ML19256E884

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Responds to 790820 Memo Re Questions Posed by Govt of West Germany.Info Covers Use of Emergency Measures Near Nuclear Facilities
ML19256E884
Person / Time
Issue date: 11/02/1979
From: Collins H
NRC OFFICE OF STATE PROGRAMS (OSP)
To: Lafleur J
NRC OFFICE OF INTERNATIONAL PROGRAMS (OIP)
References
NUDOCS 7911150481
Download: ML19256E884 (12)


Text

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UNITED STATES NUCLEAR REGULATORY COMMISSION

j WASHINGTON. D. C. 20555

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NOV 2 1979 MEMORANDUM FOR: Joseph D. Lafleur, Jr., Deputy Director Office of International Programs FR0!i:

Harold E. Collins, Assistant Director for Emergency Preparedness Office of State Programs

SUBJECT:

ANSWERS TO LIST OF QUESTIONS OF THE FEDERAL REPUBLIC 0F GERMANY DELEGATION, AUGUST 13, 1979 Your memorandum of August 20, 1979, requested that I provide answers to a list of questions submitted by a Federal Republic of Germany delegation, that visited NRC on August 13, 1979.

At that time, because of insufficient time during my presentation before them, I was not able to answer all of their questions which they had.

Enclosed are my answers to their questions and copies of the applicable references.

Harold E. Collins Assistant Director for Emergency Preparedness Office of State Programs

Enclosures:

As stated cc:

Robert G. Ryan, Director, SP-NRC 1336 027 WSf 7911150 g

These are answers to questions posed by the Federal Republic of Germany, State Ministry of Interior, North Rhine - Westphalia, which could not be answered at an August 13, 1979 meeting with the FRG delegation.

All answers given, are prepared by Mr. Harold E. Collins, Assistant Director for Emergency Preparedness, Office of State Programs, U.S. Nuclear Regulatory Commission. The answers are his own and do not necessarily reflect the opinions and views of the U.S. Nuclear Regulatory Commission itself, but in the opinion of Mr. Collins, are fair and accurate answers insofar as he was able to answer these questions.

A list of references is provided on the lar.t page and copies of all reference documents are forwarded herewith.

=

Q.l.

Do you intend to make the planning of emergency measures in the neighbourhood of nuclear facilities a pre-requisite for the granting of an operating license after the Hairtsburg accident?

A.l.

There are numerous signs that point in this direction.

It undoubtedly will come to pass as it should in my opinion and in the opinion of many of my colleagues.

The Kemeny Report (released on Octo 31, 1979) (Presidential Comission on the accident at Three Mile Island)gerrecommends this.

So does the Senate passed " Hart Bill", S.562,2 passed by the U.S. Senate 97 to 1, and now in the U.S. House of Representatives where it awaits House action.

Also, the U.S. General Accounting Office (GA0),3 recommended this in its report entitled " Areas Around Nuclear Facilities should Be Better Prepared for Radiological Emergencies" issued on March 30, 1979.

Q.2.

What legal bcsis are the planning and implementation of emergency measures based on at present?

A.2.

The only " legal basis" is the NRC Emergency Planning Regulations for licensees, 10 CFR 50, Appendix 'E'.4 These regulations are currently being changed by NRC. Also, the " Hart Bill", S.562, proposes, among other things, to codify into regulations, the existing voluntary, non-statutory, NRC guideline - Standards for State and local government Radiological Emergency Response Plans.

These existing voluntary guideline-standards are contained in NRC publication, NUREG-75/ll1.F It is important to note that at the present time, no Federal agency has statutory authority to require these plans of Sta E and local governments, but the " Hart Bill" S.562 proposes to change this situation.

Q.3.

Who is responsible for the planning

  • and implementation of emergency measures on the part of the authorities?

A.3.

For the licensee's plans, it is himself, under NRC Regulations in 10 CFR 50, Appendix 'E'.

NRC and other Federal agencies, have long recognized that primary planning and implementation of emergency measures offsite (that is outside of the site area owned or controlled by the licensee) is a responsibility of the State and local governments involved, under the inherent police and health and safety powers of these governments. The Federal government steps-in to assist, at the request of the State and local governments, or even the licensee for that matter.

Q.4.

Shall Regulatory Guide 1.101 " Emergency Planning for Nuclear Power Plants" be declared obligatory for the planning of emergency measures in all States (Federal recommendations were not applied at the time of the accident in Pennsylvania)?

6 A.4.

NRC Regulatory Guide 1.101 is a guide for NRC licensees.

It has no force of law with the States and local governments.

They (the States and local governments) may choose to follow its guidance or they may not choose to do It has no more force of law on States and local governments, than the so.

NRC's primary guidance document, NUREG-75/111, previously mentioned in Question 2.

Regulatory Guide 1.101 will undoubtedly be changed along with the Emergency Planning Regulations, 10 CFR 50, Appendix 'E'.

1336 029

.2-Q.5.

Is the license-holder (operating company) obliged to draw up an emergency plan of his own?

A.S.

Yes, under NRC Regulations 10 CFR 50, Appendix 'E'.

Q.6.

Will the " Emergency-Management-Agency" of each individual State present guides to the license-holder (operating company) according to which the planning of emergency measures is to be carried out after Harrisburg has shown that the arrangements and agreements made between the license-holders (operating companies) and the official agencies were insufficient?

A.6.

It is possible that individual States and local governments may present emergency planning guides or levy emergency planning regulations on nuclear facility licensees. We have seen some partial trends in this area, but they are as yet not fully formed or implemented.

I am of the opinion that any guides or regulations will continue to be levied on the licensee by the Federal government.

At the State and local government level, what we are seeing, is legislatton passed in three States (Illinois, California, and Oregon),/ which assess the licensees monetary funds, to pay for State and local government costs in emergency planning and preparedness supportive of these nuclear facilities.

Of interest here, is the recent staff report, prepared within the NRC's Office of State Programs, NUREG-0553.8 Q.7.

Guide 1.101 does not provide for emergency management. Are you planning to provide such management in the future?

(It was, in particular, the lack of strict and organized management that, in the beginning, lead to unforeseen confusion and insecurity among the authorities and above all among the population.)

A.7.

We look to the newly established Federal Emergency Management Agency which was established April 1,19799 to provide for this overall Federal management and to coordinate the emergency response of the entire Federal government.

The " Hart Bill" S.562 calls for a National Contingency Plan to be prepared by FEMA and for an NRC Contingency Plan to be prepared by NRC. These requirements will undoubtedly come to pass.

Q.8.

Early notification of the competent authorities is the basic requirement for an effective implementation of emergency measures.

In Harrisburg the Nuclear Regulatory Commission (NRC) was only informed three hours after the accident had occurred.

In addition, the extent of the accident was not intnediately realized by the license = holder (operating company).

Do you think that, for this reason, the installation of a reactor-remote-control-system would be either advisable or essential?

A.8.

I am not sure what is meant by a " reactor-remote-control-system" but if it is what I think it may be, in the purest sense of the word, the answer is ng The term " reactor-remote-control-system" implies the ability to control the reactor offsite, by possibly offsite authorities.

I do not envision any such system nor do I think it advisable. The idea of offsite authorities, be they either licensee management or Federal, State or local government personnel at some remote from site location, controlling a nuclear power plant in an emergency, is unworkable in my view.

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. On the other hand, if what is meant here by this term, that certain reactor operational parameters such as crucial pressures, temperatures, etc. be telemetered offsite for informational or " watch-dog" purposes, this idea has certainly been suggested before.

I have no basic quarrel with this oversight notion, but it woulti be relatively expensive for a nation with many reactors such as the U.S. and who would be doing the " watching", day-after-day? This question and other related questions need to be first explored before proposing such an oversight system.

The basic problem at TMI and at the March,1975 TVA Browns Ferry nuclear plant fire, was tardy notification to Federal, State and local authorities, that there were serious potential problems in both of these accidents.

This " mind-set" of nuclear facility management and their operators must be reversed.

Penalties for failing to promptly notify appropriate authorities of impending problems, should be severe and enforced.

Operators have the unequivocal responsibility to promptly notify those who should be-notified in the event of an emergency,5 even to the extent of putting these offsite organizations on a " standby alert" status.6 The operators must be freed from c magement " policy", which in many cases requires the operators on watch, i advise their management first which too often results in excessiv;

- !ays, especially at 4:00 a.m. on a Sunday morning.

Q.9.

Is monitoring the neighbourhood with an increased number of mobile and stationary devices of the license-holder (operating company), the licensing and emergency authorities considered to be sufficient?

A.9.

The current " State-of-the-art" in both onsite and offsite radiological monitoring in terms of appropriate fixed and mobile instruments and systems, is considered to be inadequate in the U.S.

Steps are underway to imptove this situation. The use of automatic, computerized accident assessment systems is currently being assessed and contemplated to free operators and offsite response organizations to a greater extent from the laborious manual calculations, and relatively primitive maps and plastic overlay techniques which represents the bulk of the current " State-of-the-art" in accident assessment and prediction of offsite consequences.

Q.10. Do you intend to provide for the permanent presence of expert supervisory officials knowing the plant when putting new plants, in particular prototype plants, into operation, or shouldn't a so-called State-Commissioner be present round the clock?

A.10. The notion of having qualified Federal observer / operators on duty "round-the-clock" in the Control Rooms of commercial nuclear facilities, has been proposed in some quarters of the U.S. Congress and elsewhere.

It has even been proposed that only Federal operators operate these facilities.

I cannot say whether or not either of these proposals will ever come to pass,

but I doubt it. The cost would be high and would require many trained Federal personnel. About the closest we have come to this, is the NRC Resident Inspector program, wherein a single NRC Resident Inspector has his office on the site and is on the site on a daily basis (not all shifts).

The Resident Inspector Program is currently in place.at some nuclear facilities.

Plans are to have a Resident Inspector at all sites soon.

s

. I know of no State proposing a " State-Commissioner" or other State official to be present around-the-clock.

Q.ll. Has consideration been given to replacing the operating personnel by trained personnel if an accident occurs?

A.ll. Some thought has been given to this, but mainly in terms of augmenting the onsite personnel during an emergency rather than replacing them.

These augmenting or extra personnel could either come from nuclear industry pool of qualified technical personnel, from the Federal government, or from both sources.

The latter notion is what appears to be the likely course of action during an emergency. This is essentially what happened at TMI, but not imediately.

Q.12. After the Harrisburg accident it will be necessary to examine the instrumentation in the reactor plants with a view to accident detection and identification, documentation of the course of the accident, indication and assessment of the state of the plant after the accident (instrumentation after the accident).

Do you consider the instrumentation in the reactor plants which is in keeping with the present technological and scientific developments to be adequate at all with a view to accidents?

A.12. The answer to this question is an unequivocal no' Most instrumentation currently in place in nuclear plants in this country, was not designed to be functional under severe in-plant accident conditions such as at TMI.

Measures are underway to improve this matter in terms of providing radiological monitoring instrumentation and other instrumentation specifically designed for the extreme conditions encountered in severe accidents.10 A.13. In consequence of having been alerted by the license-holder (operating company) the emergency management agency prepared the evacuation of the population living within a radius of up to 5 miles (8km), the evacuation of those living within a radius of 10 miles (16 km), and finally of those living within ~a radius of 20 miles (32 km). The Guide, however, provides for a subdivision into a restricted area 1 to 2 miles, and a thinly populated zone up to 10 miles. - According to an NRC proposal it is intended for an emergency planning zone with potential inhalation exposure and a radius of 10 miles to be provided.

For this zone, taking shelter in respective shelters and/or evacuation are recommended as essential emergency measures. -

Do you consider this subdivision to be adequate although the governor of Pennsylvania had prepared an evacuation of 20 miles?

A.13. The question refers to "ad-hoc" evacuation plans prepared by the Pennsylvania Emergency Management Agency, all the way out to 20 miles (32 kilometers) from the TMI site.

It also refers to the NRC/ EPA Task Force Report (NUREG-0396/ EPA-520/1-78-016)l0 recommendations for establishing an Emergency Planning Zone (EPZ) for the plume exposure pathway of about 10 miles (16 kilometers) about light water reactors such as TMI.

The Commission (NRC) endorsed the Task Force Report recommendations on October 5, 1979 and published its policy 24, 1979.Igtatement on this matter in the U.S. Federal.

Register on October The U.S. EPA has also endorsed the report and its recomendations and will soon put its policy statement reflecting this endorsement in the U.S. Federal Register.

Thus both U.S. agencies consider the "about 10 mile EPZ" for the plume exposure pathway to be 1 Y)b'

. guidance on this matter The NRC/ EPA Task Force Report also recommends an outer EPZ for the ingestion or food (agricultural) pathway of about 50 miles (80 kilometers).

Both EPZs can be expanded if necessary, providing some basic planning concerning protective measures has been done for both EPZs. Thus our current guidance does not include a 20 mile (32 kilometer)

EPZ for the plume exposure pathway.

Q.14. Do you consider a subdivision of this zone into sectors appropriate? The Guide does not contain any reference regarding this.

A.14. Yes.

NUREG-75/lll is a little more definitive on sectors than NUREG-0396/ EPA 520 1-78-016, but figure 1 on page 12 of the latter report, does reflect sector response.

Q.15. Are you thinking of evacuating certain population groups (women and children) first, also in the future?

A.15. Even though " selective evacuation" was recommended during the TMI accident (i.e. pregnant women and pre-school age children out to 5 miles), I personally disagree with the matter of " selective evacuation" in terms of certain groups or classifications of people.

My disagreement with this notion of " selective evacuation" is in my sworn deposition before the Kemeny Commission (the Presidential Commission on the Accident at Three Mile Island). Others share this disagreement. As I told a Kemeny Commission in'iestigator/interrogater, the idea.of a policeman going to a door of a home, knocking on it and asking the lady of the house "if she is pregnant and has small children of pre-school age in the house" - to which she replies "yes".

And the policeman saying "well you and these children leave, but your husband, grandmother and teenage children can stay".

is ridiculous in my view.

Moreso if the announcement is made over television or radio.

ho in their right mind would stay behind? The end result of most of this at TMI, was that entire households just got up and left when faced with this proposition. Some people did stay behind.

Personally, I am opposed to " selective evacuation" but that is a personal view. Others I have talked to, including State officials, also are opposed to " selective evacuation" in terms of groups or classifications of people.

I cannot say whether such " select,- evacuation" will occur in the future.

Q.16. The German basic rec,mmendations contain standard dose rates for the initiation of actual emergency measures.

(25 to 100 rem whole body dose when staying in the open air: evacuation advisable, above 100 rem required). Will standard dose rates also be determined in the American guides in the future, or do you think of leaving it at the present ad hoc-decisions of the individual governor after consultation with the NRC and other special agencies?

A.16. Two basic points need to be made here to answer this question properly.

The first point to be made is that if these numbers (" standard doses" as opposed to " dose rates") are indeed what the FRG has.in mind as acceptable doses to persons before anything is done in terms of implementing protective measures, then they are much to high when compared to U.S. Protective Action Guides (PAGs) promulgated by tiie U.S. Environmen+al Protection Agency.12

}33b

. These guides are 1-5 Rem whole body, 5-25 Rem thyroid with mandatory action to be taken at the upper end of these ranges. Thus U.S. guides are based on projected dose and not on dose rates.

The second point to be made here, is that one can decide to implement protective measures such as evacuation, sheltering or thyroid blocking (with Potassium Iodide or Iodate in appropriate dosage), based on two precepts. The first of these is to base the decision to implement protective measures on an actual technical (radiological) assessment or estimated projection of dose and compare the assessment or projection of this dose to such things as PAGs. Then decide what you want to do or can do under the circumstances that prevail. The second of these precepts is to base the decision to implement protective measures as a precautionary move.

That is, if one is uncertain about what radiological releases may occur and what their magnitude and duration may bc, then one can opt for the precautionary a

implementation of protective measures. This optioq is not based upon any technical assessment or estimated projection which might not be readily available, depending upon the circumstances.

It was precisely this latter precept which prevailed at TMI and which resulted in a precautionary selective evacuation of pregnant women and pre-school age children.

The Governor of the Commonvealth of Pennsylvania did not base his recommendations upon Protective Action Guides.

His decision was precautionary.

Q.17. Owing to lack of information on the state of the plant and, above all, owing to the fact that it was impossible to predict the further course of the accident the NRC recommended to the governor of Pennsylvania, as a precaution, to envisage evacuation within a radtus of 5 miles (k km) and make preparations for the evacuation of the population living within the radius of up to 20 miles (32 km).

Do you intend, for this reason, in future to evacuate the restricted area and the thinly populated zone immediately without,, waiting for definite measuring results when an accident is reported; above all under the aspect of an evacuation according to plan?

A.17. The answer to this question is partially contained in A.16 above. Ne option for precautionary evacuation is a valid one and may indeed be used in the future should another accident occur.

I am not quite sure what is meant by " restricted area" but if it refers to the plant site itself (inside the fence), licensees are required to have evacuation plans for non-essential personnel in the site area that they control.

The term " thinly populated zone" may refer to the U.S. " Low Population Zone" (LPZ)l3 which for all practical purposes has been rejected for emergency planning purposes and replaced by the concept of Emergency Planning Zones recommended by the NRC/ EPA Task Force on Emergency Planning and endorsed by the Commission and EPA as guidance for the States and local governments. Under some circumstances, such as a fast-breaking accident of obvious or assumed severity, there may be no time for " definite measuring results" or assessment, and immediate evacuation might be deemed necr:ary rather than wait for an assessment which may come too late after sarge radiological exposures have occurred.

1336 034 Q.18. Harrisburg has shown that a great number of those living in the neighbourhood of the nuclear power plant left their homes voluntarily and looked for alternativ' acconmodation themselves. The result were blocked roads an

,<ing to that an almost chaotic traffic situation.

Do you intend to preve those parts of the population living in the more remote zones from leaving their communities (traffic control) in order to evacuate those living closer to the nuclear power plant who are more endangered first and according to plan?

A.18. First of all, I have heard of no reports that roads were " blocked" around TMI by traffic or that the traffic situation was " chaotic".

To the best of my knowledge, the people that did leave the area, left in an orderly, spaced, manner.

I know of no plans to restrict people from leaving more remote areas from the site, in order to evacuate those living closer to the site.

Police of course could be instructed to do this in a given situation, but I don't know of any pre-conceived plans to do this.

A.19. In the Federal Republic of Germany, the required number of potassium iodide tablets is kept at hand by the competent emergency management authorities.

In the Harrisburg event they were produced in liquid fo m and made available within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Are you now also envisaging the stocking up of potassium iodide tablets or their distribution to the populatio,1 living in the neighbourhood of the nuclear power plant?

A.19. Currently there is no Federal policy or guidance developed in the U.S. on the use of potassium iodide as a thyroid blocking agent.

The U.S. Federal agency charged to develop such a Federal policy and guidance in the U.5.

Department of Health, Education and Welfare (HEW), specifically the Food and Drug Administration area of that agency.

Liquid potassium iodide (KI) solution, was provided on a " crash basis" to Pennsylvania authorities, but much later than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

This is because no KI pills were available (liquid KI was faster to produce) or even approved for manufacture by HEW at the time of the TMI accident.

01 December 15, 1978, HEW did promulgate a " call for new drug applications" (for KI tablets) to interested manufacturers, in the U.S. Federal Register.14 But this Federal Register notice, did n~t constitute Federal policy as to when and under what circ ostances this drug should be used.

plans are now afoot in NRC ret HEW, to develop a Federal policy and guidance on the manufacture, stockpiling, location and distribution of KI tablets.as a valid protective measure in some circumstances.

Q.20. In Harr isburg it has not come to a disaster.

However, are the preventive (emergency) measures taken in the medical sector sufficient to serve an increased number of radiation victims? Are hospitals and other institutions prepared for such an occurrence?

If so, how?

A.20. The answer to this question depends upon where the accident happens.

It also depends upon what is meant by "an increased number of radiation victims".

If it is perhaps a few hundred people, that is something that probably can be bandled by several regional private, public or national medical centers.

If it is thousands of people, we would be hard pressed to cope with this situation especially if radiological exposures were of the order of life threatening exposures requiring definitive medical care for exposures of this sort. We would do the best that we can.

Depending upon the numbers I3%6d of medical facilities in the location of any given nuclear power plant site, some people might have to be transported to medical facilities outside of the immediate region of the involved nuclear facility.

In general, training for medical personnel to handle radiation casualtier needs to be improved and expanded all across the U.S.

NRC and HEW are planning to provide more specialized training in this area.

Q.21. Are you considering the installation of emergency stations manned with physicians (in the neighbourhood of nuclear facilities but outside the danger zone) to be able to carry out an immediate classification? Do you think it is possible to carry out such classification by means of X-ray diagnosis without knowing the previous radiation exposure of each individual person, or is it necessary for a radiation exposure register to be made up and kept in respect of each individual living within a radius of 25 km?

A.21. The answer to the first question is no.

We will continue to rely on existing medical facilities but with an expanded training program for them.

The second question does not parse well in English, so I'm not so sure as to what the question no.

I kr.

ei..o "x-ray diagnosis" for radiation victims but then again I am not a medical doctor. Other tests such as chromosome analysis and other medical tests seem to be what is required to determine moderate to serious radiation exposures.

Dosimeters that may have been previously placed in the area or actual radiation measurements would be of great i elp in estimating doses to exposed people.

I know of no general plans to keep " radiation exposure registers" for people living near a nuclear power plant, except for the plant workers who may live in the area of the plant.

Q.22. What we have learnt from the accident and what was most important with regard to emergency planning was that all measures are dependent on the reliable assessment of the danger. Most of the aeasurir.g was done by State institutions.

Do you consider the equipment of these measuring institutes and the training of their personnel to be adequate?

A.22. First of all, to the best of my knowledge, most of the measuring of radiation in the environment at TMI, was not done by State (Pennsylvania) agencies.

It was done by the U.S. Federal government agencies (NRC, DOE, HEW, EPA) that arrived on the scene. They had much more equipment and many nore personnel than the Commonwealth of Pennsylvania.

State agencies are generairy limited in the number of qualified personnel and types of equipment that they have. The Federal perst. el are much more numerous in terms of qualified personnel', and generally equipment in the hands of Federal agencies is superior and much more diversified and sophisticated.

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.. With respect to training of personnel, probably the best overall trained radiological assessment personnel are found in the U.S. Department of Energy and its National Laboratories.

These National Laboratories can field large sophisticated radiological assessment teams.

These people and their equipment, constitute the single largest radiological assessment continger.t in the U.S.

Additionally, the U.S. EPA and the U.S. HEW, have fairly substantial resources in tenns of personnel and equipment.

U.S. NRC has very modest resources in this regard but is acquiring more - post-TMI.

State radiological personnel are for the most part well trained but relatively few in numbers when compared to the Federal resource.

Local government radiological personnel (other than basic Civil Defense personnel who are not generally well trained) are almost non-existent.

Q.23. Have skeleton exercises or full exercises been carried out by the personnel of the authorities and institutes or do you envisage requiring these in new guidelines?

A.23. Many exercises have been conducted, but they vary in terms of realism and quality.

NRC is embarked on a program to provide Standardized Exercise Scenarios to Federal, State and local governments.

Current regulations for the licensee, require that he conduct periodic exercises and drills 4 State and local exercises are covered by NRC voluntary guideline - standards.$

We envision that these exercises wil1 be required of States and local governments, to be conducted in conjunction with the licensee exercises.

Q.24. Have joint exercises been carried out by license-holders (operating companies) and authorities or do you intend to require these in new geride-lines?

A.24. As answered in A.23 above, periodic exercises are already required of licensees by current NRC regulations These regulations are now in the process of being expanded and improva.

Q.25. Is a difference being made between nuclear power plants, reprocessing plants and nuclear research and development facilities with regard to emergency planning, or are they generally looked upon as nuclear facilities?

A.25. Our emphasis has been on the power plants, but our regulations and guidance also extendg to fuel cycle plants and research and development nuclear facili ties.a Some large fuel cycle type plants have potential to cause serious events and must be factcred into the emergency planning and preparedness scheme.

Smal? research reactors should have curgency plans and be required to conduct exercises, especially anything above say 5 to 10 Megawatts thernal in my opinion. They do not need large Emergency Planning Zones, but % ould have the same general types of plans, scaled down to their size.and pc'ential for causing accidents as appropriate.

1336 037

'~

REFERENCES 1.

Report of the President's Commission on The Accident At Three Mile Island, October 30, 1979.

2.

Hart Bill, S.562, July 17, 1979.

3.

GA0 Report, " Areas Around Nuclear Facilities Should Be Better Prepared, March 30, 1979.

4.

Licensins

<re 2 ction and Utilization Facilities - Plans for Coping 2

wi th '.me. gencms Title 10, Code of Federal Regulations, Part 50, Appendix E.

5.

G de and Checklist for Development and Evaluation of State and Local Go -

.cnt Radiological Emergency Response Plans in Support of Fixed Nuclear Ft.

lities, NUREG 75/111, December 1,1974.

6.

Regulatory Guide 1.101, Emergency Planning for Nuclear Power Plants.

7.

Oregon Act: "An Act - Senate Bill No. 641, Chapter 726, Laws 1979, July 1979.

Illinois Act:

" Illinois Nuclear Safety Preparedness Act," September 1979.

California Act:

"An Act - Senate Bill No. 1183, Chapter 956, Laws 1979" September 1979.

8.

Beyond Defuse-In-Depth Cost and Funding of State and Local Government Radiological Nergency Response Plans and Preparedness in Support of Commercial Nuclear Power Stations, NUREG-0553, October 18, 1979.

9.

Federal Emergency Management Agency Executive Order 12148, July 20,1979.

10.

Regulatory Guide 1.97, Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant Conditions During and Following an Accident.

Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants, NUREG-0396/ EPA 520/1-78-016, December 1978.

11.

Federal Register Notice, Planning Basis for Emergency Responses to Nuclear Power Reactor Accidents, October 23, 1979.

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

13.

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

14.

Department of Health, Education and Welfare, Food & Drug Administration Federal Register Notice, Accidental Radioactive Contamination of Human and Animal Feeds and Potassium Iodide as a Thyroid-3 locking Agency in a Radiation Emergency, December 15, 1978.

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