[Federal Register: August 1, 2008 (Volume 73, Number 149)]
[Notices]
[Page 45029-45048]
[DOCID:fr01au08-90]

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DEPARTMENT OF HOMELAND SECURITY

Federal Emergency Management Agency

[Docket ID FEMA-2004-0004]
[Z-RIN 1660-ZA02]

Planning Guidance for Protection and Recovery Following
Radiological Dispersal Device (RDD) and Improvised Nuclear Device (IND)
Incidents

AGENCY: Federal Emergency Management Agency, DHS.

ACTION: Notice of final guidance.

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SUMMARY: The Department of Homeland Security (DHS) is issuing final
guidance entitled, ``Planning Guidance for Protection and Recovery
Following Radiological Dispersal Device (RDD) and Improvised Nuclear
Device (IND) Incidents'' (the Guidance). This Guidance is intended for
Federal agencies, State and local governments, emergency management
officials, and the general public who should find it useful in
developing plans for responding to an RDD or IND incident. The Guidance
recommends ``protective action guides'' (PAGs) to support decisions
about actions that should be taken to protect the public and emergency
workers when responding to or recovering from an RDD or IND incident.
The Guidance outlines a process to implement the recommendations,
discusses existing operational guidelines that should be useful in the
implementation of the PAGs and other response actions, and encourages
federal, state and local emergency response officials to use these
guidelines to develop specific operational plans and response protocols
for protection of emergency workers responding to catastrophic
incidents involving high levels of radiation and/or radioactive
contamination.

DATES: This notice is effective August 1, 2008.

FOR FURTHER INFORMATION CONTACT: Craig Conklin, Director Sector
Specific Agency Executive Management Office, Office of Infrastructure
Protection,

Department of Homeland Security at<PHONE_NUMBER> (phone), or
<EMAIL_ADDRESS>(e-mail), or, John MacKinney, Deputy Director,
Nuclear/Radiological/Chemical Threats and Science and Technology
Policy, Office of Policy, Department of Homeland Security, at (202)
447-3885 (phone), or<EMAIL_ADDRESS>(e-mail).

SUPPLEMENTARY INFORMATION:

Table of Contents

Preface
    (a) Introduction
    (b) Characteristics of RDD and IND Incidents
    (1) Radiological Dispersal Device (RDD)
    (2) Improvised Nuclear Device (IND)
    (3) Differences Between Acts of Terror and Accidents
    (c) Phases of Response
    (1) Early Phase
    (2) Intermediate Phase
    (3) Late Phase
    (d) Guidance for RDD and IND Incidents
    (1) Protective Actions
    (2) Protective Action Guides (PAGs)
    (3) Early and Intermediate Phase Protective Action Guides for
RDD and IND Incidents
    (A) Early Phase PAGs
    (B) Intermediate Phase PAGs
    (4) Late Phase Guidance
    (5) Emergency Worker Guidance
    (e) Operational Guidelines for Early and Intermediate PAGs
    (1) Derived Response Levels (DRLs)
    (2) Derived Intervention Levels (DILs) for Food
    (3) Radiation Levels for Control of Access to Radiation Areas
Appendix 1. Planning for Protection of Emergency Workers Responding
to RDD and IND Incidents
    (a) Guidelines for Emergency Workers in Responding to RDD and
IND Incidents
    (b) Controlling Occupational Exposures and Doses to Emergency
Workers
    (c) Understanding Radiation Risks
    (d) Preparedness
Appendix 2. Risk Management Framework for RDD and IND Incident
Planning
    (a) The Stages of the Risk Management Framework for Responding
to RDD and IND Incidents
    (1) Define the Problems and Put Them in Context
    (2) Analyze the Risks
    (3) Examine the Options
    (4) Make a Decision
    (5) Take Action To Implement Decision
    (6) Evaluate the Results
    (b) Technical Advisory Committee
Appendix 3. Federal Cleanup Implementation Cleanup Activities
Overview
    (a) General Management Structure
    (1) Technical Working Group
    (2) Stakeholder Working Group
    (b) Activities
    (1) Optimization and Recommendation
    (2) Public Review of Decision
    (3) Execute Cleanup
Appendix 4. Operational Guidelines for Implementation of Protective
Action Guides and Other Activities in RDD or IND Incidents
    (a) Group A: Access Control During Emergency Response Operations
    (b) Group B: Early Phase Protective Action (Evacuation or
Sheltering)
    (c) Group C: Relocation and Critical Infrastructure Utilization
in Affected Areas
    (d) Group D: Temporary Access to Relocation Areas for Essential
Activities
    (e) Group E: Transportation and Access Routes
    (f) Group F: Release of Property From Radiologically Controlled
Areas
    (g) Group G: Food Consumption
    (h) Derivation of Operational Guidelines
Appendix 5. References
Appendix 6. Acronyms/Glossary

Background

    This Guidance was developed to address the critical issues of
protective actions and protective action guides (PAGs) to protect human
health and to mitigate the effects caused by terrorists' use of a
Radiological Dispersal Device (RDD) or Improvised Nuclear Device (IND).
This document provides guidance for site cleanup and recovery following
an RDD or IND incident, and affirms the applicability of existing 1992
EPA PAGs for radiological emergencies.
    The development of this Guidance was directed by the White House,
Office of Science and Technology Policy, through the National Science
and Technology Council, Committee on Homeland and National Security,
Subcommittee on Standards (SoS). In 2003, the SoS convened a senior
level Federal working group, chaired by DHS, to develop guidance for
response and recovery following a radiological dispersal device (RDD)
or improvised nuclear device (IND) incident. The working group
consisted of senior subject matter experts in radiological/nuclear
emergency preparedness, response, recovery, and incident 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 Nuclear Regulatory
Commission (NRC).
    On January 3, 2006, DHS issued the ``Preparedness Directorate;
Protective Action Guides for Radiological Dispersal Device (RDD) and
Improvised Nuclear Device (IND) Incidents; Notice'' (71 FR 174, Jan. 3,
2006), and requested public comments on this interim Guidance. Some
changes to the Guidance were made as a result of these comments. A
summary of the comments on the interim Guidance document and responses
are available at Docket ID No. FEMA-2004-0004 at http://
www.regulations.gov.
    In addition to the issuance of this Guidance, in response to
interagency working group discussions and public comments, further
guidance will be provided for the consequences that would be unique to
an IND attack. This Guidance was not written to provide specific
recommendations for a nuclear detonation (IND), but to consider the
applicability of existing PAGs to RDDs and INDs. In particular, it does
not consider very high doses or dose rate zones expected following a
nuclear weapon detonation and other complicating impacts that can
significantly affect life-saving outcomes, such as severely damaged
infrastructure, loss of communications, water pressure, and
electricity, and the prevalence of secondary hazards. Scientifically
sound recommendations for responders are a critical component of post-
incident life-saving activities, including implementing protective
orders, evacuation implementation, safe responder entry and operations,
and urban search and rescue and victim extraction. In the interim, this
Guidance should be used until the IND guidance is developed.
    The intended audience of this document are Federal, State, and
local radiological emergency response and incident management
officials. This Guidance is not intended to impact site cleanups
occurring under other statutory authorities such as the Environmental
Protection Agency's (EPA) Superfund program, the Nuclear Regulatory
Commission's (NRC) decommissioning program, or other Federal and State
cleanup programs. In addition, the scope of this Guidance does not
include situations involving U.S. nuclear weapons accidents.
    In addition to the issuance of this Guidance, further guidance is
being planned for the devastating consequences that would be unique to
INDs. In the interim, the present document will provide general RDD and
IND guidance.
    By agreement with the Environmental Protection Agency (EPA), the
Guidance being published today is final and its substance will be
incorporated without change into the revision of the 1992 EPA Manual of
Protective Actions Guides and Protective Actions for Nuclear Incidents
(the PAG Manual). This notice of final guidance will therefore sunset
upon publication of the new EPA PAG Manual (see, http://www.epa.gov/
radiation/rert/pags.html). The reader will then be directed to the

new EPA PAG Manual, where these provisions may be found.

(a) Introduction

    For the early and intermediate phases of response, this document
presents levels of projected radiation dose at which the Federal
Government recommends that actions be considered to avoid or reduce
adverse public health consequences from an RDD or IND incident. This
document incorporates 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
Guidance presents a process for establishing appropriate exposure
levels based on site-specific circumstances. This Guidance addresses
key radiological protection questions at each stage of an RDD or IND
incident (early, intermediate, and late) and constitutes advice by the
Federal government to Federal, State, and local decision makers.
    The objective of the Guidance is to aid decision makers in
protecting the public, first responders, and other emergency workers
from the effects of radiation, and cleaning up the affected area, 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.
    This Guidance for RDD and IND incidents is not a set of absolute
standards. The guides 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
justified. The Guidance provides Federal, 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.
    This RDD/IND Guidance 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 affecting 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 results in a radiological incident.
(1) Radiological Dispersal Device (RDD)
    An RDD poses a threat to public health and safety through the
malicious spread of radioactive material 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 several square miles. However, most experts agree
that the likelihood of impacting a very large area is low. In most
plausible scenarios, the radioactive material would not result in
acutely harmful radiation doses, and the primary public health concern
from those materials would be increased risk of cancer to exposed
individuals. Hazards from fire, smoke, shock (physical, electrical, or
thermal), shrapnel (from an explosion), hazardous materials, and other
chemical or biological agents may also be present.
(2) Improvised Nuclear Device (IND)
    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 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 and deposit over very large
areas. If a 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
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. An IND would have grave consequences for
the human population and create a large radius of severe damage from
blast and fires, which could not occur in a nuclear power plant
accident.
    Second, the radiological release from an RDD or IND may start
without any advance warning and would likely have a relatively short
duration. In a major nuclear power plant accident, there is likely to
be several hours or days of warning before the release starts, and the
release is likely to be drawn out over many hours. This difference
means that most early phase, and some intermediate phase, protective
action decisions, which may be made in a timely fashion during power
plant incidents, must be made much 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 center with a large population. Because of the rural setting in
which many nuclear facilities are located, the lower number and density
of people affected by a nuclear plant incident would be less, making
evacuations much more manageable, and the amount of critical
infrastructure impacted is also likely to be smaller.
    Fourth, large nuclear facilities have detailed emergency plans
developed over years that are periodically exercised including
specified protective actions, evacuation routes, and methods to quickly
alert the public of the actions to take. This would not be the case for
an RDD or IND incident. This level of radiological emergency planning
typically does not exist in most cities and towns without nearby
nuclear facilities.
    Fifth, the radioactive material releases from a nuclear power plant
incident would be well known in advance based on reactor operational
characteristics

whereas releases associated with an RDD or IND would not.
    Sixth, in an act of terrorism, the incident scene becomes a crime
scene. As such, the crime scene must be preserved for forensic
investigation. This may impact emergency responders during the early
and intermediate phases of response. It should be noted that other
personnel responding to the incident (i.e., law enforcement, security
personnel) will be involved in addition to emergency responders.

(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
radiological incidents. The phases represent time periods in which
response officials would be making public health protection decisions.
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 protective
actions are required, and when actual field measurement data generally
are not available. Exposure to the radioactive plume, short-term
exposure to deposited radioactive materials, and inhalation of
radioactive material are generally taken into account 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, considering a time period for
protective actions of hours to a few days. 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, however, there may be
no time to take protective actions to significantly reduce plume
exposure. Also, 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 may only be time to make early phase
protective action recommendations (e.g., evacuation, or shelter-in-
place) many miles from the explosion to protect areas against exposure
to fallout. Areas close to the explosion will be devastated, and
communications and access will be extremely limited. Assistance will
likely not be forthcoming or even possible for some hours. Self-guided
protective actions are likely to be the best recourse for most
survivors (e.g., evacuation perpendicular to the plume movement if it
can be achieved quickly, or sheltering in a basement or large building
for a day or more after the incident \1\). Due to the lack of
communication and access, outside guidance and assistance to these
areas can be expected to be delayed. Therefore, response planning and
public outreach programs are critical measures to meet IND preparedness
objectives.
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    \1\ Additional protective action guides and recommendations are
needed for the close-in zones after an IND. A follow-on Federal
effort is underway to address this critical need.
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(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 incident 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 can be terminated.
    During the intermediate phase, decisions must be made on the
initial actions needed to recover from the incident, reopen critical
infrastructure, and return to a state of relatively 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.
Local officials must weigh public health and welfare concerns,
potential economic effects, and many other factors when making
decisions. 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. This phase ends when all the remediation actions
have been completed. With additional time and increased understanding
of the situation, there will be opportunities to involve key
stakeholders in providing sound, cost-effective cleanup recommendations
that are protective of human health and the environment. 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 alternatives, costs, and impacts. The
relationship between typical protective actions and the phases of the
incident response are outlined in Figure 1. There is overlap between
the phases; this framework should be used to inform planning and
decision-making.
BILLING CODE 9110-21-I

[GRAPHIC] [TIFF OMITTED] TN01AU08.003

BILLING CODE 9110-21-C

(d) Guidance for RDD and IND Incidents

    This section defines protective actions and protective action
guides, and provides guidance for their implementation in RDD and IND
incidents. In addition, this section provides guidance for protection
of emergency workers, and a strategy for devising cleanup plans,
criteria, and options.
(1) Protective Actions
    Protective actions are activities that should be conducted in
response to an RDD or IND incident in order to reduce or eliminate
exposure 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 medical countermeasures, decontamination (including
decontamination of persons evacuated from the affected area), 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. Many
factors should be considered when deciding whether or not to order a
protective 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 population increases.
(2) Protective Action Guides (PAGs)
    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 are designed to be taken before the
anticipated dose is realized.
    The Environmental Protection Agency (EPA) has 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). The
PAGs presented in this manual, hereafter referred to as the 1992 EPA
PAGs, are non-regulatory. They are designed to provide a flexible basis
for decisions under varying emergency circumstances. The 1992 EPA PAGs
meet the following principal 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 result in more benefit than harm.
    The 1992 EPA PAG Manual, however, was not developed to address
response actions following radiological or nuclear terrorist incidents
and does not address long-term cleanup. The 1992 EPA 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 1992 EPA PAGs were designed principally to
address the impacts of commercial NPP accidents, the worst type of
incident under consideration at that time. This is important for two
reasons: Commercial nuclear power plant accidents are almost always
signaled by preceding events, giving plant managers time to make
decisions, and giving local emergency managers time to communicate with
the public and initiate evacuations if necessary. In addition, the
suite of radionuclides present at nuclear power plants is well-known,
and is dominated by relatively short-lived isotopes.
    The 1992 EPA PAG Manual provides a significant part of the basis of
this document and should be referred to for additional details. In
deriving the recommendations contained in this Guidance, new types of
incidents and scenarios that could lead to environmental radiological
contamination were considered. The interagency working group determined
that the 1992 EPA PAGs for the early and intermediate phases, including
emergency responder guidelines, are also appropriate for use in RDD and
IND incidents. This Guidance is intended to supplement the 1992 EPA PAG
Manual for application to RDD and IND incidents, including providing
new late phase guidance.
    The RDD/IND Guidance provides generic criteria based on balancing
public health and welfare with the risk of various protective actions
applied in each of the phases of an RDD or IND incident. The RDD/IND
Guidance is specific to radiation and radioactive materials, and must
be considered in the context of other chemical or biological hazards
that may also be present. Though the early and intermediate PAGs in
this Guidance are values of dose to be 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 into and
out of contaminated areas.
    Because of the short time frames required for emergency response
decisions in the early and intermediate phases, it is likely there will
not be opportunities for local decision makers to consult with a
variety of stakeholders before taking actions. Therefore, this Guidance
incorporates the significant body of work done in the general context
of radiological emergency response planning from the development of the
1992 EPA PAGs, and represents the results of scientific analysis,
public comment, drills, exercises, and a consensus at the Federal level
for appropriate emergency action.
    In order to use the early and intermediate phase PAGs to make
decisions about appropriate protective actions, decision makers will
need information on suspected radionuclides; projected plume movement,
and radioactive 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) Early and Intermediate Phase Protective Action Guides for RDD and
IND Incidents
    The early and intermediate phase RDD/IND PAGs are generally based
on the following sources: The 1992 EPA PAGs developed by EPA in
coordination with other Federal agencies through the Federal
Radiological Preparedness Coordinating Committee; guidance developed by
the FDA for food and food products and the distribution of potassium
iodide. Table 1 provides a summary of the early and intermediate phase
PAGs for protection of the general public in an RDD or IND incident and
key protective actions.

                           Table 1--Protective Action Guides for RDD and IND Incidents
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                                          Protective action
               Phase                        recommendation                    Protective action guide
----------------------------------------------------------------------------------------------------------------
Early..............................  Sheltering-in-place or       1 to 5 rem (0.01-0.05 Sv) projected dose.\b\
                                      evacuation of the
                                      public\a\.
                                     Administration of            5 rem (0.05 Sv) projected dose to child
                                      prophylactic drugs--         thyroid.\c,e\
                                      potassium iodide\c,e\
                                      Administration of other
                                      prophylactic or
                                      decorporation agents\d\.
Intermediate.......................  Relocation of the public...  2 rem (0.02 Sv) projected dose first year.
                                                                   Subsequent years, 0.5 rem/y (0.005 Sv/y)
                                                                   projected dose.\b\
                                     Food interdiction..........  0.5 rem (0.005 Sv) projected dose, or 5 rem
                                                                   (0.05 Sv) to any individual organ or tissue
                                                                   in the first year, whichever is limiting.
                                     Drinking water interdiction  0.5 rem (0.005 Sv) projected dose in the first
                                                                   year.
----------------------------------------------------------------------------------------------------------------
\a\ Should normally begin at 1 rem (0.01 Sv); take whichever action (or combination of actions) that results in
  the lowest exposure for the majority of the population. Sheltering may begin at lower levels if advantageous.
\b\ Total Effective Dose Equivalent (TEDE)--the sum of the effective dose equivalent from external radiation
  exposure and the committed effective dose equivalent from inhaled radioactive material.
\c\ Provides thyroid protection from radioactive iodine only.
\d\ For other information on other radiological prophylactics and medical countermeasures, refer to http://
  www.fda.gov/cder/drugprepare/default.htm, http:/www.bt.cdc.gov/radiation, or http://www.orau.gov/reacts.
\e\ Committed Dose Equivalent (CDE). FDA understands that a KI administration program that sets different
  projected thyroid radioactive dose thresholds for treatment of different population groups may be logistically
  impractical to implement during a radiological emergency. If emergency planners reach this conclusion, FDA
  recommends that KI be administered to both children and adults at the lowest intervention threshold (i.e., >5
  rem (0.05 Sv) projected internal thyroid dose in children) (FDA 2001).

    In the early and intermediate phases of an RDD or IND incident
there may not be adequate information to determine radiation levels or
make dose projections because there may be little or no advance notice
of an attack, the characteristics of the RDD or IND may not be
immediately known, monitoring equipment may not be available to make
measurements, or there may not be time to do measurements or
projections before emergency response actions need to be initiated.
Therefore, to use this guide to determine whether protective action is
needed in a particular situation, it may be necessary to compare the
PAGs to results of a dose projection. In general, it should be
emphasized that realistic assumptions, based on incident-specific
information, should be used when making radiation dose projections so
that the final results are representative of actual conditions rather
than overly conservative exposures. It is very important that local
officials responsible for carrying out emergency response actions
conduct advance planning to ensure that they are adequately prepared if
such an incident were to occur.
(A) Early Phase PAGs
    For the early phase, the 1992 EPA PAGs for evacuation and
sheltering-in-place are appropriate for RDD and IND incidents (see
Table 1). Early phase protective action decisions in an RDD or IND must
be made quickly, and with very little confirmatory data. While
sheltering-in-place should be carried out at 1 rem (0.01 Sv)
sheltering-in-place can begin at any projected dose level.
    FDA guidance on the administration of stable iodine is also
considered appropriate (useful primarily for NPP incident involving
radioiodine release). The administration of other medical
countermeasures should be evaluated on a case-by-case basis and depend
on the nature of the event and radionuclides involved.
    The initial zone should be established and controlled around the
incident site, as is the case for other crime scenes and hazards. This
Guidance allows for the refinement of that area if the radiation
exposure levels warrant such action. Advance planning by local
officials for messaging, communications, and actions in the event of an
RDD or IND are strongly encouraged.
(B) Intermediate Phase PAGs
    The decisions in the intermediate phase will focus on the return of
key infrastructure and services, and the rapid return to 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 concern. Thus, the RDD/IND
Guidance serves to guide decisions on returning to impacted areas,
leaving impacted areas, and providing assurance that an area was not
impacted. The intermediate phase is also the period during which
planning for long-term site cleanup and remediation should be
initiated.
    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 rem (0.02 Sv) in the first year and 0.5 rem (0.005
Sv) in any subsequent year are considered appropriate for RDD and IND
incidents. However, for 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 relocation decisions, the availability of adequate
accommodations for relocated people should be considered. Decision
makers may need to consider limiting action to those areas most
severely affected, phasing relocation implementation based on the
resources available.
    The relocation PAGs apply principally to personal residences, but
may impact other locations as well. For example, these PAGs 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 individual occupancy time 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 by residents in a home.
    The intermediate phase PAG for the interdiction of food is set at
0.5 rem (0.005 Sv) projected dose in the first year, and the
intermediate phase PAG for the interdiction of drinking water is set at
0.5 rem (0.005 Sv) projected dose for the first year for RDD and IND
incidents. These values are consistent with those now used or being
considered as PAGs for other types of nuclear/radiological incidents.
    The use of simple dose reduction techniques is recommended for
personal property and all potentially contaminated areas that continue
to be occupied. This technique is also consistent with the 1992 EPA
PAGs developed for other types of nuclear/radiological incidents.
Examples of simple dose reduction techniques would be washing all
transportation vehicles (e.g., automobiles, trains, ships, and
aircraft), personal clothing, eating utensils, food preparation
surfaces, and other personal property before next use, as practicable
and appropriate.
(4) Late Phase Guidance
    The late phase involves the final cleanup of areas and property at
which radioactive material is 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 cleanup and site recovery.
    Because of the extremely broad range of potential impacts that may
occur from RDDs and INDs (e.g., light contamination of one building to
widespread destruction of a major metropolitan area), a pre-established
numeric cleanup 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 and the impacted area is small, 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, achieving
low cleanup levels for remediation of the entire area, and/or
maintaining existing land uses, may not be practicable.
    It should be noted that an intermediate phase PAG is not equivalent
to a starting point for development of the late phase cleanup process.
However, contamination and radiation levels existing after an incident
(e.g., concentrations, or dose rates), as well as actions already
taken, provide practical starting points for further action and
cleanup. The goal of cleanup is to reduce those levels as low as is
reasonable. It is possible that final criteria for reoccupation at a
given incident site may be either below or above the intermediate phase
PAG dose value, since no dose or risk cap for the late phase is
explicitly recommended under this Guidance.
    Late phase cleanup criteria should be derived through a site-
specific optimization process, which should include potential future
land uses, technical feasibility, costs, cost-effectiveness, and public
acceptability. 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. 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
as a basis for RDD and IND site cleanup planning.
    Broadly speaking, optimization is a flexible, multi-attribute
decision process that seeks to weigh many factors. Optimization
analyses are quantitative and qualitative assessments applied at each
stage of site recovery decision-making, from evaluation of remedial
options to implementation of the chosen alternative. The evaluation of
cleanup alternatives, for example, should factor in all relevant
variables, including areas impacted (e.g., size and location relative
to population), types of contamination (chemical, biological, and/or
radioactive), human health, public welfare, technical feasibility,
costs, and available resources to implement and maintain remedial
options, short-term effectiveness, long-term effectiveness, timeliness,
public acceptability, and economic effects (e.g., on residents,
tourism, and business, and industry).
    Various Federal, and State agencies, along with other organizations
(e.g., national and international advisory organizations), already have
guidance and tools that may be used to help establish cleanup levels.
The optimization process allows local decision makers to draw on the
thought processes used to develop the dose and/or risk benchmarks used
by these State, Federal, or other sources. These benchmarks, though
developed within different contexts, may be useful for analysis of
cleanup options. Decision makers might reasonably determine that it is
appropriate to move up or down from these benchmarks, depending on the
site-specific circumstances and balancing of other relevant factors.
    In developing this Guidance, the Federal Government recognized that
experience from existing programs, such as the EPA's Superfund program,
the NRC's standards for decommissioning and decontamination to
terminate a plant license, and other national and international
recommendations, may be useful in planning the cleanup and recovery
efforts following an RDD or IND incident. This Guidance allows the
consideration and incorporation, as appropriate, of any or all of the
existing environmental program elements.
    The site-specific optimization process includes quantitative and
qualitative assessments applied at each stage of site cleanup decision
making, from initial scoping and stakeholder outreach, to evaluation of
cleanup options, to implementation of the chosen alternative. The
evaluation of options for the late phase of recovery after an RDD or
IND incident should consider 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 risk.
     Public welfare.
     Ecological risks.
     Actions already taken during the early and intermediate
phases.
     Projected land uses.
     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.
     Short-term effectiveness.
     Long-term effectiveness.
     Timeliness.
     Public acceptability, including local cultural
sensitivities.

     Economic effects (e.g., on employment, tourism, and
business).
     Intergenerational equity.
    The site-specific optimization process provides the best
opportunity for decision makers to gain public confidence through the
involvement of stakeholders. This process should begin during, and
proceed independently of, intermediate phase protective action
activities.
    Appendix 3 provides additional details on a process that may be
used to implement this Guidance, describing the role of the Federal
Government and how it could integrate its activities with State and
local governments and the public. For some radiological terror
incidents, States may take the primary leadership role in cleanup and
contribute significant resources toward recovery of the site.
    As explained in Appendix 3, the Incident Command or Unified Command
should develop a schedule with milestones for conducting the
optimization process as soon as practicable following the incident.
While the goal should be to complete the initial optimization process
as soon as possible following an incident (depending on the size of the
incident), the schedule must take into consideration incident-specific
factors that would affect successful implementation. This schedule may
need to reflect a phased approach to cleanup and is subject to change
as the cleanup progresses.
(5) Emergency Worker Guidelines
    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.
Following an IND detonation in particular, the highest priority
missions should also include actions such as suppression of fires that
could result in further loss of life.
    For the purposes of this Guidance, ``emergency worker'' is defined
as any worker who performs an early or intermediate phase work action.
Table 2 shows the emergency worker guidelines for early phase emergency
response actions. In intermediate and late phase actions (i.e., cleanup
and recovery), standard worker protections, including the 5 rem (0.05
Sv) occupational dose limit, apply.

                           Table 2--Emergency Worker Guidelines in the Early Phase \2\
----------------------------------------------------------------------------------------------------------------
  Total effective dose equivalent
        (TEDE) \a\ guideline                   Activity                              Condition
----------------------------------------------------------------------------------------------------------------
5 rem (0.05 Sv)....................  All occupational exposures.  All reasonably achievable actions have been
                                                                   taken to minimize dose.
10 rem (0.1 Sv)....................  Protecting valuable           All appropriate actions and controls
                                      property necessary for       have been implemented; however, exceeding 5
                                      public welfare (e.g., a      rem (0.05 Sv) is unavoidable.
                                      power plant).
                                                                   Responders have been fully informed
                                                                   of the risks of exposures they may
                                                                   experience.
                                                                   Dose >5 rem (0.05 Sv) is on a
                                                                   voluntary basis.
                                                                   Appropriate respiratory protection
                                                                   and other personal protection is provided and
                                                                   used.
                                                                   Monitoring available to project or
                                                                   measure dose.
25 rem (0.25 Sv) \b\...............  Lifesaving or protection of   All appropriate actions and controls
                                      large populations. It is     have been implemented; however, exceeding 5
                                      highly unlikely that doses   rem (0.05 Sv) is unavoidable.
                                      would reach this level in    Responders have been fully informed
                                      an RDD incident; however,    of the risks of exposures they may
                                      worker doses higher than     experience.
                                      25 rem (0.25 Sv) are         Dose >5 rem (0.05 Sv) is on a
                                      conceivable in a             voluntarily basis.
                                      catastrophic incident such   Appropriate respiratory protection
                                      as an IND incident.          and other personal protection is provided and
                                                                   used.
                                                                   Monitoring available to project or
                                                                   measure dose.
----------------------------------------------------------------------------------------------------------------
a The projected sum of the effective dose equivalent from external radiation exposure and committed effective
  dose equivalent from internal radiation exposure.
b EPA's 1992 PAG Manual states that ``Situations may also rarely occur in which a dose in excess of 25 rem for
  emergency exposure would be unavoidable in order to carry out a lifesaving operation or avoid extensive
  exposure of large populations.'' Similarly, the NCRP and ICRP raise the possibility that emergency responders
  might receive an equivalent dose that approaches or exceeds 50 rem (0.5 Sv) to a large portion of the body in
  a short time (Limitation of Exposure to Ionizing Radiation, National Council on Radiation Protection and
  Measures, NCRP Report 116 (1993a). If lifesaving emergency responder doses approach or exceed 50 rem (0.5 Sv)
  emergency responders must be made fully aware of both the acute and the chronic (cancer) risks of such
  exposure.

    This Guidance document and the emergency worker guidelines were
developed for a wide range of possible radiological scenarios, from a
small RDD that may impact a single building to an IND that could
potentially impact a large geographic region. Therefore, the 5, 10 and
25 rem guidelines (Table 2) should not be viewed as inflexible limits
applicable to the range of early phase emergency actions covered by
this Guidance. Because of the range of impacts and case-specific
information needed, it is impossible to develop a single turn-back dose
level for all responders to use in all events, especially those that
involve lifesaving operations. Indeed, with proper preparedness
measures (training, personal protective equipment, etc.) many
radiological emergencies addressed by this document, even lifesaving
operations, may be manageable within the 5 rem (0.05 Sv) occupational
limit. Moreover, Incident Commanders should make every effort to employ
the ``as low as reasonably achievable'' (ALARA) principle after an
incident. Still, in some incidents medically significant doses above
the annual occupational 5 rem (0.05 Sv) dose limit may be unavoidable.
For instance, in the case of a catastrophic incident, such as an IND,
Incident Commanders may need to consider raising the lifesaving and
valuable property (i.e., necessary for public welfare) emergency worker
guidelines in order to prevent further loss of life and prevent the
spread of massive destruction. Ensuring that emergency workers have
full knowledge of the

associated risks prior to initiating emergency action and medical
evaluation of emergency workers after such exposure is essential. (See
Appendix 1 for additional discussion of ALARA.)
---------------------------------------------------------------------------

    \2\ In the intermediate and late phases, standard worker
protections, including the 5 rem occupational dose limit, would
normally apply.
---------------------------------------------------------------------------

    Ideally, the Incident Commanders should define and enforce the
emergency dose limits in accordance with the immediate risk situation
and the type of emergency action being performed (see Table 2).
However, in the case of an attack it may not be possible to conduct
dose measurements or projections before initiating emergency response
activities. Therefore, it is crucial that officials responsible for
carrying out emergency response actions in the early phase conduct
thorough advance planning to ensure that they are adequately prepared
if such an incident occurs. Planning should include evaluating data and
information on possible or anticipated radiation exposures in RDD or
IND incidents, developing procedures for reducing and controlling
emergency responder exposures to allowable dose limits (Table 2),
obtaining appropriate personal protective equipment (e.g., respirators,
clothing) for protecting emergency responders who enter contaminated
areas, and developing appropriate decision-making criteria for
responding to catastrophic incidents that may involve high radiation
exposure levels. Planning should also include informing and educating
emergency workers about emergency response procedures and controls as
well as the acute and chronic (cancer) risks of exposure, particularly
at higher dose levels. Effective advance planning will help to ensure
that the emergency worker guidelines are correctly applied and that
emergency workers are not exposed to radiation levels that are higher
than necessary in the specific emergency action.
    In addition, as part of advance planning, officials should develop
a process for assessing hazards and for determining appropriate actions
in incidents that may involve high radiation doses. Decisions regarding
emergency response actions in incidents involving high radiation
exposures require careful consideration of the benefits to be achieved
by the ``rescue'' or response action (e.g., the significance of the
outcome to individuals, large populations, general welfare, or valuable
property necessary for public welfare), and the potential health
impacts (i.e., acute and chronic) to emergency workers. The planning
for a potential high radiation exposure incident should consider how to
weigh the potential for and significance of the success of the
emergency response/rescue operation against the potential for and
significance of the health and safety risks to the emergency workers.
Federal, state and local emergency response officials should use these
guidelines to develop specific operational plans and response protocols
for protection of emergency response workers.

(e) Operational Guidelines for Early and Intermediate PAGs

    Implementation of the early and intermediate PAGs may be 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 whether actions
need to be implemented. Federal agencies are continuing development of
operational guidelines to support the application of this Guidance, and
other site-level decisions; therefore, they are provided here in
overview only.
    Some values already exist that could potentially serve as
operational guidelines for RDD and IND response and recovery
operations, and there are various tools available to help derive
operational guidelines for response planning. Appendix 4 presents a
summary of the types of operational guidelines for RDD and IND response
operations currently under development.
    Additional tools and assessment methodologies to aid in planning
and development of operational guidelines for use with PAGs for a wide
range of situations are available from the Federal Radiological
Monitoring and Assessment Center (FRMAC). These tools and methods are
written to support FRMAC operations during radiological and nuclear
emergency responses. The FRMAC manuals provide detailed methods for
computing Derived Response Levels (DRLs) and doses based on measurement
or modeling results and suggest input parameters for various
situations.\3\
---------------------------------------------------------------------------

    \3\ These materials and additional information on the FRMAC can
be obtained at http://www.nv.doe.gov/nationalsecurity/
homelandsecurity/frmac.
---------------------------------------------------------------------------

    Some examples of existing values that can be used as operational
guidelines for RDD and IND response operations and tools that could be
used to establish site-specific operational guidelines include, derived
response levels, derived intervention levels for food, and radiation
levels for control of access to radiation areas.
(1) Derived Response Levels (DRLs)
    The 1992 EPA PAG Manual contains guidance and Derived Response
Levels (DRLs) for various potential exposure pathways, including
external exposure, inhalation, submersion, ground shine, and drinking
water, for application in the early and intermediate phases. These
values serve as, or can be adapted to serve as, operational guidelines
to readily determine if protective actions need to be implemented. The
summed ratios of radionuclide concentrations obtained through field
measurements can be compared to the DRLs to determine whether the PAGs
are likely to be exceeded. If concentrations of radionuclides obtained
through field measurements are less than the DRLs, the PAGs are not
likely to be exceeded and, thus, a protective action may not need to be
taken.
(2) Derived Intervention Levels (DILs) for Food
    The FDA has developed Derived Intervention Levels (DILs) for
implementation of the early and intermediate PAGs for food. These DILs
establish levels of contamination that can exist on crops and in food
products and still maintain dose levels below the food PAGs, and could
therefore be used as operational guidelines for RDD and IND incidents.
More information on DILs can be found in ``Accidental Radioactive
Contamination of Human Food and Animal Feeds: Recommendations for State
and Local Agencies'' (U.S. Department of Health And Human Services,
Food and Drug Administration, August 13, 1998).
(3) Radiation Levels for Control of Access to Radiation Areas
    Additional operational guidelines for use in the early and
intermediate phases of response are being developed for issues such as
clearance of personal and real property, land and facility access, and
for response actions. A DOE project supported by an interagency effort
is developing needed tools and operational guidelines that address
continued use, or necessary control for personal property (e.g.,
vehicles, equipment, personal items, debris) and real property (e.g.,
buildings, roads, bridges, residential and commercial areas, national
monuments and icons) that may be impacted by an RDD or IND incident.
The effort includes consideration of short and long term use

or access to areas. A DOE report \4\ is available for review, and use
as appropriate. The report includes proposed operational guidelines and
their technical derivation, and provides tools such as the computer
model RESRAD-RDD \5\ for calculating incident-specific guidelines and
worker stay-time tables for access control, and dose-based soil and
building contamination levels to assist in the site-specific
optimization process. The goal of the DOE report is to provide
sufficient information to assist decision makers and responders in
executing their responsibilities in a safe way. Appendix 4 of this
Guidance provides a more detailed overview of the operational
guidelines contained in the DOE draft report and their intended
applications.
---------------------------------------------------------------------------

    \4\ Preliminary Report on Operational Guidelines Developed for
Use in Emergency Preparedness and Response to a Radiological
Dispersal Device Incident, DOE/HS-0001. The report and associated
material will be available at http://www.ogcms.energy.gov.
    \5\ RESRAD-RDD is derived from RESRAD, which is a computer model
designed to estimate radiation doses and risks from residual
radioactive materials. The RESRAD model has been applied to
determine the risk to human health posed at over 300 sites in the
United States and abroad that have been contaminated with radiation.
---------------------------------------------------------------------------

Appendix 1--Planning for Protection of Emergency Workers Responding to
RDD and IND Incidents

    The purpose of this appendix is to provide Federal, state, and
local decision makers with information on how to prepare for, and
implement emergency worker guidance in RDD and IND incidents.
Because there may not be adequate information or time for
determining radiation levels or making dose projections in the early
phase of an RDD or IND incident, it is very important that emergency
management officials conduct worker health and safety planning and
training in advance to ensure they are adequately prepared if such
an incident occurs.
    Planning should include evaluating data and information on
possible or anticipated radiation exposures in RDD and IND incidents
and on acute and chronic risks of radiation exposures, developing
procedures for reducing and controlling emergency worker exposures,
obtaining appropriate personal protective equipment (e.g.,
respirators, protective clothing) to help protect emergency workers
who enter exposure areas, and developing appropriate decisionmaking
criteria for responding in catastrophic incidents, such as an IND,
that may involve high exposure levels. Planning should also include
training and educating emergency workers about emergency response
procedures in radiological environments, radiation exposure controls
and the risks of exposure, particularly at higher levels. Effective
planning and training will help to ensure that exposures to
emergency workers are kept to the lowest radiation levels necessary
for the particular emergency response action.
    This appendix provides information to assist local, State, and
Federal authorities, and emergency workers in planning for
radiological emergencies, in particular those related to terrorist
attacks using RDDs and INDs. The appendix is not intended to provide
comprehensive training guidance. Other information useful in the
planning process may be available from the following organizations:
     The National Council on Radiation Protection and
Measurements,
     the International Commission on Radiological
Protection,
     the International Atomic Energy Agency,
     the American Nuclear Society,
     the Health Physics Society, and
     the Conference of Radiation Control Program Directors.

(a) Guidelines for Emergency Workers in Responding to RDD and IND
Incidents

    Table 2 in Section (d)(5) of the Guidance shows the emergency
worker guidelines for the early phase. In the intermediate and late
phases, standard OSHA and other worker health and safety standards
apply. The DOE and NRC also have standards that govern worker health
and safety for normal operations at their owned or licensed
facilities. OSHA's occupational radiation dose limit (1.25 rem
(0.0125 Sv) per annual quarter, or 5 rem (0.05 Sv) total in one
year) minimizes risk to workers consistent with the Occupational
Health and Safety Act (29 U.S.C. 651 et seq.).
    In many radiological incidents, particularly RDD situations, the
actual dose to emergency workers may be controlled to less than 5
rem (0.05 Sv). However, in other radiological incidents precautions
may not be sufficient or effective to keep emergency worker doses at
or below 5 rem (0.05 Sv), because of the magnitude of the incident
and because certain measures typically used to control exposures in
normal operations may not be applicable. For example, one of the
major radiation protection controls used in normal radiological
operations is containment of the radioactive material. Another is to
keep people away from the source material. During emergency response
to an RDD or IND incident use of these controls may not be possible
due to the nature of the incident and the urgency of response
actions. As a result, high radiation exposures for emergency
responders may be unavoidable and have the potential to exceed
regulatory limits used for normal operations. Therefore, the 5, 10
and 25 rem guidelines found in Table 2 should not be viewed as
absolute standards applicable to the full range of incidents covered
by this guidance, but rather serve as decision points for making
worker protection decisions during emergencies.
    Emergency response actions in catastrophic incidents that
involve high exposure levels require careful consideration of both
the benefits to be achieved by the ``rescue'' or response action
(e.g., the significance of the benefit to individuals, populations,
valuable property necessary for general welfare), and the potential
for acute and chronic health impacts to individuals 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 weighed against the potential for, and
significance of, the health and safety risks to workers.

(b) Controlling Occupational Exposures and Doses to Emergency
Workers

    Appropriate measures should be taken to minimize radiation dose
to emergency workers responding to an RDD or IND incident. With
proper preparedness measures (e.g., training, personal protective
equipment), many emergencies that this document addresses, including
lifesaving actions, may be possible to manage within the 5 rem (0.05
Sv) occupational limit. Emergency management officials responsible
for an incident should take steps to keep all doses to emergency
workers ``as low as reasonable achievable'' (ALARA). Protocols for
maintaining ALARA should include the following health physics and
industrial hygiene practices:
     Minimizing the time spent in the contaminated area
(e.g., rotation of emergency responders);
     Maintaining distance from sources of radiation;
     Shielding of the radiation source;
     Using hazard controls that are applicable to the work
performed;
     Properly selecting and using respirators and other
personal protective equipment (PPE), to minimize exposure to
internally deposited radioactive materials (e.g., alpha and beta
emitters); and
     Using prophylactic medications, when appropriate, that
either block the uptake or reduce the retention time of radioactive
material in the body.
    To minimize the risks from exposure to ionizing radiation, all
emergency responders should be trained and instructed to follow
emergency response plans and protocols and be advised on how to keep
exposures as low as reasonably achievable. Health physics and
industrial hygiene practices should include the use of dosimetry for
monitoring of individual exposure with real-time readings (i.e.,
real-time electronic dosimeters) and permanent records (e.g., film
badges, optically stimulated luminescent [OSL], or thermoluminescent
dosimeters [TLDs]). Also, employers should (1) develop procedures
and training that relate measurements to dose and risk, (2)
understand and practice ALARA procedures with workers, and (3)
address other issues related to performing response in a
radiological environment.

(c) Understanding Radiation Risks

    If there is the possibility that emergency workers would receive
a radiation dose higher than the 5 rem (0.05 Sv) guideline,
emergency workers should be trained to understand the risk
associated with such doses, including a thorough explanation of the
latent risks associated with receiving doses greater than 5 rem
(0.05 Sv), and acute risks at higher doses. Emergency workers should
be fully aware of both the projected acute and chronic risks
(cancer) they may

incur in an emergency response action. Furthermore, emergency
workers cannot be forced to perform a rescue action involving
radiation doses above regulatory limits, and they should be given
reasonable assurance that normal controls cannot be utilized to
reduce doses to less than 5 rem (0.05 Sv). After the event, it is
essential that emergency workers be provided with medical follow up.
    The estimated risk of fatal cancer \6\ for healthy workers who
receive a dose of 10 rem (0.10 Sv) is about 0.46 percent over the
worker's lifetime (i.e., 4-5 fatal cancers per 1000 people, or 0.4-
0.5 percent). The risk scales linearly. For workers who receive a
dose of 25 rem (0.25 Sv), the risk is about 1.1 percent. The risk is
believed to be greater for those who are younger at the time of
exposure. For example, for 20-30 year olds the estimated risk of
fatal cancer at 25 rem (1.75 percent) is about twice as large as the
risk for 40-50 year olds (0.8 percent).
---------------------------------------------------------------------------

    \6\ Risk per dose of a fatal cancer for members of the general
public is assumed to be about 6 x 10-\4\ per rem. Cancer
incidence is assumed to be about 8 x 10-\4\ per rem (see
Federal Guidance Report No. 13). Occupational risk coefficients are
slightly higher.
---------------------------------------------------------------------------

    Above 50 rem (0.5 Sv) acute effects are possible. Where
lifesaving actions may result in doses that approach or exceed 50
rem (0.50 Sv), such as in an IND incident, emergency workers need to
have a full understanding of the potential acute effects of the
expected radiation exposure, in addition to the risk of chronic
effects. The decision to take these lifesaving actions must be based
on the estimation that the human health benefits of the action
exceed the safety and health risks to the emergency workers.
    It is important to note that the approach used to translate dose
to risk in this discussion is a simplistic approach for developing
rough estimates of risks for comparative purposes. Other more
realistic and accurate 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 approaches rely on radionuclide-
specific risk factors (e.g., found in Federal Guidance Report No. 13
and EPA Health Effects Assessment Summary Tables), and are typically
used in long-term assessments, such as environmental cleanup.

(d) Preparedness

    To prepare for large radiological disasters, local officials and
Incident Commanders will need to have a decision-making process
already developed and ready to implement when they can no longer use
standard occupational dose limits or when there is the possibility
that they may face decisions involving exposures approaching or
exceeding 25 rem (0.25 Sv) for lifesaving operations. Preparedness
entails investigating the nature of the RDD and IND incident for
which local officials must be prepared, having appropriate worker
health and safety plans and protocols for such incidents, and
training and exercises to assure a level of readiness among
officials and responders.
    Incident Commanders and emergency responders should thoroughly
understand the emergency worker guidelines for radiological
emergency response, including specific emergency responder health
and safety procedures and ALARA principles. The reader is referred
to the EPA PAG Manual (May 1992), the FRMAC Radiological Emergency
Response Health and Safety Manual (May 2001), and the Hazardous
Waste Operations and Emergency Response (HAZWOPER) regulations. The
EPA has a Worker Protection (40 CFR part 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.
    The HAZWOPER regulations, found in 29 CFR 1910.120 and 1926.65,
were promulgated to protect personnel working at a hazardous waste
site, or a treatment, storage, or disposal facility, or performing
emergency response. This standard also covers employers whose
employees are engaged in emergency response without regard to the
location of the hazard (unless specifically exempted or where a more
protective safety and health standard applies). If an employer
anticipates that their employees will respond to a potential hazard,
HAZWOPER requires such actions as (1) the development of an
emergency response plan (including personnel roles, lines of
authority, training, communication, personal protective equipment,
and emergency equipment), (2) procedures for handling a response,
(3) specific training requirements based on the anticipated roles of
the responder, and (4) medical surveillance. For specific
interpretations regarding HAZWOPER and/or other occupational safety
and health standards, employers should consult the appropriate
implementing agency (e.g., appropriate Federal agencies, State
Occupational Safety and Health Programs, or State Radiation Control
Programs).

Appendix 2--Risk Management Framework for RDD and 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 recovery 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. A plan for
implementing this framework for RDD and IND incidents is provided in
Appendix 4.
    The ``Framework for Environmental Health Risk Management'' is
considered generally suitable for addressing the long-term cleanup
issues for RDDs and INDs. Given the time frames following an RDD or
IND incident there is generally not sufficient time in the early
phase to conduct a full risk assessment and get stakeholder
involvement. In order for the framework to be most useful it must be
used in planning and preparing for a radiological or nuclear
incident. Many of the basic risk management principles were also
used in development of the 1992 EPA PAGs.
    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 commensurate with the significance of
the problem, the potential severity and economic impact, the level
of controversy surrounding the problem, and resource constraints.
The health and environmental hazards that must be considered are
radiation hazards, and potentially chemical or biological hazards.
Other factors to be considered include the continued disruption in
normal activities, loss of, or limited access to critical
infrastructure and health care and general economic damage.
    The framework relies on the three key principles of (1) broad
context, (2) stakeholder participation, and (3) iteration. Broad
context refers to placing all of the health and environmental issues
in the full range of impacts and recovery factors following an RDD
or IND incident, and is intended to assure that all aspects of
public welfare 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 analysis base on information available, and
improve 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
public health impacts 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 hazard present as a result of the incident, the
options for reducing risks, and the effectiveness and costs of those
options. Decision makers also compare the economic, social,
cultural, ethical, legal, and public policy implications associated
with each option, as well as the unique safety and health hazards
facing emergency responders and ecological hazards the cleanup
actions themselves may cause. Often a stakeholder working group can
provide input needed to consider all of the relevant information.
    Stakeholders can provide valuable input to decision makers
during the long-term cleanup 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
individuals 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, or nonprofit organizations representing such
individuals. They may also include those who have

regulatory responsibility, and those who may speak on behalf the
environment generally, business and economics, or future
generations.
    Stakeholder input should be considered throughout all stages of
the framework as appropriate, including analyzing the risks,
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
reasoned 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 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 decision-making 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. The incident 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 emergency 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 of the public from
the site must be considered within the context of the societal
objectives to be achieved, and must examine cleanup options in the
context of other risks members of the community face. There may also
be broader public health or environmental issues that local
governments and public health agencies have to confront and
consider.
    The goals of the cleanup effort will extend well beyond the
reduction of potential delayed radiation health effects, and may
include:
     Public health protection goals, including mitigating
acute hazards and long-term chronic issues, and protecting 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 highways, 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 sewage 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 the likelihood is that people or the environment
will be harmed. The nature, extent, and focus of a risk analysis
should be guided by the risk management goals. The results of a risk
analysis--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 analyses 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 both the
scientific foundation of risks and the procedures for making
inferences about risks 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. They should also provide decision makers
with evaluations of the scientific support for their 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 the nature of their
connection with the cause of the risk. For this reason, risk
analyses 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 analyses and in identifying specific health
and ecological concerns.

(3) Examine the Options

    This stage of the risk management process involves identifying
potential cleanup 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 how the process of reducing
exposures and risks can improve 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 the best option. Key
questions include determining (1) the expected benefits and costs,
(2) distribution of benefits and costs across the impacted
community, (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. Adverse economic consequences may
include impacts on a community, such as 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 an
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 necessary. For example, removing all
the soil from an entire valley that is 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 to daily activities and
a sense of normalcy. Of course, the feasibility and cost-
effectiveness of an option may change in the future.

(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
intentions are met. In some cases, win-win solutions that allow
stakeholders with divergent views to achieve their primary goals are
possible. Decision makers should allow the opportunity for public
comment on proposed decisions.
    Decision makers must weigh the value of obtaining additional
information against the need for a decision, however uncertain the

decision may be. Sometimes a decision must be made primarily on a
precautionary basis. 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.

(5) Take Action To Implement the Decision

    When options have been evaluated and decisions made, a plan for
action should be developed and implemented. The issuance of
protective action recommendations is the responsibility of local
officials to protect the public and the environment during
emergencies: Long-term cleanup decisions have the same basic risk
management framework, but entail substantially more analysis and
stakeholder involvement. When government officials and stakeholders
have agreed on a strategy, cleanup activities should commence. It
may take considerable time for these actions to be completed, 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 decision-making stage. The
effectiveness of the process leading to implementation should also
be evaluated at this stage. Evaluation provides important
information about the following: 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 which indicates that a
decision or stage of the framework should be revisited; whether
unintended consequences have emerged; how stakeholder involvement
contributed to the outcome; and what lessons can be learned to guide
future risk management decisions, or to improve the decision-making
process.
    Evaluation is critical to accountability and to ensure efficient
use of valuable but limited resources. Tools for evaluation include
environmental and health monitoring, research, analyses of costs and
benefits, and discussions with stakeholders.

(b) Technical Advisory Committee

    Making decisions on the appropriate cleanup approaches and
levels following an RDD or IND incident 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 decision makers should expect
public anxiety in the face of a terrorist act involving radioactive
materials. Different regulatory authorities and organizations
historically have taken different cleanup approaches for
radioactively contaminated industrial 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 to approach this situation, and
decision makers will need to tailor the process to particular site
circumstances. This section describes one approach 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 in Washington, DC. 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 Federal agencies,
State and tribal public health and environmental agencies,
universities and private industries, the local health department,
and possibly representatives of local workers and the community. To
maximize objectivity, the committee should be an independent group
that will provide input to the decision makers, not be a part of the
decision-making team.
    The scientific expertise in the committee should reflect the
needs of the decision makers in all aspects of the decontamination
process (e.g., environmental sampling, epidemiology, risk
assessment, industrial hygiene, statistics, health physics, 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 decision-making group at
the site.
    The decision makers should develop a charter for the committee
that specifies 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.
    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 Cleanup Implementation

    This appendix provides a federally-recommended approach for
environmental cleanup after an RDD or IND incident to accompany the
risk management principles outlined in Appendix 2. This approach
describes how State and local governments may coordinate with
Federal agencies, and the public, consistent with the National
Response Framework (NRF). The approach does not attempt to provide
detailed descriptions of State and local roles and expertise. It is
assumed those details will be provided in State and local level
planning documents that address radiological/nuclear terrorism
incidents.
    This site cleanup approach is intended to function under the NRF
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 NRF. This plan is also 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 approach are
provided to address the specific needs and wide range of potential
impacts of an RDD or IND incident. During the intermediate phase,
site cleanup planners should begin the process described below,
under the direction of the on-site IC/UC, and in close coordination
with Federal, State and local officials. After early and
intermediate phase activities have come to conclusion and only long-
term cleanup activities are ongoing, the IC/UC structure may
continue to support planning and decision-making 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 extended site cleanup
than what is required under emergency circumstances.
    Radiological and nuclear terrorism incidents cover a broad range
of potential scenarios and impacts. This appendix assumes that the
Federal Government is a primary funding agent for site cleanup. In
particular, the process described for the late phase in section
(d)(4) of this document assumes an incident of relatively large
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. Decision makers should
recognize that for some radiological/nuclear terrorist incidents,
states will take the primary leadership role and contribute
significant resources toward cleanup of the site. This section does
not

address such a scenario, but states may choose to use the process
described here.
    This implementation plan does not address law enforcement
coordination during terrorism incident responses, including how the
FBI will manage on-scene activities immediately following an act of
terror. Agencies' roles and responsibilities will be implemented
according to the NRF and supporting documents. Also, victim triage
and other medical response procedures are beyond the scope of this
Guidance. The plan presented in this appendix is not intended to
impact site cleanups occurring under other statutory authorities
such as EPA's Superfund program, the NRC's decommissioning program,
or State-administered cleanup programs.

Cleanup Activities Overview

    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
cleanup 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
consists of the immediate and near-term on-scene actions of State,
local, and Federal emergency responders under the IC/UC. On-scene
actions include incident stabilization, lifesaving activities, dose
reduction actions for members of the public and emergency
responders, access control and security, emergency decontamination
of persons and property, ``hot spot'' removal actions, and
resumption of basic infrastructure functions.
    The second process pertains to environmental cleanup, which is
initiated soon after the incident (during the intermediate phase)
and continues into the late phase. The process starts with convening
stakeholders and technical subject matter experts to begin
identifying and evaluating options for the cleanup of the site. The
environmental cleanup process overlaps the intermediate phase
activities described above and should be coordinated with those
activities. This process is interrelated with the ongoing
intermediate phase activities, and the intermediate phase protective
actions continue to apply through the late phase until cleanup is
complete.
    Cleanup planning and discussions should begin as soon as
practicable after an incident to allow for selection of key
stakeholders and subject matter experts, planning, analyses,
contractual processes, and cleanup activities. States may choose to
pre-select stakeholders for major incident recovery coordination.
These activities should proceed in parallel with ongoing
intermediate phase activities, and coordination between these
activities should be maintained. Preliminary remediation activities
during the intermediate phase--such as emergency removals,
decontamination, resumption of basic infrastructure function, and
some return to normalcy in accordance with intermediate phase PAGs--
should not be delayed for the final site remediation decision.
    A process for addressing environmental contamination that
applies an optimization process for site cleanup is presented below.
As described in this document, optimization is a flexible process in
which numerous factors are considered to achieve an end result that
considers local needs and desires, health risks, costs, technical
feasibility, and other factors. The general process outlined below
provides decision makers with input from both technical experts and
stakeholder representatives, and also provides an opportunity for
public comment. The extent and complexity of the process for an
actual incident should be tailored to the needs of the specific
incident; for smaller incidents, the workgroups discussed below may
not be necessary.
    The goals of the process described below are: (1) Transparency--
the basis for cleanup decisions should be available to stakeholder
representatives, and to the public at large; (2) inclusiveness--
representative stakeholders should be involved in decision-making
activities; (3) effectiveness--technical subject matter experts
should analyze remediation options, consider established dose and
risk benchmarks, and assess various technologies in order to assist
in identifying a final solution that is optimal for the incident;
and (4) shared accountability--the final decision to proceed will be
made jointly by Federal, State, and local officials.
    Under the NRF, FEMA may issue mission assignments to the
involved Federal agencies, as appropriate, to assist in response and
recovery. Additional funding may be provided to State/local
governments to perform response/recovery activities through other
mechanisms. The components of the process are as follows:

(a) General Management Structure

    Planning for the long-term cleanup should begin during the
intermediate phase, and at that time, a traditional NIMS response
structure should still be in place. However, NIMS was developed
specifically for emergency management and may not be the most
efficient response structure for long-term cleanup. If the cleanup
will extend for years, the IC/UC may decide to transition at some
point to a different long-term project management structure.
    Under the NRF and NIMS, incidents are managed at the lowest
possible jurisdictional level. In most cases, this will be at the
level of the Incident Command or Unified Command (IC/UC). The IC/UC
directs on-scene tactical operations. Responding local, State, and
Federal agencies are represented in the IC/UC and Incident Command
Post in accordance with NIMS principles regarding jurisdictional
authorities, functional responsibilities, and resources provided.
For INDs, and large RDDs, multiple Incident Command Posts (ICPs) may
be established to manage the incident with an Area Command or
Unified Area Command supporting the ICPs and prioritizing resources
and activities among them. If the RDD/IND incident happens on a
Federal facility or involves Federal materials, the representatives
in the UC may change appropriately and the response will be
conducted according to the applicable Federal procedures.
    Issues that cannot be resolved at the IC/UC or Unified Area
Command level may be raised with the JFO and JFO Unified
Coordination Group for resolution. The JFO coordinates and
prioritizes Federal resources, and when applicable, issues mission
assignments to Federal agencies under the Stafford Act. Issues that
cannot be resolved at the JFO level may be raised to the DHS NOC,
senior-level interagency management groups, and the White House
Homeland Security Council.
    Day-to-day tactical management, planning, and operations for the
RDD/IND cleanup process will be managed at the IC/UC level, but for
large-scale cleanups, it is expected that the JFO Unified
Coordination Group will review proposed cleanup plans and provide
strategic and policy direction. The agency(s) with primary
responsibility for site cleanup should be represented in the JFO
Unified Coordination Group. The IC/UC will need to establish
appropriate briefing venues as the cleanup process proceeds,
including the affected mayor(s) and Governor(s).
    The discussion below assumes a traditional NIMS IC/UC structure;
if the IC/UC transitions later to a different management structure
for a longer-term cleanup, the IC/UC would need to determine the
appropriate way to incorporate the workgroups described below into
that structure.
    Appendix 2 presented the general steps in the cleanup process:
Analyze the risks, examine the options, make and implement a
decision, evaluate the results. This process will be managed by the
IC/UC, who ultimately determines the structure and organization of
the Incident Command Post, but the discussion below provides one
recommended approach for managing the cleanup process within a NIMS
ICS response structure. The Incident Command Post Planning Section
has the lead for response planning activities, working in
conjunction with other sections, and would have the lead for
development of the optimization analysis, working closely with the
Operations Section. The NIMS describes the units that make up the
Planning Section, and allows for additional units to be added
depending on site-specific needs. NIMS states that for incidents
involving the need to coordinate and manage large amounts of
environmental sampling and analytical data from multiple sources, an
Environmental Unit may be established within the Planning Section to
facilitate interagency environmental data management, monitoring,
sampling, analysis, assessment, and site cleanup and waste disposal
planning. RDD/IND incidents would involve the collection of not only
large amounts of radiological data, but also data related to other
environmental and health and safety hazards, and would therefore
likely warrant the establishment of an Environmental Unit in the
Planning Section. Planning for FRMAC radiological sampling and
monitoring activities will be integrated into the Planning Section,
and coordinated with other Situation and Environmental Unit data
management activities.

    The IC/UC would assign the responsibility for coordinating and
development of the optimization analysis to a specific unit. For
incidents in which the contaminated area is small and the analysis
is straightforward, the IC/UC may choose to assign such
responsibilities to the Environmental Unit. On the other hand, for
large incidents requiring more complicated tradeoffs or the
evaluation of cleanup goals with broad implications, the IC/UC may
choose to establish a separate unit in the Planning Section (for
example, a Cleanup Planning Unit) to coordinate the development of
the optimization analysis. The IC/UC may then convene a technical
working group and a stakeholder working group, managed by the
Environmental or Cleanup Planning Unit, to analyze cleanup options
and develop recommendations. The Environmental or Cleanup Planning
Unit would coordinate working group processes and interactions and
report the results of the optimization analysis and workgroup
efforts to the IC/UC through the Planning Section Chief.
    The development and completion of the optimization analysis is
expected to be an iterative process, and for large incidents, the
cleanup will likely proceed in phases, most likely from the
``outside in'' toward the most contaminated areas. The extent of the
analysis and process used to develop it would be tailored to the
needs of the specific incident, but the following working groups may
be convened by the IC/UC to assist decision makers in the
optimization process, particularly for large or complex cleanups.

(1) Technical Working Group

    A technical working group should be convened as soon as
practicable, normally within days or weeks of the incident. The
technical working group would be managed by the Planning Section
Unit that is assigned responsibility for the optimization analysis.
The technical working group may or may not be physically located at
the ICP. The group may review data and documents, provide input
electronically, and meet with incident management officials. The
group may also be asked to participate in meetings with the JFO
Unified Coordination Group if needed.
    Function: The technical working group provides multi-agency,
multi-disciplinary expert input on the optimization analysis,
including advice on technical issues, analysis of relevant
regulatory requirements and guidelines, risk analyses, and
development of cleanup options. The technical working group would
provide expert technical input to the IC/UC; it would not be a
decision-making body.
    Makeup: The technical working group should include selected
Federal, State, local, and private sector subject matter experts in
such fields as environmental fate and transport modeling, risk
analysis, technical remediation options analysis, cost, risk and
benefit analysis, health physics/radiation protection, construction
remediation practices, and relevant regulatory requirements. The
exact selection and balance of subject matter experts is incident-
specific. The Advisory Team for the Environment, Food, and Health is
comprised of Federal radiological experts in various fields who may
warrant representation on the technical working group.

(2) Stakeholder Working Group

    The stakeholder working group should be convened as soon as
practicable, normally within days or weeks of the incident. The
stakeholder working group would be managed by the Planning Section
Unit that is assigned responsibility for the optimization analysis.
The IC/UC may direct the Public Information Officer (who would
coordinate with the JIC) to work with the group, including
establishing a process for the group to report out its
recommendations. How and where the stakeholder working group would
meet to review information and provide its input would need to be
determined in conjunction with the group members. The stakeholder
working group may also be asked to participate in meetings with the
JFO Unified Coordination Group if needed.
    Makeup: The stakeholder working group should include selected
Federal, State, and local representatives; local non-governmental
representatives; and local/regional business stakeholders. The exact
selection and balance of stakeholders is incident specific.
    Function: The function of the stakeholder working group is to
provide input to the IC/UC concerning local needs and desires for
site recovery, proposed cleanup options, and other recommendations.
The group should present local goals for the use of the site,
prioritizing current and future potential land uses and functions,
such as utilities and infrastructure, light industrial, downtown
business, and residential land uses. The stakeholder working group
would not be a decision-making body.

(b) Activities

(1) Optimization and Recommendations

    The IC/UC directs the management of the optimization analysis
through the Planning Section. Technical and stakeholder working
groups assist in performing analyses and developing cleanup options
and provide input to the IC/UC, and may be asked to participate in
meetings with the JFO Unified Coordination Group if needed. The IC/
UC reviews the options described in the optimization analysis and
selects a proposed approach for site cleanup, in close coordination
with Federal, State and local officials. Again, depending on the
incident size, it may be necessary to conduct the cleanup in phases.
Thus, decisions on cleanup approaches may also be made in phases. As
appropriate for the magnitude of the cleanup task, the IC/UC would
brief relevant Federal, State, and local government officials on
proposed cleanup plans for approval. This may involve the office of
the affected mayor and Governor. At the Federal level, it may
involve the JFO Unified Coordination Group and higher-level
officials.

(2) Public Review of Decision

    The IC/UC should work with the POI and JIC to publish a summary
of the process, the options analyzed, and the recommendations for
public comments. Public meetings should also be convened at
appropriate times. Public comments should be considered and
incorporated as appropriate. A reconvening of the stakeholder and/or
technical working groups may be useful for resolving some issues.

(3) Execute Cleanup

    Cleanup activities should commence as quickly as practicable,
and allow for incremental reoccupation of areas as cleanup proceeds.
For significant decontamination efforts, the IC/UC may choose to
employ a technical peer review advisory committee to conduct a
review of the effectiveness of the cleanup. The technical peer
review advisory committee is discussed in more detail in Appendix 2.

Appendix 4--Operational Guidelines for Implementation of Protective
Action Guides and Other Activities in RDD or IND Incidents

    During all phases of an incident, many decisions will need to be
made at the field-level, such as making protective action decisions,
opening critical infrastructure, limited re-entry of citizens to
homes or businesses, release of personal property, and others. This
appendix presents operational guidelines being developed to assist
decision makers and emergency responders in implementing protective
actions and making other on-site decisions.\7\ Operational
guidelines are levels of radiation or concentrations of
radionuclides that can be accurately measured by radiation detection
and monitoring equipment that can then be compared to PAGs, or
field-level radiation dose decision points (such as for the release
of personal property) to quickly determine what action should be
taken. In most situations, the operational guidelines will be given
in terms of external gamma rates or media-specific (e.g., surfaces,
soil, or water) radionuclide concentration units. Both external and
internal exposure potential were considered in the development of
the operational guidelines.
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    \7\ For purposes of this appendix, ``relocation area'' refers to
an area that local officials have determined is not safe for
prolonged occupation by the public, based on the intermediate phase
PAGs, and have recommended that the public be relocated.
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    This appendix discusses the operational guidelines qualitatively
and does not provide actual numeric values. The operational
guidelines are being developed to provide reasonable assurance that
field-level radiation dose decision points and the PAGs recommended
in this document can be met under different circumstances. The
operational guidelines also address, to some extent, the impact of
protective actions, such as controlling wash water after rinsing
vehicles to remove contamination. Actual conditions may warrant
development of incident-specific guidelines. To support this need,
the RESRAD-RDD \8\ software tool was developed to allow for easy and
timely calculation of site-specific operational

guidelines that can be tailored to the specific emergency and the
required response.
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    \8\ RESRAD-RDD is a computer modeling tool developed by the U.S.
Department of Energy for calculating radiation concentrations on
different media, and doses and dose rates following an RDD incident.
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    The operational guidelines are organized into seven groups that
are generally categorized by the phase of emergency response in
which they would be implemented or used for planning purposes.
Individual groups are further categorized into subgroups as
appropriate. Table 3 summarizes operational guideline groups and
subgroups. A summary description of these groups and subgroups is
provided below. Detailed descriptions of the operational guidelines,
to include their technical derivation, intended application, and
tools to assist in their application, are provided in the
Preliminary Report on Operational Guidelines Developed for Use in
Emergency Preparedness and Response to a Radiological Dispersal
Device Incidents (DOE/HS-0001, available at http://
www.ogcms.energy.gov).

                              Table 3--Operational Guidelines: Groups and Subgroups
----------------------------------------------------------------------------------------------------------------
                  Groups                                                  Subgroups
----------------------------------------------------------------------------------------------------------------
A. Access control during emergency          1. Life and property-saving measures.
 response operations.
                                            2. Emergency worker demarcation.
B. Early-phase protective action..........  1. Evacuation.
                                            2. Sheltering.
C. Relocation from different areas and      1. Residential areas.
 critical infrastructure utilization in
 relocation areas.
                                            2. Commercial and industrial areas.
                                            3. Other areas, such as parks and monuments.
                                            4. Hospitals and other health care facilities.
                                            5. Critical transport facilities.
                                            6. Water and sewer facilities.
                                            7. Power and fuel facilities.
D. Temporary access to relocation areas     1. Worker access to businesses for essential actions.
 for essential activities.
                                            2. Public access to residences for retrieval of property, pets,
                                             records.
E. Transportation and access routes.......  1. Bridges.
                                            2. Streets and thoroughfares.
                                            3. Sidewalks and walkways.
F. Release of property from radiologically  1. Personal property, except wastes.
 controlled areas.
                                            2. Waste.
                                            3. Hazardous waste.
                                            4. Real property, such as lands and buildings.
G. Food consumption.......................  1. Early-phase food guidelines.
                                            2. Early-phase soil guidelines.
                                            3. Intermediate-phase soil guidelines.
                                            4. Intermediate- to late-phase soil guidelines.
----------------------------------------------------------------------------------------------------------------

(a) Group A: Access Control During Emergency Response Operations

    These operational guidelines are designed to assist responders
in decision making for worker health and safety in the early to
intermediate phases of response when the situation has not been
fully stabilized or characterized. They are designed to guide
responders in establishing radiological control zones or boundaries
for the areas directly impacted by the RDD or IND incident where
first responders and emergency response personnel are working. They
are not intended to restrict emergency worker access, but rather to
inform workers of potential radiological hazards that exist in the
area and to provide tools to those responsible for radiation
protection during response activities. These operational guidelines
may be used to restrict the access of nonessential personnel and
members of the public to specific areas. Examples of operational
guidelines developed in this group include life- and property-saving
measures and emergency worker zone demarcation.
    Group A operational guidelines are expressed as a series of
reference ``stay time'' tables for responders who may have only
limited health physics information and personal protective equipment
at the time of the response. For example, the health physics
information available to them could include or be limited to
measurements of the external exposure rate, gross alpha surface
contamination, beta/gamma surface contamination, and/or air
concentration. Radionuclide-specific correction factors as well as
radionuclide-specific and respiratory protection-specific tables are
also provided. Stay times are provided for a range of doses (i.e.,
0.1 rem (.001 Sv), 0.5 rem (.005 Sv), 1 rem (.01 Sv), 2 rem (.02
Sv), 5 rem (.05 Sv), 10 rem (.10 Sv), 25 rem (.25 Sv), 100 rem (1
Sv), many of which correspond to guidelines used for workers and the
public).

(b) Group B: Early-Phase Protective Action (Evacuation or
Sheltering)

    Group B operational guidelines are designed to help decision
makers make timely protective action decisions, such as whether to
evacuate or shelter the general public in the early phase. These
operational guidelines are similar to values presented in the FRMAC
Assessment Manual for evacuation and sheltering. Group B operational
guidelines are typically expressed as limiting concentrations of
radioactivity in surface soil.

(c) Group C: Relocation and Critical Infrastructure Utilization in
Affected Areas

    These operational guidelines are intended for early-to
intermediate-phase protective actions. They are designed for use in
deciding whether to relocate the public from affected areas for a
protracted period of time. Screening values are provided to
delineate areas that exceed the relocation PAGs. These areas include
residential areas, commercial/industrial areas, and other areas such
as parks, cemeteries, and monuments. Group C operational guidelines
also assist in efforts to ensure that facilities critical to the
public welfare can continue to operate, if needed. These facilities
include hospitals, airports, railroads and ports, water and sewer
facilities, and power and fuel facilities. These operational
guidelines are typically expressed as soil, building, or street-
surface contamination concentrations (e.g., pCi/m2).

(d) Group D: Temporary Access to Relocation Areas for Essential
Activities

    Group D operational guidelines pertain to intermediate phase
protective actions. They are designed to assist in determining
constraints necessary to allow for temporary access to restricted
(relocation) areas. For example, the public, or owners/employees of
businesses, may need temporary access to residences, or commercial,
agricultural, or industrial facilities in order to retrieve
essential records, conduct maintenance to protect facilities,
prevent environmental damage, attend to animals, or retrieve pets.
These operational guidelines describe the level and timeframes at
which these actions can be taken without supervision or radiological
protections. The public or employees may occasionally (e.g., a few
days per month) access areas that do not exceed these guidelines.
Temporary access to

relocation areas that exceed these levels should be permitted only
under the supervision, or with the permission of, radiation
protection personnel. The guidelines are typically expressed in
terms of stay-times during which the public or employees may access
the areas without receiving a predetermined dose.

(e) Group E: Transportation and Access Routes

    These operational guidelines apply to intermediate phase
actions. They are designed to assist in determining whether
transportation routes (e.g., bridges, highways, streets) or access
ways (e.g., sidewalks and walkways) may be accessed by the public
for general, limited, or restricted use. The relocation PAGs serve
as the basis for these operational guidelines. For example,
operational guidelines may be defined for industrial or commercial
use of various roads, bridges, or access ways. These may be
necessary to allow for access between non-relocation areas via a
highway that passes through a relocation area or for access to
recovery areas in the immediate area of an incident. These
operational guidelines assume regular or periodic use and are not
appropriate for one-time events, such as evacuation or relocation
actions. They are typically expressed as surface contamination
concentrations (e.g., pCi/m2).

(f) Group F: Release of Property From Radiologically Controlled
Areas

    Group F operational guidelines are intended for intermediate to
long-term recovery-phase protective actions. During response and
recovery operations, property and wastes must be cleared from
radiologically controlled areas (relocation areas). Property
includes personal property, debris and non-radiological wastes,
hazardous waste, and real property (e.g., buildings and lands).
These operational guidelines support such actions. Because
subsequent retrieval of cleared, or released, properties will be
difficult, these levels should be consistent with late-phase cleanup
goals wherever practicable. For this reason, they should not be
applied to property that will continue to be used within controlled
areas. These operational guidelines should also be used for
screening property that was located outside the controlled area for
possible contamination. In general, the operational guidelines in
this group provide reasonable assurance that the cleared property is
acceptable for long-term, unrestricted use (or appropriate
disposition, in the case of wastes) without further radiological
reassessment or control.
    For personal property such as vehicles and equipment, the
operational guideline values were derived using the ANSI N13.12
standard clearance screening levels.\9\ These draft operational
guidelines are available for review and use as appropriate at http:/
/www.ogcms.energy.gov. The guidelines establish three property
categories: at greater than 200 times ANSI N13.12 screening levels,
monitored remediation or control is recommended; at levels between
10 and 200 times the levels, self-remediation (conventional washing)
of the property is recommended as soon as practical; and below the
self-remediation levels, no control or protective action is
necessary.
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    \9\ The American National Standards Institute (ANSI) produces
consensus based national standards. ANSI standard N13.12, Surface
and Volume Radioactivity Standards for Clearance, can be found at
http://hps.org/hpssc/N13_12_1999.html.
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    Operational guidelines for real property (buildings and lands)