ML20149F056

From kanterella
Jump to navigation Jump to search
Advises That Draft Concept of Util Offsite Planning Evaluation Criteria, & Evaluation Criteria for Util Offsite Plans Reviewed.Comments Provided on Encl marked-up Copies.Criteria Must Address Response Organization
ML20149F056
Person / Time
Issue date: 11/17/1987
From: Bores B
NRC
To: Bellamy R
NRC
Shared Package
ML20149C585 List:
References
FOIA-87-794 NUDOCS 8801140108
Download: ML20149F056 (1)


Text

.

6:

4py 916  %  %

w $%% -

,.Q- alnH L/

& y & #A aQ r AA JA &

GSM J y A e d s it t 4 /

~ /d 9h" s p yzs yya wApt c y e, a yx

~%

y~u n fy2 AG- y , dL .2 a ;r4 W 'Tf A" #bY& W p % an an.

an 17~

a y a a.

d6/L yiV17 i

i l

l 8801140108 880111 BE AIR 87-794 PDR h [p

l Draft I

~

h. -

1 CONCEPT OF UTillTY OFFSITE PLANNING EVALUATION CRITERIA '

I

/ \

1. The concept of "of fsite response organization" is adopted and defined as v, the utility offsite emergency response organization along with other par- '

ticipating voluntary d ri gngza s a g l g State and Federal governments eng:ging in th: d:; .:;;::n. Of ef f:it: -..m,

[ :n; 'e- a nuclear power plant.' Throughout the revised Evaluation Criteria "of f site response organization" replaces references to State and local governments.

2. In addition, Evaluation Criteria were modified or added to compensate for lack of participation by State and local governments in the planning process, such as:
a. Identification of the functions which require State and local authorization before implementing ( A.2.a).

$ 4 m .

b. Afrovision of additional personhel to advise and assist State and local officials in an emergency ( S[. ,

c, - - y

c. Provision for advising State and local of ficials on emergency actions to be t a ken (0.4. , E . 6. a . , J .10. f . ) .
d. Provision for coordinating emergency messages with State and local governments where possible (E.3.).
e. Provision for communications with non participating State and local emergency operations f acilities (F.1.),

f.

jProvisionforpublicinformationdescribingtheroleoftheoffsite

' response organization vs. the State and local organizations during '

the emergency (G.I.e.).

Establishment of an emergency operations center for useg in directing l

) 9 and controlling offsite response functions (H.3.).

CRITERI A/UTillTY OFFSITE PLANS WL 11/06/87 S (- d-[ h th f ]f b N () ,

5

.A Ora f t V ap p th*= -

h.

/

Offsite response organization should have the means (even though they don't have the responsibility) for activating the alert and p notification system (E.6.a. and J.9. ).

i. Provision for encouraging participation in exercises and drills by State and local governments but not requiring it (N.6.).

J. Provision of training to persons in the etil!!y'; offsite response organization who will be responders (0.4.k.).

1 k.

Y Provision fer pro'ef ding copies of the of fsite plan to non participating State and local governments.

t CRITERI A/ UTILITY OFFSITE PLANS py Li 11/06/87

Oraft PROPOSED FOR INTERIM USE AND COMMENT Appendix 6 Evaluation Criteria for Utility Offsite Plans Thefollowingprovides/riteriatobeusedforthedevelopmentandevtluation of utility offsite emergency response plans and preparedness. (The/lanning

//andards are repeated here for convenience.) These Evaluation Criteria modify those applicable to State and local response organizations and should be used in their place. The following assumptions were used in developing the Evalua-tion Criteria in this appendix, in an actual emergency, State and local officials will:

1. exercise their best efforts to prot:ct the health and safety of the public;
2. cooperate with the utility and follow the utility offsite plan; and
3. have tne resources sufficient to implement those portions of the utility cffsite plar. w ere h

State or local response is necessary.

4 CRITERIA / UTILITY OFFSITE PLANS F 11/06/87

Draft EVALUATION CRITERIA FOR UTILITY OFFSITE PLANS P?anning Standards and Evaluation Criteria A. Assignment of Responsibility (Organization Control)

Planning Standard Primary responsibilities for emergency response by the nuclear facility licensee, and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various sup-porting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

Es a'vation Criteria

1. a. The offsite plan shall identify the elements of the offsite response organization for Emergency Planning Zones (see Appendix 5).*
b. The offsite response organization shall specify its concept of operations, and its relationship to the total effort. The concept of operation will explain how the offsite response organization will function with non participating State and local governments, and will specify the various modes of operatfor..

"Of f site response organization is defined as the utility offsite emergency response organization along with other participating voluntary and private organizations, and local, State and Federal governments engnireian MwM developmeni, vi omite emergericy p1w,-fee a nuclear power plant

-t, he Q $h & W *% W E CRITERIA /VTILITY OFFSITE PLANS 1 11/06/87

Oraft

c. The offsite plan shall illustrate these interrelationships in a block diagram. This diagram will define the roles for the offsite response organization and non participating State and local governments, and identify the lead interfaces.
d. The offsite response organization shall identify a specific individ-ual by title who shall be in charge of the emergency response.
e. The offsite response organization shall provide for 24-hour per day emergency response, including 24-hour per day manning of communica-tions links.
2. a. The offsite response organization shall specify the functions and responsibilities for major elements and key individuals by title, of emergency response, including the following: Command and Control, Alerting and Notification, Communications, Public Information, Acci-dent Assessment, Public Health and Sanitation, Social Services, Fire and Rescue, Traffic Control, Emergency Medical Services, Law Enforce-ment, iransportation, protective Response (including authority to request Federal assistance and to initiate other protective actions),

and Radiological Exposure Control. The description of these functions shall include a clear and concise summary such as a table of primary and support responsibilities using the agency as one axis, and the function as the other. This description shall specify those functions which require State and local authorizaton before implementing, such as:

1. Directing traffic;
11. Blocking roadways, erecting barriers in roadways and channeling traffic; iii. Posting traf fic signs on roadways; M S # iv. Removing obstructions f rom public roadways, including towing M ** d M { v. vehicles; Activating sirens and directing the broadcasting of EBS messages; CRITERIA / UTILITY OFFSITE PLANS 2 11/06/87

Draft

51. Making decisions and recommendations to the public concerning protective actions for the plume exposure pathway; vii. Making decisions and recommendations to the public concerning protective actions for the ingestion exposure pathway; viii. Making decisions and recommendations to, the public concerning recovery and reentry; I ix.

w/ [ Dispensing fuel from tank trucks to automobiles along roadsides; U 7 fx . Performing access control at an EOC, relocation centers and the EPZ oerimeters; and y 7 {xi. Agreements with other c g . cA .2 The plan shall also identify similar functions and responsibilities and interfaces for an anticipated State and local response to an emergency.

b. The offsite plan shall contain (by reference to specific acts, codes or statutes) the legal basis for such authorities.
3. The of f site plan shall include written agreements referring to the con-cept of operations developed between Federal agoncies, the offsite respotte organization, and other support organizations having an emer-gency response role within the Emergency Planning Zones. The agreements shall icentify the emergency measures to be provided and the mutually acceptable criteria for their implementation, and specify the arrange-ments for exchange of information. These agreements may be provided in an appendix to the of fsite plan or the offsite plan itself may contain descriptions of these matters and a signature page in the plan may serve to verify the agreements. The signature page format is appropriate for l

organizations where response functions are covered by laws, regulations or executive orders where separate written agreements are not necessary.

4. The of f site response organization shall be capable of continuous (24-hour) operations for a protracted period. The individual in the offsf te response organization who will be responsible for assuring continuity,of resources (technical, administrative, and material) shall be specified by title.

CRITERIA / UTILITY OFFSITE PLANS 3 11/06/87

. Oraft

n. prognosis for worsening or termination of event based on plant information.
5. The offsite response organization shall establish a system for disseminat-ing to the public appropriate information contained in initial and followup messages received from the licensee including the appropriate notification to appropriate broadcast media, e.g., the Emergency Broadcast System (EBS).

i The offsite response organization shall establish administrative and

6. /

physical means, and the time required for notifying and providing prompt instructions to the public within the plume exposure pathway Emergency Planning Zone (see Appendix 3 of NUREG-0654/ FEMA-REP-1, Rev. 1). It shall be the licensee's responsibility to demonstrate that such means exist, regardless of who implements this requirement.

The of fsite response organization should have the means to activate the system.

7. The of f site response organization shall provide written messages intended for the public, consistent with the licensee's classification scheme. In particular, draf t messages to the public giving instructions with regard to specific protective actions to be taken by occupants of af fected areas shall ce prepared and included as part of the of f site plans. Such mes-sages should include the appropriate aspects of sheltering,4.;., M r# -

kercH:' Onr :ttS[ thyroid blocking or evacuation. The role of the licensee is to provide supporting information for the messages. For ad hoc respiratory protection see "Respiratory Protective Devices Manual" American Industrial Hygiene Association, 1963 pp. 123-126. '.

l'

%The prescripted messages should address the various conditions such as the dele-gation of authority by the State and local governments to the offsite response organization to issue prompt instructions.

' f 7l

. ye %

  1. p dj.p '

e, /

CR]TERIA/ UTILITY OFFSITE PLANS 9 11/06/87

Draft F. Emergency Communications planning Standaro Provisions exist for prompt communications among principal response organiza-tions to emergency personnel and to the public.

Evaluation Criteria

1. The communication plans for emergencies shall include organizational titles and alternates for both ends of the communication links. Reliable primary and backup means of communication for the utility and the offsite response organization shall be established. The utility and the offsite response organization shall establish the capability to communicate with scann non participating State and local governments via ==p.-emergency telephone number (s) (e.g.. 911) and via one other backup mode such as the ability to transmit via existing emergency radio frequencies. Each plan shall include:
a. provision foi 24-hour per day notification to and activation of the offsite response organization's emergency response network; and at a mirimum, a telephone link and alternate, including 24-hour per day ear.nir.g of com?.unication links that initiate emergency response actions.
b. provision for communications with contiguous States and local govern-ments within the Emergency Planning Zones; k&['Mia/ c. provision for communications as needed with Ferieral emergency
  1. response organizations; Y '
d. provision for communications between the nuclear facility and the licensee's near-site Emergency Operations Facility, offsite response organization's emergency operations centers, and radiological monitor-ing teams; &

CRITERI A/ UTILITY OFFSITE PLANS 10 11/06/87

Oraft

. e. provision for alerting or activating emergency personnel in e4eh'idu response organization; ,

I

2. The of f site response organization shall ensure that a coordinated ]

communication link for fixed and mobile medical support facilities l exists.

3. The of fsite response organization shall conduct periodic testing of the entire emergency communications system (see evaluation criteria H.10, 1 N.2.a and Appencix 3 of NUREG-0654/FEHA-REP-1, Rev.1).

l 6

CRITERI A/ UTILITY OFFSITE PLANS 11 11/06/87

Oraft G. public Education and Information Planning Standard information is made available to the public on a periodic basis on how they will be notified and what their initial actions shall be in an emergency (e.g., listening to a local broadcast station and remaining indoors), the principal points of contact with the news media for disserination of informa- ,

tion during an emergency (including the physical location or locations) are established in advance, and procedures for coordinated dissemination of infor-mation to the public are established.

Evaluation Criteria

1. The offsite response organization shall provide a coordinated periodic (at least annu' ally) dissemination of information ta the public regarding how they will be notified and what their actions should be in an emer-gency. This information shall include, but not necessarily be limited to:
a. e O:atio.al information on radiation; b, contact for additional information;
c. protective measures, e.g. , evacuation routes and relocation centers, sheltering, respiratory protection, radioprotective drugs;
d. special needs of the handicapped; and

~

e. special steps to be taken to describe the role of the offsite re-g sponse organization vs. the State and local organizations during the 4,tg p emergency.

% 7 Means for accomplishing this dissemination may include, but tre not necessarily limited to: information in the telephone book; posting in public areas; and publications distributed on an annual basis.

CRITERIA / UTILITY OFFSITE PLANS 12 11/06/87

Draft I. Accident Assessment Planning Standard Adequate methods, systems and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

Evaluation Criteria

7. The offsite response organization shall describe the capability and re-sources for field monitoring within the plume exposure Emergency Planning Zone which are an intrinsic part of the concept of operations for the facility.
8. The of f site response organization, where appropriate, shall provide methods, equipment and expertise to make rapid assessments of the actual or potential magnitude and locations of any radiological hazards through liquid or gaseous release pathways. This shall include activation, noti-fication means, field team composition, transportation, communication, m:rltceirg equipment and estimated deployment times.
9. The of f site respon;e organization shall have a capability to detect and measure radioiodine concentrations in air in the plume exposure EPZ as low es 10 ' pCi/cc (microcuries per cubic centimeter) under field condi-tions. Interference from the presence of noble gas and background radia-tion shall not dc:r^ to=the stated minimum detectable activity.

A%

10. The offsite response organization shall establish means for relating the various measured parameters (e.g., contamination levels, water and air activity levels) to dose rates for key isotopes (i.e., those given in Table 3, page 18 of NUREC-0654/ FEMA-REP-1, Rev.1) and gross radioactivity measurements. Provisions shall be made for estimating integrated dose from the projected and actual dose rates and for comparing these estimates with the protective action guides. The detailed provisions shall be l described in separate procedures, i

C;1TERI A/UTIL.'TY OFFSITE PLANS 15 11/06/87

Oraft

2. 1.* . Arrangements to locate and track the airborne radioactive plume shall be made, using :Mh;r e,- t:S Federal .aavof f site response organization resources. AA d

d N,

.)

f i

i CRITERI A/ UTILITY OFFSITE PLANS 16 11/06/87

Oraft K. Radiological Exposure Control Planning Standard Means for controlling radiological exposures, in an emergency, are established for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides.

Evaluation Criteria

3. a. The offsite response organization shall make provision for 24-hour-per-day capability to determine the doses received by emergency personnel involved in any nuclear accident, including volunteers.

They shall also make provisions for distribution of dosimeters, both self-reading and permanent record devices.

b. The offsite response organization shall ensure that dosimeters are read at appropriate frequencies and provide for maintaining dose re:ords for emergency workers involved in any nu: lear accident.

4 The off site response organization shall establish the decision chain for authorizing ettergency workers to incur exposures in excess of the EPA General Public Protective Action Guides (i.e., EPA PAGs for emergency workers and lifesaving activities).

5. a. The of fsite response organization. =r :pprepri;' , shall specify action. levels f or aew. mining the need for decontamination,
b. The offsite response organization, me =m:pri:'A shall establish the means for radiological decontamination of 6mergency personnel wounds, supplies, instruments and equipment, and for waste disposal.

CRITERIA / UTILITY OFFSITE PLANS 21 11/06/87  !

  • 1 l

i

Oraft M. Recevery anc Reentry Planning and Postaccident Operations Planning Standard General plans for recovery and reentry are developed.

Evaluation Criteria

1. The offsite response organization -- '"

shall develop general plans and procedures for reentry and recovery and describe the means by which decisions to relax protective measures (e.g., allow reentry into an evacuated area) are reached. This process should consider both existing and potential conditions.

M

3. The offsite plan shall specify means for informing members of theAoffsite response organizations that a recovery operation is to be initiated, and -- -

of any changes in the organizational structure that may occur.

4 The ef f site plan shall establish a method for periodically estimating total pcpulation exposure.

4 CRITERIA /UTillTY OFFSITE PLANS 23 11/06/87

Oraft

  • .. Excrcises crd Drills F'anning Standard Periodic exercises are (will be) conducted to evaluate major portions of emer-gency response capabilities, periodic drills are (will be) conducted to cevelop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.

Evaluation Criteria

1. a. An exercise is an event that tests the integrated capability and a major portion of the basic elements existing within emergency pre-paredness plans and organizations. The emergency preparedness exercise shall simulate an emergency that results in offsite radio-logical releases which will require response by offsite response organizatio'ns. Exercises shall be conducted as set forth in NRC and FEMA rules,
b. A a. exercise shall include mobilization of offsite response organi-zation resources adequate to verify the capability to respond to an a: cide t scenario requiring response. This includes the demonstration c fG.4 6 W,;;# [tjCM capabilities to interface with non-participating State and ,

C f).*~= MW WM) local government, but does not,the use of stand, ins for the antic- >

ipated State and local response e offsite response organization shall provide for a critique of the biennial exercise by Federal and offsite response organization observers / evaluators. The scenario shall be varied from exercise to exercise such that all major elements of the plans and preparedness organizations are tested within a six-year period. Each organization shall make provisions to start an exercise between 6:00 p.m. and 4:00 a.m. Exercises shall be conducted during different seasons of the year. At least one exercise shall be unannounced.

2. A drill is a supervised instruction period aimed at testing, developing and maintaining skills in a particular operation. A drill is often a CRITERIA / UTILITY OFFSITE PLANS 24 11/06/87

. , Oraft hN to evaluate the ability of organizations to respond as n!hd hr tii the l

offsite plan. The critique shall be conducted as soon as practicable after the exercise, and a formal evaluation shall result from the critique.

5. The offsite response organization shall establish means for evaluating observer and participant comments on areas needing improvement, including emergency plan procedural changes, and for assigning responsibility for implementing corrective actions. The offsite response organization shall establish management control used to ensure that corrective actions are implemented.
4. The offsite response organization shall attempt to involve the non participating x State and local government in the exercises and drills, but their participation is not required.

CRITERIA / UTILITY OFFSITE PLANS 27 11/06/87 J

9 NOTICE l i

FEDERAL EMERGENCY MANAGDER AGENCY NUC12AR REGUIATORY OCtt41SSION Interim-Use Docment: Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (Criteria for Utility Offsite Plaming and Preparedness)

The Nuclear Regulatory Conraission (NRC) and the Federal Emergency Management Agency (FEMA) have jointly developed an interim-use document entitled:

Criteria for Preparation and Evaluation of Radiological Emergency Response

) Plans and Preparedness in Support of Nuclear Poser Plants (Criteria for Utility

, Offsite Planning and Preparedness). The document has been published as Suppleent 1 to NUREG-06%/FHiA-REP-1, Rev.1. The guidance contained in this

! document is to be used for the developraent, review and evaluation of offsite utility radiological emergency planning and preparedness for accidents at l

comercial nuclear power plants. It applies to situations in which State and/or local governments decline to participate in the planning and j preparedness process for such accidents. This document is available for interim use, public review and ums=nt.

While this document contains changes and additions to the evaluation criteria l of NUREG-06%/FD4A-REP-1, Rev.1, no changes have been made to its 16 planning standards. The existing evaluatim criteria have been modified to address utility-developed compensatory measures resulting from the non-participation of State and/or local governments in energency plaming and preparedness.

4YdTNO1T/

~

3d gg, f

"One free copy, to the extent of available supplv, is obtainable by writing to:

Document Control Branch, Distribution Section, Office of Administration and Resources Manageaent, U.S. Nuclear Regulatory Comission, Washington, D. C.

20555.

Coerents should be sent by (90 days from the date of pubitcation) to: David Meyer, Chief, Rules and Procedures Branch, Mail Stop 4000 tUBB, Washington, D.C. 20555. Coments may be sent throuah the mail or hand-carried to this address between the hours of 7:30 a.m. to 4: 15 p.m.

For further infor;ation, contact: Marshall E. Sanders, Chief, Program Development branch, Technological Hazards Division, Federal Emergency Management Agency, 500 C Street, S.W. , Washington, D. C. 20472 (telephone: 202-646-2861); or David B. Matthews, Chief, Emergency Preparedness Branch, Nuclear Regulatory Comission, Washington, D. C. 20555 (telephone: 301-492-9647).

Datedthis!

day of h ,1987, at Washington, D.C.

~'

/.

- , w(I Yi /,

-l w wf Frank J. Congsl, Director Division of' Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission

$Y Richard W. Krinn ~ .= _ _ J Assistant Associate Director Office of Natural and Technological Hazards State and local Programs and Support Federal Energmcy Managanent Agency

M/t 1/87 For Comment TABLE OF CONTENTS Page I. Introduction A. Purpose 1

8. Interim Use of Document 1 C. Authorities 1 D. Assumptions 2

E. Scope 2

F. Definitions 3 G. Summary of Changes 3 II. Planning Standards and Evaluation Criteria A. Assignment of Responsibilty (Organization Control) 5 B. Onsite Emergency Organization 7 C. Emergency Response Support and Resources 7 D. Emergency Classification System 9 E. Notification Methods and Procedures 10 F. Emergency Communications 13 G. Public Education and Information 14 H. Emergency Facility and Equipment 16 I. Accident Assessment 17 J. Protectise Response 18 K. Radiological Exposure Control 21 L. Medical and Public Health Support 22 M. Recovery and Reentry Planning and Post-accident Operations 23 N. Exercises and Orills 24

0. Radiological Emergency Response Training 27 P. Responsibility for the Planning Effort: Development, Periodic Review and Distribution of Emergency Plans 29 i

Wr ,

For Comment 4

CRITERIA FOR UTILITY OFFSITE PLANNING AND PREPAREDNESS I. INTRODUCTION A. Purpose The Nuclear Regulatory Commission (NRC) and the Federal Emergency Manage-ment Agency (FEMA) have added a supplemen to NUREG-0654/ FEMA-rep-1, Rev.

1 that provides guidance for the development, review and evaluat'on of utility offsite radiological emergency response planning and preparedness for those situations in which State and/or local governments decline to participate in emergency planning.

B. Interim Use of Document This cocument has been developed for interim use in reviewing and evaluat-ing utility prepared offsite emergency plans and preparedness. This interim-use document is intended to be used with Section I and Appendices 1-5 of the existing NUREG-0654/ FEMA-REP-1, Rev. 1. A notice has been pro-vided in the Federal Register to announce the availability of this docu-ment and to invite public review and comment.* Subsequent to the receipt of comments, this document will be issued in final. Except where specifically mndified, the existing licensee-only evaluation criteria of the current Section II are not affected by this document. For those situations in which State and/or local governments are participating in tl.e eiergency planning process, the existing NUREG-0654/ FEMA-REP-1, Rev. 1 evaluatior, criteria will apply.

C. Authorities ,

This document is intendt to facilitate the implementation of the changes to 10 CFR Part 50.47; ;... :91 10 CFR Part 50, Appendix E Section IV.F of the NRC regulations cates . ' der 29,1987 (52FR42078) dealing with the following: "Evalv. fon of tbt .equacy of Off-Site Emergency Planning for Nuclear Power Plan'< at the Ope eting License Review Stage Where State and/or Local Goverr ,cnts Decline ,o Participate in Off-Site Emergency Planning." It is co. s: stent wit the provisions of the FEMA /NRC Memoran-dum of Understanding de.ed Aprit .S, 1985, wherein the parties agreed to evaluate plans prepared o ""'ities on behalf of State and local governments.

'The comment period expires on about February 29, 1988. Comments may be sent to David Meyer, Chief, Program Procedures Branch, Mail Stop - 4000 MNBB, Washington 0.C. 20555. Comments may be sent through the mail or hand-carried to this address between the hours of 7:30 a.m. and 4:15 p.m.

1

For Comment O. ' Assumptions The following NRC/ FEM' assumptions are used for the development, review and' evaluation of utility offsite plans and preparedness.

1. In an actual radiological emergency, State and local officials that have declined to participate'in emergency planning will:
a. Exercise their best efforts to protect the health and safety of the public;
b. Cooperate with the utility and follow the utility offsite plan; and
c. Have the resources sufficient to implement those portions of the utility offsite plan where State and local response is necessary.

Although it is assumed that non participating State and local organizations viil respond and follow the utility's off site plan, it is not assumed that these organizations will be as familiar with the plan as if they had par-ticipated in the planning process and exercised with the utility. There-fore, the utility's offsite response plan and the offsite response organi-zation will provide compensating actions throu deal with the coordination of inforn.ation and'gh the usewith resources of liaisons State andto local governments and to provide advice and assistance to responding State and .ocal governments in implementing their assigned roles and func-tions under the utility's of f site response plan.

E. Scope In developing this document, the planning standards of NUREG-0654/ FEM- i REP-1, Rev. 1 have not been changed and they apply to the offsite response  ;

organization defined below. This complies with the NRC rule change cited i in C. above. The guidance will be used for the development, review and evaluation of offsite emergency plans and preparedness in which State and/or local governments decline to participate in emergency planning and '

preparedness. The planning standards are the same as those used to eval-uate licensee, State and local plans and preparedness. The evaluation criteria have been modified with due allowance for the non participation of State and local governments and for the compensatory measures that

' must be proposed, developed and implemented by the utility. The utility offsite plans and oreparedness will be expected to account for the vary-ing degrees of participation that the utility is able to gain from State and local organizations during the planning process; and the resources to ,

implement the offsite plan must be identified and committed by the  !

utility and by State and local governments participating in the planning process. The appropriate FEM guidance memoranda, policy memoranda and rep documents (e.g., rep-2,10,12) will be applied to define the condi-tions of adequacy and inadequacy of emergency plans and preparedness for specific evaluation criteria. The numbering pattern for the evaluation criteria in this document is the same as that used in the existing Sec-tion II of NUREG-0654/ FEM-FEp-1, Rey, 1. Therefore, numbers that apply to licensee-only evaluation criteria are missing and additional criteria have been assigned new numbers.

2

For Comment F. Definitions The following definitions apply to the use of this document.

1. Offsite Response Organization (ORO): The utility offsite emergency response organization along with other participating voluntary and private organizations, and local, State and Federal governments engaging in the development of offsite emergency plans and prepared-ness for a nuclear power plant.
2. Nonparticipating Organization: Those organizations including State and local governments that decline to participate in emergency plan-ning and preparedness for a nuclear power plant.

G. Summary of Changes The following is a summary of the changes to the evaluation etiteria of NUREG-0654/ FEMA-REP-1, Rev. 1.

1. The concept of "offsite response organization" is adopted and defined.

Throughout the revised evaluation criteria "offsite response organiza-tion" replaces references to State and local governments.

2. In addition, evaluation criteria were modified or added to compensate for lack of participation by State and local governments in the planning process, for these functions:
a. Identification of the functions which require State and local authorization before implementing (A.2.a.).
b. Provision of additional personnel to advise and assist State and local officials in an emergency (C.5.).
c. Provision for advising State and local officials on emergency actions to be taken (0.4., J.10 f.).
d. Provision for coordinating emerger.cy messages with State and local governments (E.8.).
e. Provision for communications with non participating State and local emergency operations facilities (F.1.).
f. Provision for public information describing the role of the offsite response organization vs. the State and local organiza-tions during the emergency (G.1.e.).
g. Establishment of an emergency operations center for use in directing and controlling offsite response functions (H.3.).
h. Offsite response organization shall have the administrative and physical means (even though they might not have the responsi-bility) for activating the alert and notification system (E.6.

and J.9.).

3

For Comment

i. Recommendation or the use of potassium iodide (KI) for the gen-eral public (J.10.f.)

J. Provision for encouraging participation in exercises and drills by State and local governments but not requiring it (N.2.a. and N.6.).

k. Provision of training to persons in the utility's offsite response organization who will be responders (0.4.k.).
1. Provision for offering training to non participating State and local governments and other organizations (0.6.).
m. Provision for providing copies of the offsite plan and its revisions to non participating State and local government entities with which the offsite response organi:ation identifies interfaces in its offsite plan (P.11).

4

For Comment II. PLANNING STANDARDS AND EVALUATION CRITERIA A. Assignment of Responsibility (Oraanization Control}

Planning Standard Primary responsibilities for emergency response by she nuclear facility licensee, and by State and local organizations within the Emergency Plan-ning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

Evaluation Criteria

1. a. The offsite plan shall identify the elements of the offsite response organization for Emergency Planning Zones (see Appendix 5 of NUREG-0654/ FEMA-REP-1, Rev.1). 2
b. The offsite response organization shall specify its concept of operations, and its relationship +o the total ef fort. The con-capt of operation will explain his the offsite response organi-zation will function with non parsicipating State and local governments, and will specify the various modes of operation,
c. The offsite plan shall illustrate these interrelationships in a block diageam. This diagram will define the roles for the off-i site response organization and non participating State and local governments, and identify the lead interfaces,
d. The offsite response organization shall identify a specific individual by title who shall be in charge of the emergency response.
e. The offsite response organization shall provide for 24-hour per day emergency response, including 24-hour per day staf fing of communications links.
2. a. The offsite response organization shall specify the functions and responsibilities for major elements and key individuals by title, of emergency response, including the following: Command and Control, Alerting and Notification, Communications, Public Information, Accident Assessment, Public Health and Sanitation, Social Services, Fire and Rescue, Traffic Control, Emergency Medical Services, Law Enforcement Transportation, Protective Response (including authority to request Federal assistance and to initiate other protective actions), and Radiological Exposure 2Of fsite response organization is defined as the utility offsite emergency response organization along with other participating voluntary and private organizations, and local, State and Federal governments engaging in the development of offsite emergency plans for a nuclear power plant.

5

For Comment Control. The description of these functions shall include a clear and concise sumary such as a table of primary and support responsibilities using the agtney as one axis, and the function as the other. This description shall specify those functions which such as:

require State and local authorization before implementing,

1. Directing traf fic; ii. Blocking roadyays, erecting barriers in roadways and channeling traffic; 111. Posting traffic signs on roadways; iv. Removing obstructions from public roadways, including tow-ing vehicles;
v. Activating sirens and directing the broadcasting of EBS messages; vi. Making decisions and recommendations to the public concern-ing protective actions for the plume exposure pathway; vii. Making decisions and recommendations to the public concern-ing protective actions for the ingestion expoture pathway; viii. Making decisions and recommendations to the public concern-ing recovery and reentry; ix. Dispensing fuel from tank trucks to automobiles along roadsides;
x. Performing access control at an EOC, relocation centers and the EPZ perimeters; and The offsite plan shall also identify similar functions and responsibilities and interfaces for an anticipated State and local response to an emergency.
b. The offsite plan shall contain where applicable (by reference to specific acts, codes or statutes) the legal basis for such avt,horities including those that reserve functions to State and local governments.

3.

The offsite plan shall include written agreements referring to the concept of operations developed between Federal agencies, the offsite response organization, and other support organizations having an emergency response role within the Emergency Planning Zones. The agreements shall identify the emergency measures to be provided and the mutually acceptable criteria for their implementation, and spe-cify the arrangements for exchange of information. These agreements I may be provided in an appendix to the offsite plan or the offsite plan itself may contain descriptions of these matters and a signature page in the of fsite plan may serve to verify the agreements. The signature page format is appropriate for organizations where response functions are covered by laws, regulations or executive orders where separate written agreements are not necessary.

4. The offsite response organization shall be capable of continuous (24-hour) operations for a protracted period. The individual in the i

of fsite response organization who will be responsible for assuring continuity of resources (technical, administrative, and materiel) l shall be specified by title.

6 t

t

For Comment B. Onsite Emergency Organization (Not Applicable)

C. Emergency Response Support and Resources Planning Standard Arrangements for requesting and effectively using assistance resources have been made, arrangements to accommodate State and local staff at the licensee's near-site Emergency Operations Facility have been made, and other organizations capable of augmenting the planned response have been identified.

Evaluation Criteria

1. The Federal government maintains in-depth capability to assist li-censees, States and local governments through the Federal Radiolog-ical Emergency Response Plan. Each offsite response organization and licensee shall make provisions for incorporating the Federal response capability into its operation plan, including the following:
a. specific persons by title authorized to request Federal assist-ance; see A.1.d., A.2.a.;

b, specific Federal resources expected, including expected times of arrival at specific nuclear facility sites; and

c. specific licensee and offsite response organization resources available to support the Federal response, e.g. , air fields, command posts, telephone lines, radio frequencies and tele-communications c'nters.
2. a. The offsite response organization may dispatch representatives is,the licensee's near-site Emergency Operations Facility.

(Technical analysis representatives at the near-site EOF are preferred.)

b. The licensee shall prepare for the dispatch of representatives to the offsite response organization's emergency operations center and to principal emergency operations centers of partici-pating and non participating governments,
c. The offsite response organization shall prepare for the dispatch of a representative to principal offsite governmental emergency operations centers.
3. The offsite response organization shall identify radiological labora-tories and their general capabilities and expected availability to provide radiological monitoring and analyses tryices which can be used in an emergency.
4. The offsite response organization shall identify nuclear and other facilities, organizations or individuals which can be relied upon in an emergency to provide assistance. Such assistance shall be iden-tified and supported by appropriate letters of agreement.

7

.- - - . . .= . _ . . . . .- .-. -.~. . _ . . . _ . . . . _ _ _ . -

For Comment

5. The offsite response organization shall provide personnel to advise and assist State and local officials in implementing those portions of the of fsite plan where State or local response is identified.

i l

4 1

1 1

4 f

I l

l l

1 1

8 1

For Comment D. Emergency Classification System Planning Standard A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.

Evaluation Criteria

3. The offsite response organization shall establish an emergency classi-fication and emergency action level scheme consistent with that established by the facility licensee.
4. The offsite response organ,Jat.ca should have procedures in place that provide for implementing eme,genev actions and that provide for advising State and local officials on emergency actions to be taken which are consistent with the emergency actions recommended by the nuclear facility licensee, taking into account local offsite condi-tions that exist at the time of the emergency.

9

For Comment E. Notification Methods and Procedures planning Standard Procedures have been established for notification by the licensee of State and local response organizations and for notification of emergency per-sonnel by all response organizations; the content of initial and followup messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established.

Evaluation Criteria

1. The offsite response organization shall establish procedures which describe the bases for notification cf all response organizations consistent with the emergency classification and action level scheme set forth in Appendix 1 of NUREG-0654/ FEMA-REP-1, Rev. 1. These procedures shall . include means for verification of messages. The specific details of verification need not be included in the offsite plan.
2. The offsite response organization shall establish procedures for alerting, notifying, and mobilizing emergency response personnel.
3. The licensee in conjunction with the offsite response organization shall establish the content of the initial emergency messages to be sent from the plant. These measures shall contain information about the class of emergency, whether a release is taking place, poten-tially a ffected population and areas, and whether protective measures may be necessary.
4. Each licensee shall m ti provisions for followup messages from the facility to the offsite response nrganization (and to offsite author-ities where possible) which shall contain the following information if it is known and appropriate:
a. location of incident and name and telephone number (or communi-cations channel identification) of caller;
b. date/ time of incident;
c. class of emergency;
d. type of actual or projected release (airborne, waterborne, surface spill), and estimated duration / impact times;
e. estimate of quantity of radioactive material released or being released and the points and height of releases;
f. chemical and physical form of released material, including estimates of the relative quantities and concentration of noble gases, iodines and particulates; 10

. For Coment

g. meteorological conditions at appropriate levels (wind speed, direction (to and from), indicator of stability, precipitation, if any);
h. actual or projected dose rates at the boundary; projected inte-grated dose at site boundary;
i. projected dose rates and integrated dose at the projected peak 4 and at 2, 5 and 10 miles, including sector' O affected;
j. estimate of any surface radioactive contamination inplant, onsite or offsite;
k. licensee emergency response actions underway;
1. recommended emergency actions, including protective measures; m, request for any needed onsite support by offsite organizations; and
n. prognosis for worsening or termination of event based on plant information.
5. The offsite response organization shall establish a system for dis-seminating to the public appropriate information contained in initial and followup messages received from the licensee including the appro-priate notification to appropriate broadcast media, e.g., the Emergency Broadcast System (EBS).
6. The offsite response organization shall establish administrative and phys', cal means, and the time required for notifying and providing pro pt instructions to the public within the plume exposure pathway Ev.rgency Planning Zone (see Appendix 3 of NUREG-0654/ FEMA-REP-1, key. 1 And FEMA-REP-10). It shall be the licensee's responsibility to demonstrate that such means exist, regardless of who implements this requirement. The offsite response organization shall have the administrative and physical means to activate the system.
7. The offsite response organization shall provide written messages intended for the public, consistent with the licensee's classifica-tion scheme. In particular, draft messages to the public giving instructions with regard to specific protective actions to be taken by occupants of affected areas shall be prepared and included as part of the offsite plans. The prescripted messages should address the various conditions such as the delegation of authority by the State and local governments to the offsite response organization to issue prompt instructions. Such messages should include the appropriate i aspects of sheltering, e.g., handkerchief over mouth, thyroid block-ing or evacuation. The role of the licensee is to provide supporting information for the messages. For ad hoc respiratory protection see "Respiratory Protective Devices Manual" American Industrial Hygiene Associat,1on, 1963 pp. 123-126.

11

For Coment

8. There shall be provisions for coordinating emergency messages with participating and non participating State and local governrtents.

12 4

For Comment F. Emergency Communications planning Standard provisions exist for prompt communications among principal response organiza-tions to emergency personnel and to the public.

Evaluation Criteria

1. The communication plans for emergencies shall include organizational titles and alternates for both ends of the conmunication links. Reliable primary and backup means of communication for the utility and the offsite response organization shall be established. The utility and the offsite response organization shall establish the capability to communicate with non participating State and local governments sia normal emergency telephone number (s) (e.g., 911) and via one other backup mode such as the ability to transmit via existing emergency radio frequencies. Each offsite plan shall include:
a. provision for 24-hour per day notification +.o and activation of the offsite response organization's emergency r(sponse network; and at a minimum, a telephone link and alternate, including 24-hour per day manning of communication links that initiate emergency response actions;
b. provision for communications with contiguous States and local govern-ments within the Emergency Planning Zones;
c. provision for communications as needed with Federal emergency response organizations;
d. provision for communications between the nucleaa facility and the licensea's near-site Emergency Operations Facility, offsite response organization's emergency operations centers, anc radiological monitor-ing teams; e, provision for alerting or activating emergency personnel in each response organization;
2. The offsite response organization shall ensure that a coordinated communication link for fixed and mobile medical support facilities exists.
3. The offsite response organization shall conduct periodic testing of the entire emergency communications svstem (ses evaluation criteria H.10, N.2.a and Appendix 3 of NUREG-0654/ FEMA-REP-1, Rev. 1).

13

For Comment G. public Edu:ation and Information Planning Standard Information is made available to the public on a periodic basis on how they will be notified and what their initial actions shall be in an emergency (e.g., listening to a local broadcast station and remaining indoors), the principal points of contact with the news media for dissemination of informa-tion during an emergency (including the physical location or locations) are established in sdvance, and procedures for coordinated dissemination of infor-mation to the public are established.

Evaluation Criteria

1. The offsite response organization shall provide a coordinated periodic (at least annually) dissemination of information to the public regarding how they will be notified and what their actions should be in an emer-gency. This information shall include, but not necessarily be limited to:
a. educational information on radiation;
b. contact for additional information;
c. protective measures, e.g., evacuation routes and relocation centers, sheltering, respiratory protection, radioprotective drugs;
d. .special needs of the handicapped; and
e. special steps to be taken to describe the role of the of'- e-sponse organization vs. the State and local organization. the emergency.

^

Means for accomplishing this dissemination may include, but are not necessarily limited to: information in the telephone book; posting in public areas; and publications distributed on an annual basis.

2. Th public information program shall provide the permanent and transient adult population within the plume exposure EPZ an adequate opportunity to
become aware of the information annually. The programs should include
provision for written material that is likely to be available in a resi-dence during an emergency. Updated information shall be disseminated at least annually. Signs or other measures (e.g., decals, posted notices, or other means, placed in hotels, motels, gasoline stations and phone booths) shall also be used to disseminate to any transient population within the plume exposure pathway EPZ appropriate information that will be helpful if an emergency or accident occurs. Such notices should refer the transient to the telephone directory or other source of local emergency information and guide the visitor to appropriate radio and television frequencies.
3. The of fsite response organizatien shall designate the points of contact and physical locations for use by news media during an emergency. This should include provisions for accommodating State and local government public information personnel assigned a role under the offsite plan.

14

For Comment

4. a. The offsite response organization shall designate a spokesperson who shall have access to all necessary information. ,
b. The offsite response organization shall establish arrangements for timely exchange of information among designated spokespersons.
c. The offsite response organization shall establish coordinated arrangements for dealing with rumors.
5. The offsite response organization shall conduct coordinated programs at least annually to acquaint news media with the offsite emergency plans, information concerning radiation, and points of contact (see G.I.e) for release of public information in an emergency.

l 1

15

For Comment H. Emergency Facilities and Equipment Planning Standard Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

Evaluation Criteria

3. The offsite responst organization shall establish an emergency opera-tions center for use in directing and controlling offsite response functions.
4. The offsite response organization shall provide for timely activation and staffing of the facilities and centers described in the offsite plan.
7. The offsite response organization, where appropriate, shall provide for offsite radiological monitoring equipment in the vicinity of the nuclear facility.
10. The offsite response organization shall make provisions to inspect, inventory and operationally check emergency equipment / instruments at least once each calendar quarter and af ter each use. There shall be sufficient reserves of instruments / equipment to replace those which are removed from emergency kits for calibration or repair. Calibration of equipment shall be at intervals recommended by the supplier of the equipment.
11. The offsite plan shall, in an appendix, include identification of emer-gency kits by general category (protective equipment, communications equipment, radiological monitoring equipment and emergency supplies).
12. The of fsite response organization shall establish a central point (pref-erably assocjated with the licensee's near-site Emergency Operations Facility), for the receipt and analysis of all field monitoring data and coordination of sample media.

16

For Comment I. Accident Assessment planning Standard Adequate methods, systems and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

Evaluation Criteria

7. The offsite response organization shall describe the capability and re-sources for field monitoring within the plume exposure Emergency Planning Zone which are an intrinsic part of the concept of operations for the facility.
8. The offsite response organization, where appropriate, shall provide methods, equipment and expertise to make rapid assessments of the actual or potential magnitude and locations of any radiological hazards through liquid Or gaseous release pathways. This shall include activation, noti-ficatic.. means, field team composition, transportation, communication, monitoring equipment and estimated deployment times.
9. The of fsite response organization shall have a capability to detect and measure radiciodine concentrations in air in the plume exposure EPZ as low as 10 ' pCi/cc (microcuries per cubic cent.imeter) under field condi-tions. Interference from the presence of noble gas and background radia-tion shall not decrease the stated minimum detectable activity.
10. The offsite response organization shall establish means for relating the various measured parameters (e.g., contamination levels, water and air activity levels) to dose rates for key isotopes (i.e., those given in Table 3, page 1.8 of NUREG-0654/ FEMA-REP-1, Rev.1) and gross radioactivity measurements, Provisions shall be made for estimating integrated dose from the prcjected and actual dose rates and for comparing these estimates with the protective action guides. The detailed provisions shall be described in separate procedures.
11. Arrangements to locate and track the airborne radioactive plume shall be made, using either or both Federal and offsite response organization resources.

17 M

For Comment J. Protective Response Planning Standard A range of protective actions have been developed for the plume exposure path-way EPZ for emergency workers and the public. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure path-way EPZ appropriate to the locale have been developed.

s Evaluation Criteria J

2. Each licensee and offsite response organization shall make provisicns for evacuation routes and transportation for onsite individuals to some suit-able offsite location, including alternatives for inclement weather, high traffic density and specific radiological conditions.
9. The offsite response organization shall establish a capability for imple-menting protective measures based upon protective action guides and other criteria. The offsite response organization shall describe the means for recommending protective actions to the public, for activating the alert and notififcation system, and for notifying the public of protective ac-l tion recommendations. This shall be consistent with the recommendations I of EPA regarding exposure resulting from passage of radioactive airborne l plumes (EPA-520/1-75-001), and with those of DHHS/FDA regarding radioac-  !

, tive contamination of human food and animal feeds as published in the l Federal Register on October 22, 1982 (47 FR 47073).

10. The offsite response organization's plans to implement protective measures for the plume exposure pathway shall include:
a. Maps showing evacuation routes, evacuation areas, preselected radio-logical, sampling and monitoring points, relocation centers in host areas, and shelter areas (identification of radiological sampling and monitoring points shall include the designations in Table J-1 of NUREG-0654/ FEMA-REP-1, Rev. 1 or an equivalent uniform system describ.d in the offsite plan);
b. Maps showing population distribution around the nuclear facility.

This shall be by evacuation areas (licensees shall also present the f information in a sector format);

c. Means for notifying all segments of the transient and resident population;
d. Means for protecting those persons whose mobility may be impaired due to such factors as institutional or other confinement. These means shall include notification, support and assistance in implement-ing protective measures where appropriate;
e. Provisions for the use of radioprotective drugs, particularly for emergency workers and institutionalized persons within the plume exposure EPZ whose immediate evacuation may be infeasible or very difficult, including quantities, storage, and means of distribution; 18

For Comment

f. The offsite response organization's plans should include the method by which decisions by the State Health Department for administering radioprotective drugs to the general population can be made during an emergency. The plan shall adopt the method used by the State where such a method is available. The plans shall provide for advising State Health Departments regarding such decisions; and the predeter-mined condition under which such drugs may be used by offsite emergency workers;'
g. Means of relocation;
h. Relocation centers in host areas which are at least 5 miles, and preferably 10 miles, beyond the boundaries of the plume exposure emergency planning zone (see J.12.);
i. Projected traffic capacities of evacuation routes under emergency conditions;
j. Control of access to evacuated areas and organization responsibili-ties for such control;
k. Identification of and means for dealing with potential impediments (e.g., seasonal impassability of roads) to use of evacuation routes, and contingency measures;
1. Time estimates for evacuation of various sectors and distances based on a dynamic analysis (time-motion study under various conditions) for the plume exposure pathway emergency planning zone (see Appen-dix 4, NUREG-0654/ FEMA-REP-1, Rev. 1); and t
m. The bases for the choice of recommended protective actions from the plume exposure pathway during emergency conditions. This shall in-clude enected local protection afforded in residential units or other shelter for direct and inhalation exposure, as well as evacua-tion time estimates.8 4

'See DHHS Federal Register notice of July 24, 1985 (50 FR 30258) entitled Federal Policy on Distribution of Potassium Iodide Around Nuclear Power Sites for Use as a Thyroid Blocking Agent.

  • The following reports may be considered in determining protection afforded .

(1) "Public Protection Strategies for Potential Nuclear Reactor Accidents" Sheltering Concepts with Existing Public and Private Structures" (SAND 77-1725), Sandia Laboratory.

(2) "Examination of Offsite Radiological Emergency Measures for Nuclear Reactor Accidents Involving Core Molt" (SAND 78-0454), Sardia Laboratory.

(3) "Protective Action Evaluation Part II, Evacuation and Sheltering as Pro-tective Actions Against Nuclear Accidents Involving Gaseous Releases" (EPA 520/1-78-0018). U.S. Environmental Protection Agency.

19

For Comment

11. The offsite response organization shall specify the protective measures to be used for the ingestion pathway, including the methods for protect-ing the public from consumption of contaminated foodstuffs. This shall include criteria for deciding whether dairy animals shall be put on stored feed. The offsite plan shall identify procedures for detecting contamination, for estimating the dose commitment consequences of uncon-trolled ingestion, and for imposing protection procedures such as impound-ment, decontamination, processing, decay, product diversion, and preserva-tion. Maps for recording survey and monitoring data, key land use data (e.g., farming), dairies, food processing plants, water sheds, water supply intake and treatment plants and reservoirs shall be maintained. Provisions for maps showing detailed crop information may be by including reference to their availability and location and a plan for their use. The maps shall start at the facility and include all of the 50-mile ingestion pathway EPZ.

Up-to-date lists of the name and location of all facilities which regularly process milk products and other large amounts of food or agricultural products originating in the ingestion pathway Emergency Planning Zone, but located elsewhere, shall be maintained.

12. The offsite response organization shall describe the means for register-ing and monitoring of evacuees at relocation centers in host areas. The personnel and equipment available shall be capable of monitoring within about a 12-hour period all residents and transients in the plume exposure EPZ arriving at relocation centess.

1 20

For Comment K. Radiological Exposure Control Planning Standard Means for controlling radiological exposures, in an emergency, are established for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides.

Evaluation Criteria

3. a. The offsite response organization shall make provision for 24-hour-per-day capability to determine the doses received by emergency personnel involved in any nuclear accident, including volunteers.

They shall also make provisions for distribution of dosimeters, both self-reading and permanent record devices,

b. The offsite response organization shall ensure that dosimeters are read at appropriate frequencies and provide for maintaining dose records for emergency workers involved in any nuclear accident.

4 The offsite response organization shall establish the decision chain for authori:ing emergency workers to incur exposures in excess of the EPA General Public Protective Action Guides (i.e., EPA PAGs for emergency workers and lifesaving activities).

5, a. The offsite response organization, as appropriate, shall specify action levels for determining the need for decontamination.

b. The of f ite response organization, as appropriate, shall establish the means for radiological decontamination of emergency personnel wounds, supplies, instruments and equipment, and for waste disposal.

e p

21

For Comment L, Medical and public Health Support Planning Standard Arrangements are made for medical services for contaminated injured individuals.8 Evaluation Criteria

1. The offsite response organization shall arrange for local and backup hospital and medical services having the capability for evaluation of radiation exposure and uptake, including assurance that persons providing these services are adequately prepared to handle contaminated individuals,
3. The offsite response organization shall develop lists indicating the location of public, private and military hospitals and other emergency medical services facilities within the State or contiguous States con-sidered capable of providing rnedic.I support for any contaminated injured individual. The listing shall include the name, location, type of f acility and capacities and any special radiological capabilities. These emergency medical services should be able to radiologically monitor con-tamination personnel, and have facilities and trained personnel able to care for contaminated injured persons.

4 The offsite response organization shall arrange for transporting victims of radiological accidents to medical support facilities.

'The availability of an integrated emergency medical services system and a public health emergency plan serving the area in which the facility is located and, as a minimum, equivalent to the Public Health Service Guide for Developing Health Disaster Plans, 1974, and to the requirements of an emergency medical services system as outlined in the Emergency Medical Services System Act of 1973 (PL 93-154 a.nd amendments in 1979 PL 96-142), should be a part of and con-sistent with overall State or local disaster control plans and should be com-patible with the specific overall emergency response plans for the facility.

22

For Comment M. Recovery and Reentry planning and Postaccident Operations Planning Standard General plans for recovery and reentry are developed.

Evaluation Criteria

1. The offsite response organization, as appropriate, shall develop general plans and procedures for reentry and recovery and describe the means by which decisions to relax protective measures (e.g., allow reentry into an evacuated area) are reached. This process should consider both existing and potential conditions.
3. The offsite plan shall specify means for informing members of the offsite response organization that a recovery operation is to be initiated, and of Ony changes in the organizational structure that may occur.

4 The offsite plan shall establish a method for periodically estimating total population exposure.

i k

l 23

For Comment N. Exercises and Drills Planning Standard Periodic exercises are (will be) conducted to evaluate major portions of emer-gency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.

Evaluation Criteria

1. a. An exercise is an event that tests the integrated capability and a major portion of the basic elements existing within emergency pre-paredness plans and organizations. The emergency preparedness exercise shall simulate an emergency that results in offsite radio-logical releases which will require response by offsite response organizations.

Exercises shall be conducted as set forth in NRC and FEMA rules.

b. An exercise shall include mobilization of offsite response organi-zation resources adequate to verify the capability to respond to an accident scenario requiring response. This includes the demonstration of of f site response organization capabilities to interface with non-participating State and local government, but does not include the use of standins for the anticipated State and local response. The offsite response organization shall provide for a critique of the biennial exercise by Federal and offsite respense organization observers /

evaluators. The scenario shall be varied from exercise to exercise such that all major elements of the plans and preparedness organiza-tions are tested within a six year period. Each organization shall make provisions to start an exercise between 6:00 p.m. and 4:00 a.m.

Exercises shall be conducted during different seasons of the year. At least one exercise shall be unannounced.

2. A drill is a supervised instruction period aimed at testing, developing and maintaining skills in a particular operation. A drill is often a component of an exercise. A drill shall be supervised and evaluated by a qualified drill instructor. The offsite response organization shall conduct drills, in addition to the biennial exercise at the frequencies indicated below:
a. Communication Drills Communications between the licensee and the offsite response organiza-tion within the plume exposure pathway Emergency Planning Zone shall be tested monthly. Communications with Federal emergency response organizations and offsite response organizations within the ingestion pathway shall be tested quarterly. Communications between tne nuclear facility, offsite response organization's operations centers, and field assessment teams shall be tested annually. Communication drills shall also include the aspect of understanding the content of  !

messages. If practicable, attempts should be made to include non-participating organizations in the monthly communications drills. 1 I

24

for Comment

c. Medical Emergency Drills A medical emergency drill involving a simuiated contaminated individ-ual which contains provisions for participation by the local support services agencies (i.e., ambulance and offsite medical treatment facility) shall be conducted annually. The offsite portions of the medical drill may be performed as part of the required biennial exercise.
d. Radiological Monitoring Drills Plant environs and radiological monitoring drills (onsite and off-site) shall be conducted annually. These drills shall include collection ar.d analysis of all sample media (e.g., water, vegetation, soil and air). and provisions for communications and record keeping.

Where appropriate, local organizations shall participate.

e. H_ealth physics Orill Health Physics drills shall be conducted semi-annually which involve response to, and analysis of, simulated elevated airborne and liquid samples and direct radiation measurements in the environment.
3. The offsite response organization shall describe how exercises and drills are to be carried out to allow free play for decisionmaking and to meet the following objectives. Pending the development of exercise scenarios and exercise evaluation guidance by NRC and FEMA the scenarios for use in exercises and drills shall include but not be limited to the following:
a. The basic objective (s) of each drill and exercise and appropriate evaluation criteria;
b. The date"(s), time period, place (s) and participating organizations;
c. The simulated events;
d. A time schedule of real and simulated initiating events;
e. A narrative summary describing the conduct of the exercises or drills to include such things as simulated casualties, offsite fire department assistance, rescue of personnel, use of protective cloth-ing, deployment of radiological monitoring teams, and public infor-mation activities; and
f. A description of the arrangements for and advance materials to be provided to official observers.
4. Official observers from Federal government and the offsite response organization shall nbserve, evaluate, and critique the required exer-cises. A critique shall be scheduled at the conclusion of the exercise to evaluate the ability of organizations to respond as called for in the offsite plan. The critique shall be conducted as soon as practicable af ter the exercise, and a formal evaluation shall result from the critique.

25

For Comment

, a ,

5. The offsite response organization shall estt511sh means for evaluating observer and participant comments on areas needing improvement, including emergency plan procedural changes, and for assigning responsibility for implementing corrective actions. The offsite response organization shall establish nianagement control used to ensure that corrective i actions are impler.ented.
6. The offsite response organization shall attempt to involve the non-participating State and local government in the exercises and drills,  ;

but their participation is not required. J l

1 l

I 26

For Comment

+ ,

O. Radiological Emergency Response Training Planning Standard Radiological emergency response training is provided to those who may be called on to assist in an emergency.

Evaluation Criteria

1. The offsite response organization shall assure the training of appropri-ate individuals. The offsite response organization shall participate in and receive training. Where mutual aid agreements exist between local agencies such as fire, police and ambulance / rescue, the training shall also be offered to the other departments who are members of the mutual aid district.8

)

4 The offsite respc' e organization shall establish a training program for instructing and qualifying personnel who will implement radiological emer-gency response plans.8 The specialized initial training and periodic retraining programs (including the scope, nature and frequency) shall be provided in the following categories:

a. Directors or coordinators of the response organizations;
b. Personnel responsible for accident asses'sment;
c. Radiological monitoring teams and radiological analysis personnel;

' Training for hospital personnel, ambulance / rescue, police and fire department shall itici ide the procedures for notification, basic radiction protection, and their expected roles. For those local services support organizations who will enter the site, training shall also include site access procedures and the identity (by posjtion and title) of the individual in the onsite emergency l organization who will control the organizations support activities. Offsite emergency response support personnel should be provided with appropriate identi-fication cards where required.

81f the offsite response organization lacks the capability and resources to accomplish this training, they may look to the licensee and the Federal govern-ment (FEMA) for assistance in this training.

27

For Comment

. u '

d. Police, security and fire fighting personnel;
f. First aid and rescue personnel; ,
g. Local support services personnel including Civil Defense / Emergency Service personnel;
h. Medical support personnel; i

J. Personnel responsible for transmission of emergency information and instructions; and

k. Personnel responsible for interfacing with State and local responders.
5. The offsite response organization shall provide for the initial and annual retraining of personnel with emergency response responsibilities.
6. The offsite 'sponse organization shall offer training to non participating State and loc.) governments and other organizations. ,

^

f f

I i

i t

28 i

For Comment 3 .. ,

P. Responsibility for the planning Effort: Development. Periodic Review and Distribution of Emergency Plans planning Stan.dard Responsibilities for plan development and review and for distribution of emer-gency plans are established, and planners are properly trained.

Evaluation Criteria

1. The of fsite response organization shall provide for the training of indi-viduals responsible for the offsite planning effort.
2. The offsite response organization shall identify by title the individual with the overall authority and responsibility for radiological emergency response planning.
3. The offsite response organization shall designate an Emergency Planning Coordinator with responsibility for the development and updating of emer-gency plans and coordination of these offsite plans with other response organizations.
4. The of fsite respor.se organization shall update its plan and agreements as needed, review and certify it to be current on an annual basis. The update shall take into account changes identified by drills and

) exercises.

5. The of fsite emergency response plans and approved changes to the plans shall be forwarded to all participating organizations and appropriate individuals with responsibility for implementation of the plans. Revised -

pages shall be dated and marked to show where changes have been made.

6. The offsite p,lan shall contain a detailed listing of supporting plans and their source.
7. The offsite plan shall contain as an appendix listing, by title, pro-cedures required to implement the offsite plan. The listing shall include the section(s) of the offsite plan to be implemented by each procedure.
8. The offsite plan shall contain a specific table of contents. Plans sub-mitted for review should be cross-referenced to these criteria.
10. The offsite response organization shall provide for updating telephone numbe*s in emergency procedures at least quarterly.
11. The offsite response organization shall provide copies of the offsite plan and its revisions to non participating State and local government entities where interfaces are identified in Planning Standard A.

29

. /2 9 2ld/o .

$pa n:;eq%,

+

UNITED $TATES y o 9, NUCLEAR REGULATORY COMMISSION 9 i

t, l wasmoTow o.c.mes k ....* / November 6, 1987 MEMORANDUM FOR: Robert M. Berr,ero, NMSS Thomas T. Martin, RI Denwood F. Ross, RES Joseph Scinto, OGC James H. Sniezek, NRR FROM: Edward L. Jordan, Chairman Committee to Review Generic Requirements

SUBJECT:

CRGR MEETING,NO. 124 - AGENDA MODIFICATION The Committee to Review Generic Requirements (CRGR) will meet on Thursday, November 12, 1987, 1-5 p.m. in Room 6110 MNBB. The agenda is as follows:

1-4 p.m. T. Novak will present for CRGR review proposed Amendments to 10 CFR Part 21, "Reporting of Defects and Noncompliance" and 10 CFR 50.55(e), "Reporting of Defects in Design and Construction."

(This enclosure was previously distributed to members via meno dated October 28,1987.)

> 4-5 p.m. F. Congel will brief the CRGR on the proposed evaluation criteria for review of offsite response organization emergency plans prepared by reactor licensees. The proposed evaluation criteria have been developed for implementing the revised Emergency Planning Rule reviewed by CRGR at Meeting No.107.

If a CRGR member cannot attend the meeting, it is his responsibility to assure that an alternate, who is a;; proved by the CRGR Chairman, attends the meeting.

Persons making presentations to the CRGR are responsible for (1) assuring that the information required for CRGR review is provided to the Committee (CRGR Charter - IV.B), (2) coordinating and presenting views of other offices, (3) as appropriate, assuring that other offices are represented during the presenta-tion, and (4) assuring that agenda modifications are coordinated with the CRGR

, contact (J. Conran X29855) and others involved with the presentation. Division Directors or higher management should attend meetings addressing agenda items under their purview.

In accordance with the ED0's March 29, 1984 memorandum to the Commission con-cerning "Forwarding of CRGR Documents to the Public Document Room (PDR)," the

_ ~

k ( l 11 ) (@ SS X; E Vl'

1 d 2-enclosure, which contains predecisional information, will not be released to the POR until the NRC has considered (in a public forum) or decided the matter addressed by the information, g

d rdan, Chairmah Commi e to Review Generic Req rements

Enclosure:

As stated cc w/ enclosures:

SECY V. Stello, Jr.

cc w/o enclosure:

Commission (5)

J. Lieberman J. Keppler W. McDone.ld Regional Administrators W. Parler T. Novak F. Ceagel D. Matthews mwm y

3

  • Draft -

4 EVALUATION CRITERIA FOR UTILITY OFFSITE PLANS Planning Standards and Evaluation Criteria A. Assignment of Responsibility (Organization Controli, Planning Standard Primary responsibilities for emergency response by the nuclear facility licensee, and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various sup-porting organizations have been specifically established, and each principal response organization has staff to respond and to augunt its initial response on a continuous basis.

Eva'ua tion Criteria

1. a. The offsite plan should identify the offsite response organization and ti.e State, local, Federal ana private sector organizations (in-cluding utilities), that may respond to an actual anersency,
b. The offsita response organization should specify its concept of operations, and its relationship to the total effort.
c. The offsite plan should 111ustrate these interrelationships in a block diagram.
d. The offsite response organization should identify a specific individ-ual by title who shall be in charge of the emergency response.

-s CRITERIA /VIILITY OFFSITE PLANS 1 10/07/87 m s f I f --

-r

' o Dra f t

e. The offsite response organization should proYide for 24-hour per day emergency response, including 24-hour per day manning of comunica-tions links.
2. a. The offsite response organization should specify the functions and responsibilities for major elements and key individuals by title, of emergency response, including the folicwing: Comand and Control, Alerting and Notification Communications, Pubite Information, Acci-dent Assessment, Public Health and Sanitation, Social Senices, Fire and Rescue, Traffic Control. Emergency Medical Services, Law Enforce-ment, Transportation, Protective Response (including authority to request Federal assistance and to initiate other protective actions),

and Radiological Exposure Control. The description of these functions should include a clear and concise sumary such as a table of primary and support responsibilities using the agency as one axis, and the function as the other. The plan should also identify similar func-tions and responsibilities for an anticipated State and local respor.se to an emergency. The plan should identify the interfaces between the offsite response orgar,ization and the State and local response organization.

b. The offsite plan shall contain (by reference to specific acts, codes or statutes) the legal bar.f s for such authorities.
3. The offsite plan should include written agreements referring to the con-cept of operations developed between Federal agencies, the offsite response organization, and other support organizations having an emer-gency response role within the Emergency Planning Zones. The agreements should identify the crargency measures to be proYided and the mutually acceptable criteria for their implementation, and specify the arrange-ments for exchange of infomation. These agreements nay be provided in an appendix to the plan or the plan itself may contain descriptions of these matters and a signature page in the plan ray serve to Yerify the agreements. The signature page fonrat is appropriate for organizations where response functions are covered by laws, regulations or executive orders where separate written agreements are not necassary.

CRITERIA /UTIllTY OFFSITE PLANS 2 10/07/87  ;

Draft 4.

The offsite response organization should be capable of continuous (24-hour) operations for a protracted period. - The individual in the offsite response organization who will be responsible for assuring continuity of resources (technical, administrative, and material) should be specified by title.

CRITERIA / UTILITY OFFSITE PLANS 3 10/07/87

Draft i

8. Onsite Emergency Organization (Not Applicable)

C. Emergency Response Support and Resources I 1

Planning Standard '

Arrangements for requesting and effectively using assistance resources have been made, arrangelnents to accom.mdate State and local staff at the licensee's I near-site Emergency Operations facility have been made, and other organiza-tions capable of augmenting the planned response have been identified.

Evaluation Criteria

1. The Federal government maintains in-depth capability to assist licensees, States and local governments through the Federal Radiological Monitoring and Assessment Plan. Each offsite response organization and ifcensee should make provisions for incorporating the Federal response capability into its operation plan, including the folicwing:
a. s spec fic persor.s by title duthorized to request Federal assistance; see A.1.d., A.2.3.
b. specific Tederal resources expected, including expected times of arrival at specific nuclear facility sites; and
c. specific licensee and offsite response o.ganization resources avail-able to support the Federal response, e.g., air fields, connand posts, telephone Ifnes, radio frequencies and telecomunications centers.
2. a. The offsite response organization mg dispatch representatives to the Ifeensee's near-site Emergency Operations Facility. (Technical analysis representatives at the near-site EOF are preferred.)

CRITERIA / UTILITY OFFSIT PLANS 4 10/07/87

Draft o .

b.

The offsite response organization should prepare for the dispatch of a representative to principal offsite governmental emergency opera-tions centers.

3.

The offsite response organization should identify radiological labora-tories and their general capabilities and expected availability to pro-vide radicio;ical monitoring and analyses services which can be used in an energency.

4 The offsite response organization should identify nuclear and other facil-ities, organizations or individuals which can be relied upon in an emer-gency to provide assistance.

Such assistance should be identified and supporteo by appropriate letters of agreement.

5.

The offsite response organization should provide personnel to accompany and advise State and local officials in an eraergency.

1 CRITERIA / UTILITY OFFSITE PLANS 5 10/07/87 l

Draft l

D. Emergency Classification System 1

Planning Standard A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facil-ity licensee, and State and local response plans call for reliance on informa-tion provided by facility licensees for determinations of minimum initial off-site response measures.

Evaluation Criteria (1. An emergency classification and emergency action level scheme as set forth in Appendix 1 must be established by the licensee. The specific instruments, parametars or equipment status shall be shown for establish-ing each emergency class, in the in-plant emergency procedures. The plan should identify the parameter values and equipment status for each emer-gency class.)

(2. The initiating conditions should include the example conditions found in Appendix 1 and all postulated accidents in the Final Safety Analysis Report (FSAR) for the nuclear facility.)

3. The offsite response. organization should establish an eneigency classiff-cation and emergency action level scheme consistent with that established by the fr.cility ifcensee.
4. The offsite response organization should have procedures in place that provide for advising State and local officials on emergency actions to'bc taken which are consistent with the emergency actions recomended by the nuclear facility licensee, taking into account local offsite c;nditions that exist at the time of the emergency.

CRITERIA / UTILITY OFFSITE PLANS 6 10/07/87

Draft E. Notification Methods and Procedures Planning Standard Procedures have been established for notification by the licensee of State and local response organizations and for notification of emergency personnel by all response organizations; the content of initial and fo11cwup ressages tc response organizations and the public has been established; and means to pro-vide early notification and clear instruction to the populace within the plume e2posure pathway Emergency Planning Zone have been established.

Evaluation Criteria

1. The offsite response organization should establish procedures which describe the bases for notification of response organizations consistent with the erergency classification and action level scheme set forth by the licensee. These procedures should include means for verification of messages. The specific details of verification need not be included in the plan.
2. The offsite rcsponse organization should estab?ish procedures for afect-ing, notifying, and mobilizing emergency response personr;al.
3. The licensee in conjonction with the offsite response organization should establish the content of the initial emergency messages to be sent from the plant. These measures shall contain inforr>. tion about the class of emergency, whether a release is taking place, potentially affected population and areas, and whether protective measures may be necessary.

There should be provisions for coordinating these nessages with State and local governments where possible.

4. Each licensee shall make provisions for follovup messages from the facil-ity to the offsite response organization (and to offsite authorities where possible) which should contain the following inforination if it is known and appropriate:

CRITERI A/ UTILITY OFFSITE PLANS 7 10/07/87

Dra f t

a. location of incident and name and telephone nuv6er (or communications  !

l channel identification) of caller

b. date/ time of incident;
c. class of emergency;
d. type of actual or projected release (airborne, waterberne, surface spill), and estimated duration / impact times;
e. estimate of quantity of radioactive material released or being re-leased and the points and height of releases;
f. chemical and physical foni of released material, including estimates of the relative quantities and concentration of noble gases, fodines and particulates;
g. meteorological conditions at appropriate levels (wind speed, direc-tion (to and from), indicator of stability, precipitation, if any);
h. actual or projected dose rates at the boundary; projected integrated dose at site boundary;
i. projected dose rates and integrated dose at the p'rojected peak and at 2, 5 and 10 miles, including sector (s) affected; j.

estimate of any surface radioactive contamination inplant, onsite or offsite;

k. licensee emergency response actions underway;
i. recommended emergency actions, including protective measures;
m. request for any needed onsite support by offsite organizations; and CRITERIA / UTILITY OFFSITE PLANS 8 10/07/87

Draft

n. prognosis for worsening or termination of event based on plant information.
5. The offsite response organization should establish a system for disseminat-ing to the public appropriate information contained in initial and followup messages received from the licensee including the appropriate notification to appropriate broadcast media, e.g., the Emergency Broadcast System (EBS).
6. The offsite response organization should establish administrative and physical means, and the time required for notifying and providing prompt instructions to the public within the plume exposure pathway Emergency Planning Zone. It should be the licensee's responsibility to demonstrate that such means exist, regardless of who implements this requirement. It should be the responsibility of the State and local governments to acti-vate such a system.
7. The offsite response organization should provide written messages intended for the public, consistent with the licensee's classification scheme. In particular, draft messages to the public giving instructions with regard to specific protective actions to be taken by occupants of affected areas should be prepared and included as part of the offsite plans. Such messages should include the appropriate aspecis of sheltaring, e.g., hand-kerchief over mouth, thyroid blocking or evacuation. The role of the licensee is to provide supporting infonnation for the messages.

CRITERIA /UTil.lTY OFFSITE PLANS 9 10/07/87

Draft o

F. Emergency Comun'..ations Planning Standard Provisions exist for prompt comunications among principal response organiza-tions to emergency personnel and to the public.

Evaluation Criteria

1. The comunication plans for energencies should include organizational titles and alternates for both ends of the communication Ifnks. Each organization should establish reliable primary and backup means of comunication for licensees and the offsite response organization. Such systems should be selected to be compatible with one another including that of the State and local response organi7ation where possible. Each plan should include:

a, provision for 24-hour per day notification to and activation of the offsite response organization's emergency response network; and at a minimum, a telephone link and alternate, including 24-hour per day manning of comunication links that initiate emergency response actions.

b, provision for comunications with offsite response organizations for contiguous States within the Emergency Planning 7ones;

c. provision for corrnunications as needed with Federal emergency response organizations;
d. provision for comunications betwen the nuclear facility and the licensee's near-site Emergency Operations Facility, State and local offsite re<ponse organization's emergency operations centers, and radiological monitoring teams; CRITERIA / UTILITY OFFSITE PLMS 10 10/07/87

Draft e, provision for connunications with State an.1 local Emergency Opera-tions Facilities; and

f. provision for alerting or activating emergency personnel in each response organization.
2. The offsite response organization should ensure that a coordinated comunication link for fixed and mobile medical support facilities exists.
3. The offsite response organization should conduct periodic testing of the entire emergency comunications system (see evaluation criteria H.10, N.2.a and Appendix 3).

F l

l CRITERIA / UTILITY OFFSITE PLANS 11 10/07/87

Draft G. Public Education and Infomation Planning Standard Infonnation is made available to the publi.c on a periodic basis on how they will be notified and what their initial actions should be in an emergency (e.g., listening to a local broadcast station and remaining indoors), the principal points of contact with the news media for disseetnation of infoma-tion during an emergency (including the physical location or locations) are established in advance, and procedures for coordinated dissemination of infor-mation to the public are established.

Evaluation Criteria

1. The offsite response organization should provide a coordinated periodic (at least annually) dissemination of infonration to the public regarding hew they will be notified and what their actions should be in an emer-gency. This information should include, but not necessarily be limited to:
a. aducational inforr.ation on radiation;
b. contact for additional infomation;
c. protective measures, e.g., evacuation routes and relocation centers, sheltering, respiratory protection, radioprotective drugs; and
d. special needs of the handicapped.

Means for accccplishing this dissemination may include, but are not necessarily limited to: Infonnation in the telephone book; periodic information in utility bills; posting in public areas; and pubitcations distributed on an annual basis.

CRITERIA / UTILITY OFFSITE PLANS 12 10/07/87

l Draft

2. The public information program should provide the permanent and transient adult population within the plume exposure EPZ an adequate opportunity to become aware of the infomation annually. The programs should include provision for written material that is likely to be available in a rest- '

dence during an emergency. Updated infomation should be disseminated at least annually. Signs or other measures (e.g., decals, posted notices.

or other means, placed in hotels, motels, gasoline stations and phone booths) should also be used to disseminate to any transient population within the plume exposure pathway EPZ appropriate infonnation that would be helpful if an emergency or accident occurs. Such notices should refer the transient to the telephone directory or other source of local emergency information and guide the visitor to appropriate radio and television frequencies.

3. The offsite response organization should designate the points of contact and physical locations for use by news media during an emergency.
4. a. The offsite response omanization shculd designate a spokesperson who should have access to all necessary infor:ation.
b. The offsite response organization should establish arrangements for

~

timely exchange of infomation among designated spokespersons.

c. The offsite response organization should establish coordinated arrangements for dealing with rumors.
5. The offsite response organization should conduct coordinated programs at least annually to acquaint news media with the emergency plans, infor:r,a-l tion concerning radiation, and points of contact for release of public infonnation in an emergency.

t CRITERIA / UTILITY OFFSITE PLANS 13 10/07/87

Draft

' N. Emergency Facilities and Equipment Planning Standard Adequate emergency facilities and enuipment to support the emergency response are provided and maintained.

Evaluation Criteria

1. The offsite response organization should establish an emergency opera-tions center for use in directing and controlling response functions.
2. The of fsite response organization should provide for tirely activation and staffing of the facilities and centers described in the plan.
3. The offsite response organization, where appropriate, should provide for offsite radiological monitoring equipment in the vicinity of the nuclear facili ty.
4. The offsite response organization should r,ake provisions to inspect, inventory and operationally check emergency equipa,ent/ instruments at least once each caleadar quarter and after each use. There should be sufficient reserves of instruments / equipment to replace those which are removed from emergency kits for calibration or repefr. Calibration of equipment should be at intervals reconnended by the supplier of the equipment.
5. The offsite plan should, in an appendix, include identification of emer-gency kits by general category (protective equipment, coanunications equipment, radiological monitoring equipment and ecergency supplies).
6. The offsite response organization should establish a central point (pref-erably associated with the licensee's near-site Emergency Operations Facility), for the receipt and analysis of all fleid monitoring data and coordination of sample media.

CRITERIA / UTILITY OFFSITE PLANS 14 10/07/87

Draft I. Accident Assessment Planning Standard Adequate methods, systems and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

EYaluation Criteria

1. The offsite response organization should describe the capability and re-sources for field monitoring within the plume exposure Emergency Planning Zone which are an intrinsic part of the concept of operations for the fa cil i ty.
2. The offsite response organization, where appropriate, should provide rnethods, equipetnt and expertise to make rapid assessments of the actual or potential magnitude and locations of any radiological bazards through liquid or geseous release pathways. This should include activation, noti-fication means, fleid team composition, transportation, comunication, monitoring equipment and estimated deployment times.
3. The offsite response organization should have a capability to detect and neasure radiofodine concentrations in air in the plume exposure EPZ as low as 10-7 mCf/cc (nicrocurfea ?2r cubic centimeter) under field condi-tions. Interference from the presence of noble gas and background radia-tion shall not decrease the stated minimum detectable activity.
4. The offsite response organization should establish means for relating the various measured parameters (e.g., contamination levels, water and air activity levels) to dose rates for key isotopes and gross radioactivity mea surements. Provisions shall be made for estimating integrated dose from the projected and actual dose rates and for corparing these estimates with the protective action guides. The detailed provisions should be described in separate procedures.

CRITERIA / UTILITY OFFSITE PLANS 15 10/07/97 1

Draft

5. Arrangements to locate and track the airborne radioactive plume shall be made, using either or both Federal and offsite response organization resources.

e l

I e

CRITERIA / UTILITY OffSITE PLANS 16 10/07/37

Draft

=

J. Protective Response Planning Standard A range of protective actions have been devel? ped for the plume exposure path-way EPZ for ecergency workers and the pub 1fc. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions tir the ingestion exposure path-way EPZ appropriate to the locale have been deveicped.

Evaluation Criteria

1. Each licensee and offsite response organization should make provisions for evacuation routes and transportation for onsite individuals to some suit-able offsite location, including alternatives for inclement weather, high traffic density and specific radiological conditions.
2. Each offsite response organization should establish a capability for advising state and local organizations on irrplementing protective meas-ures based upon protective action guides and other criteria. This shall be consistent with the recomendations of EPA regarding exposure result-ing from passage of radioactive airborne plumes, and with those of DHEW (DHHS)/FDA regarding radioactive contamination of human food and animal feeds.
3. The organization's plans to implement protective reasures for the plume l exposure pathway shall include:

{

a. Maps shewing evacuation routes, evacuation areas, preselected radio-logical sar@ ling and rnonitoring points, relocation centers in host areas, and shelter areas;  !

l l

b. Maps showing population distribution around the nuclear facility. I This shall be by evacuation areas (licensees shall also present the infomation in a sector fomat);

CRITERIA / UTILITY OFFSITE PLANS 17 10/07/87 l

Draft

c. Means for notifying all segments of the transient and resident population; 1
d. Means for protecting those persons whose mobility may be impaired I due to such factors as institutional or other confinement; e, Provisinns for recommending the use of and making available radio-protective drugs, particularly for emergency workers and institu- l tionalized persons within the plume exposure EPZ whose inmediate evacuation may be infeasible or very difficult, including quantities, l storage, and means of distribution.

l l

f. The offsite response organization's plans should include the method by which decisions by the State Health Department for administering radioprotective drugs to the general population are made during an emergency and provide for advising State Health Departments on how to make such decisions.
g. Means of relocation;
h. Relocation centers in host areas which are at least 5 miles, and preferably 10 miles, beyond the boundarie's of the plume (xposure emergency planning zone;
i. Projected traffic capacities of evacuation routes under emergency conditions; 1

l j. Control of access to evacuated areas and. organization responsibili-ties for such control;

k. Identificat.fon of and means for dealing with potential impediments (e.g., seasonal fepassability of roads) to use of evacuation routes, and contingency measures; CRITERIA / UTILITY OFFSITE PLANS 18 10/07/87

Draft

1. Time estimates for evacuation of various sectors and distances based on a dynamic analysis (time-motion study under various conditions) for the plume exposure pathway emergency planning zone; and

.: . The bases for the choice of recomended protective actions from the plume exposure pathway during emergency conditions. This should in-clude expected local protection afforded in residential unit.s or other shelter for direct and inhalation exposure, as well as evacua-tion time estimates.

4 The offsite response organization should specify the protective measures to be used for the ingestion pathway, including the methods for protect-ing the public from consumption of contaminated foodstuffs. This should include criteria for deciding whether dairy animals should be put on stored feed. The plan should identify procedures for detecting contami-nation, for estimating the dose comitment consequences of uncontrolled ingestion, and for imposing protection procedures such as impoundment, decontamination, processing, decay, product diversion, and preservation.

The location of maps for recording survey and monitoring data, key land use data (e.g., farming), dairies, food processing plants, water sheds, water supply intake and treatrent plants and resenoirs should be idan-ti fied. Provisions for maps showinc detailed crop infonnation may be by including reference to their avsflability and location and a plan for their use. The ups shall start at the fecility and include all of the 50-mile ingestion pathway EPZ. Up-to-date lists of the name and location of all facilities which regularly process milk products and other large amounts of food or agricultural products originating in the ingestion pathway Emergency Planning Zone, but located elsewhe e, should be nintained.

5. The offsite response organization should describe the means for register-ing and monitoring of evacuees at relocation centers in host areas. The personnel and equipment available should be capable of monitoring within about a 12-hour period all residents and transients in the plume exposure EpZ arriving at relocation centers.

CRITERIA / UTILITY OffSITE PLANS 19 10/07/87

Draft K. Radiological Exposure Control Planning Standard Means for controlling radiological exposures, in an emergency, are established for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides.

Evaluation Criteria

1. a. The of fsite response organization should make provision for 24-hour-per-day capability to detemine the doses received by emergency personnel involved in any nuclear accident, including volunteers.

They should also c.ake provisions for distribution of dosimeters, both self-reading and pemanent record devices.

b. The offsite response organization should ensure that dosimeters are read at appropriate frequencies and provide for traintaining dose records for emergency workers involved in any nuclear accident.

~

2. The offsite response organization should establish the decision chain for authorizing emergency workers to incur exposures in excess of the EPA General Public Frotective Action Guides (i.e., EPA PAGs for emergency workers and lifesaving activities).
3. a. The offsite response organization, as appropriate, should specify action levels for determining the need for decontamination.
b. The offsite response organization, as appropriate, should establish the means for radiological decontamination of emergency personnel wounds, supplies, instruments and equipment, and for waste disposal.

CRITERIA / UTILITY OFFSITE PLANS 20 10/07/87

Draft L. Medical and Public Health Support Planning Standard Arrangements are made for medical services for contaminated injured individuals.

Evaluation Criteria

1. The offsite response organization should arrange for local and backup hospital and medical services having the capability for evaluation of radiation exposure and uptake, including assurance that persons providing these services are adequately prepared to handle contaminated individuals.
2. The offsite response organization should develop lists indicating the location of public, private and military hospitals and other emergency medical services facilities within the State or contiguous States con-sidered ca;able of providing medical support for any contaminated injured individual. The listing shall include the name, location, type of facility and ambulatory /non-ambulatory capacities and any special radio-logical capabilities. These emergency medical services should be able to radiologically monitor contacination persennel, and have facilities and trained personnel able to care for contaminated frJured persons.
3. Each organization should arrange for transporting victims of radiological accidents to medical support facilit.ies.

CRITERI A/ UTILITY OFFSITE PLANS 21 10/07/87

Draft M.

Recovery and Reentry Planning and Postaccident Operations Planning Standard General plans for recovery and reentry are developed.

Evaluation Criteria 1.

The of fsite response organization, as appropriate, should develop general plans and procedures for reentry and recovery and describe the means by which decisions to relax protective measures (e.g., allow reentry into an evacuated area) are reached. This process should consider both existing and potential conditions.

2.

The offsite plan should specify means for informing members of the offsite response organization that a recovery operation is to be initiated, and of any changes in the organizational structure that may occur.

3.

Each plan should establish a method for periodically esti,tating total population exposure.

I CRITERIA /UTIllTY OffSITE PLANS 22 10/07/87 l

i

l Draft N. Exercises and Drills Planning Standard Periodic exercises are (will be) conducted to evaluate major portions of emer-gency response capabilities, periodic drills are (will be) conducted to

{

develop and maintain key skills, and deficiencies identified as a result of l

e.xercises or drills are (will be) corrected.

Evaluation Criteria

1. a. An exercise is an event that tests the integrated capability and a major portion of the basic elements existing within emergency pre-paredness plans and organizations to the extent possible. The energency preparedness exercise should simulate an emergency that results in offsite radiological releases which would require response by offsite response organizations. Exercises should be conducted as set forth 1.1 NRC and FEM rules,
b. An exercise should include enbilization of offsite response organi-ration resources adequa te to verify the capability to respond to an eccident scenario requiring response. Th'e offsite response orge.nization should provide for a critique of the biennial exercise

, by Faderal and offsite response organization observers / evaluators.

The scenario should be varied from exercise to exercise such that all major elements of the plans and preparedness organizations are tested within a six-year period. Each organization should make provisions to start an exercise between 6:00 p.m. and 4:00 a.m.

Exercises should be conducted during different seasons of the year.

At least one exercise should be unannounced.

2. A drill is a supervised instruction period aimed at testing, developing and maintaining skills in a particular operation. A drill is often a component of an axercise. A delli shall be supervised and evaluated by a qualified drill instructor. The offsite response organization should CRITERIA / UTILITY OffSITE PLMS 23 10/07/87

Draft conduct drills, in addition to the biennial exercise at the frequencies indicated below:

a. Cc munication Drill; Consonications with the offsite response organization within the plume exposure pathway Emergency Planning Zone should be tested monthly. Corsunications with Federal emergency response organiza-tions and offsite response organizations within the ingestion pathway should be tested quarterly. Comunications between the nuclear facility, offsite response organization's operations centers, and field assessment teams should be tested annually. Comunica tion drills should also include the aspect of understanding the content of messages.
b. Medical Emergency Drills A medical emergency drill involving a simulated contaminated individ-ual which contains orovisions for participation by the local support services agencies (i.e., ambulance and offsite udical treatment facility) should be conducted annually. The offsite portions of the medical drill may be performed as part of the required biennial exercise,
c. Radiological Monitoring Drills Plant environs and radiological monitoring drills (onsite and off-site) should be conducted annually. These drills should include collection and analysis of all sample media (e.g., water, vegetation, soil and air), and provisions for communications and record keeping.

Where appropriate, local organizations should participate.

CRITERI A/ UTILITY OFFSITE PLANS 24 10/07/87

Oraft

d. Health Physics Drill (1) Health Physics drills should be conducted semiannually which involve response to, and analysis of, simulated elevated air-borne and liquid samples and direct radiation measurements in the environment.

(2) Analysis of inplant liquid samples with actual elevated radia-tion levels including use of the post-accident sampling system shall be included in Health Physics drills by licensees annually.

3. The offsite response organization should describe how exercises and drills are to be carried out to alicw free play for decisforeaking and to meet the folicwing objectives. Pending the development of exercise scenarios and exercise evaluation guidance by NRC and FEFA the s:enarios for use in exercises and drills shall include bet not be limited to the fo11cwing:
a. The basic objective (s) of each drill and exercise and appropriate evaluation criteria;

~

b. The date(s), time period, place (s) and p rticipating organizations;
c. The simulated events;
d. A time schedule of real and simulated initiating events;
e. A narrative sumary describing the conduct of the exercises or drills to include such things as simulated casualties, offsite fire department assistance, rescue of personnel, use of protective cloth-ing, deploynent of radiological monitoring teams, and public infor-mation activities; and
f. A description of the arrangements for and advance materials to be provided to official observers.

CRITERIA / UTILITY OFFSITE PLANS 25 10/07/07

~ '

Draft 4 0' 3

4. Official observers from Federal government and the offsite response organization should observe, evaluate, and critique the required exer-cises. A critique should be scheduled at the conclusion of the exercise to evaluate the ability of organizations to respond as called for in the plan. The critique should be conducted as soon as practicable after the exercise, and a fonnal evaluation should result from the critique.
5. The offsite response organization should establish means for evaluating observer ano participant coernents on areas needing improvement, including emergency plan procedural changes, and for assigning responsibility for implementing corrective actions. The offsite response organization should establish management control used to ensure that corrective actions are implemented.
6. The offsite response organization should provide for participation in exercises and drills by State and local governments te the extent feast-ble, either through actual participation or through simulation.

e CRITERIA / UTILITY OFFSITE PLANS 26 10/07/87

. Draft

.o .

O. Radiological Emergency Response Training Planning Standard Radiological emergency response training is provided to those who may be called on to assist in an emergency.

Evaluation Criteria 1.

The offsite response organization should assure the training of appropri-ate individuals. The offsite response organization should participate in-and receive training. The offsite response organization should offer training to State and local response organizations who are expected to respend during an emergency. 'n'here inutual aid agrements exist between local agencies such as fire, police and ambulance /.escue, the training shall also be offered to the other departuents who are . einbers of the mutual aid district.

2. The offsite response organization should establish a training pregev, for instn2cting and qualifying personne' who will fcpiment radiolc.gical acer-gency respease plans. The speciali .ed initial training and periodic

~

retraining programs (including the scope, nature and frequency) should ba provided in the following categories:

1. Directors or coordinators of the response organizations;
b. Personnel responsible for accident assessment;
c. Radiological monitoring teams and radiological analysis personnel;
d. P(lice, security and fire fighting personnel; I
e. First aid and rescue personnel; I i

CRITERIA / UTILITY OFFSITE PLANS 27 10/07/87 l

i

Draft

f. Local support services personnel including Civil Defense / Emergency Service personnel (training should be offered); l
g. Medical suppert personnel; '
h. Personnel responsible for transmission of emergency inforfration and in., truc t ion s.
3. The offsite response organization should provide for the initial and annual retraining of personnel with emergency response responsibilities, i
4. The offsite response organization should provide specific training to persons who will be responsible for interfacing with state and local responders.

i as

(

CRITERIA / UTILITY OFFSITE PLANS 28 10/07/87

Draft P. Responiibility for the Planning E;' fort: Development, Periodic Review and

_ Distribution of Emergency Plans Planning Standard Respons)bilities for plan development and review and for distribution of emer-gency plans are established, and planners are properly trained.

Evaiustion Criteria

1. The offsite response organization should provide for the training of indi-viduals responsible for the planning effort.
2. The offsite response organization should identify by title the individual with the overall authority and responsibility for radiological emergency response planning. .
3. The offsite response organization should designate an Energency Planning Coordinator with responsibility for the development and updating of emergency plans and coordination of these plans with other response organizations.
4. The offsite response organization should update its plan and agreements as needed, review and certify it to be current on an annual basis. The update snall take into account changes identified by drills and exercises.
5. The offsite emergency response plans and approved changes to the plans should be foniarded to all organizations and appropriate individuals with responsibility for in1plementation of the plans. Revised pages shall be dated and marked to show where changes have been made.

I:. The offsite plan should contain a detailed listing of supporting plans and their source.

CRITERIA /L'TILITY OffSITE PLANS 29 10/07/87

Oraft

  • 7. The offsite plan should contain as an appendix listing, by title, pro-cedures required to implement the plan. The listing should include the section(s) of the plan to be implemented by each procedure.
8. The offsite plan should contain a specific table of contents. Plans sub-mitted for review should be cross-referenced to these criteria.
9. The offsite response organization should provide for updating telephone numbers in emergency procedures at least quarterly.
10. The offsite response organization should provide periodic notification of State and local government personnel of the details of the offsite plan, the arrangerents included for their involvement in the event of a real emergency, and the availability of training.

CRITERIA / UTILITY OffSITE PLANS 30 10/07/87

ch Federal Emergency Management Agency k

  • Washington, D.C. 20472 007 2 8 ic Mr. Victor Stello Executive Director for Operations U.S. Nuclear Regulatory Comission Washington, D.C. 20555

Dear Mr. Stello:

We have reviewed the assumptions, presented in the October 21,1987 mmorandum from Frank Congel of your staff to Richard Krim of my staff, which you wish the Federal Doergency Management Agency (FDiA) to use in evaluating radiological emergency response plans autruitted by a utility in those cases where State ard/or local goverrments do not participate in offsite ememency plannirs around nuclear power plants.

I believe that this issue is of such importance that you and I should correspoM directly on the agreements that we reached at our meeting on October 15, 1987, and on related matters.

We can accept tentatively assumptions numbers 1 and 2 as stated in Mr. Congel's October 21, 1987 mecorandum, but we suggest alternative wording for ntrnber 3, as follows:

(3) have the resources sufficient to implement thase portions of the utility offsite plan where State or local response is necessary.

This change clarifies that FD%, in its evaluation of the utility plan, will not be required to review the existence or adequacy of State and local resources.

This alternative wordirg is consistent with the approach presented in Mr. Corgel's menorandtra which calls for the assumptions that State and local roverrrnents t

will res;ord and follow the utility offsite plan in an actual ememency. The alternative wording reflects my understanding of your position on the resources issue, as discussed in our meetirg of October 15,1987.

As stated in our meeting of October 15, 1987, since the assunctions originate with the Nuclear Regulatory Comission (NRC) and are based on general presumption rather than specific verified facts, PSG will not be in a position to defend the assunptions in NRC regulatory proceedirgs. It is expected that the NRC will defend the assunptions in hearings and in other le6al and public forums.

Let me reiterate that what we agree to at this time is tentative. As we proceed jointly with NRC in the project concerning criteria for the evaluation of a utility plan, there may be a need to add or delete asstrnptions or make other c.harges. However, asstmptions 1, 2 and reworded 3 should provide a wrking framework for the criteria effort.

I si t f k^ l ,

~ "

.?.

During our meeting on October 15, 1987, you and I also discussed sending out the criteria for public comment prior to using it for the evaluation o'f an offsite radiological emergency response plan submitted by a utility. As an alternative, you proposed a procedure whereby after concurrence by FEMA and NRC, the utility plan criteria would be used on an interim basis to 9 review the utility plan for the Massachusetts part of the Seabrook Emergency Planning Zone, according to the provisions of the FEMA /NRC Memorandum of Understanding. At the same time, a notice would be published in the Federal Register that the criteria are available for coment. Copies would also be sent to States and other parties for comment. A similar process was used in 1980 for the publication of NUREG-0654/ FEMA-REP.1, Rev.1. Based on this.

precedent, we accept this procedure, with the understanding that any appropriates changes in the criteria will be made promptly after review of the public,' *I g' coment s . Since we are proceding on the basis that any' revised criteria '

will be applicable to plan development as well as evaluation, there should also be an understanding that any offsite utility plan reviewed under the interim criteria might also require changes due to the revised, final criteria.

Lastly, I wish to thank you for arranging for the additional resources placed at our disposal to assist us in carrying out the project on the utility, plan evaluative criteria.

If you have any questions, please call me at 646-3692.

Sin erely.

_ fr Yw Dave McLoughlin Deputy Associate Director State and Local Programs and Support 9

/

ti UNITED STATES a NUCLEAR REGULATORY COMMISSION

$' ,j , cAsHwotew,0. c. rosss j b #

Oc tober 21, 1987 y o....p l

MEMORANDUM FOR: Richard W. Krisen Assistant Associate Director Office of Natural and Technological Hazards Programs Federal Emergency Management Agency FROM: Frank J. Congel, . Director Division of Radittion Protection and Emergency Preparedness Office of Nuegen Reactor Regulation

SUBJECT:

DEVELOPMENT OF UTILITY OFFSITE PLAN EVALUATION CR1,TERIA This responds to the understanding reached at the October 15, 1987 meeting between FEM and NRC, and reflected in Dave McLoughlin's October 16, 1987 memorandum to Victor Stello. We agreed that the NRC would provide written instructions which state specifically the assunptions upon which utility of f-site plan reviews would be conducted by FFMA.

In developing evaluation criteria and in reviewing utility sponsored offsite

state l emergency response plans FEMA should assume that in an actual emergency, health l and local offietals will ((1)) exercise their best efforts to protect the 2 cooperate with the utility and follow the utility and offsitesafety plan, of andthe p(ublic,3) apply resources that are within the general capabilities of state and local governments to implement those portions of the utility offsite plan where state or local response is necessary.

As we further agreed, any FEMA findings on the adequacy of utility offsite

, plans will necessarily include the caveat that FEM was requested by the NRC l to use the above assumptions in evaluating a utility offsite plan.

Q Frank J. Congel, Director Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation CONTACT: Edward M. Podolak, Jr. , MRR

492-7290 1

1

\.

~

+- '0

~

. . oCT.19 '87 32:23 FD9 m RED CTR P.02 Federal Emergency M.anagement Agency l

. , Wuhington, D.C. 20472 l

October 16, 1987 i MDORNOJM PCR: Victor J. Stello Executive Director for Operations  !

Nuclear Regulatory Ccrnission l1 F MM: ve McM ughlin Deputy Associate Dimotor i

State and kcal Programs and Support SUBJECT Develo;nent of Utility Plan Evaluative Criteria his is to follow up on several issues raised at the meeting yesterday between members of our staffs about the developnent of criteria suitable for the evaluation of offsite emergency plans develo;ed by utilities.

You requested that we supply you with the names of the Argome National  ;

laboratory staff nee $ed as additional resources in connection with the project en the utility plan evaluative criteria. In the process of campiling the list of names, we have concluded that four staff are necessary.

B e names are: Mr. John Ely, Mr. Kanrmth Immer, Ms. Saa Ann Curtis and Mr. William Gasper. In addition, it will be necessary for Argonne to supply four additicr.a1 staff to backfill and perform the functions nomally required by FEMA ducir.g the duratim of the criteria devole;aent project.

I would like to stress the importance of having written instructions pre-pared by the Naelear Regulatory Cacr.insion, befom beging the project, which state a;ecifically the assumpticr.s upon which the plan reviews would be conducted. It would be 1@>asible to develop the criteria without knowing the omeoptual framework within which they att to opemte sudoess-fully.

Given the above resouroes and agreement en the assumptions, we are prepared to begin woric with NRC staff en October 26, 1987 on the develo;nent of criteria suitable for the evaluaticri of utility plans by FEMA. We would also be prepared to disseminate the document resulting frcus that project by Neverter 12, 1987, to the participants in the meeting to be held en Friday, Novertber 13, at 9:00 a.m. in the FDM offices. Free cur view, the purpose '

of that meeting would be to consider the criteria document and any potential issues which would need to be addressed by FEMA and NRC ama.agement.

I ho;e that this is helpful. If you have any gaestians, please feel free to call me at 646-3692 I

J

_ _ .