-27 15) FEMA REP-13 (12/86) GUIDANCE ON OFFSITE EMERGENCY RADIATION MEASUREMENT SYSTEMS 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 State policies on the use and distribution of potassium iodide (KI) FEMA coordinated the development of a Federal policy statement The specific procedures for providing KI to emergency workers are set -28 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 Emergency Workers--Potassium Iodide will be made available, in the MASSACHUSETTS It is the decision of the Radiation Control Program of the Massachusetts At GENCY Federal Emergency Management Agency Region I J.W. McCormack Post Office and Court House July 9, 1986 Mr. Robert J. Boulay State Emergency Management Director 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 Natural and Technological Hazards Division Enclosures CC: Richard Strame 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. De 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 That it must be demonstrated that the plans will assure 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. |