final site remediation
decision.
Presented below is a process for addressing
environmental contamination that applies an
optimization process for site cleanup.
Optimization (described more fully in the
‘‘Application of PAGs for RDD or IND
Incidents’’) is a flexible process in which
numerous factors are considered to achieve
an end result that balances local needs and
desires, health risks, costs, technical
feasibility, and other factors. The general
process outlined below provides decision
makers with input from both technical
experts and stakeholder representatives, as
well as providing an opportunity for public
comment. The extent and complexity of the
process for an actual incident should be
tailored to the needs of the specific incident;
for smaller incidents, the teams discussed
below may not be necessary.
The goals of the process described below
are: (1) Transparency—the basis for cleanup
decisions should be available to stakeholder
representatives, and ultimately to the public
at large; (2) inclusiveness—representative
stakeholders should be involved in
decisionmaking activities; (3) effectiveness—
technical subject matter experts should
analyze remediation options, consider dose
and risk benchmarks, and assess various
technologies in order to assist in identifying
a final solution that is optimal for the
incident; and (4) shared accountability—the
final decision to proceed will be made jointly
by DHS, State, and local officials.
If Federal agencies do not have their own
authorities to enable them to participate in
the overall recovery and restoration process,
then DHS would issue mission assignments
to the involved Federal agencies to
participate in the overall recovery and
restoration process. Additional funding may
be provided to State/local governments to
perform response/restoration activities
through other mechanisms. The components
of the process are as follows:
(i) Teams
(A) Decision Team
Makeup: The Decision Team consists of the
Secretary of DHS, the governor of the State,
the mayor or equivalent, and the head of the
lead Federal agency (or their respective
designated representatives with authority to
commit resources on behalf of affected
persons).
Function: The function of the Decision
Team is to make the final decision on
recommendations received from the
Recovery Management Team, commit
resources, and commence cleanup activities.
The Decision Team will raise unresolved
national level policy issues to the Interagency
Incident Management Group (IIMG) and/or to
the Assistant to the President for Homeland
Security, as appropriate.
(B) Recovery Management Team
State and DHS officials should select a
Recovery Management Team as soon as
possible after the incident. The size and
makeup of the team will be dependent on the
incident, but would be expected to consist of
senior-level officials. The Recovery
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Management Team will normally be located
at the JFO in order to enhance information
flow and response coordination.
Makeup: The Recovery Management Team
should include DHS, affected State and/or
local representatives, and the Federal lead
technical agency. The Recovery Management
Team should be co-chaired by a DHS and
State official. The makeup is flexible and
may accommodate other individuals, as
necessary.
Functions: The functions of the Recovery
Management Team are to select participants
for the Stakeholder and Technical Working
Groups; provide facilitation, oversight and
guidance during the cleanup analyses and
decisionmaking process; oversee working
group interactions; maintain communications
between working groups; receive and review
options and recommendations; ensure the
development and implementation of
community involvement and public
information strategy; and prioritize
recommendations when they are forwarded
to the Decision Team for action.
(C) Stakeholder Working Group
The Stakeholder Working Group should be
convened as soon as practicable, normally
within weeks of the incident.
Makeup: The Stakeholder Working Group
should include selected Federal, State, and
local representatives; local non-governmental
representatives; and local business interests.
The exact selection and balance of
stakeholders is incident specific. The
Stakeholder Working Group should be cochaired by DHS and State and/or local
representatives.
Function: The function of the Stakeholder
Working Group is to provide input to the
Technical Working Group and the Recovery
Management Team concerning local needs
and desires for site restoration, proposed
cleanup options, and recommendations for
recovery.
(D) Technical Working Group
The Technical Working Group should be
convened as soon as practicable, normally
within weeks of the incident.
Makeup: The Technical Working Group
should include selected Federal, State, local,
and private sector subject matter experts in
such fields as environmental fate and
transport modeling, risk analysis, technical
remediation options analysis, cost risk and
benefit analysis, health physics/radiation
protection, construction remediation
practices, and relevant regulatory
requirements. The exact selection and
balance of subject matter experts is incident
specific. The Technical Working Group
should be chaired by the Federal lead
technical agency assigned responsibility for
performing cleanup operations and cochaired by the State/local technical agency.
Function: The Technical Working Group
provides expert input on technical issues,
analysis of relevant regulatory requirements
and guidelines, risk analyses, and evaluation
of options as directed by the Recovery
Management Team. The actual technical
analyses will be the responsibility of the
Federal lead technical agency for cleanup.
The Technical Working Group should also
receive input from the Stakeholder Working
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Group. Technical Working Group written
products are provided to the Recovery
Management Team.
(ii) Activities
(A) Optimization and Recommendation
(Lasts Weeks to Months)
The Recovery Management Team, in
consultation with the Stakeholder Working
Group and Technical Working Group, will
develop a process for the three teams to work
together in order to provide the opportunity
for local concerns to inform the work of the
Technical Working Group. The Technical
Working Group and Recovery Management
Team should assist in answering questions
the Stakeholder Working Group may have
regarding technical issues and provide
information regarding cleanup options.
The Stakeholder Working Group should
present local goals, needs, and desires for the
use of the site, and prioritize current and
future potential land uses and functions,
such as utilities and infrastructure, light
industrial, downtown business, and
residential land uses. The lead technical
agency will oversee technical optimization
analyses for site cleanup in collaboration
with the Recovery Management Team,
Technical Working Group, and Stakeholder
Working Group. The Technical Working
Group will analyze assumptions, review risk
analyses for various proposed remediation
options, assess technical feasibility and cost
of the options, and identify the estimated
time to complete restoration options and
their potential impacts on the local
community.
The Stakeholder Working Group will
provide input to the Technical Working
Group, but may also provide options and
recommendations directly to the Recovery
Management Team. The Technical Working
Group will consider input from the
Stakeholder Working Group in its analyses,
and provide input to the Recovery
Management Team on remediation options
and recommended approaches and rationale.
It is important that the Technical Working
Group and the Stakeholder Working Group
maintain confidentiality concerning all
aspects of the analyses. All outside contacts,
such as press interviews, concerning the
ongoing work and deliberations should be
coordinated through the Recovery
Management Team.
As the Technical Working Group
completes its analyses and formulates its
recommendations, it will present this
information to the Recovery Management
Team for final review. The Recovery
Management Team will present the Decision
Team with options, recommendations for
final action, and supporting documentation.
(B) Public Review of Decision
The Decision Team should publish a
summary of the process, the options
analyzed, and the recommendation for public
comment. Public meetings may also be
convened as appropriate. Public comment
should be considered and incorporated as
appropriate. A reconvening of the Recovery
Management Team, Stakeholder Working
Group, and Technical Working Group may be
useful for resolving some issues.
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(C) Execute Cleanup
Assuming a Presidential declaration of a
major disaster or emergency, DHS may issue
mission assignments to the Federal
departments and agencies that have the
capability to perform the required cleanup or
remediation activities. For significant decontamination efforts, decision makers may
choose to employ a technical peer review
advisory committee to conduct a review of
the effectiveness of the cleanup.
(b) Implications of DHS as Lead Federal
Agency
In both the early and intermediate phases
of the response, activities are expected to
proceed as described under existing plans
and agreements, except that the Federal
response will be coordinated by DHS through
the PFO. Anticipated actions include the
following:
• When NIRT assets are called upon by the
Secretary of DHS, they will come under the
‘‘authority, direction, and control’’ of the
Secretary or his designee for the duration of
the response. As such, they will not work for
State or local governments, nor will they
work independently under their agency of
origin (either DOE or EPA), as they may
under existing plans. A DOE senior energy
official will act as the single point of contact
for tasking of DOE nuclear/radiological
support requested by the PFO or Federal
Coordinating Office (FCO).
• Federal, State, and local field teams and
experts should coordinate data collection and
analysis through the FRMAC (now a DHSdirected asset) once it is operational.
• All Federal information—such as
protective action recommendations, analyses,
projections, and information to be provided
to the public—is expected to pass through
the PFO or FCO, in coordination with State
and local officials, prior to its release to the
press and the public. A JIC may be
established to provide the organizational
structure for coordinating and disseminating
official information to the public. It is
recognized, however, that in some cases, onscene responding Federal agencies may need
to communicate directly with the media/
public on tactical operations and matters
affecting public health and safety,
particularly early in the response.
Appendix 4—Operational Guidelines
for Implementation of the Protective
Action Guides During RDD or IND
Events
As noted in Section F of the document,
operational guidelines are levels of radiation
or concentrations of radionuclides that can
be accurately measured by radiation
detection and monitoring equipment, and
then related or compared to the PAGs to
quickly determine if protective actions need
to be implemented. In most situations, the
guidelines will be given in terms of external
gamma rates or media-specific radionuclide
concentration units. Both external and
internal exposure potential will be
considered in their development.
This appendix describes examples of
measurable guidelines that will be developed
by groups or categories to assist decision
makers and response workers in deciding on
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193
and applying protective actions. This
appendix discusses the guidelines
qualitatively and does not provide actual
values. The operational guidelines will be
developed to provide reasonable assurance
that the PAGs, the dose levels recommended
in this report, can be met for appropriate
situations under assumed circumstances. The
guidelines will also consider the impact of
protective actions, such as rinsing of vehicles
to remove contamination, and when control
of wash water is necessary. Actual conditions
may warrant development of incidentspecific guides, and this document does not
preclude such development. Part of the
development process will include the
development of tools to allow for the
preparation of site-specific operational
guidelines that can be tailored to the
emergency and the required response.
At this time, the operational guidelines are
subdivided into six groups. They are:
• Access Controls During Emergency
Response Operations (Group A)
• Relocation Areas (Group B)
• Critical Infrastructure Utilization in
Relocation Areas (Group C)
• Temporary Access to Relocation Areas
for Essential Activities (Group D)
• Transportation and Access Routes
(Group E)
• Property Control for Release of Property
to Non-impacted Areas (Group F)
The purpose of operational guidelines for
each of these groups is discussed in the
following paragraphs, along with examples of
specific operational guides that are needed
for each group. However, as discussed in
Section F, some operational guidelines have
been previously developed and are available
(e.g., EPA PAG Manual 8 and ‘‘Radiological
Emergency Response Health and Safety
Manual’’ 9). At this time, the appendix
contains no recommendations for actual
values. As they are developed, information
on recommended operational guidelines and
associated tools will be made available for
review.
(a) Access Controls During Emergency
Response Operations (Group A)
The operational guidelines in this group
are intended for use during emergency
response operations. They guide responders
in establishing radiological control zones or
boundaries in affected areas where response
activities are being conducted. These
operational guides are not intended to restrict
emergency responder access but rather to
inform responders of potential radiological
hazards existing in the areas and to provide
tools for those responsible for radiation
protection during response activities. Group
A operational guidelines may be used to
restrict access of non-essential personnel and
members of the public to specific areas.
These guidelines are most applicable
during the early and intermediate phases of
8 ‘‘Manual of Protective Action Guides and
Protective Actions for Nuclear Incidents,’’ U.S.
Environmental Protection Agency, May 1992, EPA–
400–R–92–001.
9 ‘‘Radiological Emergency Response Health and
Safety Manual,’’ May 2001, available at https://
www.nv.doe.gov/programs/frmac/
DOCUMENTS.htm.
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the emergency when the situation has not
been fully stabilized or characterized and
may therefore need to be applied initially
with limited data and then revised (e.g., areas
reclassified or remarked), as appropriate.
Group A operational guidelines are generally
for the areas directly impacted by the RDD
or IND incident where first responders and
emergency response personnel are working.
However, they may also be applicable in
contaminated areas where unrelated
accidents or emergencies occur after the RDD
or IND situation has been stabilized. Group
A operational guidelines are not intended to
restrict emergency response or lifesaving
actions, but they are rather intended to help
focus radiological protection resources on
areas of highest priority. They do, however,
define areas that should be restricted to the
public and non-essential personnel.
Examples of operational guidelines being
developed in this group include those for the
following:
(1) Life and Property Saving Measures
Areas exceeding guidance levels pose a
significant radiological hazard even if access
is for short periods. Access should be
permitted only when there is a significant
benefit associated with the activity to be
conducted that outweighs the associated
radiological risks. The PAGs applied for
development of these operational guides
include the 25 rem lifesaving response
worker guidelines (Table 1B in Appendix 1)
and the property-saving guidelines that are
applicable when it is not possible to limit
response worker dose to the 5 rem worker
PAG.
(2) Emergency Worker Demarcation
Areas exceeding these guides should not be
used to restrict response worker access.
However, the public and non-essential
personnel should not be allowed general
access to the areas exceeding these levels. To
the extent time and resources permit and do
not interfere with response actions, officials
responsible for radiation protection should
establish procedures to monitor worker
access and exposures in these areas. In most
situations, the worker protection PAG of 5
rems is applicable (Table 1 in the main text
and Table 1B in Appendix 1).
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(b) Relocation Areas (Group B)
The operational guidelines for this group
are intended as screening values to delineate
areas that exceed the relocation PAGs. These,
or similar operational guides, have been
developed or are presented in the FRMAC
manual (Volume II) and will be assessed.
Examples of operational guidelines being
developed in this group include:
(1) Relocation From Residential Areas
Areas exceeding these levels pose a
significant possibility of causing doses that
exceed relocation PAGs under normal
residential use, and unless specific
assessments indicate otherwise, the public
should be relocated from the areas. The 2
rems in the first year and 0.5 rem/yr
thereafter (Table 1) are applicable for the
development of these operational guidelines.
Temporary access may be consistent with
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Group D, Temporary Access Operational
Limits.
used for all or some of the facilities so that
the list may be compressed.
(2) Relocation Considerations for
Commercial/Industrial Areas
Areas exceeding these guides pose a
significant likelihood for causing doses that
exceed public relocation PAGs under normal
industrial or commercial use scenarios and
should be considered for relocation. The 2
rems in the first year and 0.5 rem/yr
thereafter (Table 1) are applicable for the
development of these operational guidelines
unless the employers have radiation
protection programs in place to protect
workers consistent with applicable
requirements (e.g., OSHA 29 CFR 1910.1096,
NRC 10 CFR 20, DOE 10 CFR 835), or unless
site-specific analyses justify other operational
limits. Temporary access for essential
activities should be guided by operational
guides in Group D. Or, if the facility is
providing a service necessary to maintain
public welfare, Group C operational limits
should serve as a guide.
(1) Hospitals
(3) Other Areas
These operational guides apply to areas
that are not used as residences and are not
normal work places (e.g., parks, cemeteries,
monuments). The value of these guidelines
will likely differ from the relocation areas
previously mentioned because of differing
occupancy and use, although the dose
guidelines remain 2 rems in the first year and
0.5 rems/yr thereafter (Table 1). Access to
such areas should be limited if the guides are
exceeded.
These relocation operational guidelines
will provide reasonable assurance that the
worker or the public, as appropriate, will not
exceed PAGs, and that appropriate
radiological protection supervision is
available in, and focused on, the higher risk
areas so as to provide protection and
oversight for emergency responders.
(c) Critical Infrastructure Utilization in
Relocation Areas (Group C)
The operational guidelines for this group
are intended as screening values to ensure
facilities critical to the public welfare can
continue to operate if needed. These guides
only apply to facilities in areas that exceed
relocation PAGs and, as a result, have been
closed for general use and access. The
operational guidelines are generally
applicable during intermediate phase
activities.
During the emergency activities, Group A
operational guidelines will generally be
applicable or in use. Group C operational
guides assume a generally stable and
characterized situation. The levels are
derived assuming employees spend two
thousand hours per year (a more realistic
value may be employed if known) on the job
and that the maximum dose will be less than
5 rems/yr. Facilities that exceed these
operational guides and are essential for
overall public welfare may need to be
assessed to identify specific conditions and
possible mitigation controls. In the following
list of possible operational guidelines, a
number of different guides have been
identified, and future analyses may indicate
that the same operational guidelines may be
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These guidelines are recommended to
allow continued use of health care facilities
and services that are in areas that exceed
relocation criteria. If alternative facilities and
services are available, they should be
employed before applying these guidelines.
(2) Airports, Railroads, and Ports
These guidelines are recommended to
allow use of transport facilities located in
areas exceeding relocation guidelines that are
essential to providing services and products
necessary for the welfare of the region.
(3) Water and Sewer Facilities
These guidelines are for utilities in
relocation areas that are necessary to provide
services for the region.
(4) Power and Fuel
These guidelines are for utilities in
relocation areas that are necessary to provide
services for the region.
It is emphasized that these guidelines only
apply when continuous operation of these
and other facilities are essential to
maintaining the public welfare and when this
cannot be achieved under Group B or Group
D guidelines for relocation and temporary
access decisions, respectively.
(d) Temporary Access to Relocation Areas
for Essential Activities (Group D)
The public, or employees of businesses,
may need to have temporary access to
residences or commercial, agricultural, or
industrial facilities in order to retrieve
essential records or equipment, conduct
maintenance to protect the facility, prevent
environmental damage, attend to animals, or
retrieve pets. These operational guides are
levels at which these actions can be taken
without radiological supervision. The public
or employees may occasionally access (a few
days per month) the areas not exceeding
these guides. Temporary access to relocation
areas that exceeds the levels should only be
permitted under the supervision, or with the
permission of, radiation protection
personnel. These operational guidelines will
be derived to provide assurance that the
doses will be below the 0.5 rem relocation
PAG (Table 1, after the first year) for the
following:
(1) Worker Access to Businesses for Essential
Actions
Areas meeting these levels may be accessed
for limited periods to retrieve essential
materials or perform essential functions (e.g.,
perform facility maintenance, attend to
animals, maintain security).
(2) Public Access to Residences for Retrieval
of Critical Property, Pets, or Records
Areas in relocation areas meeting these
criteria may be accessed by the public for
limited periods to attend to important
maintenance, retrieve needed records, or
retrieve pets.
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(e) Transportation and Access Routes
(Group E)
The operational guidelines for this group
are intended to assist in determining if
transportation routes or access ways may be
used by the public for general, limited, or
restricted use. The relocation PAGs are used
as the basis for operational guidelines for
general access. Restricted use may be based
on other guidelines as well. For example,
operational guides may be defined for
industrial/commercial use of various roads,
bridges, or access ways. These may be
necessary to allow for access between nonrelocation areas via a relocation area or to
allow for emergency recovery access in the
immediate area of the RDD or IND incident.
These operational guides assume regular or
periodic use and are not appropriate for onetime events, such as evacuation or relocation
actions. In general, these operational
guidelines need to be developed giving
consideration to the relocation PAGs, worker
protection guidelines, and potential for
combined doses. Three examples of
operational guidelines for this group are
discussed as follows, and as these are
developed, it is possible that all or some of
the categories can be consolidated.
(1) Bridges
Bridges meeting these operational
guidelines are acceptable for public vehicular
use (or restricted use, where appropriate).
(2) Streets and Thoroughfares
Streets and thoroughfares meeting these
operational limits are acceptable for general
vehicular passage or restricted vehicular
passage, as appropriate.
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(3) Sidewalks and Walkways
These operational limits are for nonvehicular access (e.g., individuals walking
from parking lots or trains to places of
business, or workers delivering goods). They
should also apply to bridges and streets if
significant non-vehicular passage is
anticipated.
(f) Release of Property From Radiologically
Controlled Areas (Group F)
During response and recovery operations,
property (vehicles, equipment, and waste)
will need to be cleared from controlled areas.
The operational guidelines in this group will
be developed to support such actions.
Because retrieval of cleared or released
properties would be difficult, wherever
practicable, these levels should be similar to
those likely to define late phase goals. For
this reason, they should not be applied to
property that will remain in use in controlled
areas. Many areas may not exceed relocation
PAGs and therefore, they will be accessible
to the public at levels considerably above the
operational guides in this group. Use of such
property should not be assumed
unacceptable merely because it exceeds these
guides. These operational guidelines should
also be used for screening property that was
outside the controlled area. In general, the
operational guides in this group provide
reasonable assurance that the property
cleared is acceptable for long-term,
unrestricted use (or designated disposition in
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the case of wastes) without further or future
reassessment. Property includes the
following:
(1) Personal Property (Except Waste)
These operational guides will apply to
property to be permanently cleared from the
affected area for general reuse. They should
not be used for property that will continue
to be used in the affected areas (e.g., areas
where residual activity is significantly above
background).
(2) Waste
The RDD or IND incident may generate
significant quantities of waste that contain
small amounts of radioactivity. This waste
may be rubble resulting from the device or
from demolition associated with recovery, or
it may be in the form of municipal waste or
industrial waste from areas that are
contaminated at levels below the relocation
PAGs and associated operational guidelines.
Waste meeting these operational limits may
be considered for disposal in normal
landfills, and waste exceeding these limits
should be disposed at appropriate low-level
radioactive waste sites.
(3) Hazardous Waste
Hazardous waste resulting from the RDD or
IND or associated recovery operations will
contain varied levels of residual radioactive
material. Waste meeting these criteria may be
considered for treatment and disposal to a
legally permitted facility. Waste exceeding
these concentrations should be managed as
mixed waste.
(4) Real Property
Relocation PAGs and associated
operational guides will be developed for
application to the management of real
property, but it is recognized that the
optimization process applied during late
phase activities (which will likely overlap
with the intermediate phase) will be applied
to areas that contain residual radioactive
material at concentrations below the
operational guides for relocation. Until the
optimization process determines the target
cleanup levels, it is not possible to
generically define release operational
guidelines for release of real property. Tools
and unit concentrations to dose factors may
be developed that can be applied on a sitespecific basis by decision makers involved in
the optimization to help define interim, or
even final, operational guides for certain
areas. However, no suggested or
recommended generic operational guidelines
can be developed before optimization process
considerations.
Group F operational guides are intended to
provide guidance for permanent clearance of
property leaving radiologically controlled
areas. These guides are developed to provide
reasonable assurance that attaining them will
minimize or eliminate the need for further
response actions. It will be difficult to collect
or re-call ‘‘released property’’ should late
phase decisions about ‘‘safe exposures’’
identify more restrictive levels than those
used to release property in the early and
intermediate phases. Therefore, the property
control operational guides (Group F) will be
based on potential doses that are a fraction
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195
of the intermediate phase PAGs. Wherever
practicable, these levels should be similar to
those likely to define late phase goals. As
with all the operational guidelines,
alternative levels may be developed and used
if conditions and needs justify. Group F
operational guides are not applicable to
continued use of property in impacted areas.
Note: Although agencies have identified
values for selected operational guides, none
have reached consensus. The development of
these values will continue as part of an
interagency process. Several sources exist
that contain useful operational guidelines or
information to support the development of
operational guidelines that will eventually be
included directly, or by reference with, the
recommendations in this document and
subsequent reports documenting the
operational guidelines. The interagency
workgroup developing these guidelines will
consider these and other materials being
developed by Federal agencies and other
groups, such as the American National
Standards Institute (ANSI) and National
Council on Radiation Protection and
Measurement (NCRP). Consistent with
direction from Congress in FY2003
Supplemental Appropriations Legislation,
the DOE is conducting analyses and
developing models to support the completion
of operational guidelines identified in this
appendix. A significant fraction of the
operational guidelines were completed and
submitted for interagency review in late
FY2005. Completion of the analyses and
revisions based on interagency input (and
peer review) is anticipated in the middle of
FY2006. As the operational guidelines are
developed and worked through the
interagency process, they will be made
available for review on the Internet.
Appendix 5—Acronyms/Glossary
AMS
Aerial Measuring System—A DOE
technical asset consisting of both fixed wing
and helicopter systems for measuring
radiation on the ground; a deployable asset
of the NIRT.
ALARA
As low as reasonably achievable—A
process to control or manage radiation
exposure to individuals and releases of
radioactive material to the environment so
that doses are as low as social, technical,
economic, practical, and public welfare
considerations permit.
ANSI
American National Standards Institute.
CFR
Code of Federal Regulations.
CMS
Consequence Management Site
Restoration, Cleanup and Decontamination
Subgroup.
DEST
Domestic Emergency Support Team—A
technical advisory team designed to predeploy and assist the FBI Special Agent in
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Federal Register / Vol. 71, No. 1 / Tuesday, January 3, 2006 / Notices
Charge. The DEST may deploy after an
incident to assist the FBI and the PFO.
Derived Intervention Level—the
concentration of a radionuclide in food
expressed in Becquerel/kg which, if present
throughout the relevant period of time (with
no intervention), could lead to an individual
receiving a radiation dose equal to the PAG.
DOD
Department of Defense.
DOE
Department of Energy.
DRL
Derived Response Level—A level of
radioactivity in an environmental medium
that would be expected to produce a dose
equal to its corresponding PAG.
EOC
Emergency Operations Center.
EPA
Environmental Protection Agency.
Federal Bureau of Investigation.
FCO
Federal Coordinating Officer.
Food and Drug Administration.
FRMAC
Federal Radiological Monitoring and
Assessment Center—A coordinating center
for Federal, State, and local field personnel
performing radiological monitoring and
assessment—specifically, providing data
collection, data analysis and interpretation,
and finished products to decision makers.
The FRMAC is a deployable asset of the
NIRT.
HHS
Department of Health and Human Services.
HAZWOPER
Hazardous Waste Operations and
Emergency Response Standard (29 CFR
1910.120).
HSOC
rmajette on DSK29S0YB1PROD with NOTICES5
Homeland Security Operations Center—
DHS headquarters to integrate and provide
overall steady-state threat monitoring and
situational awareness for domestic incident
management on a 24/7 basis.
HSPD
Homeland Security Presidential Directive.
IC/UC
Incident Command/Unified Command—A
system to integrate various necessary
functions to respond to emergencies. The
system is widely used by local responders.
Under Unified Command, multiple
jurisdictional authorities are integrated.
Jkt 223001
PPE
RAP
NCRP
National Council on Radiation Protection
and Measurement.
FDA
15:58 Nov 10, 2010
PFO
JOC
Joint Operations Center—The focal point
for management and coordination of local,
State and Federal investigative/law
enforcement activities.
FBI
VerDate Mar<15>2010
IND
Improvised Nuclear Device—Nuclear
weapons that are fabricated by an adversary
State or terrorist group from illicit nuclear
material and that could produce nuclear
explosions.
JIC
Joint Information Center—A focal point for
the coordination and provision of
information to the public and media
concerning the Federal response to the
emergency.
Department of Homeland Security.
DIL
PAG
JFO
Joint Field Office—The operations of the
various Federal entities participating in a
response at the local level should be
collocated in a Joint Field Office whenever
possible, to improve the efficiency and
effectiveness of Federal incident management
activities.
DHS
IIMG
Interagency Incident Management Group—
A headquarters-level group to facilitate
national-level domestic incident management
and coordination of Federal operations and
resources for certain incidents defined in
HSPD–5 or in anticipation of such incidents.
NIMS
National Incident Management System—
The Homeland Security Act of 2002 and
HPSD–5 directed the DHS to develop a
NIMS. The purpose of the NIMS is to provide
a consistent nationwide approach for
Federal, State, and local governments to work
effectively and efficiently together to prepare
for, respond to, and recover from domestic
incidents.
NIRT
Nuclear Incident Response Team—Created
by the Homeland Security Act of 2002, the
NIRT consists of radiological emergency
response assets of the DOE and the EPA.
When called upon by the Secretary for
Homeland Security for actual or threatened
radiological incidents, these assets come
under the ‘‘authority, direction, and control’’
of the Secretary.
NRC
Nuclear Regulatory Commission.
NRP
National Response Plan—The Homeland
Security Act of 2002 and the HPSD–5
directed the DHS to develop an NRP. The
purpose of the NRP is to integrate Federal
Government domestic emergency prevention,
preparedness, response, and recovery plans
into one all-discipline, all-hazards plan.
OSHA
Occupational Safety and Health
Administration.
PO 00000
Frm 00024
Fmt 4701
Sfmt 9990
Protective Action Guide—Provides the
projected dose to a reference individual, from
an accidental or deliberate release of
radioactive material at which a specific
protective action to reduce or avoid that dose
is recommended.
Principal Federal Official—The PFO will
act as the Secretary of Homeland Security’s
local representative, and will oversee and
coordinate Federal activities for the incident.
Personal Protective Equipment.
R
Roentgen—Measure of exposure in air.
RAD
Radiation absorbed dose.
Radiological Assistance Program—A DOE
emergency response asset that can rapid
deploy at the request of State or local
governments for technical assistance in
radiological incidents. RAP teams are a
deployable asset of the NIRT.
RDD
Radiological Dispersal Device—A device or
mechanism that is intended to spread
radioactive material from the detonation of
conventional explosives or other means.
REAC/TS
Radiation Emergency Assistance Center/
Training Site—A DOE asset located in Oak
Ridge, TN, with technical expertise in
medical and health assessment concerning
internal and external exposure to radioactive
materials. REAC/TS is a deployable asset of
the NIRT.
rem
The conventional unit of dose equivalent.
The product of the absorbed dose in rad, a
quality factor related to the biological
effectiveness of the radiation involved and
any other modifying factors.
RERT
Radiological Emergency Response Team—
An EPA team trained to do environmental
sampling and analysis of radionuclides.
RERT provides assistance during responses
and takes over operation of the FRMAC from
DOE at a point in time after the emergency
phase. RERT is a deployable asset of the
NIRT.
TEDE
Total Effective Dose Equivalent—The sum
of internal and external doses.
Dated: December 5, 2005.
Robert Stephan,
Assistant Secretary, Office of Infrastructure
Protection, Preparedness Directorate.
[FR Doc. 05–24521 Filed 12–30–05; 8:45 am]
BILLING CODE 9110–21–P
E:\FR\FM\03JAN2.SGM
03JAN2
Agencies
[Federal Register Volume 71, Number 1 (Tuesday, January 3, 2006)]
[Notices]
[Pages 174-196]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 05-24521]
[[Page 173]]
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Part II
Department of Homeland Security
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Preparedness Directorate; Protective Action Guides for Radiological
Dispersal Device (RDD) and Improvised Nuclear Device (IND) Incidents;
Notice
Federal Register / Vol. 71, No. 1 / Tuesday, January 3, 2006 /
Notices
[[Page 174]]
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DEPARTMENT OF HOMELAND SECURITY
Z-RIN 1660-ZA02
Preparedness Directorate; Protective Action Guides for
Radiological Dispersal Device (RDD) and Improvised Nuclear Device (IND)
Incidents
AGENCY: Preparedness Directorate, Department of Homeland Security.
ACTION: Notice of draft guidance for interim use with request for
comment.
-----------------------------------------------------------------------
SUMMARY: The Preparedness Directorate of the Department of Homeland
Security (DHS) is issuing guidance entitled, ``Application of
Protective Action Guides for Radiological Dispersal Devices (RDD) and
Improvised Nuclear Device (IND) Incidents'' for Federal agencies, and
as appropriate, State and local governments, emergency responders, and
the general public who may find it useful in planning and responding to
an RDD or IND incident. The guidance recommends ``protective action
guides'' (PAGs) to support decisions about actions that may need to be
taken to protect the public when responding to or recovering from an
RDD or IND incident. It also outlines a process to implement the
recommendations and discusses operational guidelines that may be useful
in the implementation of the PAGs. The full text of the document is
included in this Notice. This guidance is provided for interim use and
will be revised based on comments received. The Preparedness
Directorate is seeking input on the appropriateness, implementability
and completeness of the guidance.
DATES: The draft guidance contained in this notice is released for
interim use effective January 3, 2006. Comments on this draft guidance
should be received on or before March 6, 2006.
ADDRESSES: You may submit comments, identified by Docket Number DHS-
2004-0029 and Z-RIN 1660-ZA02, by one of the following methods:
Federal eRulemaking Portal: https://www.regulations.gov.
Follow the instructions for submitting comments.
E-mail: FEMA-RULES@dhs.gov. Include Docket Number DHS-
2004-0029 and Z-RIN 1660-ZA02 in the subject line of the message.
Fax: 202-646-4536.
Mail/Hand Delivery/Courier: Rules Docket Clerk, Office of
the General Counsel, Federal Emergency Management Agency, Room 840, 500
C Street, SW., Washington, DC 20472.
Instructions: All submissions received must include the agency name
and docket number (if available) or Regulatory Information Number (RIN)
for this rulemaking. All comments received will be posted without
change to https://www.regulations.gov, including any personal
information provided.
Docket: For access to the docket to read background documents or
comments received, go to https://www.regulations.gov. Submitted comments
may also be inspected at 500 C Street, SW., Room 840, Washington, DC
20472.
FOR FURTHER INFORMATION CONTACT: Craig Conklin, Chief, Nuclear and
Chemical Hazards Branch, Preparedness Division, Department of Homeland
Security, NAC, Washington, DC 20528, 703-605-1228 (phone), 703-605-1198
(facsimile), or craig.conklin@dhs.gov (e-mail.)
SUPPLEMENTARY INFORMATION:
(a) Introduction
(1) Background on the Guidance
Since the terrorist events in the United States on September 11,
2001, there has been increased worldwide effort to avert and respond to
terrorist attacks. In addition, based on intelligence information, the
potential for terrorist attacks in the United States involving
radiological materials or a nuclear device has grown. The Federal
Government has responded with an aggressive approach to planning and
preparedness, utilizing the resources and expertise found in
departments and agencies across the government. Prior to September 11,
radiological emergencies were considered bounded by potential nuclear
power plant accidents. However, new terrorist scenarios have emerged
that offer new and different response challenges.
In order to prepare for potential attacks, DHS held a Federal
interagency ``dirty bomb'' exercise as part of the Top Officials-2
Exercise (TOPOFF-2) in Seattle, Washington, May 12-16, 2003. The
exercise brought to light a number of issues in Federal radiological
emergency response and recovery. One of the most important issues
raised was how long-term site restoration and cleanup would be
accomplished following an act of radiological terrorism. This question
was part of a larger discussion of Federal Government protective action
recommendations following acts of radiological or nuclear terror. The
Environmental Protection Agency (EPA) published PAGs in the ``Manual of
Protective Action Guides and Protective Actions for Nuclear Incidents''
(EPA 400-R-92-001, May 1992), in coordination with the Federal
Radiological Preparedness Coordinating Committee (FRPCC). However, the
EPA Manual, often called the PAG Manual, was not developed to address
response actions following radiological or nuclear terrorist incidents.
Also, the PAG Manual does not address long-term cleanup.
In 2003, DHS tasked an interagency working group to address these
issues. The working group consisted of senior subject matter experts in
radiological/nuclear emergency preparedness, response, and consequence
management. The following Federal departments and agencies were
represented on the working group: DHS, EPA, Department of Commerce
(DOC), Department of Energy (DOE), Department of Defense (DOD),
Department of Labor (DOL), Department of Health and Human Services
(HHS), and the Nuclear Regulatory Commission (NRC).
The result of the interagency working group process is the
following Federal consensus guidance entitled, ``Application of
Protective Action Guides for Radiological Dispersal Device (RDD) and
Improvised Nuclear Device (IND) Incidents.'' (June 1, 2004). In it, the
Federal agencies support the use of existing early and intermediate
phase PAGs, as found in the EPA PAG Manual, for acts of radiological
and nuclear terrorism. The working group also developed late phase
guidance, also contained in the consensus guidance, for the cleanup and
restoration of a site following an act of radiological or nuclear
terrorism that is based on the principle of site-specific optimization.
In developing this draft guidance, DHS convened a focus group of
representatives from 13 State agencies with expertise in radiological
emergency response and consequence management. The State
representatives were asked to review the draft guidance and provide
detailed comments on its content, structure, and presentation. DHS was
particularly interested in how States would make use of the guidance
and how well the guidance would serve to facilitate Federal and State
(or local) government interactions during a radiological terrorism
response. Overall, the State representatives responded very positively
to the guidance. A number of improvements suggested by the States were
incorporated into the draft guidance being published today.
The purpose of this guidance is to aid Federal decision makers in
protecting the public and emergency responders from the effects of
radiation during an emergency and to provide guidelines and a process
for site cleanup and recovery following an RDD or IND incident. This
guidance is designed to
[[Page 175]]
be compatible with the National Incident Management System (NIMS) and
the National Response Plan (NRP).
This guidance presents levels of radiation exposure at which the
Federal Government recommends that actions be considered to avoid or
reduce radiation dose to the public from an RDD or IND incident. The
intended audience for this document is principally Federal Government
emergency response planners and officials; however, this document
should also be useful to State and local governments for response
planning. The protective action guides incorporate guidance and
regulations published by the EPA, the Food and Drug Administration
(FDA), and the Occupational Safety and Health Administration (OSHA),
and address key health protection questions faced in the various phases
(early, intermediate, and late) of response to an incident.
These PAGs are not absolute standards and are not intended to
define ``safe'' or ``unsafe'' levels of exposure or contamination.
Rather, they represent the approximate levels at which the associated
protective actions are recommended. This guidance may also be used by
State and local decision makers, and provides flexibility to be more or
less restrictive as deemed appropriate based on the unique
characteristics of the incident and local considerations.
This guidance is not intended for use at site cleanups occurring
under other statutory authorities such as EPA's Superfund program, the
NRC's decommissioning program, or other Federal or State cleanup
programs. In addition, the scope of this guidance does not include
situations involving United States nuclear weapons accidents.
(2) Characteristics of RDD and IND Incidents
An RDD is any device that causes the purposeful dissemination of
radioactive material across an area without a nuclear detonation. The
mode of dispersal typically described as an RDD is an explosive device
coupled with radioactive material. An RDD poses a threat to public
health and safety and the environment through the spread of radioactive
materials, and any explosive device presents an added immediate threat
to human life and property. Other means of dispersal, both passive and
active, may be employed. Dissemination of radioactive material not
carried out via a device would still be treated like an RDD by
responders and decision makers.
There is a wide range of possible consequences that may result from
an RDD depending upon the type and size of the device, the type and
quantity of radioactive material, and how dispersion is achieved. The
consequences of an RDD may range from a small, localized area (e.g., a
street, single building or city block) to large areas, conceivably
several square miles. However, most experts agree that the likelihood
of a large impacted area is low. In most plausible scenarios, the
radioactive material would not result in acutely harmful radiation
doses and the public health concern from the radioactive materials
would likely focus on the chronic risk of developing cancer among
exposed individuals. Hazards from fire, smoke, shock, shrapnel (from an
explosion), industrial chemicals and other chemical or biological
agents may also be present.
An IND is an illicit nuclear weapon bought, stolen, or otherwise
originating from a nuclear State, or a weapon fabricated by a terrorist
group from illegally obtained fissile nuclear weapons material that
produces a nuclear explosion. The guidance does not apply to acts of
war between nation-states involving nuclear weapons. The nuclear yield
achieved by an IND produces extreme heat, powerful shockwaves, and
prompt radiation that would be acutely lethal for a significant
distance. It also produces potentially lethal radioactive fallout,
which may spread far downwind and deposit over very large areas. An IND
would result in catastrophic loss of life, destruction of
infrastructure and contamination of a very large area. If nuclear yield
is not achieved, the result would likely resemble an RDD in which
fissile weapons material was dispersed locally.
(3) RDD and IND Incidents v. Accidents
Acts of radiological and nuclear terrorism differ from radiological
and nuclear accidents in several key ways. Accidents occur almost
exclusively at well-characterized fixed facilities, or along prescribed
transit routes. Facility operators have a good understanding of the
kinds of radiological incidents that may occur, and have developed
safeguards, plans, and procedures to deal with them. Exercises are
regularly held to practice emergency plans and procedures, and
improvements are made where necessary. Local communities, such as those
around nuclear power plants (NPPs) or weapons production facilities,
are informed and involved in emergency planning, including development
of public communication strategies, practicing shelter-in-place, and
orderly evacuation along prescribed routes. Accidents may also occur
along transit routes, but these are relatively rare and substantial
contingency planning and exercising occurs for transportation accidents
as well.
Acts of radiological and nuclear terrorism, on the other hand, may
occur virtually anywhere. Major cities are potential targets of such
incidents. The number of potential targets and the diverse
circumstances of potential attacks make focused response planning
almost impossible. Even a rural setting could fall victim, if for
example, a device were to go off prematurely. Most nuclear facilities
are located in semi-rural settings around which the number of people
affected would be less and the amount of critical infrastructure
impacted is likely to be less.
The scope of potential accidents is limited and fairly well
understood. Facilities tend to have fixed quantities of licensed
radioisotopes or well characterized types of radionuclides on site that
may be released in an accident. The number of ways accidents can occur
(within reason) is limited, making possible effective contingency
planning and improved safety. Accidents of any magnitude are limited to
a relatively small number of facilities, and these tend to have highly
trained personnel, advanced security, advanced process designs with the
most rigorous safeguards and back-up systems, and the most aggressive
contingency planning. The design of commercial nuclear power reactors
in the United States, for example, precludes a Chernobyl-type of
nuclear accident. Smaller facilities, such as radiopharmaceutical or
radiation source manufacturers, generally possess much less radioactive
material (or only short half-life materials) that may be involved in an
accidental release.
Finally, an RDD or IND incident may be initiated without any
advance warning and the release would likely have a relatively short
duration. With a major NPP accident, the most severe type of incident
previously considered, there is likely to be several hours or days of
warning before the release starts and the release may be drawn out over
many hours. The benefit of time is critical. Advance notice affords
time to make appropriate decisions, communicate to the public, and
execute orderly evacuation, if necessary, or other protective actions.
This difference means that most early and some intermediate phase
protective actions must be made more quickly and with less information
in an RDD or IND incident if they are to be effective.
[[Page 176]]
(4) Phases of Response
Typically, the response to an emergency can be divided into three
time phases. Although these phases cannot be represented by precise
time periods and may overlap, they provide a useful framework for the
considerations involved in emergency response planning. The early phase
(or emergency phase) is the period at the beginning of the incident
when the source (e.g., fire or contaminated plume) at the incident is
active, field measurement data are limited or not available, and
immediate protective action decisions are required. Exposure to the
radioactive plume, short-term exposure to deposited materials and
inhalation of radioactive material are generally included when
considering protective actions for the early phase of a radiological
emergency. The response during the early phase includes the initial
emergency response actions to retrieve and care for victims, stabilize
the scene, and public health protective actions (such as sheltering-in-
place or evacuation) in the short term. Life-saving and first aid
actions should be given priority.
In general, early phase protective actions need to be made very
quickly, and the protective action decisions can be modified later as
more information becomes available. If an explosive RDD is deployed
without warning, there may be no time to take protective actions to
reduce plume exposure. In the event of a covert dispersal, discovery or
detection may not occur for days or weeks, allowing contamination to be
dispersed broadly by foot, vehicular traffic, wind, rain or other
forces. If an IND explodes, there would only be time to make early
phase protective action recommendations to protect against exposure
from fallout in areas miles downwind from the explosion.
The intermediate phase of the response may follow the early phase
response within as little as a few hours, up to several days. The
intermediate phase of the response is usually assumed to begin after
the incident source and releases have been brought under control and
protective action decisions can be made based on some field
measurements of exposure and radioactive materials. Activities in this
phase typically overlap with early and late phase activities, and may
continue for weeks to many months until protective actions are
terminated. During the intermediate phase, decisions must be made on
the initial actions needed to begin recovery from the incident, reopen
transportation systems and critical infrastructure, and return to some
state of normal activities.
The late phase is the period when recovery and cleanup actions
designed to reduce radiation levels in the environment to acceptable
levels commence and ends when all the recovery actions have been
completed. In the late phase, decision makers will have more time and
information to allow for better data collection and options analyses.
In this respect, the late phase is no longer a response to an
``emergency situation,'' as in the early and intermediate phases, and
is better viewed in terms of the long-term objectives of cleanup and
restoration of the site to meet the needs and desires of the community
and region. With the additional time and increased understanding of the
situation, there will be opportunities to involve key stakeholders in
providing sound, cost-effective recommendations.
(5) Protective Action Guides
A PAG is the projected dose to a reference individual from an
accidental or deliberate release of radioactive material at which a
specific protective action to reduce or avoid that dose is recommended.
Thus, protective actions, such as evacuation or sheltering-in-place,
should normally be taken before the anticipated dose is realized. The
PAG Manual, published by EPA in coordination with the FRPCC, provides
the basis for this proposed guidance and may be referred to for
additional details. The EPA PAGs achieve the following criteria and
goals: (1) Prevent acute effects, (2) reduce risk of chronic effects
and, (3) require optimization to balance protection with other
important factors and ensure that actions taken cause more benefit than
harm.
The PAG Manual was written to address the kinds of nuclear or
radiological incidents deemed likely to occur. While intended to be
applicable to any radiological release, the PAGs were designed
principally to meet the needs of commercial nuclear power plant
accidents, the worst type of incident under consideration in the PAGs.
This is important for two reasons: commercial nuclear power plant
accidents are almost always signaled by preceding events, giving plant
managers time (hours or days) to make decisions, and local emergency
managers time to communicate with the public and initiate evacuations
if necessary; and, the suite of radionuclides is well-known, and is
dominated by relatively short-lived isotopes. As a result of September
11, the Federal Government has reevaluated the PAGs for their
applicability to RDD and IND incidents.
The PAGs are non-regulatory, and are meant to provide a flexible
basis for decisions under varying emergency circumstances. Many factors
should be considered when deciding whether or not to order an action
based on the projected dose to a population. For example, evacuation of
a population is much more difficult and costly as the size of the
subject population increases. Further, there is a statistical increase
in casualties directly related to the size of the population evacuated
that must be taken into consideration. Thus, considering incident-
specific factors like these, actual projected doses at which action is
recommended may vary up or down.
(b) Developing the Proposed Guidance
(1) Use of Existing PAGs
In deriving the recommendations contained in this guidance, new
types of incidents and scenarios that could lead to environmental
radiological contamination were considered. The working group
determined that the existing PAGs for the early and intermediate
phases, including worker protection guides, published in the EPA PAG
Manual, are also appropriate for use in RDD and IND incidents. The
proposed recommendations are provided in Table 1 in Section D.3 of the
following guidance. Appendix 1 of the following guidance provides
additional details regarding worker protection recommendations and
includes additional Response Worker Guidelines in Table 1B.
(2) Guidance for Late Phase Site Cleanup and Restoration
The working group evaluated existing Federal dose and risk-based
standards, guidance and benchmarks for site cleanup and restoration as
possible guidance for use after an RDD or IND. Standards considered
included those of the EPA under the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), and DOE and NRC
standards under the Atomic Energy Act of 1954, as amended. In addition,
cleanup guidance and benchmarks issued by national and international
radiation advisory bodies (such as the International Commission on
Radiological Protection and the International Atomic Energy Agency)
were considered.
The working group also examined variations of these standards,
guidance and benchmarks by explicitly considering the possibility of
achieving more or less stringent risk or dose levels, and by using
target ranges.
[[Page 177]]
The working group determined that the nature of potential impacts
from radiological and nuclear terror incidents was extremely broad.
Because of the broad range of potential impacts that may occur from
RDDs and INDs ranging, for example, from light contamination of a
street or building, to widespread destruction of a major metropolitan
area, a pre-established numeric guideline was not recommended as best
serving the needs of decision makers in the late phase. Rather, a site-
specific process is recommended for determining the societal objectives
for expected land uses and the options and approaches available to
address RDD or IND contamination. For example, if the incident is an
RDD of limited size, such that the impacted area is small, then it
might reasonably be expected that a complete return to normal
conditions can be achieved within a short period of time. However, if
the impacted area is very large, then achieving even very low criteria
for remediation of the entire area and/or maintaining existing land
uses may not be practicable.
The process recommended in the guidance was based on the risk
management framework discussed in Appendix 2. This process may be
implemented through engaging knowledgeable technical experts and key
stakeholders to provide decision makers with advice on the options,
costs and implications of various courses of action. The guidance
recommends that the level of effort and resources invested be scaled to
the significance of the incident, scope of contamination, potential
severity of economic impact, technical feasibility, and resource
constraints. This process should result in the selection of the most
appropriate solution that is sensitive to the range of involved
stakeholders. Such a process where multiple factors are considered in
developing options and deciding on action is often referred to as
optimization.
Optimization is a concept that is common to many State, Federal and
international risk management programs that address radionuclides and
chemicals, although it is not always referred to as such. Broadly
speaking, optimization is a flexible, multi-attribute decision process
that seeks to consider and balance many factors. Optimization analyses
are quantitative and qualitative assessments applied at each stage of
site restoration decisionmaking, from evaluation of remedial options,
to implementation of the chosen alternative. The evaluation of cleanup
alternatives, for example, should factor all relevant variables,
including; areas impacted (e.g., size, location relative to
population), types of contamination (chemical, biological, and
radioactive), human health, public welfare, technical feasibility,
costs and available resources to implement and maintain remedial
options, long-term effectiveness, timeliness, public acceptability, and
economic effects (e.g., on residents, tourism, business, and industry).
The optimization process is an approach that may accommodate a
variety of dose and/or risk benchmarks identified from State, Federal
or other sources (e.g., national and international advisory
organizations) as goals or starting points in the analysis of
remediation options. These benchmarks may be useful for analysis of
remediation options and levels may move up or down depending on the
site-specific circumstances and balancing of other relevant factors.
(3) Implementation of Site Cleanup and Restoration
The guidance presents an implementation plan for long-term site
cleanup and restoration analysis and decisionmaking that is described
in detail in Appendix 3 of the guidance. The implementation plan was
designed principally to describe Federal interactions with State and
local governments and public stakeholder representatives. For purposes
of this guidance, it is assumed that the RDD or IND incident is
significant in size and scope of contamination and that the Federal
Government will be the primary source of funding for site cleanup and
restoration. This plan is compatible with NIMS and the NRP, and should
be seen as a framework for assessing a site, evaluating technologies
and remediation options, assessing costs and timeframes, and
incorporating local input on current and future land uses so that site
cleanup and restoration may be approached in a fair and open manner.
The plan describes a collaborative and iterative approach in which
two work groups, one of stakeholders and one of technical subject
matter experts, interact to develop cleanup options for the site under
the supervision and oversight of a team of senior local, State and
Federal management officials. The stakeholder workgroup would represent
local interests, and relate local land use preferences and public
health and welfare concerns. The technical work group would perform
analyses, evaluate technologies and options, assess cost-effectiveness,
and estimate timelines for completion. Ongoing discussions between the
groups should result in a remediation solution and cleanup criteria for
site restoration that are generally acceptable to involved
stakeholders. The options and recommended decision would be forwarded
up to decisionmakers for final approval so that cleanup can commence.
The constitution of the groups and the interactions among them may
be shaped to meet specific local needs and concerns. For example,
larger, more complex incidents may require a number of technical
experts with specific skills and knowledge, and the location may
warrant varying stakeholder group composition. The implementation plan
is scalable to the situation.
The goal of the whole process is to reach an agreed upon approach
to site cleanup and restoration within a reasonable timeframe that is
effective, achievable, and meets the needs of local stakeholders. The
final decision must be approved by local, State and Federal decision
makers.
(c) Tools and Guidelines To Support Application of the PAGs
The need for protective action will be based on a determination of
whether PAGs will be exceeded. To facilitate first responder activities
and the use of PAGs in the field, operational guidelines are needed
which can be readily used by local decision makers and by responders.
Radiation doses are not directly measurable and must be calculated
based on measurable quantities such as exposure rates, radiation count
rates or decays per unit surface area, or radioactivity per unit
volume. Operational guidelines are levels of radioactivity or
concentrations of radionuclides that can be accurately measured by
radiation detection and monitoring equipment and related or compared to
the dose-based PAGs to quickly determine if protective actions need to
be implemented. Appendix 4 of the guidance provides examples of
existing operational guidelines, and those being developed.
Federal Government agencies are continuing development of the
operational guidelines to support the application of the protective
action guides in this document, as well as tools that will help in the
development of incident-specific operational guidelines when they are
needed. As the Federal agencies develop these guidelines and tools,
they will be made available for review on the internet at the DOE's Web
site at https://www.ogcms.energy.gov. This webpage will provide the
status of operation guideline development and contain or provide a link
to downloadable documents and tools related to the guidelines.
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(d) Specific Questions for Reviewers
The Preparedness Directorate/DHS welcomes any comments and
suggestions regarding the subject document. However, we would
appreciate if reviewers specifically address the following issues:
Is the presentation and format of the document useful and
appropriate for its intended purpose? If not, why not and how should it
be changed?
Is the implementation process in Appendix 3 of the
proposed guidance clear and appropriate for its intended purpose? Are
roles and responsibilities sufficiently defined in the document?
Does the guidance provide the appropriate balance between
(a) public health and environmental protection goals; and (b) the
flexibility needed for the decision makers to conduct emergency
response actions and address public welfare needs, costs and benefits,
technical feasibility and societal interests during response to and
recovery from an incident? If not, how should the guidance be changed
to provide the appropriate balance?
Are the proposed PAGs for the early and intermediate
phases implementable? Are they appropriate? If not, why not and what
alternatives do you recommend?
Is the discussion on worker protection and response worker
protection helpful? Does Appendix 1 of the proposed guidance provide an
adequate discussion of expectations and the use of the alternate
response worker guidelines for life and property saving situations? If
not, what additional information is needed to make the discussion
adequate?
Are the operational guidelines being developed and
discussed in Appendix 4 of the proposed guidance useful? Are the
groupings clear and appropriate? Are there additional operational
guides that should be developed?
Is the optimization process proposed for late phase site
restoration and cleanup reasonable and sufficiently flexible to address
RDD and IND situations? If not, what changes need to be made to improve
the process?
Is a flexible process without pre-established limits an
appropriate method for site recovery? Would a flexible process with
goals, ranges or limits be more appropriate?
What other guidance or tools are needed to assist in the
implementation of the recommendations?
(e) References
``National Response Plan'' (NRP), January 2005.
``National Incident Management Plan'' (NIMS), March 1, 2004
``Manual of Protective Action Guides and Protective Actions for
Nuclear Incidents'' (EPA PAG) EPA 400-R-92-001, May 1992.
Complete Text of the Guidance
Application of Protective Action Guides for Radiological Dispersal
Device (RDD) and Improvised Nuclear Device (IND) Incidents
Prepared by the Department of Homeland Security in coordination
with the Department of Commerce, Department of Defense, Department of
Energy, Department of Labor, Department of Health and Human Services,
Environmental Protection Agency, Nuclear Regulatory Commission.
Table of Contents
(a) Introduction
(b) Characteristics of RDD and IND Incidents
(1) Radiological Dispersal Device
(2) Improvised Nuclear Device
(3) Differences Between Acts of Terror and Accidents
(c) Phases of Response
(1) Early Phase
(2) Intermediate Phase
(3) Late Phase
(d) Protective Actions and Protective Action Guides for RDD and IND
Incidents
(1) Protective Actions
(2) Protective Action Guides
(3) Protective Action Guides for RDD and IND Incidents
(i) Early Phase PAGs
(ii) Intermediate Phase PAGs
(iii) Late Phase PAGs
(e) Federal Implementation
(f) Operational Guidelines
Appendix 1. Radiation Protection for the Responder and Planning
for Implementation of the Protective Action Guides
Appendix 2. Risk Management Framework for RDD and IND Incident
Planning
Appendix 3. Federal Implementation
Appendix 4. Operational Guidelines for Implementation of the
PAGs During RDD or IND Events
Appendix 5. Acronyms/Glossary
Preface
Homeland Security Presidential Directive 5 (HSPD-5), Management of
Domestic Incidents, states, ``to prevent, prepare for, respond to and
recover from terrorist attacks, major disasters, and other emergencies,
the United States Government shall establish a single, comprehensive
approach to domestic incident management.'' It also assigns the
Secretary of the Department of Homeland Security (DHS) the role of
Principal Federal Official for domestic incident management.
DHS coordinated the development of this document in order to
address the critical issues of protective actions and protective action
guides (PAGs) to mitigate the effects caused by terrorist use of a
Radiological Dispersal Device (RDD) or Improvised Nuclear Device (IND).
This document was developed to provide guidance for site cleanup and
recovery following an RDD or IND incident and affirms the applicability
of existing PAGs for radiological emergencies. The intended audience of
this document is Federal radiological emergency response and
consequence management officials. In addition, State and local
governments may find this document useful in response and consequence
management planning. These guides are not intended for use at site
cleanups occurring under other statutory authorities such as the
Environmental Protection Agency (EPA) Superfund program, the Nuclear
Regulatory Commission's decommissioning program, or other Federal and
State cleanup programs. In addition, the scope of this document does
not include situations involving United States nuclear weapons
accidents.
Underlying the development and implementation of the
recommendations in the report is a risk management framework for making
decisions to provide for public safety and welfare. Appendix 2 provides
a summary of the framework based upon the report, ``Framework for
Environmental Health Risk Management,'' published in 1997 by the
Commission on Risk Assessment and Risk Management. The stages in this
framework--(1) Defining the problem and putting it into context, (2)
analyzing the risks, (3) examining the options, (4) making decisions
about which options to implement, (5) taking action, and (6) conducting
an evaluation of the results--are applicable to each of the stages of
response to an RDD or IND incident. However, the recommended guidelines
for early and intermediate phase actions already incorporate
consideration of the first four stages, so that action can be taken
immediately to respond to the incident. All of the stages of the risk
management framework will be applicable in the process of establishing
the criteria for the late phase of the response, as described later in
this report, because each situation will have its own unique problems,
risks, options, and decisions.
The Consequence Management, Site Restoration/Cleanup and
Decontamination (CMS) Subgroup of the DHS RDD/IND Working Group
accomplished this effort. The CMS Subgroup consists of subject matter
experts in radiological/nuclear
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emergency preparedness and response. In addition to DHS, the following
departments and agencies contributed to this effort: Department of
Commerce (DOC), Department of Defense (DoD), Department of Energy
(DOE), Department of Labor (DOL), Department of Health and Human
Services (HHS), Environmental Protection Agency (EPA), and Nuclear
Regulatory Commission (NRC).
(a) Introduction
For the early and intermediate phases of response, this document
presents levels of radiation exposure at which the Federal Government
recommends that actions be considered to avoid or reduce adverse public
health consequences from an RDD or IND incident. These PAGs incorporate
guidance and regulations published by the EPA, Food and Drug
Administration (FDA), and the Occupational Safety and Health
Administration (OSHA). For the late phase of the response, this
document presents a process to establish appropriate levels based on
site-specific circumstances. This document addresses the key questions
at each stage of an incident (early, intermediate, and late) and
constitutes advice by DHS to Federal, State, and local decision makers.
The objectives of the guides are to aid decision makers in
protecting the public, first responders, and other workers from the
effects of radiation, while balancing the adverse social and economic
impacts following an RDD or IND incident. Restoring the normal
operation of critical infrastructure, services, industries, business,
and public activities as soon as possible can minimize adverse social
and economic impacts.
These guides for RDD and IND incidents are not absolute standards.
The guides are not intended to define ``safe'' or ``unsafe'' levels of
exposure or contamination, but rather they represent the approximate
levels at which the associated protective actions are justified. The
guides give State and local decision makers the flexibility to be more
or less restrictive as deemed appropriate based on the unique
characteristics of the incident and local considerations.
The PAGs can be used to select actions to prepare for, respond to,
and recover from the adverse effects that may exist during any phase of
a terrorist incident--the early (emergency) phase, the intermediate
phase, or the late phase. There may be an urgent need to evacuate
people; there may also be an urgent need to restore the services of
critical infrastructure (e.g., roads, rail lines, airports, electric
power, water, sewage, medical facilities, and businesses) in the hours
and days following the incident--thus, some response decisions must be
made quickly. If the decisions on the recovery of critical
infrastructure are not made quickly, the disruption and harm caused by
the incident could be inadvertently and unnecessarily increased.
Failure to restore important services rapidly could result in
additional adverse public health and welfare impacts that could be more
significant than the direct radiological impacts.
(b) Characteristics of RDD and IND Incidents
A radiological incident is defined as an event or series of events,
deliberate or accidental, leading to the release, or potential release,
into the environment of radioactive material in sufficient quantity to
warrant consideration of protective actions. Use of an RDD or IND is an
act of terror that produces a radiological incident.
(1) Radiological Dispersal Device
An RDD poses a threat to public health and safety through the
spread of radioactive materials by some means of dispersion. The mode
of dispersal typically conceived as an RDD is an explosive device
coupled with radioactive material. The explosion adds an immediate
threat to human life and property. Other means of dispersal, both
passive and active, may be employed.
There is a wide range of possible consequences that may result from
an RDD, depending on the type and size of the device, and how dispersal
is achieved. The consequences of an RDD may range from a small,
localized area, such as a single building or city block, to large
areas, conceivably many square miles. However, most experts agree that
the likelihood of impacting a large area is low. In most plausible
scenarios, the radioactive material would not cause acutely harmful
radiation doses, and the primary public health concern from those
materials would be chronic risk of cancer to exposed individuals.
Hazards from fire, smoke, shock (physical, electrical or thermal),
shrapnel (from an explosion), industrial chemicals, and other chemical
or biological agents may also be present.
(2) Improvised Nuclear Device
An IND is a nuclear weapon originating from an adversary State or
fabricated by a terrorist group from illicit special nuclear material
that produces a nuclear explosion. The nuclear yield achieved by an IND
produces extreme heat, powerful shockwaves, and prompt radiation that
would be acutely lethal for a significant distance. It also produces
radioactive fallout, which may spread far downwind and deposit over
very large areas. If nuclear yield is not achieved, the result would
likely resemble an RDD in which fissile weapons material was utilized.
(3) Differences Between Acts of Terror and Accidents
Most radiological emergency planning has been conducted to respond
to potential nuclear power plant accidents. RDD and IND incidents may
differ from a nuclear power plant accident in several ways, and
response planning should take these differences into account. First,
the severity of an IND incident would be dramatically greater than any
nuclear power plant accident (although an RDD would likely be on the
same order of magnitude as a nuclear power plant accident). An IND
would have vastly greater radiation levels and would create a large
radius of severe damage from blast and heat, which could not occur in a
nuclear power plant accident.
Second, the release from an RDD or IND may start without any
advance warning and would likely have a relatively short release
duration. With a major nuclear power plant accident there is likely to
be several hours of warning before the release starts, and the release
is likely to be drawn out over many hours. This difference means that
most early, and some intermediate phase, protective action decisions
must be made more quickly (and with less information) in an RDD or IND
incident if they are to be effective.
Third, an RDD or IND incident is more likely to occur in a major
city with a large population. Because of the rural setting in which
many nuclear facilities are located, the number of people affected by a
nuclear power plant incident may be less and the amount of critical
infrastructure impacted is also likely to be smaller.
Fourth, large nuclear facilities have detailed emergency plans that
are periodically exercised, including specified protective action
sectors, evacuation routes, and methods to quickly warn the public on
the protective actions to take. This would not be the case in an RDD or
IND incident. This level of radiological emergency planning typically
does not exist for most cities and towns without nuclear facilities.
Fifth, the type of radioactive material involved could and probably
will be different from what is potentially
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released for a nuclear power plant incident.
(c) Phases of Response
Typically, the response to an RDD or IND incident can be divided
into three time phases--the early phase, the intermediate phase, and
the late phase--that are generally accepted as being common to all
nuclear incidents. Although these phases cannot be represented by
precise time periods and may overlap, they provide a useful framework
for the considerations involved in emergency response planning.
(1) Early Phase
The early phase (or emergency phase) is the period at the beginning
of the incident when immediate decisions for effective use of
protective actions are required and actual field measurement data is
generally not available. Exposure to the radioactive plume, short-term
exposure to deposited materials, and inhalation of radioactive material
are generally included when considering protective actions for the
early phase. The response during the early phase includes initial
emergency response actions to protect public health and welfare in the
short term. Priority should be given to lifesaving and first-aid
actions.
In general, early phase protective actions should be taken very
quickly, and the protective action decisions can be modified later as
more information becomes available. If an explosive RDD is deployed
without warning, there may be no time to take protective actions to
reduce plume exposure. In the event of a covert dispersal, discovery or
detection may not occur for days or weeks, allowing contamination to be
dispersed broadly by foot, vehicular traffic, wind, rain, or other
forces. If an IND explodes, there would only be time to make early
phase, protective action recommendations to protect against exposure
from fallout in areas many miles downwind from the explosion.
(2) Intermediate Phase
The intermediate phase of the response may follow the early phase
response within as little as a few hours. The intermediate phase of the
response is usually assumed to begin after the source and releases have
been brought under control and protective action decisions can be made
based on measurements of exposure and radioactive materials that have
been deposited as a result of the incident. Activities in this phase
typically overlap with early and late phase activities, and may
continue for weeks to many months, until protective actions are
terminated.
During the intermediate phase, decisions must be made on the
initial actions needed to recover from the incident, reopen critical
infrastructures, and return to a general state of normal activity. In
general, intermediate phase decisions should consider late phase
response objectives. However, some intermediate phase decisions will
need to be made quickly (i.e., within hours) and should not be delayed
by discussions on what the more desirable permanent decisions will be.
All of these decisions must take into account the health, welfare,
economic, and other factors that must be balanced by local officials.
For example, it can be expected that hospitals and their access roads
will need to remain open or be reopened quickly. These interim
decisions can often be made with the acknowledgement that further work
may be needed as time progresses.
(3) Late Phase
The late phase is the period when recovery and cleanup actions
designed to reduce radiation levels in the environment to acceptable
levels are commenced, and it ends when all the recovery actions have
been completed. With the additional time and increased understanding of
the situation, there will be opportunities to involve key stakeholders
in providing sound, cost-effective recommendations. Generally, early
(or emergency) phase decisions will be made directly by elected public
officials, or their designees, with limited stakeholder involvement due
to the need to act within a short timeframe. Long-term decisions should
be made with stakeholder involvement, and can also include incident-
specific technical working groups to provide expert advice to decision
makers on impacts, costs, and alternatives.
The relationship between typical protective actions and the phases
of the incident response are outlined in Figure 1. Plainly, there is
overlap between the phases, and this framework should be used to
support a timely decision making process, irrespective of the
perception of which incident phase might be applicable.
BILLING CODE 9110-21-P
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[GRAPHIC] [TIFF OMITTED] TN03JA06.000
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(d) Protective Actions and Protective Action Guides for RDD and IND
Incidents
(1) Protective Actions
Protective actions are activities that may be conducted in response
to an RDD or IND incident in order to reduce or eliminate exposure to
members of the public to radiation or other hazards. These actions are
generic and are applicable to RDDs and INDs. The principal protective
action decisions for consideration in the early and intermediate phases
of an emergency are whether to shelter-in-place, evacuate, or relocate
affected or potentially affected populations. Secondary actions include
administration of prophylactic drugs, decontamination, use of access
restrictions, and use of restrictions on food and water. In some
situations, only one protective action needs to be implemented, while
in others, numerous protective actions should be implemented.
(2) Protective Action Guides
PAGs are the projected dose to a reference individual, from an
accidental or deliberate release of radioactive material at which a
specific protective action to reduce or avoid that dose is recommended.
Thus, protective actions are designed to be taken before the
anticipated dose is realized. The ``Manual of Protective Action Guides
and Protective Actions for Nuclear Incidents'' \1\ published by the EPA
(also known as the EPA PAG Manual) provides a significant part of the
basis
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of this document and may be referred to for additional details.
---------------------------------------------------------------------------
\1\ ``Manual of Protective Action Guides and Protective Actions
for Nuclear Incidents,'' U.S. Environmental Protection Agency, May
1992, EPA-400-R-92-001.
---------------------------------------------------------------------------
The existing PAGs meet the following principle criteria and goals:
(1) Prevent acute effects, (2) reduce risk of chronic effects, and (3)
require optimization to balance protection with other important factors
and ensure that actions taken cause more benefit than harm.
In this document, PAGs are generic criteria based on balancing
public health and welfare with the risk of alternatives applied in each
of the phases of an RDD or IND incident. The PAGs are specific for
radiation and radioactive materials, and must be considered in the
context of other chemical or biological hazards that may also be
present. Though the PAGs are values of dose avoided, published dose
conversion factors and derived response levels may be utilized in
estimating doses, and for choosing and implementing protective actions.
Other quantitative measures and derived concentration values may be
useful in emergency situations; for example, for the release of goods
and property from contaminated zones, and to control access in and out
of contaminated areas.
Because of the short time frames required for emergency response
decisions, it is likely there will not be opportunities for local
decision makers to consult with a variety of stakeholders before taking
actions. Therefore, the early and intermediate phase EPA PAGs have been
based on the significant body of work done in the general context of
radiological emergency response planning, and represent the results of
public comment, drills, exercises, and a consensus at the Federal level
for appropriate emergency action.
In order to use the PAGs to make decisions about appropriate
protective actions, decision makers will need information on suspected
radionuclides; projected plume movement and depositions; and/or actual
measurement data or, during the period initially following the release,
expert advice in the absence of good information. Sources of such
information include: on-scene responders as well as monitoring,
assessment, and modeling centers.
(3) Protective Action Guides for RDD and IND Incidents
The PAGs for RDD and IND incidents are generally based on the
following sources: the PAGs developed by EPA in coordination with other
Federal agencies through the Protective Action Guide Subcommittee of
the Federal Radiological Preparedness Coordinating Committee; guidance
developed by the FDA for food and food products and the distribution of
potassium iodide; and OSHA regulations.
In order to use this guide, there may be a need to compare the PAG
to the results of a risk assessment or dose projection. It should be
emphasized that, in general, when making radiation dose projections,
realistic assumptions should be used so the final results are
representative of actual conditions.
Table 1 provides a summary of the key actions and suggested PAGs
for an RDD or IND incident.
Table 1.--Protective Action Guides for RDD or IND Incidents
----------------------------------------------------------------------------------------------------------------
Phase Protective action Protective action guide Reference
----------------------------------------------------------------------------------------------------------------
Early.............................. Limit Emergency Worker 5 rem (or greater under EPA PAG Manual.
Exposure. exceptional
circumstances\1\.
Sheltering of Public.. 1 to 5 rems projected EPA PAG Manual.
dose\2\.
Evacuation of Public.. 1 to 5 rems projected EPA PAG Manual.
dose\3\.
Administration of For potassium iodide, FDA FDA Guidance \6\.
Prophylactic Drugs. Guidance dose values\4\
\5\.
Intermediate....................... Limit Worker Exposure. 5 rem/yr................... See Appendix 1.
Relocation of General 2 rems, projected dose EPA PAG Manual.
Public. first year Subsequent
years: 500 mrem/yr
projected dose.
Food Interdiction..... 500 mrem/yr projected dose. FDA Guidance \7\.
Drinking Water 500 mrem/yr dose........... EPA guidance in
Interdiction. development.
Late............................... Final Cleanup Actions. Late phase PAG based on
optimization .
----------------------------------------------------------------------------------------------------------------
\1\ In cases when radiation control options are not available or, due to the magnitude of the incident, are not
sufficient, doses above 5 rems may be unavoidable. For further discussion see Appendix 1.
\2\ Should normally begin at 1 rem; however, sheltering may begin at lower levels if advantageous.
\3\ Should normally begin at 1 rem.
\4\ Provides protection from radioactive iodine only.
\5\ For other information on medical prophylactics and treatment please refer to https://www.fda.gov/cder/drugprepare/default.htm or https://www.bt.cdc.gov/radiation/index/asp or https://www.orau.gov/reacts.
\6\ ``Potassium Iodide as a Thyroid Blocking Agent in Radiation Emergencies,'' December 2001, Center Drug
Evaluation and Research, FDA, HHS (https://www.fda.gov/cder/guidance/5386fnl.htm).
\7\ ``Accidental Radioactive Contamination of Human Food and Animal Feeds: Recommendations for State and Local
Agencies,'' August 13, 1998, Office of Health and Industry Programs, Center for Devices and Radiological
Health, FDA, HHS (https://www.fda.gov/cdhr/dmqrp/84.html).
(i) Early Phase PAGs
For the early phase, the existing PAGs for evacuation, sheltering,
relocation, and protection of emergency workers are appropriate for RDD
and IND incidents. FDA guidance on the administration of stable iodine
is also considered appropriate (only useful for an IND or NPP incident
involving radioiodine release). The administration of other
prophylactic drugs should be evaluated on a case-by-case basis and
depend on the nature of the event and radioisotopes involved. It can be
expected that an initial zone will be established and controlled around
the site of the incident, as is the case for other crime scenes and
hazards. These guides allow for the refinement of that area if the
presence of radiation or radioactive material warrants such action.
The response during the early phase includes initial emergency
response actions to protect public health and welfare in the short
term. Priority should be given to lifesaving and first-aid actions.
Incident commanders should define and enforce an allowable emergency
dose limit in accordance with the immediate risk situation. Following
IND detonation, the highest priority missions will include suppression
of ignited fires to prevent further loss of life. High radiation doses
to emergency personnel in IND situations, substantially exceeding the
nominal occupational level of 5 rem may be unavoidable. While every
effort to employ as low as reasonably achievable (ALARA) principles
after an
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IND event will be made, medically significant exposures may also be
unavoidable (see Appendix 1, Section E). Medical evaluation of
emergency response personnel after such exposure is recommended.
(ii) Intermediate Phase PAGs
The decisions in the intermediate phase will focus on the return of
key infrastructure and services, and the rapid restoration of normal
activities. This will include decisions on allowing use of roads,
ports, waterways, transportation systems (including subways, trains,
and airports), hospitals, businesses, and residences. It will also
include responses to questions about acceptable use and release of real
and personal property such as cars, clothes, or equipment that may have
been impacted by the RDD or IND incident. Many of the activities will
be concerned with materials and areas that were not affected but for
which members of the public may have a concern. Thus, the PAGs serve to
guide decisions on returning to impacted areas, leaving impacted areas,
and providing assurance that an area or material was not impacted. See
Appendix 1 for a discussion of occupational safety and health
standards.
For the intermediate phase, relocation of the population is a
protective action that can be used to reduce dose. Relocation is the
removal or continued exclusion of people (households) from contaminated
areas in order to avoid chronic radiation exposure, and it is meant to
protect the general public. For the intermediate phase, the existing
relocation PAGs of 2 rems in the first year and 500 mrems in any year
after the first are considered appropriate for RDD and IND incidents.
However, for some IND incidents, the area impacted and the number of
people that might be subject to relocation could potentially be very
large and could exceed the resources and infrastructure available. For
example, in making the relocation decision, the availability of
adequate accommodations for relocated people should be considered.
Decision makers may need to consider limiting action to those most
severely affected, and phasing relocation implementation based on the
resources available.
The relocation PAG applies principally to personal residences but
may impact other facilities as well. For example, it could impact work
locations, hospitals, and park lands as well as the use of highways and
other transportation facilities. For each type of facility, the
occupancy time of individuals should be taken into account to determine
the criteria for using a facility or area. It might be necessary to
avoid continuous use of homes in an area because radiation levels are
too high. However, a factory or office building in the same area could
be used because occupancy times are shorter. Similarly, a highway could
be used at higher contamination levels because the exposure time of
highway users would be considerably less than the time spent at home.
The intermediate phase PAGs for the interdiction of food and water
are set at 500 mrem/yr each for RDD and IND incidents. These values are
consistent with those now used or being considered as PAGs for other
types of nuclear incidents.
The use of simple dose reduction techniques is recommended for
personal property and all potentially contaminated areas that continue
to be occupied. This use is also consistent with the PAGs developed for
other types of nuclear incidents. Examples of simple dose reduction
techniques would be washing of all transportation vehicles (e.g.,
automobiles, trains, ships, and airplanes), personal clothing before
reuse, eating utensils, food preparation surfaces before next use, and
other personal property, as practicable and appropriate.
(iii) Late Phase PAGs
The late phase involves the final cleanup of areas and property
with radioactive material present. Unlike the early and intermediate
phases of an RDD or IND incident, decision makers will have more time
and information during the late phase to allow for better data
collection, stakeholder involvement, and options analysis. In this
respect, the late phase is no longer a response to an ``emergency
situation,'' and is better viewed in terms of the objectives of site
restoration and cleanup.
Because of the extremely broad range of potential impacts that may
occur from RDDs and INDs (e.g., ranging from light contamination of one
building to widespread destruction of a major metropolitan area), a
pre-established numeric guideline is not recommended as best serving
the needs of decision makers in the late phase. Rather, a process
should be used to determine the societal objectives for expected land
uses and the options and approaches available, in order to select the
most acceptable criteria. For example, if the incident is an RDD of
limited size, such that the impacted area is small, then it might
reasonably be expected that a complete return to normal conditions can
be achieved within a short period of time. However, if the impacted
area is large, then achieving even low cleanup levels for remediation
of the entire area and/or maintaining existing land uses may not be
practicable.
The Risk Management Framework described in Appendix 2 provides such
a process and helps assure the protection of public health and welfare.
Decisions should take health, safety, technical, economic, and public
policy factors into account. Appendix 3 utilizes the framework to
manage Federal RDD and IND site cleanup and restoration.
Optimization (broadly defined) is a concept that is common to many
State, Federal, and international risk management programs that address
radionuclides and chemicals, although it is not always identified as
such. Optimization is a flexible approach where a variety of dose and/
or risk benchmarks may be identified from State, Federal,