DEPARTMENT OF HOMELAND SECURITY

Federal Emergency Management Agency

Docket ID FEMA-2004-0004

Z-RIN 1660-ZA02

Planning Guidance for Protection and Recovery Following Radiological
Dispersal Device (RDD) and Improvised Nuclear Device (IND) Incidents;
Response-to-Comments 

_______________________________________________________________________

	The Department of Homeland Security (DHS) published interim guidance
for response to, and cleanup of, radiological dispersal device (RDD) and
improvised nuclear device (IND incidents.  The interim Guidance,
published at 71 FR 174, Jan. 3, 2006, was titled “Protective Action
Guides for Radiological Dispersal Device (RDD) and Improvised Nuclear
Device (IND) Incidents.”  This Guidance was developed by an
interagency working group of the National Science and Technology
Council, Committee on Homeland and National Security, Subcommittee on
Standards (hereafter called the Working Group).  The Guidance recommends
protective action guides (PAGs) for protection of the public in RDD and
IND incidents, based on PAGs published by the Environmental Protection
Agency (EPA) and other agencies, and recommends the use of site-specific
optimization as an appropriate strategy for developing site cleanup
criteria and plans.

The general public was invited to comment on all aspects of the
document.  In particular, comments were invited on the following
specific topics:  

Is the presentation and format of the document useful and appropriate
for its intended purpose?  If not, why not, and how should it be
changed?

Is the implementation process in Appendix 3 of the proposed Guidance
clear and appropriate for its intended purpose?  Are roles and
responsibilities sufficiently defined in the document?

Does the Guidance provide the appropriate balance between (a) public
health and environmental protection goals; and (b) the flexibility
needed for the decision makers to conduct emergency response actions and
address public welfare needs, costs and benefits, technical feasibility
and societal interests during response to and recovery from an incident?
 If not, how should the Guidance be changed to provide the appropriate
balance?

Are the proposed PAGs for the early and intermediate phases
implementable? Are they appropriate?  If not, why not and what
alternatives do you recommend?

Is the discussion on worker protection and emergency responder
protection helpful?  Does Appendix 1 of the proposed Guidance provide an
adequate discussion of expectations and the use of the alternate
response worker guidelines for life and property saving situations?  If
not, what additional information is needed to make the discussion
adequate?

Are the operational guidelines being developed and discussed in Appendix
4 of the proposed Guidance useful?  Are the groupings clear and
appropriate? Are there additional operational guides that should be
developed?

Is the optimization process proposed for late phase site restoration and
cleanup reasonable and sufficiently flexible to address RDD and IND
situations?  If not, what changes need to be made to improve the
process?

Is a flexible process without pre-established limits an appropriate
method for site recovery?  Would a flexible process with goals, ranges
or limits be more appropriate?

What other guidance or tools are needed to assist in the implementation
of the recommendations?

	Eighty comment submissions were received on the interim RDD/IND
Guidance through April 14, 2006.  The commenters included:

One international organization

Seven State departments of public health

Three State emergency management agencies

Three local and regional agencies

Nineteen professional and nongovernmental organizations

Thirty-eight private citizens

Three Consulting firms

The federal interagency Working Group that developed the Guidance
evaluated the comments.  A summary of these comments and the Working
Group’s response is presented here.  

1 - General Approval/Disapproval of PAGs

1.1 - Generally Approved of Guidance as Written

	Several commenters generally approved of the interim Guidance, stating
that the interim Guidance as written are thorough, useful, and flexible.
 Of these comments, several commended the interim Guidance as an
excellent resource and guidance tool for emergency response planning and
for direct use by emergency responders.  Many comments supported the use
of existing Federal guidance from the Environmental Protection Agency
(EPA), and Food and Drug Administration (FDA), as part of the framework
for response following an RDD or IND incident.  

1.2 - Generally Approved, but believed Additional Guidance Is Needed

	Several commenters generally approved of the interim Guidance, but also
believed they should include additional guidance.  A few of these
commenters suggested more emphasis on responder and public education
because the general public has no experience with RDD or IND incidents. 
An international organization suggested additional guidance for the
period when an RDD or IND incident remains a threat but is not yet an
actuality.  Another group stated that the PAGs for the early and
intermediate phases should be revised for an IND incident.  The Working
Group notes that while the Guidance was not developed to address the
threat of RDD or IND incidents, the protective actions contained in the
Guidance can be used in response to a specific threat.  This Guidance
was developed to provide protective action guides to support decisions
about actions that should be taken to protect the public when responding
to, or recovering from, an RDD or IND incident.  This Guidance presents
levels of radiation exposure at which the Federal Government recommends
that actions be considered to avoid or reduce radiation dose to the
public from an RDD or IND incident.  The intended audience for this
Guidance is emergency management officials at the Federal, State, tribal
and local levels.  The Guidance should be used in coordination with
other existing response and operational guidelines, such as the National
Incident Management System (NIMS), to develop response and recovery
plans prior to an incident.

	Due to the vast differences in radiation exposures between an RDD and
an IND incident and in response to comments received, the Working Group
has recommended that separate guidance be developed for the high dose
rate zones expected in an IND.  In the interim, this Guidance should be
used.	

	The Working Group agrees that public information and responder
education are important elements in preparing for an RDD or IND event
and encourages response planners to include these items in their
jurisdictions’ preparedness efforts.  Training and outreach efforts
are available to ensure that emergency responders are familiar with the
RDD/IND Guidance.  In addition, there will be an effort to incorporate
this Guidance into regional and national exercises so local emergency
responders will become familiar with them. 

1.3 - Generally Disapproved of the Guidance as Written

	Several commenters generally disapproved of the proposed Guidance as
written.  One of these commenters stated that the proposed early and
intermediate phase PAGs did not include sufficient information for first
responders on the various types of radioactive material that would be
encountered, instrumentation needed for response, and steps to take
during a response.  

	The Working Group maintains that this Guidance is not the appropriate
vehicle to address these concerns.  This Guidance is designed to assist
in the decision to implement protective actions, but is not designed to
serve as a response plan or standard operating procedures for local,
State, or Federal responders.  Tactical decision making prior to,
during, or after an RDD or IND event should be guided by local response
protocols, preparedness training and operational planning. Training is
available for RDD response which includes information about different
types of radioactive materials.  It is expected that specific response
plans that are appropriate to a given incident will be developed by
State and local agencies in preparation for such events. 

	One commenter stated that a lack of flexibility in the proposed PAGs
would be detrimental during emergency response, but did not elaborate as
to the type of flexibility that was desired.  To the contrary, the
Guidance was explicitly designed to provide flexibility in support of
decision makers without establishing rigid standards that could impede
emergency response efforts.  Several commenters raised concerns that
proposed cleanup levels would be inadequate and not protective of public
health, resulting in exposure levels that would be too high and thus
present an unacceptable level of risk.  The Working Group believes these
commenters misunderstood the Guidance as it was written; the early and
intermediate radiation dose guidelines are flexible protective action
guides for local decision makers to consider, under emergency
circumstances, while weighing other factors that would influence the
implementation of protective action guides, such as weather, evacuation
routes and other risks.  The early and intermediate PAGs do not differ
from the existing guidance developed by the Environmental Protection
Agency (the EPA PAGs) for nuclear reactor accidents.  The EPA PAGs are
designed to offer flexibility to responders in determining the
appropriate course of action based on the unique circumstances present
at the time of a particular incident.  This Guidance is consistent with
these concepts.

	The site-specific optimization process recommended for cleaning up the
affected area will result in a stakeholder defined/approved
site-specific clean up level that results in level of dose (or risk)
agreed to by affected parties.  This flexible approach will permit state
and local decision makers to consider varying clean up approaches based
on the size and scope of the incident, unique characteristics of the
radioactive material, incident site, technical feasibility, land uses,
exposure pathways, and socio-economic considerations.

2 -  Consistency and Appropriateness of Guidance

2.1 - Based on Existing EPA PAGs for Early and Intermediate Phases

	Fifteen comments were received from organizations and individuals about
the proposed use of the existing early and intermediate phase EPA PAGs
for early and intermediate phases of RDD and IND incidents.  Some of the
commenters endorsed applying the 1992 EPA PAGs for response, site
cleanup, and recovery following both RDD and IND incidents, while others
supported the use of the 1992 EPA PAG Manual, only for RDD incident
response.  Among these, a State agency supported using the 1992 EPA PAGs
for RDD incidents and for later phases of IND incidents because
volunteer responders, Federal, State, and local governments have used
EPA guidance for 20 years.  In a similar show of support, a different
State agency noted that most assumptions in the 1992 EPA PAG Manual were
scientifically sound and protective of human health and safety. 

	One commenter strongly recommended developing new PAGs for both RDD and
IND incidents, rather than using the 1992 EPA PAGs and another stated
that the document was deficient in describing the implementation of the
PAGs in the early phase of responding to an IND incident.  The Working
Group believes that the 1992 EPA PAGs provide an adequate technical
basis for this Guidance for planning for, and responding to, an RDD or
IND incident.  As mentioned earlier, additional guidance is proposed for
responding to IND incidents in close-in hot zones.

	One State agency approved of using the 1992 EPA PAGs for early and
intermediate phase activities, but recommended developing new late phase
PAGs for returning the public to previously contaminated areas.  The
Working Group believes that the optimization process outlined for the
late phase will provide a more flexible approach to cleanup of a site
when flexibility is most needed, and thus will not force the abandonment
of a city against the wishes local officials. It should be noted that in
the late, or cleanup, phase PAGs are not longer applicable.

	A local emergency management agency suggested modifying values found in
the 1992 EPA PAGs to address the high levels of radiation that would be
present after an RDD or IND incident, and recommended that victims
shelter-in-place, while authorities outside the fallout area organize
rescue and evacuation efforts.  Similarly, another commenter recommended
weighing the risks of sheltering against the risks of mass evacuation
from an urban area, and recommended accounting for extreme weather
conditions when making such decisions.  The Working Group notes that
these concerns do not require modification of the proposed Guidance;
rather Federal, State, and local agencies should consider using this
Guidance to develop specific operational plans and response protocols
for ordering shelter and evacuation and for protection of workers in
emergencies involving high radiation doses.  The decision to implement
public evacuation or shelter-in-place is ultimately the responsibility
of local officials, who should base these decisions on all available
incident-specific information, including the location of the incident,
levels of radiation present, the timing of the release, current weather
conditions, population characteristics, and egress and transportation
logistics.    

	One commenter was concerned that the relocation PAG of 2 rem/year for
the first year after an incident and 0.5 rem/year in subsequent years
might not be applicable to a large-scale RDD incident because an RDD
would likely use a long-lived radionuclide.  The commenter recommended
implementing additional protective measures.  One other commenter
suggested setting radiation exposure limits at levels allowed by the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP),
rather than at higher levels allowed by the 1992 EPA PAGs.  The Working
Group does not agree with this recommendation because the RDD/IND
Guidance must provide flexibility and scalability for decision makers to
be able to respond to a wide variety of potential impacts and unique
circumstances.  

	A State environmental agency noted that an RDD or an IND would likely
be detonated without warning and would immediately impact the public,
making dose assessment difficult to accomplish and population impacts
difficult to predict rapidly.  The agency suggested allowing flexibility
in the proposed PAGs for decision makers to adjust action levels in
response to available resources, areas impacted, and maximization of
public safety.  Indeed, this Guidance does not present rigid decision
points, but was designed to be flexible, allowing decision makers the
latitude to respond accordingly to unpredictable RDD and IND incidents. 


2.2 - Integration with other Existing Protocols

	Several commenters addressed integrating the proposed Guidance with
other existing protocols.  Comments included a recommendation for
recognizing that the lowest reasonably achievable dose could be much
higher in the event of a terrorist use of a nuclear device than during
normal peace time, and a request for providing both International System
of Units (SI) and English units for radiation in the document.  One
commenter recommended basing criteria for release of property from
contaminated areas on risk/dose-based standards (e.g., American National
Standards Institute, ANSI N13.12-1999, Surface and Volume Radioactivity
Standards for Clearance).  Commenters also requested clarification as to
whether the proposed Guidance would supersede the EPA PAG Manual or be a
stand-alone document.   

	Equivalent measures in SI units have been provided in parentheses
following each measurement; however, rad and rem will remain the primary
units of measurement to ensure consistency with other Federal guidance
and documents.  The use of a dose-based standard may be of use in
developing operational guidance, such as release of property, and in
fact ANSI N13.12 is being used for operational guides development.  A
statement has been added to the document to clarify that this Guidance
will stand on its own as guidance for the specific situation of RDDs and
INDs until it is integrated into an upcoming revision of the EPA PAG
Manual, after which readers are referred to the EPA PAG Manual.

	One commenter suggested using FDA Derived Intervention Levels to
address dispersal of radioactive material in a municipal water system or
a commodity handling facility.  This issue is addressed in the existing
1992 EPA PAG Manual.

	A State agency recommended revising the planning standards in the
Criteria for Preparation and Evaluation of Radiological Emergency
Response Plans and Preparedness in Support of Nuclear Power Plants,
NUREG 0654/FEMA REP 1, to reflect new standards developed under the
proposed Guidance.  A second commenter recommended harmonizing these
PAGs with international guidance to include justification and time
duration for protective actions.  

	Making changes to the cited preparedness regulations is beyond the
scope of this effort.  With regard to the second comment, harmonization
with international guidance was one of the factors that were important
to the Working Group during the development of this Guidance.  Although
this Guidance is not identical to international guidance, it is not
inconsistent.  The goal was to develop the most useful and
scientifically sound Guidance for RDD and IND response and cleanup,
consistent with the National Response Framework.

	One commenter approved of using the 5 rem dose limit for emergency
workers, as given in Occupational Safety and Health Administration
(OSHA) regulations, and two State health agencies affirmed that the
RDD/IND Guidance takes a standardized approach to worker exposure
limits, based on OSHA recommendations and requirements.  A third
commenter thought there were conflicts between OSHA and other Federal
radiation standards, which could mean that a non-radiation worker might
incur a higher dose than an emergency response radiation worker. 
Additional commenters stated that occupational standards and guidance in
the emergency worker guidelines rely on conflicting materials from OSHA,
NRC, the Department of Energy (DOE), and State radiation control
agencies and suggested resolving inconsistencies so that emergency
responders can develop effective plans.  In addition, several commenters
recommended adjusting the 25 rem Total Effective Dose Equivalent (TEDE)
in Table 1 to meet the 50 rem limit recommended for life saving in
International Commission on Radiological Protection (ICRP) 1990,
International Atomic Energy Agency (IAEA) 1999, and National Council on
Radiation Protection and Measurements (NCRP) 2000 documents.  

According to the 1992 EPA PAG Manual, there is no dose limit for workers
performing lifesaving duties.  This Guidance remains consistent with the
EPA document.  However, the current guidelines are designed to
accommodate potentially catastrophic situations associated with RDD and
INDs.  The Guidance reflects the EPA 1992 PAGs, which state that
“Situations may also rarely occur in which a dose in excess of 25 rem
for emergency exposure would be unavoidable in order to carry out a
lifesaving operation or avoid extensive exposure of large
populations.”  Similarly, the NCRP and ICRP raise the possibility that
emergency responders might receive a dose that approaches or exceeds 50
rem (0.5 Sv) to a large portion of the body in a short time (see NCRP
Report No. 116, Limitation of Exposure to Ionizing Radiation, 1993). 
Exposure to these high doses presumes that Incident Commanders have
determined such exposures are justified and the emergency responders are
informed in advance of the risks associated with such high exposures. 
The Guidance reflects recommendations found in the EPA PAG Manual, and
those of the NCRP.

	One commenter recommended incorporating the work of the Interagency
Steering Committee on Radiation Standards (ISCORS) into the Guidance. 
The agencies and subject matter experts who were represented on the
Working Group for the current Guidance overlap significantly with those
represented on ISCORS, and ISCORS is therefore considered represented.  
 

	Numerous commenters suggested using CERCLA Superfund cleanup standards.
 A State emergency management agency pointed out that Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA) guidance
considers future use scenarios, compliance with existing standards,
State acceptance, community acceptance, and cost of cleanup.  Similarly,
other commenters suggested using CERCLA guidance to set lower limits for
optimization and occupational limits, and the ICRP to set upper limits
for optimization.  A State agency suggested using ICRP reference levels,
along with Federal and State decommissioning regulations to create an
optimization process allowing flexibility for verifying if a dose is
reasonable and acceptable, or if mitigation, cleanup, and relocation
activities are necessary.  One commenter compared the RDD/IND Guidance
with the Health and Environmental Protection Standards for Uranium and
Thorium Mill Tailings (40 CFR Part 192) to see if publicly funded
cleanups are being held to less stringent cleanup standards.  Another
suggested using the decontamination procedures specified in the military
guidance on Management of Equipment Contaminated with Depleted Uranium
or Radioactive Commodities, (AR 700-48, DA PAM 700-48), including
isolation of contaminated materials and strict protections against use
of radioactive food and water.  

	These standards and approaches to determining clean up levels, as well
as other approaches, were carefully considered by the Working Group. 
The consensus of the Federal agencies involved was that for events such
as these a site-specific optimization process offers decision makers the
flexibility necessary given the unpredictable nature and scale of
possible RDD and IND attacks.  The site-specific optimization approach
allows for cleanup to very low levels when the circumstances permit. 
However, the Working Group does not believe the Federal government
should be in a position to potentially require abandonment of lands
following an act of terrorism that state and local governments wish to
recover, just because the cancer risk level may be higher than
traditional clean up standards.  This Guidance does not set a different
bar based on who is funding the cleanup.  Rather, it recognizes that if
communities and lands are to be recovered, compromises may need to be
made.  The site-specific optimization process will allow local
stakeholders to share in decisions about future land uses, with
appropriate recovery operations, to ensure the health and safety of
those returning to the affected communities.  

A State environmental agency stated that the OSHA ionizing radiation
standards cited in Appendix 1 are outdated, and suggested revising the
standards to reflect current NRC radiation protection practices found at
10 CFR part 20.  The Working Group notes that all Federal and State
regulatory agencies use the 5 rem dose criterion as the limit for
standard occupational radiation exposure. However, the current
guidelines are designed for the catastrophic situations associated with
RDD and INDs.  The Guidance  follows the EPA 1992 PAG Manual, which
states that “Situations may also rarely occur in which a worker dose
in excess of 25 rem limit for emergency exposure would be unavoidable in
order to carry out a lifesaving operation or avoid extensive exposure of
large populations.”  Similarly, the NCRP and ICRP raise the
possibility that emergency responders might receive a dose that
approaches or exceeds 50 rem (0.5 Sv) to a large portion of the body in
a short time.  Exposure to these high doses presume that Incident
Commanders have determined such exposures are justified and that
emergency responders are informed in advance of the risks associated
with such high exposure operations.   

A labor union recommended including three additional OSHA standards in
the final Guidance: Hazardous Waste Operations and Emergency Response
(HAZWOPER) (29 CFR 1910.120); Access to Exposure and Medical Records (29
CFR 1910.1020); and, Recording and Reporting Occupational Injuries and
Illnesses (29 CFR 1904) and emphasized the need for all public employees
to have the same health and safety protections during RDD or IND
incidents.  The Guidance now references HAZWOPER, which incorporates the
other standards when applicable. 

	One commenter noted a need for prompt notification and coordination
between State and local resources, especially without coordination by a
nuclear power plant licensee.  The commenter recommended identifying:
(1) the States’ radiation control agencies as emergency response
organizations to notify promptly, and (2) a primary agency to perform
accident assessment and develop protective action recommendations during
RDD and IND incidents.  This Guidance is intended to guide decision
making by Federal, State and local officials for protection of the
public and workers during response actions, not outline State or local
incident response protocols for a radiological/nuclear incident.  

	One commenter supported the proposed emergency dose limit of 10 rem to
protect valuable property, pointing out that it corresponds with IAEA,
ICRP, and NCRP recommendations.  In addition, another commenter
recommended including a wide range of science-based tools for
decision-making in accompanying operational guidelines, based on the 20
years of research on the effectiveness of radiological/nuclear response
strategies.  Operational guidelines are being developed in a separate
process by DOE.  Information and resources on the development of these
guidelines is available on the internet at http://www.ogcms.energy.gov/.

	A State agency suggested that Appendix 3 of the proposed Guidance
conflicts with a long-standing commitment by the Federal Government to
support States during radiological emergencies, with States directing
response activities, and using Federal assets as needed.  The commenter
recommended adoption of the nationwide REP program system already in
place, because it is tested through drills and exercises and proven to
work effectively.  This Guidance calls for States to take the primary
leadership role and contribute significant resources toward cleanup of
the site for radiological or nuclear terrorist incidents below a certain
threshold.  The process detailed in the appendix, in which Federal
agencies will work closely with State and local governments, presumes
incidents of a more catastrophic nature that would be aided by Federal
assistance, including funding, in line with the framework established in
the National Response Framework (NRF).  

	One commenter suggested that the Emergency Response Guidebook be
included as a reference for first responder issues, including Protective
Clothing, Fire and Spill Control, Criminal/Terrorist Use of
Chemical/Biological/Radiological Agents, Indicators of a Possible
Radiological Incident, and Personal Safety Considerations. 

	The commenter also recommended adding a References and Resources
section to help emergency responders develop RDD and IND response plans.
 The commenter suggested adding:

The Centers for Disease Control’s (CDC) “Cooperative Agreement for
Public Health Emergency Guidance; ”

The National Institute of Environmental Health Sciences (NIEHS)
“Minimum Health and Safety Training Criteria: Guidance for HAZWOPER,
HAZWOPER-Supporting and All Hazards Disaster Prevention, Preparedness &
Response;” and

The NIEHS “Worker Training in a New Era: Responding to New Threats.”

These resources are stand-alone guides.  These and many others are
available through Federal, State and local outreach and training
programs.

3 - Structure, Format, and Presentation 

	Three general comments were received from organizations calling for
improvements to the structure, format, and presentation of the proposed
Guidance. These comments stated that the proposed Guidance was difficult
to read and interpret (in part because of the text size and arrangement
of material to meet the stylistic requirements of the Federal Register).
 The commenter recommended adding visual aids to illustrate differences
between RDD and IND incidents, and suggested including relevant
recommendations and guidance, rather than referring readers to the other
documents for further information. 

	Efforts have been made to make the Guidance more readable within the
Federal Register’s rules on the format and style of published content.
 As mentioned earlier, when the 1992 EPA PAGs are revised, this final
Guidance will be incorporated into the revised EPA PAG Manual.  The
Guidance will also be posted online in a more readable format.  

3.1 - Overall Usefulness and Appropriateness 

	Several commenters stated that the proposed Guidance presentation and
format were well developed, useful, and appropriate for the document’s
intended purpose, with one commenter approving of the presentation
because it emphasized that emergency response should be different for
RDD and IND incidents.  Several other commenters approved of flexibility
for RDD and IND incident response in order to adjust to the situation. 
One commenter noted that a major difference between nuclear power plant
incidents and RDD and IND incidents is that nuclear power plants
regularly exercise, drill, and plan for specific types of accidents;
localities cannot do the same for RDD and IND incidents. Commenters
suggested including additional introductory information to the Guidance
to help individuals who are new to radiological emergency response and
new to using PAGs.  Additional commenters stated that the Federal
implementation process in Appendix 3 was particularly clear and
appropriately defined roles and responsibilities.  

	The Working Group notes that the introductory information in the
proposed Guidance, as written, provides information to individuals who
are reasonably familiar with radiological emergency response.  The
Guidance is not designed to be a primer for general audiences.  However,
more thorough background and introductory information for radiological
emergency responders is expected to be included in the upcoming revision
of the 1992 EPA PAG Manual.

A local emergency management agency suggested modifying the preface to
emphasize the primary priority of saving human life after an RDD or IND
incident.  The Working Group agrees with the comment and the statement
was added to the discussion of the emergency responder PAGs in the final
Guidance.    

	One commenter suggested clarifying language on responder and worker
protection, specifically suggesting that the Working Group modify the
phrase, “no individual should be forced to perform a rescue action
that involves substantial personal risk” to state that “no
individual should be forcibly prevented from performing a lifesaving or
property saving action.”  The Working Group has clarified that
statement; however, the Working Group recognizes that not all lifesaving
activities may be justified when they jeopardize the life and safety of
the rescuers. 

	Special individual exposure guidance, often in excess of standard
occupational exposure limits, is required for emergency response
operations because the benefits associated with establishing control at
the scene of a large radiological disaster can be so great (NCRP 2001). 
As recommended by national and international agencies, normally only
actions involving lifesaving justify acute exposures that are
significantly in excess of the annual occupational dose limit.  The use
of volunteers and emergency workers who are trained in performing such
operations during emergencies is highly recommended, because such
workers would be trained in radiation protection procedures, thereby
minimizing worker exposure. Exposures during emergency operations that
do not involve lifesaving should, to the extent possible, be controlled
to the occupational exposure limits (NRCP 1991), as should exposures
occurring under non-emergency circumstances.  

	A State environmental agency suggested adding information to section
(f) of Appendix 4, specifying the criteria to use when releasing
controlled material to a still-contaminated, and uncontrolled area.  The
recommendations of the commenter are expected to be included in the
operational guidelines, which will be made available for public comment.


	A State environmental agency recommended revising the FDA Derived
Intervention Levels (DILs) to account for the radionuclide that would be
present after an RDD or IND incident.  The Working Group does not
believe that revising FDA DILs is appropriate for this Guidance.   Given
that there is no way to predict the type or amount of radionuclide that
will be present after an RDD or IND incident, this request is beyond the
scope of this Guidance.  

	One commenter recommended modifying Table 1, “Protective Action
Guides for RDD or IND Incidents,” so that it contains separate charts
for RDD and IND incidents. This commenter also recommended adding
information for responding to an IND incident, including specifics on
addressing elevated levels of radiation, thermal effects, and
electromagnetic pulse (EMP) effects.  The current version of the table
contains appropriate PAGs for both RDD and IND incidents.  DHS
recognizes that applying the existing EPA PAGs has evident limitations
with respect to INDs.  The table addresses low dose range protective
actions, which, in the case of an IND, applies to the largest number of
affected people.  However, the Working Group recognizes that INDs
present an extraordinary challenge nearer to the point of detonation. 
As mentioned earlier, the Working Group has recommended additional work
be done to develop guidance for IND hot zones nearer to ground zero, and
expects this work to be done.

	A commenter suggested adding a footnote to the row labeled "Mortality"
in Table 1C so that acute radiation syndrome (ARS) includes an
explanation that delayed effects are not taken into account in
determining mortality in this table.  Table 1C, “Acute Radiation
Syndrome” has been deleted from the final Guidance document.  The
Working Group decided that the material in the table did not
substantially add to the development of the Guidance or enhance the
discussion on planning for the protection of radiation workers.  Readers
are referred to the original reference for this table, NCRP 2001. 

3.2 - Clear, Plain Language 

	The Working Group received a few comments expressing support for the
use of clear, plain language in the Guidance, including the suggestion
that a plain language explanation be added to the criteria for
implementing actions to help decision makers understand, consider, and
explain the criteria to the general public.  The commenter noted past
nuclear emergencies in Chernobyl and Goiania, Brazil, where the public
took inappropriate action because of lack of understanding of
information about radioactive materials, and also noted that there is a
tendency to implement actions at lower levels when guidance is unclear. 
The subject matter addressed in these PAGs tends to call for more
technical or scientific language, and is intended for an audience
familiar with radiological emergency response planning.  The Working
Group has, however, revised the document with this comment in mind, and
increased the use of plain language as appropriate.  According to EPA,
the release of the revised 1992 EPA PAG Manual will be supported by
education and outreach that will contribute to the successful
implementation of the Guidance.  

3.3 - Addressing RDDs and INDs Separately

	Several commenters stated that the Guidance should address RDD and IND
incidents separately.  One commenter stated that the proposed PAGs did
not adequately address the significant doses, dose rates, and size of
the impacted area associated with an IND incident.  The commenter
recommended providing a specific early phase worker guideline of 25 rad
with possible extension to 100 rad for lifesaving activities, for IND
incidents.  The commenter also questioned the efficacy of large-scale
evacuation from areas in which the majority of dose had already been
received.  The commenter also pointed to modeling showing that
cumulative doses in the first year following an IND incident would
exceed the intermediate phase 2-rem PAG for distances up to 100 miles
from the epicenter, impacting areas up to several hundred square miles. 
Another commenter was concerned that the proposed Guidance would not be
applicable near the epicenter of an IND incident, or to areas downwind. 
Similarly, another commenter stated that detonation of an IND would
likely come without warning, and that the spread of the radioactive
plume would happen quickly with immediate, unavoidable significant
doses.

	The Working Group agrees that there may be incidents, especially an
IND, that could produce high radiation doses and dose rates, and that
radiation deposition patterns from fallout will vary depending on
numerous factors.  This Guidance only provides a guide for protection of
populations subject to low doses that would be found further downwind of
an IND incident. As noted earlier, the Working Group has determined that
separate guidance must be developed uniquely for the high dose and
dose-rate zones resulting from an IND.  Such guidance with associated
protective actions is complicated by numerous factors in the post-IND
environment; time and space do not permit this discussion here.  In the
interim, this RDD/IND Guidance should be used.

	A few commenters recommended prioritizing lifesaving efforts in the
first days following an IND incident, and suggested providing a separate
index for response workers with IND-specific information.  Several other
comments suggested adding visual aids to illustrate the differences,
particularly in fallout and radioactive decay, between IND and RDD
incidents.  As mentioned above, additional guidance will be developed
for INDs.  However, the worker guidelines for lifesaving should be the
same whether the event is triggered by an RDD or an IND. 

	Two commenters believed that the optimization process for late phase
cleanup was adequate for RDD incidents, but inadequate for IND
incidents.  To the contrary, the Working Group firmly believes that the
optimization process is appropriate for both RDD and IND incidents;
since site-specific optimization is process-oriented, the resulting
cleanup decisions can be made in the same way regardless of the initial
level of contamination, the size of the contaminated area, the type of
technologies to be applied, the cost of the overall cleanup, the
projected future uses of the contaminated lands, or the final target
cleanup goal.  The decision making process will however be more complex
and difficult for an IND, because an IND incident would be much larger
in scope than the typical RDD incident, impact a broad range of land
types or uses (urban, suburban, agricultural, etc.), affect multiple
ecosystems and involve other types of hazards.     

	A State environmental protection agency recommended increasing PAG
flexibility for IND incidents to allow necessary adjustment of action
levels according to available resources, area impacted, and maximization
of public safety.  Another State agency suggested revisions to the dose
chart for responder and worker protection during the initial and
intermediate phases of an IND incident, as doses in excess of OSHA
standards would be expected.  Another stated that the PAGs for an IND
incident should be higher than the PAGs for an RDD incident.  This
commenter added that PAGs for IND incidents should place more emphasis
on using practical methods to maintain doses that would minimize acute
radiation syndrome.  

	As stated earlier, the PAGs in this Guidance are not rigid standards;
rather, they are approximate levels at which the associated protective
actions should be considered, weighing many local and incident-specific
factors.  These PAGs provide the necessary flexibility to allow decision
makers to implement the best possible response to be protective of
emergency workers and the public. Therefore, taking protective action at
higher dose levels for an IND, given particular circumstances, is
consistent with this Guidance. However, the Working Group is fully aware
that additional guidance is needed for responses to IND incidents.  The
development of such guidance is in the planning stages.

4 – Content of PAGs

4.1 – Early/Intermediate Phase

	Several commenters, including State and local agencies, suggested that
the language and exposure values as presented in the Guidance should be
re-examined for consistency and appropriateness with the level of
response (e.g., lifesaving response vs. post-emergency missions
unrelated to lifesaving missions).  The Working Group agrees that these
PAGs and the exposure values for various emergency response actions
should be consistent and believes that the final Guidance accomplishes
this goal.  As stated earlier, separate guidance is being developed for
IND incidents. .  

	A State environmental agency noted that Federal guidance, including the
National Response Plan, indicates that the distinction between the early
and intermediate phase will be blurred during an IND or RDD event. 
These two phases are likely to completely overlap, yet the PAGs indicate
there will be a difference between the two.  The use of response phases
is simply a mechanism to describe incident circumstances and appropriate
protective actions. As shown in Figure 1, (Relationship between Exposure
Routes, Protective Measures, & Timeframes for Effects), and reflected in
the text, the Working Group believes that the Guidance is clear on both
the distinctions as well as potential overlap between the phases. 

	Some commenters suggested that emergency responders should not only
receive medical clearance prior to responding to an incident, but should
also be given the right to give informed consent.  One commenter
stressed that any action taken by emergency responders in an environment
with radiation exposure levels greater than 25 rem should be done only
on a voluntary basis.  The Working Group believes decisions regarding
response worker medical clearance are best handled by the worker’s
employer, subject to applicable regulations.  The Working Group agrees
that workers subject to high radiation doses, in excess of OSHA
regulations, should be on a voluntary basis and has clarified the
Guidance to emphasize this.  

	Another commenter stated that the proposed PAGs overlook the
Intermediate Phase.  According to the commenter, this is the time of the
greatest uncertainty, confusion, and the most interaction between the
victims and the scene.  The Working Group believes that, as stated in
the final Guidance, this phase is clearly described and the PAGs provide
the appropriate protective action guidance for this portion of an
incident. 

	One organization stated that the guides of 2 rem for the first year and
0.5 rem for each year thereafter for the public to return to their
residences is above other public exposure limits commonly used.  The
organization added that the underlying goal or standard be one that is
protective, and then risk management decisions could justify a need to
deviate from that standard as appropriate.  Although the Working Group
agrees with the commenter that the relocation PAG is above other public
exposure limits developed for other purposes, the public exposure
guideline was not intended to apply under emergency circumstances.  All
exposure limits depend on the particular use for which they were
developed.  The PAG is protective of public health and safety for the
emergency contexts to which it applies.

	A State agency also suggested that implementation of the PAGs for the
early and intermediate phases is entirely dependent on the radiological
expertise and instrumentation available at the scene.  The Working Group
notes that commenter’s statement about the dependence on on-scene
expertise and instrumentation could be true of any type of incident in
which hazardous materials are released, not just RDD or IND incidents,
and does not change the Guidance.  In addition, several commenters
proposed that the PAGs for early and intermediate phases are appropriate
for RDD incidents, but would likely not be appropriate for most IND
incidents.  These commenters did not find the proposed early phase PAGs
to be practically implementable, but did find the intermediate-phase
PAGs to be implementable.  These commenters reasoned that the PAGs
should be based on a broad review and analysis of exposure guidance
issued by NCRP, ICRP, and other national and international
organizations, rather than rely only on EPA guidance developed in the
late 1980s.  The Working Group emphasizes that the decision to apply
EPA’s PAGs for the early and intermediate phase was made after
conducting just the type of broad review and analysis that the commenter
recommends.  Specifically, the interagency Working Group of technical
experts came to the conclusion that the basis for the 1992 PAGs remained
the soundest approach to radiological emergency response. 

 On the other hand, several commenters stated that the PAGs for the
early and intermediate phases are implementable.  They noted that States
with nuclear power reactors in their jurisdictions have used the EPA
PAGs for over 20 years and successfully carried out full-scale emergency
response exercises. 

	One commenter made several suggestions regarding specific language in
the Guidance.  The first suggestion was to revise a paragraph in the
language about the early phase which begins with "the response during
the early phase includes…” to include shelter-in-place and
evacuation options.  A second suggestion was to change another sentence
in the early phase to include: "public training and information on how
to quickly size up a building and identify radiation protective areas
based on the size and mass of the building."  The Working Group has
included the first concept in the final Guidance.  The second change,
however, may be appropriate within the context of IND-specific guidance
yet to be developed.  

	This commenter also addressed the following statement in Appendix 4,
second paragraph, first sentence, which begins with "this appendix
describes the examples of measurable guidelines that will be developed .
. ."  The commenter suggested adding specific task areas to the
guidelines, including the following: acquisition and distribution of
dosimetry and high range radiation survey meters to responders,
shelter-in-place guidelines for the first to 48-72 hours, evacuation
guidelines, exposure control guidelines, anti-contamination and
decontamination guidelines, public education and public information
guidelines.

	As noted above, the appendix does not attempt to outline all guidelines
that could be, or ultimately need to be, developed.  The appendix
provides examples of basic guidelines for the benefit of the reader.  It
is expected that State and local agencies will develop other, more
detailed guidelines in preparation for response to such events. 

	A different commenter requested clarification of the statement which
reads "when making radiation dose projections, realistic assumptions
should be used so the final results are representative of actual
conditions."  The commenter asked what was meant by “realistic
assumptions?”  The final Guidance clarifies that assumptions should be
developed by technical experts in coordination with the Incident
Commander, based on the situation at hand.  Exposure assumptions are to
be representative of actual conditions and parameters rather than a
hypothetical maximally exposed individual.

Two commenters noted that, because RDD and IND incidents could occur
with short or no advance notice, the release may be relatively short in
duration, but cleanup and recovery may take months depending on the
levels and types of contamination.  One of these commenters highlighted
that the implementation process appears clear and appropriate for those
familiar with radiological response and recovery.  The Working Group
agrees with the commenters and has provided additional clarification in
the final Guidance.  

	Numerous commenters stated that the forthcoming operational guidelines
will be useful when they are developed.  They thought the discussion in
Appendix 4 of the draft Guidance gave a "big picture" view of access and
release stages, but also believed that an incident-specific document was
needed to address the details.  A few commenters suggested that the
operational guidelines should also include additional information. 
Specifically, additional information should be added in Group F: Release
of Property from Radiologically Controlled Areas to the criteria used to
release controlled material to an uncontrolled area, and to section
(f)(iii) of the appendix - "Radiation Levels for Control of Access to
Radiation Areas,” to provide decontamination procedures and shelter
guidelines.  The Working Group agrees in part, and the forthcoming
operational guidelines will address the commenters’ concerns regarding
sheltering guidelines.  The Working Group also notes that there are
existing sources which contain guidance on decontamination procedures,
though the Working Group recognizes the limitation of current
decontamination technologies for RDD and IND applications. States and
localities should incorporate operational guidelines into their plans
and procedures, and develop training for their personnel.  

	One commenter stated that Figure 1 appears to make the assumption that
an incident will be identified as being an RDD at the onset.  In
reality, depending on location, time of event, and other factors,
identifying the incident as an RDD may take several hours or longer. 
The commenter is correct in its description of likely events after an
incident.  Figure 1 is provided merely as an example of representative
events.  

	One organization asked whether, under any circumstances involving
either an RDD or an IND, it would be advisable to administer
prophylactic drugs prior to the actual event. Generally speaking,
administration of prophylactic drugs, such as potassium iodide (KI),
prior to an RDD event is not advisable.  The unpredictability of such an
RDD/IND incident would make it impossible to know when and where to
administer such drugs, even if it were advisable.  On the other hand,
there could be situations (such as an IND event) where HHS, in
discussions with the Incident Commander, may decide that certain
prophylactic drugs may be beneficial immediately following an event.  In
the assessment of the Working Group’s subject matter experts
concerning the various types of sources that would likely be used in an
RDD, there are none that would benefit from the prophylactic use of KI. 
 In all situations, great care must be exercised to assess the utility
of such drugs and to minimize any adverse health effects that could
occur. 

	The commenter also stated that there appear to be two alternative
actions, each with its own concerns: (1) respond as we currently do or
(2) respond and stand back.  The commenter suggested that the Risk
Management Framework and the three key principles of "broad context,
stakeholder participation, and iteration" should perhaps be applied to
mitigate these concerns, because the first responders are also
"stakeholders" in RDD and IND events.  The Working Group notes that the
Risk Management Framework is intended for use principally in the late
phase.  The Guidance is not intended to instruct first responders on how
to respond to RDD/IND incidents.  Those instructions should be based on
the procedures developed by State and local organizations. 
Organizations seeking additional guidance for the early phase could look
to other reference sources for management of terrorist events involving
radioactive materials, such as provided in NCRP Report No. 138 (NCRP
2001) and to the 1992 EPA PAG Manual and its expected revision.  

	One commenter recommended science-based strategies for protecting the
public and responders.  The Working Group believes that science was
fully incorporated in the PAG development, but also that science is not
the sole basis for protecting the public and emergency workers. 
Decision makers must also consider numerous practical, social, economic,
and related factors.     

4.1.1 – Responder/Worker Protection

	Four commenters expressed serious reservations regarding what they
perceived to be high radiation limits permitted under the current
emergency responder guidelines and were concerned that such limits are
inconsistent with OSHA and NRC guidelines. Another commenter noted that
current guidelines in State Radiological Emergency Response Plans and
other sources state that emergency workers who are dispatched for
missions that potentially expose them to 25 rem or greater may only
undertake the mission voluntarily.   

	In this Guidance levels of exposure for life-saving activities are
consistent with worker dose guidelines presented in the 1992 EPA PAGs
and represent a consensus of the Federal agencies who participated in
the Working Group, including OSHA.  The final Guidance is clear that
missions involving doses in excess of regulatory standards should only
be taken on a voluntary basis and with full awareness of the risks
involved.  The worker guidelines are not rigid limits, but rather define
points at which full disclosure of the chronic and acute risks
associated with high radiation doses should occur.  The Guidance also
recommends using the ALARA (as low as reasonably achievable) principle
for radiation protection, rather than automatically defaulting to a
specific limit for lifesaving efforts.  

	The Guidance is meant to support planning and other preparedness
activities at the Federal, State, and local levels by providing general
information on ways to protect workers.  It is anticipated that Federal,
State, and local responders will use the information in Appendix 1 of
the Guidance (and information from other sources) to develop emergency
plans, standard operating procedures, and training for RDD and IND
incidents.  Regarding concerns about inconsistencies in the level of
protection afforded to emergency responders, the Working Group notes
that the NRC and OSHA regulatory limits are designed for normal,
day-to-day occupational exposures and are not meant to be used for
life-saving activities in high exposure level emergency scenarios. 

	Several commenters expressed reservations about the currently accepted
radiological limits, advocating that proper risk assessments be made
prior to automatically sending in emergency responders during an RDD/IND
event.  One of these commenters added that risk assessments should be
based on actual data, rather than implausible specifications.  Although
the Working Group agrees that risk assessment is an important element of
protecting emergency responders, there may not be sufficient time during
an emergency to perform these assessments in the detail that is normally
expected.  In radiological emergencies some estimation of the dose and
risk must be performed and the worker should be briefed on that
assessment.  Over time and as information is gathered, risk assessments
should be increasingly relied upon for both emergency responder and
public protection.  Appendix 1 of the Guidance provides additional
clarification about the distinction between emergency workers in
occupational settings and in emergency situations.  

	Several commenters suggested that the proposed Guidance does not offer
any clear operational guidelines or strategies for emergency response
and fail to realistically define hazard boundaries.  Operational
protocols, such as those proposed by the commenters, are outside the
scope of this Guidance. 

4.1.2  Training

	A local emergency management agency contended that simple measures for
responder protection could be expanded to include a safety measures
section.  The commenter added that, in order to reduce responder
radiation exposures, personnel should be rotated out of the Hot Zone.  A
labor union commented that health care workers must be protected when
providing care to emergency responders.  Another commenter claimed that
the Guidance must advise the general population of decontamination
measures.  The Working Group agrees that these are all important
considerations; however, they are outside the scope of the current
document.  

	A State agency stated that Appendix 1 should avoid the use of legal and
regulatory jargon, and another commenter suggested that Table 1B
incorporate “Gamma Radiation” into the title because most emergency
workers will only have dosimeters receptive to gamma radiation.  The
Working Group has revised the final PAGs to minimize the detailed
references to regulatory authorities.  The Working Group disagrees with
the second comment; there is no rationale for changing the title of
Table 1B.  

	One commenter argued that the expectation that emergency responders
should receive less than 5 rem would have the effect of a significant
increase in casualties in the event of an RDD or IND incident.  As in
any emergency situation, the Working Group believes that it is essential
that the safety of both the general public and emergency responders be
considered before any response action is taken.  Emergency response
guidance levels represent a balance between the risk to the worker and
the benefit gained in public protection.  Furthermore, there is not an
‘expectation’ that doses will be kept below 5 rem.  Indeed, the
Guidance follows the EPA 1992 PAGs, which state that “Situations may
also rarely occur in which a dose in excess of 25 rem for emergency
exposure would be unavoidable in order to carry out a lifesaving
operation or avoid extensive exposure of large populations.” 
Similarly, the NCRP and ICRP raise the possibility that emergency
responders might receive a dose that approaches or exceeds 50 rem (0.5
Sv) to a large portion of the body in a short time.  Exposure to high
doses presumes that incident commanders determine such exposures are
justified and the emergency responders are informed in advance of the
risks associated with such high exposures.

	One commenter recommended that provisions for exposure to high level
radiation should be made in Appendix 1.  The Working Group notes that
this information will be included in future IND guidance.

	A commenter asked for clarification on where to find guidance that
addresses explosive incidents that are non-nuclear.  Routine protocols
would not cover events such as multiple injuries, ruptured lungs, large
numbers of personnel having disorientation (inner ear equilibrium), and
massive cuts on dozens of personnel due to flying window glass caused by
an IND or RDD.  The response to non-nuclear explosive incidents and
improvised explosive devices (IEDs) are not covered in this Guidance,
though the similarities in response requirements are clear.

	A private company suggested that site cleanup and recovery can follow a
generic checklist for the routine items and could be supplemented based
on the type of radionuclides, the secondary events, and collateral
damage.  The Working Group agrees to some extent with the commenter and
encourages State and local agencies to incorporate this into their
preparedness guidance.   

	One commenter stated that there is an unrealistic assumption that
police, fire, and emergency medical service (EMS) officers who are
designated to serve as Incident Commanders have the skills and knowledge
to make the decisions referred to in these PAGs.  The Working Group
recognizes that Incident Commanders will need to seek out the specific
radiological support they need if put in charge of responding to an RDD
or IND incident.  Incident Commanders should be supported by State and
Federal radiological experts and other radiological professionals, and
as discussed above, should carefully weigh both the risks and benefits
associated with proposed emergency actions.  Local jurisdictions may
need to arrange agreements with neighboring Radiological Emergency
Response Plan States to receive assistance.  One goal of the Guidance is
to encourage States and localities to develop mutual aid plans and
protocols that address radiation protection during an RDD or IND
incident and to develop training for personnel who are likely to serves
as Incident Commanders.  Providing for this training and planning is,
however, beyond the scope of this Guidance.

	One commenter asked if firefighters are expected to refer to these PAGs
before initiating fire suppression operations.  The commenter noted that
most of the nation's firefighters are volunteer personnel who, in many
cases, do not have training in hazardous materials.  As stated earlier,
the Working Group believes that emergency workers who may respond to an
RDD or IND incident should have basic training in radiation protection. 
This includes having the proper training for using protective equipment
and basic measurement equipment necessary for performing their duties.

	A commenter stated that clarification of the term "alternative response
worker" is necessary and suggested using the term "emergency responder"
for the early phase of the incident.  The Working Group is applying the
terms “emergency responder” and  “emergency worker” in both the
early and intermediate phases.  The term "alternative response worker"
has been deleted.  

	Another commenter recommended evacuating the “High Zone” to control
the dose to the population therein.  The commenter further recommended
controlling access to the High Zone to limit the number of
non-contaminated persons entering the most contaminated area, and
excluding all nonessential people.  The Working Group agrees that
actions should be taken to limit the number of people entering
radiation-contaminated areas.

4.1.3 – Public/Environmental Health

	A State environmental agency asserted that the Guidance offers a good
balance between (a) public health and environmental goals, and (b) the
flexibility needed for decision makers to conduct emergency response
actions and address public welfare needs, costs and benefits, technical
feasibility, and societal interests during the response to and recovery
from an incident.  Another State agency believed that public health and
environmental issues were not adequately addressed, and that specifics
need to be added for the elevated levels of radiation and thermal or EMP
effects accompanying an IND event.  The same commenter also stated that
the first responder guidelines were written as though they were directed
at a nuclear power plant emergency, not a nuclear detonation.  

	This Guidance was developed to address the radiological hazards posed
by an RDD or IND incident.  They were not intended to guide response to
non-radiological effects that might be produced by such and incident
(e.g., EMP, or fire). The Working Group agrees that first responders may
be impeded in performing traditional functions during the early phase. 
However, through effective education and outreach activities, drills and
exercises, and well-developed response protocols, the possibility of
impeded responses can be minimized.

A third agency was concerned that responders may be impeded by balancing
appropriate emergency response action with less critical issues.  The
commenter believed that lifesaving measures, fire/damage suppression,
care and transport of victims, and controlling access to the immediate
scene should take precedence over other public welfare needs, costs and
benefits, technical feasibility, and societal interests during the early
phase.  These other concerns are better addressed in the intermediate
phase, according to the commenter.  The Working Group agrees that
lifesaving and fire/damage suppression should be the focus of the early
phase, and the Guidance reflects this priority.  The site-specific
optimization cleanup approach, in which local stakeholders consider
public welfare needs, costs and benefits, technical feasibility, and
societal interests, is designed specifically for the late phase.  

	One organization suggested that sheltering-in-place is likely to be
more protective than evacuation, and thus recommended sheltering as the
preferred protective action. Furthermore, the organization recommended
that the minimum level for initiation of evacuation after a radiological
terrorist event be the same as the 1992 EPA PAG Manual levels for
evacuation under hazardous conditions.  Two additional commenters
mentioned that the threshold for sheltering the public (Table 1) should
be lower than that for evacuation.

	The Working Group agrees that in many cases, sheltering may be more
effective than evacuation to protect the public.  Whether or not
sheltering is the appropriate protective action, however, will depend on
the nature of the incident. Appendix C of the 1992 EPA PAG Manual
recommends sheltering for projected doses anywhere between 1-5 rem, but
that sheltering may take place at lower projected doses.  It should be
noted that decision makers have access to guidelines for exposure for
both evacuation and sheltering. 

	One commenter stated that the level that triggers access control to
radiation areas is unrealistically and unnecessarily low, and that the
public should not be forced to relocate at such low exposure levels. 
Another commenter argued that the proposed guidelines offer the public
less protection from radiation than existing standards set by the NRC
and the EPA.  Two other commenters believed that the proposed threshold
levels were unacceptably high and could lead to a significant risk of
cancer.  They believed that the current threshold levels do not
adequately protect the public and first responders, and therefore should
be brought in line with Superfund cleanup levels.  Another commenter
suggested that decontamination procedures should change based on the
numbers of contaminated individuals and the extent of their exposure.  

	The Working Group disagrees with the commenters that the levels are too
low or too high.  The consensus of the Working Group was that the levels
are (a) appropriate, (b) consistent with existing guidance, (c) employ
the same assumptions about risks from radiation exposure and benefits of
protective action, and (d) use the same principles of optimization that
are the common basis for all other radiation protection guidance. 
Furthermore, these values can be revised downward or upward as
necessary, depending on the unique characteristics of an incident. 
Regarding the argument that decontamination procedures should change
based on the size of the contaminated population and the degree of
contamination, detailed information on decontamination procedures is
outside the scope of this Guidance.  

	One commenter mentioned that it is important to recognize the hazards
inherent in disposing of contaminated wash water if washing is used as a
dose reduction technique.  A citizens’ group advocated for strict
guidelines for the interdiction of contaminated drinking water,
agricultural, and food products.  Another commenter stated that Table 1
needs additional details regarding food and drinking water interdiction,
such as the addition of a time scale.  Another commenter recommended
modifying the exposure route timing for ingestion of contaminated water
and/or food, given that a close proximity to the blast area could
immediately contaminate any food or drink since contamination of skin or
clothing could easily spread to food or drink.  

	The Working Group agrees with the first three commenters that the
implementation issue deserves additional treatment.  The disposal of
contaminated water and solid waste must be factored into the
environmental consequences associated with the response.  PAGs for the
interdiction of contaminated drinking water and agricultural and food
products are contained in the final Guidance.  These PAGs will not
include the extent of details requested by the commenter, e.g., addition
of a time scale, because this information can be found in other sources.
 The Working Group disagrees that proximity to the blast area would
necessarily result in contaminated food and drink.   Regardless, any
food or beverage within a contaminated zone may be disposed of as a
precaution without attempting to apply food and water PAGs, especially
during the early phase; however, the PAGs could be applied.  The
information in Figure 1 is intended to be representative, rather than
serve as a factual description of all potential RDD/IND incidents.  

	A State environmental agency suggested adding more guidance for the use
of prophylactic drugs, specifically guidance for the use of KI and its
limitations. Another commenter recommended having a generic
(standardized) operating plan to conservatively protect the public and
the environment when "radiation doses are not directly measurable and
must be calculated based on measurable quantities such as exposure
rates."  Finally, a commenter suggested that the column divisions in
Table 1C are too broad, especially the 200-600 rad column.

	Although the Working Group agrees that guidance on KI is important, the
reader is referred to the original FDA guidance on the administration of
potassium iodide (66 FR 64046, December 11, 2001), rather than providing
detailed guidance here.  The Working Group does not agree that
standardized approaches are always the most public health protective;
however it agrees that the public must be protected by estimating
exposures as best as is feasible when radiation doses cannot be directly
measured.  The Guidance encourages the use of realistic assumptions in
the absence of dose measurements.  Finally, the Working Group has
removed Table 1C from the Guidance, preferring to reference the original
citation, NCRP Report 138, 2001.

4.2 – Late Phase and Optimization Process

	Although two organizations stated that the optimization process appears
reasonable and sufficiently flexible, the majority of commenters on the
late phase portion of the Guidance, which recommends a site-specific
optimization process, urged the Working Group to amend the Guidance to
include fixed exposure bounds or goals. As examples of specific goals,
one commenter suggested an upper limit of 500 mrem/year and a lower
benchmark of 100 mrem/year with a lower limit of 25 mrem/year for use in
the late phase optimization process; another commenter suggested that
the Guidance include a range within which the optimization process
should be applied, such as 15 – 500 mrem/year.  An additional
commenter proposed their own numeric values for site clean-up
guidelines.  In addition, several agencies maintained that the
optimization process for the late phase may not be effective without
predetermined exposure limit goals, or at least a range of acceptable
limits.  Some of these agencies added that the optimization process, as
proposed, is too open-ended to be effective. Another group of commenters
stated that a flexible process with pre-established goals would be a
better approach to the remediation process.  Additional commenters added
that using the concept of optimization without guidelines would add to
the time involved in the late phase cleanup process.  The commenters
believed that, at a minimum, some goals should be predetermined to give
State and local agencies a target to aim for.  

	The Working Group believes that the site-specific optimization approach
in the late phase offers the greatest flexibility to respond to the wide
variations in circumstances and impacts that may be encountered in
potential IND and RDD incidents, from a small contamination event
confined to a building, to several dozen city blocks, to thousands of
square kilometers stretching across several states.  Each incident will
require a site-specific approach that accounts for the nature of the
incident, extent of contaminated lands and infrastructure, future land
use issues, technical feasibility, public welfare needs, cost, and local
public input.  The Guidance also encourages consideration of
radiological cleanup benchmarks, whether from Federal or State agencies,
or national or international organizations, including standards,
regulations and guidance that may be appropriate to the particular
circumstances of an incident. 

	As stated, pre-established numeric criteria are not recommended because
of the wide variation of potential impacts that may result from RDDs and
INDs.  A small incident, affecting a small area, could likely be cleaned
up to very low levels; however, to clean up a large incident affecting a
large area, such as a large RDD or an IND, to a pre-determined numeric
goal may not be technically or economically feasible.  A pre-determined
cleanup number, or even a range, could be overly prescriptive and
restrain flexibility of State and local officials attempting to recover
an affected site and return it to productive use.  The Working Group
does not believe the Federal Government should require State and local
governments to clean up in a manner that may force the abandonment of a
city or lands impacted by terrorists.  The site-specific optimization
approach incorporates substantive stakeholder involvement, encourages
consideration of cleanup benchmarks, and allows for development of
flexible cleanup options and plans development that meets the
requirements of State/local governments and affected communities, and
that will most likely lead to successful recovery of the impacted city
or lands.  

	A State agency believed that it was unfair to make State and local
response agencies develop guidelines through an involved process of
optimization while in the midst of responding to a radiological
terrorism event.  Another State agency argued that decision makers will
need more than a loose framework to derive sound policy and gain public
confidence.  The same commenter believed that setting uniform cleanup
standards should remain a Federal responsibility.  A third State agency
stated that, without clear goals or a commitment from the Federal
Government to pay for decontamination to a certain standard, the costs
of cleanup and disposal will likely dictate the level of release for
unrestricted use.  According to the commenter, this issue may wreak
havoc in the decision making process.  Therefore, an optimization
process must provide for a complete, defensible, and final decision by
all parties, including the Federal Government, and leave no room for
doubt about cleanup levels, potential health risks, or the standards
used in the decision to release or restrict public use of property.

	Regarding the first comment, the Working Group expects States to plan
and prepare for incidents before they occur, including how contamination
will be dealt with.  This is consistent with Federal, State and local
planning for other types of incidents, both natural disasters and
accidents.  This planning/preparedness process has worked for response
officials located near large industrial facilities and in areas prone to
natural disasters such as flooding, hurricanes, and tornados.  In
response to the second comment, the Working Group believes that by
establishing a Federally-recommended process, State and local officials
have the opportunity to be a significant partner in an integrated,
informed decision making process.  Concerning Federal payment, the
Federal Government has never agreed in advance to pay for cleanup
activities as a result of either a natural or man-made disaster.  
However, nothing precludes the Federal Government from committing funds
for cleanup as part of a recovery.  While cleanup costs are a very
important consideration in the optimization process (it may be cheaper
to isolate an area than to remediate it), other types of costs and
benefits, such as returning to one’s home or school or place of
business, may be just as important.  The increased risk of stress
associated with being away from home may exceed the incremental risk
associated with a lower cleanup level.  Thus, cleanup costs alone should
not determine the cleanup level, but numerous site-specific and
socio-economic factors should also be carefully weighed.  Such factors
will be identified by the technical and stakeholder groups during the
optimization process.  The Working Group agrees that the optimization
process must provide an open and defensible decision. 

	Several commenters addressed various aspects of the optimization
process. A State agency supported the concept of site-specific
optimization, but expressed concerns about its implementation and the
coordination of stakeholder groups.  Another agency similarly supported
the concept of optimization, but articulated that, without predetermined
goals and numerical thresholds, competing interests of stakeholder
groups would lead to substantial delays in the cleanup process.  A State
agency suggested more guidance be provided to explain how to work
through the optimization process.  One other commenter recommended that
additional guidance or references to existing optimization processes be
provided as a template, especially given the goal of developing the
initial optimization process within six months of the incident.    

	The Working Group realizes that implementation and coordination of
stakeholder groups will place time and energy demands on officials. 
Competing interests will be a concern whether an optimization process is
used or not.  The Guidance provides a risk management framework in
Appendix 2, and basic guidance on implementing optimization.  The
Guidance also recommends consideration of benchmark standards and
criteria.  Ultimately, what will make the optimization process
successful will be the inclusiveness of the process and the technical
rigor of the supporting analyses.

	One organization did not believe it was appropriate or necessary for
stakeholders involved in the optimization process to re-examine the
fundamental radiation protection standards that have already been
developed by national and international experts.  Another commenter
suggested that major metropolitan areas identify in advance the
stakeholders that may participate in the optimization process.  One
commenter argued that it was important to include people who are not
strongly invested in the linear no-threshold hypothesis when appointing
technical advisory committees, while another requested that community
members be included as local stakeholders.  The Working Group agrees
with the commenters.  The Guidance does require that States and their
stakeholder groups re-examine radiation protection standards, especially
for their use as benchmarks.  Membership in the advisory committees and
working groups should represent a balance of technical perspectives as
well as interests associated with the land use (residential, commercial,
industrial, tourism, historic value, etc.),   and organizations
concerned with public welfare, including employment, education, and
public safety.  Moreover, States and localities might want to establish
such groups to advise decision-makers for incidents other that RDD and
IND incidents. 

	One commenter recommended that site restoration and cleanup should be
accomplished following an act of terrorism using the available DOE
Documented Safety Analysis (DSA) data accounting for facility/site
design and features incorporated to simplify decontamination and
increase the potential for a timely reuse/reactivation of equipment,
systems, and structures.  The commenter also recommended that the
Working Group quantify the statement that an RDD would be the same order
of magnitude as a nuclear power plant accident.

	The commenter is correct to the extent that DOE procedures would need
to be used for an incident at a DOE facility.  Describing the DOE
regimen, however, would be too detailed for inclusion in this Guidance. 
The Working Group has deleted the statement concerning the magnitude of
RDD and nuclear power plant accidents from this final Guidance.

 4.3 – Long-Term Consequences

	Several commenters addressed long term consequences of an IND or RDD
incident. A few commenters, including a local emergency management
agency, suggested the concept of designating a “Long Term Exclusion
Zone” to indicate that life-threatening radiation will be a factor in
recovery, unlike recovery from a natural disaster. Another commenter
questioned which exposure pathways need to be considered (ground
contamination, foodstuffs, drinking water, etc.) and whether the doses
from such pathways should be considered independently or cumulatively. 
The commenter suggested that more references and recommendations be
provided in this area.  

	The Working Group agrees with the commenters that the impacted area
will need to be divided based on the radiation levels present.  Some
areas will need to be controlled for longer time periods than others and
these determinations will have to be based on the unique characteristics
of the incident.  Regarding which exposure pathways need to be
considered, the Working Group notes that the particular pathways and
exposure parameters depend on site-specific factors and proposed land
uses, but all relevant pathways should be included in risk assessments. 


	A few organizations suggested that, even though a wide range of RDD
scenarios is possible, a numerical range should still be offered for a
long-term cleanup standard. As noted earlier, the Working Group does not
believe that the decision-makers are best served by providing numeric
cleanup values, because they could be restrictive when flexibility is
most needed to accomplish cleanup and recovery.  But, the Working Group
encourages referencing existing radiological regulations and guidance as
benchmarks in the optimization process.

	Several commenters stated that the proposed long-term dose limits would
result in an unacceptably high cancer risk for the general public, and
echoed other comments that the Guidance should be revised to use EPA
Superfund cleanup standards.  Expressing a contrary view, another
commenter suggested that radiation in low or moderate doses may actually
be beneficial to health, rather than lead to an increased risk of
cancer.  The Guidance, does not propose long-term exposure limits.  

5 - Commenters Proposing Additional Topics for the Guidance

5.1 - Availability of Radiation Monitoring Capabilities

	Several commenters stated that the use of radiation detection and
monitoring equipment should have received additional consideration in
the Guidance.  Four commenters stated that the Guidance should not
assume that there will be radiation detection and monitoring equipment
available for first responders at the onset of an RDD or IND incident. 
Two commenters supported the use of radiation detection and monitoring
equipment, but were unsure if such equipment is currently suitable for
responding to an RDD or IND incident.  Two other commenters emphasized
that there are alternative protective actions, such as evacuation, that
should occur prior to the use of radiation monitoring.

	The purpose of this Guidance is not to inform the reader on the use of
radiation detection equipment.  The early and intermediate PAGs are not
based on any assumption that radiation detection and monitoring
equipment will be available at the onset of an RDD or IND incident.  The
PAGs do assume that State and local response organizations would revise
their plans and procedures to make radiation detection and monitoring
equipment available in support of radiation protection during an
incident.  Regarding the final comment, the Working Group agrees that
protective actions can, and should, be made prior to the availability of
field measurements where appropriate.  This would be the case for any
sudden incident in which protective actions must be taken promptly to be
effective.

5.2 - Education/Training for Response and Medical Personnel

	Numerous commenters stated that additional education and training for
response personnel should be incorporated into the Guidance.  A few
commenters supported prioritizing training for local responders above
that of the Federal Government and the general public, because the local
responders will be the first on the scene of a radiation incident. 
Several others supported the notion of adding emphasis on education in
order to provide a clear understanding of RDD and IND incidents with
comprehensive planning in advance of such an incident.  Additionally, a
local emergency management agency expressed the need for widespread
public education, media relations, and Public Information Officer (PIO)
operations. 

	Even though this Guidance is not intended to provide training
information, the Working Group agrees that training, drills, and
exercises for local response personnel and volunteers (i.e., fire,
emergency medical service, law enforcement, public health, emergency
management, public works, hazardous materials, hospital and other
medical personnel) are essential to an effective response to an RDD or
IND incident.  Everyone who would potentially be involved responding to
an RDD or IND incident needs training to ensure they have the knowledge,
skills and abilities to perform their duties.  It would be optimal to
have integrated training activities which involve Federal, State and
local officials and the private sector.

	A few commenters commended the current Guidance and believed that
additional funding should be made available to provide background
information to responders and the public.  Several commenters requested
that additional funding be devoted to RDD/IND Guidance implementation,
training, drills, and exercises for responders at all levels.

	As noted above, a comprehensive training and outreach effort is
anticipated after the publication of the revised 1992 EPA PAG Manual.  

5.3 - Radiological Terrorism Event as a Crime Scene

	A few commenters stated that the Guidance should evaluate the need to
balance local responder needs to respond to affected public,
environment, economic, and general health and safety, and the Federal
Bureau of Investigation’s (FBI’s) needs to investigate a crime
associated with the terrorist incident.  One of these commenters stated
that State and local officials are not familiar or experienced with
responding to events that would involve the FBI.  Another of the
commenters recommended adding to the PAGs information specific to crime
scene investigation, preservation of evidence, and interaction between
Unified Command and the FBI, because State and local responders do not
have experience responding to radiological terrorism.  

	The inclusion of information specific to law enforcement operations and
criminal investigations is outside the scope of the Guidance.  The need
of law enforcement coordination during terrorism incident response in
early and intermediate phases needs to be in accordance with the
National Incident Management System (NIMS) for cases of terrorism.  If
an RDD or IND incident occurs at a Federal facility or involves Federal
materials, the representatives in the Unified Command may change
appropriately and the response will be according to procedures.     

5.4 - Medical Management for Mass Casualty Events

	Several commenters stated that the Guidance should include additional
language regarding medical mass care.  One agency identified a number of
issues that should be mentioned when providing guidance on mass casualty
scenarios, including setting protection levels for pregnant women. 
Another supported language that included specific lifesaving actions as
a top priority.  One commenter believed that the Guidance should speak
to the need for a certain level of control over the concerned public,
which will demand immediate mass care.  Additionally, other commenters
supported the idea that the Guidance should focus additional attention
on the psychological impact of an RDD or IND attack. 

	Medical management for mass casualty events is not the purpose of this
Guidance.  Medical management for large radiological and nuclear
incidents is being addressed at the Federal level by DHS and the U.S.
Department of Health and Human Services (HHS).  Protection of pregnant
women and injured individuals are also important issues and they are
being addressed in other guidance provided by HHS.  HHS has created a
Radiological Event Medical Management web site (http://www.remm.nlm.gov)
primarily to provide guidance for health care providers about clinical
diagnosis and treatment during mass casualty radiological/nuclear
events. Although the Working Group agrees with the commenter that
lifesaving should be the top response priority, lifesaving actions needs
to be considered with the risk to the emergency responders.  Although an
RDD or IND attack would present serious psychological implications for
the public, consideration of such effects is not within the scope of
this Guidance.  

	One commenter stated that the levels presented in the Table 1 may not
be appropriate for RDD and IND incidents.  To the contrary, the Working
Group has determined the values in Table 1 to be an appropriate
application of current practice and guidance, with the exception, as
noted earlier, of the near-in high radiation zones following an IND.

5.5 - Other

	Numerous organizations and individuals provided comments on a wide
variety of topics indirectly related to the Guidance.  These comments
range from questioning the use of traditional guidance in the drafting
of the Guidance to private industry offering their products in support
of these PAGs. 

One commenter presented the linear no-threshold (LNT) theory to
demonstrate the biphasic dose response curve and was disappointed that
the document does not recognize current radiation protection standards
based on the LNT theory.

Two commenters requested that the Working Group keep records of
exposures, injuries/illness, training, monitoring techniques, lessons
learned and post them on the Working Group web site.

One commenter suggested the need to perform surveys of remote locations
contaminated by persons fleeing the scene.  

One commenter suggested the following: (i) members with fallout shelter
operations and exposures control backgrounds should be added to the work
group; (ii) fallout radiation and decay should be described; and (iii)
electromagnetic pulse be added to the list of IND effects.

One commenter pointed out that the FEMA Radiological Emergency
Preparedness Handbook intended to replace the Radiological Emergency
Preparedness Exercise Manual has not been issued. 

Two commenters expressed concern about the radioactive waste transported
by truck each year, which is an easy terrorist target.

One commenter requested an additional section showing agency integration
to prevent functional redundancy.  

One commenter offered a product described as a first responder kit for
human skin decontamination.

	The Working Group notes that these comments are beyond the scope of
this Guidance. 

6 - Impact on States, Counties, Municipalities, and Utilities

	Numerous commenters, including several State agencies, believed that
the Guidance should be written with the understanding that the immediate
response to an RDD and IND incident will be a bottom-up approach, with
State and local agencies responding first, followed in turn by Federal
resources.  One agency expressed concern that the Guidance is written
with the assumption that the Federal response will be immediate when it
could possibly be hours away.  Additionally, the commenter believed that
there needs to be consistency at the Federal level in terms of defined
roles and Medical Emergency Radiological Response Team (MERRT)
radiological training.  A State health agency was concerned that,
similar to the NUREG-0654/FEMA-REP-1, Rev. 1 (Criteria for Preparation
and Evaluation of Radiological Emergency Response Plans and Preparedness
in Support of Nuclear Power Plants) and the EPA PAG Manual, the Guidance
will evolve into de facto rules, with the possibility that if States and
local agencies do not follow the Guidance, they will be ineligible for
FEMA funding. In a related comment, another organization stressed the
need for making additional sources of funding available to State and
local responders.

	This Guidance states that the initial response to an IND or RDD
incident will be conducted by State and local first responders.  This is
established in the NRF and is followed in this Guidance.  That said,
Federal resources should be flowing quickly to support the State and
local response.  The NRF, with the Nuclear/Radiological Incident Annex,
will guide the integration of Federal, State, and local resources for
RDD and IND incidents.  The Working Group does not agree with the
comment that the Guidance will become de facto rules.  The current EPA
PAGs have been in existence for over 20 years and they have not become
regulations, although, they have been widely adopted by Federal, State
and local decision makers for use in their response plans and
procedures.  The Working Group does not agree with the comment about the
effect on State and local agencies’ funding.  The Guidance is not
designed to be used to determine eligibility for either response or
recovery funding.

	Several commenters emphasized that proper guidance must be developed by
incorporating the Federal response into the State and local framework,
and not the other way around.  The commenters identified the Nuclear
Incident Response Team (NIRT) as a State-controlled capability.  In
addition, two commenters requested additional discussion on how the
Federal response will integrate with the established State and local
response, and clarification on which agencies will take the lead on
specific tasks.  	As stated above, this Guidance is designed to be
compatible with the NRF.  Also, in radiological incidents, NIRT assets
are under the authority and control of DHS, pursuant to the Homeland
Security Act of 2001.  

	A State environmental agency disagreed with the comments above and
believed that the process is reassuring in that the Guidance allows for
joint decision making at all levels.  This organization, as well as
another State environmental agency, found the response and recovery
overview useful as well, but asked which specific scenario would result
in the State as the lead agency.  This commenter was also concerned that
the technical work group for the optimization process will not include
the needed full stakeholder participation.  Noting that the Guidance
calls for the Federal Government to take the lead throughout this
process, the commenter believed that this could preclude certain other
groups from taking an active participatory role.  

	The Working Group believes that the Federal Government’s role is to
support the State and local decision makers and does not anticipate
assuming control over the cleanup.  The Guidance has been modified to
make this clear.  In some incidents, Federal agencies may have statutory
authorities which must be applied in the decision making process.  The
Federal Government must work hand-in-hand with State and local decision
makers to develop and implement the best possible cleanup.   

	The Working Group notes that the optimization process is open and
transparent, and that the technical work group will be constituted by
the appropriate experts.  The Working Group also notes that the
technical working group is not intended to include stakeholders; a
companion stakeholder working group is designed expressly for
stakeholder involvement.  Indeed, the purpose of the optimization
process is to assure a diversity of input to guide the way to the most
effective recovery.    

	On the issue of State and local resource availability, a local
emergency management agency stressed the need to incorporate the
resources of States with those of nuclear power plants.  The agency
noted that nuclear power plants already have personnel and equipment to
address a radiological incident.  One organization noted that State and
local authorities do not have the resources available for long-term
cleanup.  Therefore, according to this commenter, the Federal Government
should plan to assume responsibility for cleaning up RDD and IND
terrorist events, such as those presented in the Guidance.  A State
emergency services organization stated that Appendix 3 does not
adequately address the full assets and capabilities that States bring to
the response, thus creating a large gap in the implementation of the
plan.  

	It is reasonable to consider the resources of nuclear power plants as a
useful supplement to a governmental response, if available and
appropriate.  Available private resources should be factored into State
and local plans and procedures.  Although State and local resources
might not be adequate to fund a cleanup, these entities must be actively
involved in the decision-making and implementation.  Mutual aid
agreements may be drafted between nuclear power plants and other States
or local agencies.  The Working Group also notes that it is not the goal
of Appendix 3 to delineate the complete role of State and local
officials in the response or to identify all potential resources. 
Rather, the Appendix aims to provide an overview of the
Federally-recommended cleanup approach.     

	A local emergency response organization asked why they had not been
consulted in the drafting of this Guidance.  As stated above, the
Working Group consulted with a limited number of State radiological
experts, who thereby contributed to this Guidance.  The public comment
process provided for broader stakeholder input.

	One commenter suggested that the State and local agencies need to be
intimately involved up-front in the planning process and not as an
afterthought, and also recommended intermediate phase examples could
help, clarifying the "immediate intermediate" actions from the
"non-critical" actions.  The Working Group agrees that State and local
agencies need to be intimately involved in all levels of planning and
preparing for responding to RDD/IND incidents.  The Working Group
encourages State and local agencies to utilize this Guidance in their
planning and preparedness.  

	The same commenter suggested that focused response, allowing for a vast
number of potential targets and dynamic circumstances, is "almost
impossible," because nuclear reactors are located in semi-rural
settings, and chemical facilities are not.  Research reactors are
located in the middle of a college/university campus, in the heart of a
town or on its outskirts, usually near main roads that are congested at
peak hours of the day. These scenarios need to be addressed in a generic
fashion to foster State and local involvement in the planning stages. 
The Working Group does not agree with this comment, and no change has
been made to these PAGs. 

7 - International Collaboration

	An international agency stated that international notification should
be a necessary component of the Guidance because it is required under
the terms of the Convention on Early Notification of a Nuclear Accident.
 The Working Group believes that the inclusion of international
notification is beyond the scope of this Guidance. 

 Manual of Protective Guides and Protective Actions for Nuclear
Incidents, EPA400-R-92-001 (May, 1992).

 The primary occupational safety and health standard for emergency
response is the Hazardous Waste Operations and Emergency Response
(HAZWOPER) standard.

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