ML20206J464

Forwards Draft Chapter IV, Emergency Planning, of Chernobyl Implications Assessment Rept in Response to H Denton 860926 Memo.Chapter Lacks Coherency Expected in Subsequent Drafts

ML20206J464
Person / Time
Issue date:	10/27/1986
From:	Schwartz S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Speis T Office of Nuclear Reactor Regulation
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• October 27, 1986 MEMORANDUM FOR: Themis P. Spets. Director Division of Safety Review and Oversight Office of Nuclear Reactor Regulation FROM: Sheldon A. Schwartz, Deputy Director Division of. Emergency Preparedness and Engineering Response

. - Office of. Inspection and Enforcement .

SUBJECT:

CHERNOBYL IMPLICATIONS ASSESSMENT REPORT -

Enclosed please find a draft of Chapter IV. titled, " Emergency Planning" of the subject report. This responds to Harold Denton's September 26, 1986 memorandum and your memorandums on the same subject, the last dated October 21, 1986. At this point, because there are a number of different authors, the chapter lacks the coherency that I expect to achieve in subsequent drafts. Also, about

, one-fourth of the material has not yet been coordinated with FEMA.

Please send any comments that you receive on this chapter to me or Ed Podolak (telephone: 492-7290) of my staff.

Sheldon A. Schwartz, Deputy Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement cc: Marshall Sanders, FEMA i l

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)=o16 7 8704160101 870409 g

PDR FOI$ PDR SHOLLYB7 7

IV.1 ADEQUACY OF EMERGENCY PLANNING ZONE DISTANCES

1. STATEMENT OF THE ISSUE 1

l Following the Chernobyl accident, the population from a zone having a radius of 30 kilometers (18 miles) was evacuated in stages. This has been contrasted with U.S. emergency planning, which involves planning for i a plume exposure pathway emergency planning zone (EPZ) having a radius of l 10 miles. In addition, concerns regarding contamination of food products i extended over a wide region, including areas outside of the Soviet Union.

The issue is, what are the implications of the Chernobyl accident with ,

regard to the a h quacy of the 10 mile plume exposure pathway EPZ and.50 miles ingestion exposure pathway EPZ, as used in the U.S.7

2. CURRENT REGULATORY PRACTICE Emergency planning is currently required for all U.S. nuclear power '

plants for two concentric zones having radii of 10 and 50 miles (except for plants with power levels below 250 Mwt). The inner. zone, referred to as the plume exposure pathway EPZ, is one where the principal exposure

sources would be from the radioactive plume and from materials deposited

. . on the ground. The outer zone, referred to as the ingestion exposure pathway EPZ, is one where the principal exposure would be from ingestion of contaminated water or foods such as milk and fresh vegetables.

• The sizes of these zones were determined from considerations given in NUREG-0396. These specifically included consideration of the accident risks from the complete spectrum of severe accident releases given in WASH-1400. In addition, a distance of 10 miles was also chosen for the i

inner zone based on the conclusion that " detailed planning within 10

' miles would provide a substantial base for expansion of response efforts in the event that this proved necessary."

i Approval of both on-site and off-site plans are required for full power

. licensing. The plans are also required to comply with a detailed list of standards, as given in 10 CFR 50.47.

In practice, the 10 mile plume exposure pathway EPZ has become a source of considerable misunderstanding. Many people appear to believe that, in the event of an accident, a relatively hasty evacuation by everyone i within this area would be the only effective protective action. This misconception may also be fostered by periodic exercises having scenarios which call for substantial evacuation of this zone, plus the requirement that licensees submit evacuation time estimates for various sectors of the zone. Hence, it is not surprising that this zone has come to be mistakenly referred to as the evacuation planning zone.

3. WORK IN PROGRESS There has b'een significant interest in re-evaluating emergency planning.

This area began to be of interest shortly after the Three Mile Island accident when observers noted the relatively small amounts of iodine released compared to the amounts of noble clases. This led a number of l

observers to claim that severe accident re' eases or " source tems" were much lower than previously estimated. Since the severe accident releases i

-=

IV.1 Adequacy of Emergency Planning Zone Distances estimated by WASH-1400 provided the bases for the sizes of U.S. EPZ's, this had significant implications for emergency planning.

A major NRC research effort began about 1981 and has been underway since then to obtain a better understanding of fission product transport and release under severe accident conditions'. This " source tem" research

. included a very large and extensive contractor effort, including the development and application of new computer codes regarding core-melt phenomena and containment perfomance. It also included an extensive review effort by peer reviewers, industry groups, and an independent

. assessment under the auspices of the American Physical Society. The report explaining and detailing this revised methodology to calculate accident source tems was recently published in July 1986 as NUREG-0956.

Revised risk profiles for 5 representative U.S. LWR's are in preparation

- which will apply this methodology. This effort is expected to be i- published as NUREG-1150, for connent, by January 1987. '

While this research effort was in progress, the staff ha'd identified emergency planning as an area to be re-evaluated, depending upon the

_ outcome of the effort. Industry groups too, have indicated a strong interest in this area. Baltimore Gas & Electric Co. (BG&E) has requested a reduction in the size of the plume exposure EPZ for the Calvert Cliffs

. site from 10 miles to 2 miles, based upon source tem research results.

In addition, both IDCOR and the AIF have claimed that a two-mile EPZ

. would, in view of revised source term estimates, provide an equivalent or greater degree _of protection than the ten-mile EPZ, given WASH-1400 source terms.

During this period, the staff also explored alternatives to the conventional emergency planning strategies, making use solely of WASH-1400 source tems. This led to the assessment of a concept known as " graded response" which called for a prompt response, such as

. evacuation, within about two miles of the plant, to be followed by a continued assessment of accident conditions, identification of any contaminated areas, and a relocation of affected populations from these areas. A staff conclusion that such an approach had merit has been held in abeyance pending the outcome of the source tem effort.

4. ACCIDENT RESPONSE ASSESSMENT

1. The Chernobyl release occurred with essentially no warning time, a high initial energy of release (producing an initial plume height of about 1200 meters), and a release duration of about ten days.

While the release fractions are considered comparable to the more severe release categories of WASH-1400, and release durations of similar magnitude are also considered more realistic based upon recent research, the zero warning time is considered to be unique to the RBMK design.

2. Residents in the town of Pripyat were initially advised to remain indoors. Evacuation of Pripyat was ordered about 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> after the release connenced and was completed about three hours later. It is not entirely clear why Pripyat was not evacuated sooner. Possible reasons may be that the initially high energy of the plume kept dose

IV.1 Adequacy of Emergency Planning Zone Distances rates below the stated action levels (25 and 75 rem to the whole body); that a conscious decision was taken to use sheltering afforded by the numerous multi-story dwellings in the town, or that '

public transport was not imediately available. Soviet authorities have indicated that sheltering was the preferred action, and, in any event, residents of Pripyat were estimated to have received doses less than 5 rem.

3. Some time later (perhaps a few days to a week after the initial release, and possibly prompted by the high release rates which occurred on May 4th and 5th), an additional evacuation of all the

1. residents within a 30-k11ometer zone, except for those already evacuated from Pripyat was ordered. This involved all residents from an annular ring extending from about 3-km. out to 30-km. A 7

delayed evacuation such as was carried out beyond the town of '

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Pripyat is better deserving of the name relocation, rather than evacuation. It is not known over what time period,it occurred, but it appears to have required extensive resources, since a

- considerable number of fam livestock were also relocated.

,_ Indications are that most residents within this area received doses less than 10 rem, although individuals in several comunities could have received doses of 30 to 40 rem.

4. There is some indication that the Soviets had pre-planning only within a distance of about 3-km. (for the town of Pripyat). If so, I

the vast majority of the Soviet accident response represents actions taken on an-ad-hoc basis. This appears to have involved a very large effort utilizing the military as well as other centralized elements on a national level. The basis for selecting.30-kilometers as the area for these actions is not known. In addition, this distance appears to have combined aspects of both the plume exposure and ingestion exposure zones contemplated by U.S. criteria. It is important to recognize that protective actions were carried out in a staged or phased fashion, both with respect to distance as well as time. Whether this was planned or merely occurred as part of the ad hoc response to the accident is not known.

5. CONCLUSIONS AND REC 0letENDATIONS

1. The specifics of the Chernobyl release are unique to the RBMK design, and represent a near " worst case" in tems of the risks of nuclear energy. Because of differences in reactor design and containment, the probability of a severe accident is lower at U.S. comercial nuclear power plants. Therefore, accidental releases for U.S. reactors are expected to be no greater (and probably considerably less) with regard to the amounts of radioactivity released, and to have considerably greater warning times. For these reasons, assessment of the adequacy of U.S. EPZ distances in terms only of the Chernobyl release is unwarranted.

2. There are some useful implications that can be drawn from the Chernobyl accident and the response to it, however. It appears that relatively prompt protective actions (those taken within the first few hours). -

S IV.1 Adequacy of Emergency Planning Zone Distances such as evacuation and sheltering, may generally be adequate to avoid

, early health effects and achieve a good degree of dose savings within relatively short distances. Furtherinore, sheltering may be preferable to evacuation under certain conditions, especially if an initially elevated plume occurs and good sheltering is available. However, where an initial decision is' made to shelter close to the reactor, a good monitoring capability plus the ability quickly to notify the populace of any changed conditions appears to be essential.

In one respect it is difficult to compare the effectiveness of sheltering at Chernobyl and U.S. practices for protective actions because of the large difference in protective action levels between the two countries. However, it is recomended that the U.S. further

.  ; explore the relative advantages and disadvantages of sheltering vs.

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evacuation at close ~ distances for a variety of accident release.

• meterological and shelter conditions given our own protective action

-. guides.

, 3. For large releases, protective actions may be warranted over signi-ficant distances, and may possibly extend beyond areas originally designated for pre-planning. Such actions appear to have a reduced degree of urgency than those taken at shorter distances in that they can be carried out over a longer time period (of the order of one or more days) and still result in relatively low risk levels to the public. Such actions are likel relocation (delayedevacuation)ytoconsistofshelteringand/or

. The possibility that protective actions may extend beyond the range of a pre-designated planning area should be recognized, but need not be a cause for undue concern if this is accepted as a possibility, if the reduced urgency and longer time scale for response are recognized, and if a capability exists on an "ad hoc" basis to extend the range of accident response, as needed.

One of the bases for selection of the 10 mile plume exposure EPZ was, as stated earlier, that " detailed planning within 10 miles would provide a substantial base for expansion of response efforts in the event that this proved necessary."

Based on Conclusions 2 and 3, there is nothing in the Chernobyl accident and response that implies that the 10 mile plume exposure pathway EPZ in the U.S. is inadequate with regard to the ability to plan and carry out a full range of protective actions for the popu-lation within this zone, as well as beyond it, if the need should arise.

4. For large releases, concerns over contaminated water and foods such as milk and fresh vegetables may extend over very large distances, well beyond the 50 mile ingestion exposure pathway EPZ. This would involve monitoring and control efforts by a number of states as well as the federal government, and could have transnational implications, as occurred for the Chernobyl accident.

1 i

Because of the existing infrastructure and close coordination among state and federal organizations involved in radiation protection and control, a high leve of capability already, exists to handle such a

IV.1 Adequacy of Emergency Planning Zone Distances situation. Nevertheless, the Chernobyl accident does carry an impli-cation that the role intended by the 50 mile ingestion EPZ should be re-assessed in light of these considerations.

In summary, it is recommended that the NRC, in cooperation with the Federal Emergency Management Agency (FEMA):

• Further explore the relative advantages and disadvantages of sheltering vs. evacuation at close distances for a variety of

, accident release and meteorlogical conditions; and

' Re-asses the 50 mile ingestion exposure emergency planning zone in light of the Chernobyl accident experience.

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9 IV.2.A LONG-TERM RELOCATION i

1. STATEMENT OF THE ISSUES The existence of a sophisticated and experienced Civil Defense Organiza-tion, coupled with a long-standing Soviet commitment to the capability for both offensive and defensive chemical warfarel placed the Soviets in a good position for management of long-term relocation of evacuees and de-contamination of land, equipment, structures and personnel, following the accident at Chernobyl.

The Soviets have been prepared to relocate the worker and industry since Wor.1d War II.2 They have, in place, the organization, criteria, attitude

'and experience to enable them to carry out massive evacuations and long-term relocation of whole industries. Although there were some problems in communications and transportation resources, the Soviets were able to move, large populations of personnel and livestock to dispersive areas remote from the inmediate hazards of the Chernobyl accident. Long stand-ing policy maintained the organization to communicate with evacuees, main- ,

tain transportation, registration of evacuees, order and' contact between

. family units, relocate, house and feed large numbers of people in a very short time. It appears that the attitude of the Soviet people enabled long-term relocation to be effected with little difficulty, including the removal and relocation to sunmer camps and other facilities, en masse, the children of the city of Kiev.3

~.

When the authorities decided to evacuate the Chernobyl arca, 2,172 buses

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and 1,786 trucks were provided, nearly 4,000 drivers were mobilized, the reception of the evacuees in new places was organized and accommodations reserved in hotels and boarding houses.4 As a result, the 45,000 inhabitants of Pripyat, the town near Chernobyl, were evacuated in about three hours. It took more time to evacuate the people from nearby villages because the farmers did not wish to leave at the height of their spring work. However, an additional 90,000 people I

IThe Soviets have more than 80,000 officers and enlisted specialists trained

~in chemical warfare. They have 20,000 special vehicles for reconnaissance and decontamination. Chemical warfare equipment and techniques are directly trans-ferable to radioactivity decontamination and control. SOVIET MILITARY POWER .

1986 U.S.G.P.0., Washington, 1985, p. 71.

2GRAZHDANSKAYA OB0RONA (CIVIL DEFENSE), Yegorov, P.T., I. A. Shlyakhov, and N.

I. Alabin Vysshava Shkola (Publishing House for Higher Education), Moscow, 1970, p. 71.

3"There have been stories of families separated and unable to trace one anoth-er. And inevitably there have been people who tried desperately to return to their homes. Most were turned back." The Times (of London), June 12, 1986, as

' indicated in World Press Review, August 1986, p. 61.

450VIETLIFE,No.9(360), September 1986,pp.34-41.

..- - - _ _ - _ _ _ _._._._~_.-..____.____ ._

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IV.2.A Long-Tem Relocation were evacuated from the villages within the 30 km zone.5 As people ar-rived in their assigned relocations they were provided with housing, three free meals a day, and a P200 allowance. Kitchen and garden plots were allotted in the villages. It is reported that most of the evacuees quick-ly assumed the new jobs provided by local authorities.4 Evacuation and relocation of personnel were triggered by rather high* (by U. S. criteria) dose action levels which, from the available infomation appear to be:

Lower Intervention Level (consideration) for Evacuation 25 REM /yr, Whole Body 6 Upper Intervention level (mandatory) for Evacuation 75 REM /yr, Whole Body 6

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. d1though -- by Soviet Civil Defense policy -- large-scale evacuation plans .

were in existence, these had to be modified to accomodate the distribu-tion of radioactivity from the accident. Until public transportation **

- could be deployed, evacuees were sheltered in their residences, and schools were not opened. Evacuation of the Pripyat area took place on 27 April (next day), after all the necessary transportation means, equipment, escorting personnel, were gathered and relocation areas defined, manned and equipped.

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Long-term relocation was accomplished through federal resources, although public contributions to the Chernobyl Fund, as of September 1986 have accumulated to P38.4 million.4

3. CURRENT REGULATORY PRACTICE, LONG-TERM RELOCATION

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To effect pre-planning for a large-scale, long-tem evacuation / relocation of the Chernobyl-related type is beyond the authority of the NRC. Unlike 1 .the Soviet Union, where a central government exerts control all the way 55anders, Marshall E., Testimony before the U.S. Senate Subcomittee on Nuclear Regulation of the Comittee on Environments and Public Works, September 29, 1986, p. 4. -

~

450VIET LIFE, No. 9 (360), September 1986, pp. 34-41

• These appear to be Civil Defense based levels rather than what would be ex--

pected to be appropriate for use by U.S. civilian populations in peacetime.

6Konstantinov, Yu. 0., " Criteria for Making Urgent Decisions on Measures of l Protecting the Population in Case of an Accident at an AES, RADIATION SAFETY AND PROTECTION OF AES, Yegorov, Yu. A., Moscow Energoatomizat,1985, pp.

148-150.

• • The Soviets rely on public mass transportation. Private, low capacity vehi-cles are insufficient in quantity to be significantly effective in mass evacua-tion in the Soviet Union.

IV.2.A Long-Term Relocation i

down to the " evacuation commission" of an individual industrial facility or town; in the U. S. there are many organizations to coordinate with:

utility, county, state, Federal, each with their own prerogatives, inter-ests and authority.

i

4. ASSESSMENT The Soviets actively practice civil defense, supporting their efforts with organization, planning, personnel, equipment, supplies, and policy and authority from the very top of the government down to individual ~ civil

defense " commissions" within industrial complexes and villages. It would

- be useful to determine the exact extent to which plans, organizations and resources exist in the U.S. to support a short-notice, long-term reloca-tion effort such as was necessary of Chernobyl.

~ hhere is much involved in effecting a short-notice, long-term relocation -

effort. Such a study could involve, among other things: .

' National Policy and Legislation on long-term relocation Emergency Organization and its authority Transportation Resources Substitution Housing Resources Fiscal Support and Compensation

- Replacement Employment Accountability Mechanism Public Attitudes

5. CONCLUSIONS AND RECOMMENDA1 IONS Since it appears that there is uncertainty as to the preparedness of U.S.

to effect a long-term relocations, it is recommended that the NRC in cooperation with FEMA and The Federal Radiological Preparedness Coordi-i nating Committee (FRPCC) review the issue. As part of the review, factors as outlined in Section 4 above should be taken into consideration.

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IV.2.8 DECONTAMINATION

1. STATEMENT OF THE ISSUE The accident at Chernoby1 spread radioactive contamination over a wide area, with sufficient magnitude to require serious interdiction measures, including abandonment of property and massive evacuation and relocation of populations and livestock to dispersal areas remote from the hazards of the site.

Soviet comitment to the capability for both offensive and defensive chem-ical warfare has placed the Soviets in a good position for management of extensive decontamination of land, equipment, structures and personnel, following the accident at Chernobyl.1 The authorities quickly monitored the situation with aircraft.

vehicle-mounted and foot. teams and established an exclusion perimeter out to30km(18.6mi.). Within this perimeter the area was divided into '

three sectors, based on the extent and magnitude of the contamination detected: a special zone -- some 4-5 km around the plant -- where no re-entry of the general public is foreseeable in the near future, and where no activity beside that required at the installation will be pemit-ted; a 5-10 km zone, where partial reentry and special activities may be allowed after some time, and the 10-30 km zone, where the population may eventually be allowed in and agricultural activities may be resumed, but

- will be subject to a strict program of radiological surve111ance.2 Access

~is controlled at each sector boundary, keeping contaminated vehicles and

equipment within the area, and moving personnel through successive less-contaminated areas.

l The Soviets are well equipped to handle large-scale decontamination of equipment, structures and areas. Media photographs of the area around i Chernobyl reveal several kinds of sophisticated decontamination equipment which do not appear to have been hastily fabricated as a result of the accident. One particularly interesting unit resembles a " car wash" with decontamination solution sprayed from pierced vertical and overhead pipes, and drawn from a nearby water carrier. -

The Soviet military forces are known to possess the TMS-65 decontamination unit, consisting of a turbojet aircraft engine mounted on a swivel base on a truck chassis: it decontaminates vehicles as they drive past by direct-ing a decontaminating jet exhaust on the vehicles. A tank truck can be treated in about three minutes.3 IThe Soviets have more than 80,00 officers and enlisted specialists trained in chemical warfare. They have 20,000 special vehicles for reconnaissance and decontamination. Chemical warfare equipment and techniques are directly transferable to radioactivity decontamination and control. S0VIET MILITARY POWER 1985, U.S.G.P.0., Washington, 1985, p.71.

21NSAG

SUMMARY

REPORT ON THE POST-ACCIDENT REVIEWED MEETING ON THE CHERNOBYL ACCIDENT, Vienna, 30 August - 5 September 1986, IAEA, p. 79.

3HANDB00K OF SOVIET GROUND' FORCES, FM 30-40, Department of the Amy, 30 June 1975.Section XII, pp. 6-103 to 6-111.

._ __. _ _ _ . _ _ _ an _ __

l IV.2.8 Decontamination The ARS-12U decontamination vehicle is more versatile, consisting of a  :

680-gallon storage tank mounted on a truck chassis. Water or l decontaminants can be sprayed on roads, equipment, and vehicles. The l ARS-120 can also supply water and chemicals to fill small decontamination devices or for showers, and water for steam cleaning of contaminated clothing. A newer ARS-14, with a larger tank on a heavier truck is also available.3 There are also various types of steam cleaning equipment, such as the truck-mounted DDA-53, for the decontamination of clothing and light equip-ment. Field showers can be set up for personnel. Hand-used equipment, such as the portable DKY, can be used with brushes and spray nozzles to clean vehicles and equipment.3 Soviet personnel utilized in the large area decontamination effort within

- the 30-km zone appear to be from military units, and seem well equipped .

with respiratory protection, protective clothing, and well designed (from the field-use convenience aspect) radiation monitoring equipment.

In addition to the obvious buildings and other structures, roads and other

paved areas, vehicles and other equipment -- including decontamination and reconnaissance vehicles -- the Soviets are decontaminating large areas of cropland, forest, orchard, etc., as well as taking preventative measures

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to prevent or minimize contamination of the watershed and the Pripyat River.

Decontamination techniques for most of the above, including those for personnel, appear to be similar to those used in the U. S. and other loca-tions in support of the nuclear weapons testing program, the TMI-2 acci-dent, as well as interdiction related to chemical spills, etc. Although related t.o the U. S. nuclear weapons testing program, desert areas and coral atoll environments have been decontaminated, but there is little U.S.

. experience in the large scale decontamination of such terrain as forests and orchards or crcplands with the purpose of restoring viability and productivity to the land. The Soviets seem to be taking some novel ap-proaches to this problem, indicating that special agrotechnical and decon-tamination measures, designed to enable the reuse of contaminated lands for economic purposes, have been developed and are being implemented.

These methods include changing the traditional system of soil cultivation in the region, the use of special polymer dust-suppression compounds, changing the harvesting and crop processing methods, and so on.

Although extremely important in any large-scale decontamination effort, there does not appear to be any infonnation on how the Soviets are han-dling their decontamination wastes associated with the "off-site" effort.

There are indications that the higher-level on-site decontamination wastes, together with the severely contaminated structures, etc., are being placed in a radioactive waste vault associated with one of the other Chernobyl reactors. For large-scale " environmental" decontamination ef-forts in U.S. testing programs, pits have been dug, lined, and filled with

-3HANDB00K OF SOVIET GROUND FORCES, FM 30-40, Department of the Arg, 30 June 1975.Section XII, pp. 6-103 to 6-111. ,

IV.2.8 Decontamination runoff solutions from decontamination efforts, then covered, and fixed against erosion. Also, in the U.S. the ultimate disposition of the wastas would have a sociopolitical component as-well-as the technical component.

2. CURRENT REGULATORY PRACTICE l Relative to large-scale decontamination of the environment, the NRC has no experience nor policy. On-site decontamination would be the responsibili-  :

ty of the utility, using criteria established for decomissioning, if that were the direction, or established by the facility (approved by NRC) for continued operation. Off-site contamination criteria are the prerogative

of the EPA. EPA has operational guidelines for external exposure and food pathways and is in the process of preparing guidelines for rentry. These have not yet been proposed by EPA as formal guidance for Federal agencies.

~

to date, large-scale environmental decontaminations of DOE facilities have ,

been handled on an ad hoc basis. Decontaminations associated with trans-portation related situations have been essentially removal of all detect-

- able activity. The only real environmental decontamination effort near the magnitude of the Chernobyl situation was carried out by the Department T of Energy, in conjunction with elements of the U. 5. Amy, in the decon-tamination and " rehabilitation" of Bikini and Enewetok Atolls, in the Marshall Islands. The criteria were ad hoc, and based on economics and I state of the art. The results are colitroversial.

3. WORK IN PROGRESS:

Research on large-scale environmental decontamination efforts (actually results, with some spin-off on soil conditioning techniques) is currently being conducted in the Pacific in conjunction with the rehabilitation efforts for Enewetok Atoll, by LLNL, under contract with DOE.

t ,Several efforts, and reports have been written focusing on decontamination limits, but no decision has been made establishing any criteria.

l

4. ASSESSMENT:

Large-scale environmental decontamination in.the off-site area appears to be outside of the jurisdiction of the NRC, in the area governed by the

- several states and the EPA. Capability for such decontamination does not exist as such at this time, although the expertise does. lie within the Department of Energy, associated with the nuclear weapdns testing program.

No specialized decontamination equipment exists similar to that employed within the Soviet military. Heavy equipment is availaole throughout the U. S. for earth moving, water spraying, etc., but none is equipped to operate in a contaminated environment and would require modification to provide suitable protection of personnel. It would be useful to detemine

the extent to which a comparable capability exists within the U. S. and worldwide under provisions of the recently signed international convention on mutual assistance. The areas of trained and equipped personnel, or the availability of predesignated equipment and supplies should be the primary focus.

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

1 IV.2.B Decontamination

5. CONCLUSIONS AND RECOMMENDATIONS l In the Soviet Union, large-scale decontamination capability rests with the military, because it supports many aspects of Nuclear, Biological and Chemical warfare. An open U.S. question is who should have the responsi-bility and authority for large-scale radiological decontamination. Should the focus for this capability be at the utility, local, state or Federal level? Advanced planning, on a contingency basis, could be effected.

Personnel with appropriate expertise could be identified. Equipment could be assessed, and plans to expedite necessary modification, if ever required could be prepared. With the economic and technical resources available in the U. S., pre-planning should provide any needed capability.

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As a first step, it is recommended that the FEMA chaired, FRPCC review

. this issue and provide recommendations for further actions.

With respect to the disposal of the radioactive waste generated as a re-

- sult of decontamination, it is further recommended that NRC and EPA review

- this issue and provide an assessment and recommendations for any further actions.

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_ _ _ _ _ _ - _ _ - - - - ---v---, m- ,-.m-. + , .

IV.3 USE OF POTASSIUM IODIDE PILLS

1. STATEMENT OF THE ISSUE Within hours after the beginning of the accident, volunteers were distrib-uting, door to door directly to individual residents, radiciodine prophy-lactic medications to children, young adults, and other members of the affected population in the Chernobyl area.1 Whether these pills were '

potassium iodide (KI) or potassium iodate, or other fom of stable iodide in solid (pill) fom has not been confimed. Since the Soviets were able to effect distribution of these prophylactics the morning of the accident it. appears that they had stockpiles of the drug for imediate issue, the

- organization to staff the distribution, and the policy for its use. There is no question that the Soviets are prepared to distribute radioiodine prophylaxis g least in the vicinity of their nuclear power plants.

That radioiodine prophylaxis was necessary is unquestionable. It appears

• that the triggering dose level for protective actions against radioiodine uptake (whether by ingestion - milk pathway, leafy vegetables, or by inha-O lation) is 300 mSY/yr (or 30 REM /yr) to the child's thyroid.2 This level is about 5 REM above the " break-even" point above which it is believed prophylactic doses of stable iodines should be administered. Current FDA Protective Action Guides for Ingestion of Contaminated Foodstuffs indicate preventive action when the projected thyroid dose exceeds 1.5 REM, and

- emergency action when the projected thyroid dose exceeds 15 REM.3 If timely, radiciodine prophylaxis can reduce the dose to the thyroid by as much as 96%.4 Available reports indicate that doses to the thyroids of individuals from inhalation (and possible ingestion of contaminated foods) were estimated to be mostly below 300 mSv (30 REM), althou ceived thyroid doses as high as 2,500250 mSv (gh[atsome rad)5 these children may have re doses, REM is somewhat undefined, and the tem rad is used. . .at low doses, REM is essentiallyequivalenttorad).

l

2. CURRENT REGULATORY PRACTICE

- There are no federal regulations requiring the use of potassium iodide

• (KI) or other radioiodine prophylactic. There are, however, several fed-eral guidelines that have been published that relate to this issue. The ITN5KG 5URRART EPDRT ON THE POST-ACCIDENT REVIEW MEETING ON THE CHERNOBYL ACCIDENT, Vienna, 30 August - 5 September 1986, IAEA, p. 77.

2INSAG

SUMMARY

REPORT, p. 85.

3 Federal Register,1982, " Potassium iodide as a thyroid-blocking agent in a radiation emergency: final recomendations on use," FEDERAL REGISTER, 47, 28158-9, Washington, DC, USGPO.

l 411'in, L. A., Arkhangel'skaya G. V., Konstantinov Yu. O. and Likhtarev I. A.,

1972, RADIOACTIVE IODINE IN THE PROBLEM OF RADIATION SAFETY, pp. 146-151 U. S.

A. E. C. Translation TR-7536, Springfield, VA, NTIS.

SINSAG

SUMMARY

REPORT,h.85.

IV.3 Use of Potassium Iodide Pills NRC and FEMA issued CRITERIA FOR PREPARATION AND EVALUATION OF RADIOLOGI-CAL EMERGENCY RESPONSE PLANS AND PREPAREDNESS IN SUPPORT OF NUCLEAR POWER PLANTS in 1980. This guidance specifies as an evaluation criterion, the f consideration of the use of radioprotective drugs (e.g., individual thy-roid protection). The criterion places the responsibility for the protec-tion of the thyroids of individuals remaining or arriving on-site during an emergency upon the licensee of a nuclear power plant.6 An NRC-sponsored study concluded that the use of KI for the general public would be marginally cost effective at best, but recomended that stock-piles of the drug be available at or near reactor sites for use by site

- personnel, off-site emergency response personnel and controlled popula-tions in the off-site institutions (e.g., hospitals and prisons).6 The U. S. EPA recommended the use of KI as a protective action for emer- -

ilency workers but did not establish a similar policy for the general pub-

' ic. EPA's recommendations included the use of KI at a projected thyroid

- dose of 125 REM to emergency team workers.6 The FDA has recomended that doses of 130 mg K! per day for adults and 65 mg KI per day for children less than 1 year of age be considered for thy-roid blocking in radiation emergencies for those persons likely to receive a dose of 25 REM or greater to the thyroid from radiciodines. The implied

- initiation of KI prophylaxis ranges from imediately before radioiodine uptake to 4 hr after acute exposure. The duration of such treatment is not expected to exceed about 10 days.6 FEMA, as Chair of the FRPCC, issued the Federal Policy on Stockpiling and Distribution of KI for use by the general public in a radiological emergency.7 This policy in essence states that, taking into account cost, risk and benefit, that State Health Officials should review the technical information provided and reach their own conclusion on Stockpiling and Distribution of KI.

3. WORK IN PROGRESS Although there may be on-going research on the effects of radioiodine prophylaxis in the U.S., no further regulatory interest in rulemaking.

policy, etc., has been shown since the publication of the Federal Policy in July 1985.

4. ASSESSMENT There is no doubt that the Soviet radiciodine prophylactic response to the Chernobyl accident was necessary, nor is there any question that the time-ly issue of KI by those authorities has resulted in a significant reduc-tion of dose in the affected populations. With thyroid doses received in 6Meck, Robert A., Chen M. S., and Kenny, Peter J., " Criteria for the Admints-tration of KI for Thyroid Blocking of Radiofodine, HEALTH PHYSICS, Vol. 48, No.

2 (February), Pergamon Press, pp. 141-157, 1985.

750 FR 30258, July 25, 5985. " Federal Policy on the distribution of KI around nuclear power plants as a thyroidal blocking agents."

IV.3 Use of Potassium Pills the neighborhood of 250 rad, it is very possible that absence of radiofodine prophylaxis could have resulted in much higher doses, perhaps two orders of magnitude higher. (Although, there is no confirmation that those who received as much as 250 rad did not receive KI.)

The TMI-2 incident resulted in an inquiry into radiciodine prophylaxis using KI, and FDA guidelines were issued. The Federal policy is that distribution of KI to the general public is site-specific and a local decision.7

. Other authorities have taken a different approach, with the Soviet Union successful in distribution and organization of radiofodine prophylactic measures at Chernobyl. The United Kingdom also has stocks of potassium todate, and has had them for over ten years, in the areas of nuclear sub-marine bases, and other locations. (10,000 doses of potassium todate in pill form in the U. K. costs about $150-200, hermetically sealed in -

plasti-foil packages of 5 doses, each. Shelf storage .11fe appears to be greater than 10 years.)

'5 . CONCLUSIONS AND RECOMMENDATIONS In light of the Chernobyl experience, the NRC and other cognizant Federal agencies should re-examine policy to determine its adequacy in this area.

As part of this effort, additional information is needed regarding the radionuclide source term at Chernobyl versus that expected from an acci-l dent at a U.S. facility and possible adverse reactions to iodine prophylaxis in Russia and other countries.

l 73D FR 30258, July 25,1985. " Federal Policy on the distribution of KI around nuclear power plants as a thyroidal blocking agents."

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IV.4 DATA ACQUISITION AND REPORTING

1. STATEMENT OF THE ISSUE During the Chernobyl accident a great number of environmental radiation and radioactivity measurements were made. However, the systems used and formats for acquisition, presentation, and reporting of data lacked homo-geneity. It has been suggested that there is a need to establish national and international standards for such reports in order to facilitate rapid decisions about protective actions in emergency situations. In addition, there is concern that use of SI units caused difficulties because decision

, makers did not understand them.

2. CURRENT PRACTICE The vehicle for initiating a coordinated Federal response to Chernobyl was

" Federal Responses to Radioactive Contamination from Specified Foreign .

Nuclear Detonation: Multiagency Memorandum of Understanding among DAF, DOE, EPA, FAA, FDA, NOAA, and NRC." Many of the agencies responding

turned however, to the structure and experience they had developed with the Federal Radiological Emergency Response Plan (FRERP) for the details and extent of their functions and interfaces. The MOU and the Plan were not mutually exclusive but were complimentary. Future Federal response to a major accident outside of the United States involving a potential for health effects within the United States should be carried out under the Federal Radiological Emergency Response Plan (FRERP) published by FEMA on

- November 1985. The FRERP clearly establishes that DOE and EPA have the principal responsibility to coordinate environmental monitoring data.

The Department of Energy, during the initial phases of an emergency, and the EPA thereafter, will work with the appropriate Federal, state and local agencies to coordinate offsite radiological monitoring and assess-ment activities. DOE or EPA will compile and assess monitoring data and present them to the lead technical Federal agency (called the Cognizant Federal Agency [CFA]) and appropriate state agencies. The CFA will use this infomation, together with its assessment of the current condition and prognosis of the emergency on site, to develop o'r evaluate public protective action recomendations for the state (s). It should be noted that DOE or EPA could be designated the CFA. . It should also be noted that responding under the current method of DOE presenting field monitoring i data and projection to the CFA and others involves faxing and phoning information. Each group involved in has developed computer based systems that have not been fully coordinated with the agencies they would support (CFA or states). This could be a problem if large areas (several states) were involved, thus requiring a large number of interfaces.

3. WORK IN PROGRESS The NRC has discussed with FEMA and DOE the need to develop a method to send DOE field monitoring data and projections from DOE to the CFA, other Federal agencies, and states. This effort is ongoing.

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IV.4 Data Acquisition and Reporting

4. ASSESSMENT Although during Chernobyl the FRERP was not directly followed. The NRC and other agencies carried out assessments of the data as it was received.

The NRC experience indicated that the major problems associated with as-sessment of the environmental data were the result of the NRC being very remote, the preliminary nature of the results and the many diverse source of infomation. All of the infomation received were in Becquerels (Bq) that had to be converted to picocuries. This single process and did not present any problem. The picocurie levels were compared to various pro-tective action guidance levels before being presented to a decision maker.

Even if the measurements were reported in picocuries, a technical assess-ment would be required before presenting results to decision makers.

Therefore, the use of SI units did not appear to result in any problem. ,

5.

NEED FOR ADDITIONAL WORK NRC, EPA, DOE, DOT, and FEMA must develop a standard efficient method to obtain and pass on to the states, as well as share amongst themselves, the

- results of the DOE efforts to monitor and project radiological conditions.

It is recomended that this issue be reviewed by the FRPCC.

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IV.5 INGESTION PATHWAY MONITORING AND INGESTION OF FOODSTUFFS )

1. STATEMENT OF ISSUE The Russian report emphasized the need for a single point or connand to ,

handle all of the decisions affecting the relocated population. The in-gestion pathway aspects extend to the relocated population and potentially ,

far beyond. While FDA has published Protective Action Guides relative to protective action criteria for the ingestion pathway, it is not clear how they would be implemented when considerin jurisdictions and statutory authorities international, (g theFederal, large state number and of politic local) that may be involved in data gathering, decision making and imple-mentation of protective actions. ,

2. CURRENT AGENCY PRACTICE The NRC in response to a radiological emergency operates under the Federal

- Radiological Emergency Response Plan (FRERP) published by the Federal .

Emergency Management Agency (FEMA) in November 1985. The .FRERP clearly establishes a mechanism for a coordinated Federal assessment of the conse-O quences of a nuclear accident occurring within the United States. The FRERP specifies authorities and responsibilities of each Federal agency that may have a significant role in a radiological emergency. The FRERP includes the Federal Radiological Monitoring and Assessment Plan (FRMAP) for use by Federal agencies with radiological monitoring and assessment

capabilities.

In the United States, state or local governments have primary responsibil-ity for determining and implementing any measures to protect the public.

Therefore, one of the primary areas where the Federal government may be able to assist state and local governments is in advising them on initial protective action reconnendations for the public.

Under the FRERP a Cognizant Federal Agency (CFA) has been specified for most types of radiological activities carried out/ licensed within the United States. The CFA is responsible for the technical assessment of the event and making recommendations to appropriate offsite authorities.

Under the FRMAP the Department of Energy, during the initial phases of the emergency, and the EPA thereafter, will work with the appropriate Federal, state and local agencies to coordinate offsite radiological monitoring and.

- assessment activities. DOE or EPA will assess monitoring data and present them to the CFA and appropriate state agencies. The CFA will use this information, together with its assessment of the current condition and prognosis of the emergency on site, to develop or evaluate public protec-tive action reconnendations for the states.

The Department of Health and Human Services (HHS). EPA, DOE, and the U.S.

Department of Agriculture (USDA), after coordination with their state counterparts, will provide advice to the CFA, concerning possible public health impacts and associated protective measures for mitigating them.

The CFA will use this advice, as required, to develop for discussions with the state (s) decisionmaker(s) a coordinated Federal position on reconnen-dations for public protective action.

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IV.5 Ingestion Pathway Monitoring and Ingestion of Foodstuffs The criteria for establishment of which agency is CFA is established in the FRERP except in the case of radiological events outside of the United States. The FRERP does have a general provision that covers such events.

In general, it says FEMA will consult with other appropriate Federal agen-cies regarding the CFA role. The result of such consultation will be either that a Federal agency assumes the CFA role, or that a decision is made that the CFA role is not appropriate.

3. WORK IN PROGRESS FEMA has proposed that the FRERP be reviewed and revised to assure it can

- most effectively address events impacting the United States to include a basis for selection of a CFA. FEMA has begun to coordinate with the agen-cies designated in the FRERP.

4. ASSESSMENT

- The FRERP currently provides the mechanism for coordinat' ion of all Federal monitoring and protective action decision making in response to any radio-

- logical event. The plan does not specifically identify the Federal agency with the key role of CFA during an accident occurring outside of the United States which affects this country. However, the plan does provide a

_ procedure for determining the CFA at the time of the accident when one is l

- not immediately evident.

' 5. RECCMMENDATIONS It is reconnended that NRC support the FEMA initiative to review and revise the FPERP.

Further, as part of this review it is recommended that the development of national standards regarding the radioactivity levels at which foodstuffs may be safely used, or are to be interdicted, should be considered. Such standards should be sufficiently stringent to demonstrate a high level of health protection for the public, but one that would cause no undue alarm or needless economic loss.

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!Y.6 PEDICAL SERVICES

1. STATEMENT OF THE ISSUE During the Chernobyl accident 203 plant and emergency response personnel

("onsite medical services") suffered acute radiation sickness. By the time of the August 25-29, 1986 meeting in Vienna, of these 26 had died and 30 remained hospitalized. The majority of these patients had made clini-cal recovery by the end of June. The Soviets attributed their success in diagnosis and treatment to previously acquired experience and recomenda-tions of international radiology centers. As an indicator of the speed and extent of emergency medical response, the Russians reported that by 6

'a.m., April 26, 108 people had been hospitalized and an additional 24 were admitted during the day. -After initial diagnosis in local or regional hospitals, 129 patients were sent to a specialized hospital in Moscow and 72 patients were sent to clinical institutes in Kiev. All of there patients suffered from acute radiation sickness. In addition, a special-ized medical team arrived within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of the accident and within 24 .

hours had examined some 350 persons and perfomed about 1,000 blood analyses. (Reference 1)

To provide medical care for evacuees ("offsite medical services") during I the first few days after the accident, 450 brigades, made up of a total of 1,240 doctors, 920 nurses, 360 doctors assistants, and over 3,400 other

' personnel were mobilized. All evacuees (135,000) were examined after

.! personal decontamination, and those showing any irregularities were hospitalized in central regional hospitals. No persons from the general

public were found to be victims of acute radiation sickness. (Reference 1)

The International Nuclear Safety Advisory Group (INSAG) report (Reference 2) -

concluded that:

" Medical treatment of the acute radiation syndrome was effective within the limits imposed by the doses incurred. Severe skin burns induced by beta radiation added significantly to the difficulties of supportive and substantive treatment of the syndrome, and also affected to a significant degree the total outcome of the disease in 29 victims. Technical measures should be taken to prevent occurrence of extensive skin burns should an accident of a similar nature occur in the future. Bone marrow transplants

perfonned in selected cases did not appear to offer real therapeutic advantages in this group.

• Internal contamination was inconsequential in the induction of acute radiation sickness. This experience should be carefully considered by the medical comunity...It is very important to enable physicians, such as specialists in various fields and general practitioners, to give appropriate advice to members of the public concerning health consequences of accidental radiation exposure of various magnitudes and in various conditions. It appears an equally valid requirement that physicians who may be engaged in medical first aid and early treatment of accidentally exposed persons should possess adequate education and training. Therefore the IAEA should initiate, in collaboration with WHO, a study of which subjects should be intro-duced, and to what extent, into the basic and postgraduate training of physicians to assure fulfillment of these specified needs and requirements."

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IV.6 Medical Services

2. CURRENT REGULATORY PRACTICE For onsite personnel and emergency workers, NRC licensees are required to provide for onsite first aid capability and to arrange for local (primary) and backup hospital having the capability for evaluation of radiation exposure and uptake, including assurance that persons providing these services are adequately prepared to handle contaminated individuals.

For offsite members of the general public, Comission Policy is contained in a recent statement published in the Federal Register (51 FR 32SN) titled, " Emergency Planning - Medical Services." The comissTon stat 1d that its regulation required pre-accident arrangements for medical servic-es for individuals who might be severely exposed to dangerous levels of offsite radiation following an accident at a nuclear power plant. In

- addition to the previously required list of medical facilities, such *

~

arrangements would ir.clude, (1) identification of the capacities, special capabilities or other unique characteristics of the listed medical facili-ties. (2) a good faith reasonable effort by licensees or' local or State l

governments to facilitate or obtain written agreements with the listed l -

medical facilities and transportation providers, (3) provision for making available necessary training for emergency response personnel to identify, transport, and provide emergency first aid to severely exposed individu-

_ als, and (4) a good faith reasonable effort for licensees or State or local governments to see that appropriate drills and exercises are con-ducted which include simulated severely-exposed individuals. FEMA and NRC staff are preparing guidance for implementation of this policy. The guidance should be implemented within about li years.

A national response to a Chernobyl type accident would be coordinated through the Federal Radiological Emergency Response Plan which has the resources of the Radiation Emergency Assistance Center / Training Site (REAC/TS) at Oak Ridge Tennessee and the National Disaster Medical System (NDMS) headquartered in Rockville, Maryland.

I The REAC/TS has its own radiation emergency response team and maintains a computerized registry of approximately 1650 personnel that has been trained at its center, including 650 physicians. The NDMS has 4 Medical Assistance Teams (MATS) which can respond to' radiological emergencies through being au Administration (gmented by health physicists from the Food and DrugFDA), t sources. Currently, the NDMS has enrolled in its program 76.478 hospital beds in 965 non-federal medical institutions. Its goal is to have 100,000 non-federal beds and 150 MATS enrolled in its program. The NDMS also has a goal to train all of its teams in the handling of patients exposed to radiological, biological or chemical contaminants.

3. WORK IN PROGRESS

- As noted above, the NRC and FEMA are preparing guidance to implement the Cuisnission's policy on offsite medical services and the NDMS is expanding its capabilities. The medical comunity is assimilating the lessons-learned from the Chernobyl experience through its traditional C___ _ _ _ _ _ _ _ _ _ _ _ _ . _

4 j 4 IV.6 Medical Services mechanisms. One example is the International Conference on Non-Military Radiation Emergencies to be conducted by the American Medical Association on November 19-21, 1986 in Washington D.C. NRC has provided financial and technical support for this conference.

4. ACCIDENT RESPONSE ASSESSMENT As noted above, the Russians consider their medical services efforts successful. This is supported by the INSAG report.

5. . CONCLUSIONS AND RECOMMENDATIONS The medical services response to the Chernobyl accident was massive and effective. . The U.S. is also prepared to mount response to a large radio-Jogical accident. The medical services capabilities both locally and nationally to deal with a radiation emergency are increasing. It is clear from the international offers of support to the USSR, that our own nation-al medical capability is backstopped by an internationai capability. For example, the U.S. has 1,347 " burn beds" of the type that would be useful for the treatment of the most severely exposed patients. In addition to I

domestic hospital _ beds that could be converted on short notice, patients could be evacuated to other countries.

- The staff considers the present arrangement and future plans for onsite and offsite medical services around domestic conmercial nuclear power plants to be adequate. Therefore, medical services should not be carried as an open item. However, it is recommended that FEMA monitor the imple-mentation of arrangements for local medical services in the vicinity of commercial nuclear power plants, and HHS should continue to upgrade the national response.

REFERENCES:

'1. Statement by Marshall E. Sanders, FEMA, before the U.S. Senate Subcommittee on Nuclear Regulation of the Commi.ttee on Environment and Public Works, September 29, 1986 which was based upon his atten-dance at the August 25-29 meeting in Vienna, Austria where the Russians reported on the Chernobyl accident and presented the report l ,

by the USSR State Committee on the 14111zation of Atomic Energy.

i

2. INSAG.5ummaryReportontheftr.bAcndentReviewMeetingonthe Chernobyl Accident Vienna,?G Augl . - 5 September, 1986.

3. Policy Statement: Emergency Planning - Medical Services (51 FR --

32904) September 17, 1986.

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IV.7 ACCIDENT RECOVERY I. STATEMENT OF THE ISSUE The Chernobyl accident demonstrated the value of planning for recovery from severe accidents. Because the range of severe accidents is so broad and the possible variations among particular details so vast, it does not seem likely that one could or should develop detailed procedures for the full spectrum of severe accidents. Nevertheless, policy and general guidance could facilitate response to a severe accident.

Since national resources are brought to bear on severe accidents, national policy is needed to provide a framework within which national resources can be directed. For example, a national policy on entombment versus clean-up, e.g., Chernobyl versus TMI, may have direct implications in the early stages of accident mitigation. ,

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2. CURRENT AGENCY PRACTICE

- Severe accidents, such as have occurred at TMI and Chern'obyl, were dealt with largely on an ad hoc basis. With few exceptions, the operator's emergency procedures for U.S. plants do not extend beyond degraded core cooling into the recovery process. Although licensees are well equipped and trained for more probable transients and accidents, severe accidents

and recovery from severe accidents pose problems and issues and have not received the same level of operational attention.

3. WORK IN PROGRESS

4. ASSESSMENT The Chernobyl accident raises many questions about accident recovery that have not been thoroughly explored to date. Are all elements of the national resources, prepared to render assistance? Who will direct

' remedial actions and assume the liability for the collateral effects of i

remedial actions? Although some remedial actions may be indicated, liability or the complexity of technical issues may preclude non-governmental authorities from making a decision to use such measures. Does the issue of potential entombment raise issues that need to be coordinated with "

state / local governments now?

Beyond the national policy issues, questions of general guidance remain.

Should the licensee operations department have training in severe accident mitigation? Are there small changes to plants that should be made now that would greatly facilitate severe accident recovery? For example, a prefabricated flange that would permit mating a fire hose to portions of the reactor coolant system or containment would make available a seismic, ac independent source of cooling water, namely a fire truck. Would storing large quantities of crystalline boric accident on-site significantly improve severe accident recovery?

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IV.7 Accident Recovery

5. RECOMMENDATIONS National policy guidance is needed to address the fiscal, technical and material resource issues raised by severe accidents. The first step is to attempt to find an existing intergovernmental body to study this issue. The Federal Radiological Preparedness Coordinating Conmittee (FRPCC) should be asked if it has the capability to undertake this task.

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