[Federal Register: January 3, 2006 (Volume 71, Number 1)]
[Notices]
[Page 173-196]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr03ja06-118]
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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
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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ACTION: Notice of draft guidance for interim use with request for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.
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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DATES: The draft guidance contained in this notice is released for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 Comments on this draft guidance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: http://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 http://www.regulations.gov, including any personal
information provided.
Docket: For access to the docket to read background documents or
comments received, go to http://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
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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.
(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.
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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. 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.
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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, 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 http://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
BILLING CODE 9110-21-C
(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
[[Page 182]]
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 http://www.fda.gov/cder/ drugprepare/default.htm or http://www.bt.cdc.gov/radiation/index/asp or http://www.orau.gov/reacts.
ttp://www.bt.cdc.gov/radiation/index/asp or http://www.orau.gov/reactstion/index/asp or http://www.orau.gov/reacts..
\6\ ``Potassium Iodide as a Thyroid Blocking Agent in Radiation Emergencies,'' December 2001, Center Drug
Evaluation and Research, FDA, HHS (http://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 (http://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
[[Page 183]]
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, 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)
[[Page 184]]
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.
(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 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 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
[[Page 185]]
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 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
------------------------------------------------------------------------
Emergency Normal operations
------------------------------------------------------------------------
An adversary may attempt to create Key elements to radiation
conditions that will cause high protection are to contain
radiation exposures, widespread radioactivity and confine
contamination, and mass disruption. access to it.
Actions must be taken as soon as There is adequate time to fully
possible to minimize exposures even characterize situations and
when information on the risks is determine risks and mitigating
incomplete. measures.
Lack of action--due to unclear, overly Inaction or delays may increase
complicated, or reactive guidelines-- costs but rarely results in
have a high possibility of causing consequences that cannot be
unintended consequences. mitigated.
During emergencies, the undesired Consequences associated with
consequences can be significant, implementation of the standard
uncontrollable, and unpredictable. 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 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 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
[[Page 186]]
response worker guidelines \2\ (see Table 1B) for certain activities
where exposures below 5 rems cannot be maintained.
---------------------------------------------------------------------------
\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.
Table 1B.--Response Worker Guidelines
------------------------------------------------------------------------
Total effective date
equivalent (TEDE) guideline Activity Condition
------------------------------------------------------------------------
5 rems...................... All occupational All reasonably
exposures. achievable actions
have been taken to
minimize dose.
10 rems *................... Protecting valuable Exceeding 5 rems
property necessary unavoidable and all
for public welfare appropriate actions
(e.g., a power taken to reduce
plant). dose. Monitoring
available to
project or measure
dose.
25 rems **.................. Lifesaving or Exceeding 5 rems
protection of large unavoidable and all
populations. 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.
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.
[[Page 187]]
[GRAPHIC] [TIFF OMITTED] TN03JA06.001
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 radionuclide-
specific risk factors (e.g., Federal Guidance Report 13 \3\
and EPA Health Effects Assessment Summary Tables).
---------------------------------------------------------------------------
\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.
---------------------------------------------------------------------------
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
to 50 year-olds have a 5.3 per thousand risk of premature death).\5\
---------------------------------------------------------------------------
\4\ Risk per dose of a fatal concern is assumed to be about
6x10-4 per rem. Cancer incidence is assumed to be about
7x10-4 per rem. (See Federal Guidance Report 13.
\5\ Federal Guidance Report 13.
---------------------------------------------------------------------------
(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\
---------------------------------------------------------------------------
\6\ Available at http://www.nv.doe.gov/programs/frmac/DOCUMENTS.htm
.
---------------------------------------------------------------------------
(g) Occupational Standards
Under the provisions of the Occupational Safety and Health Act,
and equivalent statutes in the 26 States that operate OSHA-approved
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.
[[Page 188]]
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.
---------------------------------------------------------------------------
\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).
---------------------------------------------------------------------------
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
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 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, risk-informed
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, cost-effective, 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 well-being, 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,
[[Page 189]]
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.
(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 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.
(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 cost-
effectiveness 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
[[Page 190]]
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.
(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 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 multi-agency, 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.
(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 post-decontamination 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
[[Page 191]]
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 long-term 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, 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