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FEMA REP-13 (12/86)

GUIDANCE ON OFFSITE EMERGENCY RADIATION MEASUREMENT SYSTEMS
NON-DAIRY FOOD PATHWAY

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The third of a series of guidance documents on offsite instrumentation prepared by the Federal Radiological Preparedness Coordinating Committee, Subcommittee on Offsite Emergency Instrumentation. This report provides guidance on the selection and use of radiation instrumentation and methodologies that are currently available to detect and measure radioactive contamination, in the event of a nuclear accident at a light water nuclear power plant, with emphasis on the measurement and evaluation of nuclides in potable water and non-dairy food to determine the dose commitment to individuals. The radionuclide concentrations warranting emergency actions for potable water and edible plants are derived from the Food and Drug Administration protective action guides. Protective actions and monitoring requirements are discussed. Several alternatives for field monitoring of foodstuffs and water are presented. However, the recommended procedure for monitoring foodstuffs is field sampling in predetermined areas followed by laboratory analyses. The recommended procedure for monitoring water is collection of samples at water purification plants followed by analyses performed by experienced technical personnel.

Please provide a summary of State policies regarding the use and
distribution of potassium iodide.

State policies on the use and distribution of potassium iodide (KI)
reflect the guidance contained in elements J.10.e. and J.10.f. of
NUREG-0654/FEMA-REP-1. Under J.10.e., State and local governments
are required to make provisions for the use of KI for emergency
workers. Also, similar provisions should be made for institutionalized
persons wherein immediate evacuation is not possible. Under J.10.f.,
State and local governments are given discretion in determining if
provisions will be made to provide KI to the general public.
If they
opt to provide KI to the public, then their emergency plans should
document the method by which decisions by the State Health Department
for administering KI are to be made and the predetermined conditions
under which KI may be used.

FEMA coordinated the development of a Federal policy statement
through the Federal Radiological Preparedness Coordination Committee
on the distribution of KI around nuclear power plants. This policy was
published in the Federal Register on July 25, 1985, and is attached.

The specific procedures for providing KI to emergency workers are set
forth in all State and local government emergency response plans.
Only a few (5-7) States have opted to make provisions for the use of
KI for the general public.

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The New Hampshire and Massachusetts policies on the distribution of potassium iodide are:

NEW HAMPSHIRE

General Public--Potassium Iodide shall not be made available by the
State to the general public. It is legally available to individuals
who, based on their own personal analysis, choose to have the drug
immediately available.

Emergency Workers--Potassium Iodide will be made available, in the
event of a radiological emergency, to emergency workers. The Potassium
Iodide shall be ingested by emergency workers only after instructions
to do so from the New Hampshire Director of Public Health or designee.
Institutionalized Individuals--Potassium Iodide will be made available,
in the event of a radiological emergency, to institutionalized
individuals. The Potassium Iodide will be made available to be
ingested only after instruction to do so by the New Hampshire Director
of Public Health or designee.

MASSACHUSETTS

It is the decision of the Radiation Control Program of the Massachusetts
Department of Public Health that Potassium Iodide (KI) not be stockpiled
for distribution during a nuclear power plant incident nor will
administration of KI be recommended for the general population.
the discretion of the Commissioner of Public Health, KI will be
recommended for use by emergency personnel only in extraordinary
circumstances. In this case the utilities will provide the KI to be
used by emergency workers.

At

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GENCY

Federal Emergency Management Agency

Region I J.W. McCormack Post Office and Court House
Boston, Massachusetts 02109

July 9, 1986

Mr. Robert J. Boulay

State Emergency Management Director
Massachusetts Civil Defense Agency
and Office of Emergency Preparedness
P.O. Box 1496

400 Worcester Road

Framingham, Massachusetts 01701

Dear Mr. Boulay:

Last January, you requested that FEMA comment on a memorandum prepared by Thomas Dignan, Counsel for the New Hampshire Yankee Division of the Public Service Company of New Hampshire. A copy of that memorandum is enclosed.

The enclosed letter from the Nuclear Regulatory Commission analyzing the Dignan memo was developed in close coordination with FEMA and represents the combined views of both NRC and FEMA.

We apologize for the delay in responding to your request. Please call if you have questions.

Sincerely,

Ed Morn

Edward A. Thomas
Chief

Natural and Technological Hazards Division

Enclosures

CC:

Richard Strame
Terry Harpster

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In your memorandum of January 23, 1986 to Joseph Flynn, you communicated the request of Robert Boulay, Civil Defense Director for the Commonwealth of Massachusetts, that the Federal Emergency Management Agency (FEMA) and the Nuclear Regulatory Commission (NRC) review and comment upon a memorandum of law prepare by Thomas Dignan, Counsel for Public Service Company of New Hampshire. In his memorandum, Mr. Dignan addressed what he considered to be three misconceptions about offsite emergency response planning as it relates to the Seabrook Station.

I recently received a letter from Edward Christenbury, Director and Chief Hearing Counsel, Office of the Executive Legal Director (OELD) of NRC, which responds to your request. A copy of that letter is attached. The legal discussion in that letter reflects the combined views of our respective offices. I concur in Mr. Christenbury's analysis of the Dignan memorandum.

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In response to a request made by Edward Thomas of FEMA Region I, we have evaluated, in conjunction with Joseph Flynn of your office, an undated memorandum prepared by Thomas Dignan of Ropes and Gray on behalf of the applicants for the Seabrook nuclear plant ("Dignan Memorandum", a copy of which is attached Our Attachment A). 18 evaluation is set forth in the following discussion.

The Dignan Memorandum addresses what are described as "three misconceptions" pertaining to offsite emergency planning for the Seabrook nuclear plant, and concludes that they are "false as matter of law" (Dignan Memorandum at 1). These purported "misconceptions" are as follows:

A.

B.

That the plans must be shown to guarantee that no
adverse effects on the public health and safety will
occur no matter what kind of accident occurs at
Seabrook.

That it must be demonstrated that the plans will assure
that all persons located in the Emergency Planning Zone
or some certain portion of it can be evacuated in some
certain time.

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1It should be noted, however, that under the Commission's regulations, 10 CFR 50.3, only written regulatory interpretations provided by the General Counsel will be recognized as binding upon the Commission.

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