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Introduction. DOE Order 151.1C was published in 2005The revised Emergency Management Guide (EMG) was released in 2007In order to address questions on current policy, guidance and implementation issues, a process of Frequently Asked Questions (FAQs) was established by NA-41 in 2006. Introduction.

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1. The DOE/NNSA Emergency Management System in 2009 A Forum on Current Policy, Guidance and Implementation Issues Jim Powers Dave Freshwater Office of Emergency Management National Nuclear Security Administration U.S. Department of Energy Jim Jamison Greg Martin Science Applications International Corporation (SAIC) May 4, 2009

2. Introduction DOE Order 151.1C was published in 2005 The revised Emergency Management Guide (EMG) was released in 2007 In order to address questions on current policy, guidance and implementation issues, a process of Frequently Asked Questions (FAQs) was established by NA-41 in 2006

3. Introduction Support for a FAQ process can be found in DOE O 226.1A which requires that “… DOE directives or site-specific requirements that conflict, are unclear, or are incomplete … will be brought to the attention of the responsible DOE Headquarters policy organization (the Office of Primary Interest) for resolution.”

4. Introduction If an official interpretation of the requirements in DOE O 151.1C or guidance in the DOE G 151.1-series is needed: The NNSA Associate Administrator for Emergency Operations serves as DOE’s primary point of contact for all emergency management activities Questions or requests should be submitted directly to the Office of Emergency Operations Questions and accompanying interpretations/ clarifications are posted as FAQs on the EMI SIG website

5. Describe FAQ Process Review clarifications (e.g., FAQs) recently issued by NA-41 Review specific topics for which clarifications are now under development or being considered Solicit field experiences and oversight observations that may indicate the need for additional clarification of requirements or guidance Purpose of Workshop

6. FAQ Process Assess a question to decide its value as an FAQ for the complex Respond directly to the source of the question or go forward with FAQ process Modify question to remove program-specific information Expand or decrease scope Develop FAQ and review internally in NA-41 Release on the EMI SIG Website

7. FAQ Process Total Number of FAQs since process was initiated is 38 Of the 38, two have been revised Timely response to requests is a significant problem area: Time to respond varies from 1 month to >12 months Reasons for delays: Difficulty in developing a generally applicable response from a site-specific question Choosing the appropriate content to accurately reflect the intent of the Order/guidance Ensuring that the response constrains the applicability to the intended scope Basically a difficult question Sometimes NA-41 is simply busy … REALLY!

8. FAQ Process Goal is to reduce the time for response to an average of two months for the majority of FAQs When submitting a question, please indicate the time urgency associated with the FAQ issue/response

9. FAQ Review

10. FAQ Review Review of Recently-Issued FAQs Introduce the issue/question (origins, background, etc.) Answer provided (in the final FAQ) Discussion of relevant input to the answer, existing Order and/or Emergency Management Guide (EMG) language, other considerations, etc. Solicit questions, comments, discussion: Has anybody out there used this? What was the effect? Any further clarification/amplification needed?

11. FAQ Review Open Discussion of FAQ Issues The "Issues Parking Lot" No AD LIB policy-making here Questions that cannot be answered quickly will be tabled in the "Issues Parking Lot" Answers will be provided later Via EMI SIG listserve notification At end of this forum In new FAQ/clarification

12. Hazards Screening and Analysis (and Consequence Assessment)

13. FAQ: Selection of ARF, ARR or RF Values for EPHA Analyses The Background… A nuclear facility EPHA used median values of source term parameters from DOE HDBK-3010-94 Facility DSA used bounding parameter values for same scenario Question: Is non-bounding EPHA approach consistent with EMG guidance? Several elements of EMG apply NA-41 determined that a general clarification was needed

14. FAQ: Selection of ARF, ARR or RF Values for EPHA Analyses The Question (as generalized)… Under what conditions is it appropriate to use Airborne Release Fraction (ARF), Airborne Release Rate (ARR), or Respirable Fraction (RF) values other than the bounding values from DOE-HDBK-3010-94 in Emergency Planning Hazards Assessment (EPHA) analyses? _____________ DOE-HDBK-3010-94 Chg 1. Airborne Release Fractions/Rates and Respirable Fractions for Nonreactor Nuclear Facilities. March 2000.

15. FAQ: Selection of ARF, ARR or RF Values for EPHA Analyses The Answer (in brief)… Overall analysis approach encouraged by EMG is more “realistic” than “bounding” DOE HDBK-3010-94 data should be “…critically evaluated for applicability in each situation…” Select source term parameter values that best represent the actual material and phenomena being modeled Median values may be justified: On basis of experimental data or site experience Overall strong conservative bias in the analysis

16. FAQ: Selection of ARF, ARR or RF Values for EPHA Analyses The Reasoning… Excessive conservatism in Technical Planning Basis not necessarily a good thing Unnecessary -- program should have “stretch” capacity Credibility with planning partners Can increase program implementation costs Consistent with EMG, on the whole 95% dispersion conditions (2.6.2) “Realistic” MAR for screening (A.2.2), “Realistically analyzed” (2.2, 2.5.1), “Realistic” LPF values (2.6.1) Screening on actual inventory when no limit exists (App. A) is more consistent with a “realistic” vs. “bounding” approach

17. FAQ: Chemical Mixture Methodology (CMM) in Emergency Response The Background… CMM approved by SCAPA (2004) Methodology paper published (1999) CMM workbook released for use in (2004) Recommended in DOE G 151.1-2, Appendix F (2007) Primarily for EPHAs & planning (prospective) analyses

18. FAQ: Chemical Mixture Methodology (CMM) in Emergency Response The Question… Can the SCAPA-approved Chemical Mixture Methodology (CMM) be used in emergency response as well as for emergency planning?

19. FAQ: Chemical Mixture Methodology (CMM) in Emergency Response The Answer (in brief)… If used in planning, CMM should be available for use in response Same mix & release type: Scaling of EPHA results possible Possible use in early phase of response Different mix or release type: More time & effort needed Likely useful only in later response phases

20. FAQ: Chemical Mixture Methodology (CMM) in Emergency Response The Reasoning… CMM may provide more refined assessment of hazard for some scenarios Expectations need to be modest -- time pressures will usually limit the use of CMM to later phases of response

21. FAQ: Use of the DOT ERG for Response to Hazardous Material Release Events at Burial Sites The Background… Hazards Survey/EPHA requirements do apply to burial ground remediation No hazard-specific response tools (EALs, PAs) available for "unknown hazard" dispersal event during unearthing activities Dispersal event with unknown waste is similar to transportation event with unknown cargo

22. FAQ: Use of the DOT ERG for Response to Hazardous Material Release Events at Burial Sites The Question… Could the DOT Emergency Response Guidebook (ERG) Guide Number 111 (Mixed Load/ Unidentified Cargo) provide a reasonable basis for initial response to actual or potential release events involving unknown hazardous material being unearthed during burial site remediation?

23. FAQ: Use of the DOT ERG for Response to Hazardous Material Release Events at Burial Sites The Answer (in brief) … ERG #111 could serve as reasonable basis for initial response to such events Initial protective actions EALs (following approach of FAQ on Classification of Onsite Transportation Accidents) Other specific ERGs may apply for specific types of material expected in a burial ground (e.g., #161 for low level rad waste)

24. FAQ: Use of the DOT ERG for Response to Hazardous Material Release Events at Burial Sites The Answer (con’d) … EPHA analysis required if both type and quantity can be determined Transition from ERG-based response to the site's DOE O 151.1C planning/preparedness program must be clearly defined Fixed timeframe; or Activity-based milestone (external to DOE O 151.1C requirements)

25. FAQ: Use of the DOT ERG for Response to Hazardous Material Release Events at Burial Sites The Reasoning… If the hazard is truly unknown, any EPHA analysis is purely hypothetical ERG is a proven tool for effective response to comparable situations Goal: operate under the ERG guidance only until the material comes under an EPHA-based (151.1C-compliant) program

26. Leased Facility Issues

27. FAQ: DOE-Owned Leased Facilities The Background… DOE O 151.1C paragraph 4.a.(15) requires that arrangements with lessees must effectively integrate the activities of a DOE-owned leased facility into the DOE/NNSA site-wide emergency management program.

28. FAQ: DOE-Owned Leased Facilities The Question… What is a DOE-owned leased facility, and does this paragraph apply to an offsite facility operated by a DOE contractor?

29. FAQ: DOE-Owned Leased Facilities The Answer (in brief)… A DOE-owned leased facility is a facility within a DOE/NNSA site that is leased to others for non-DOE work. Requirement does not apply to offsite facilities that are leased by a DOE/NNSA contractor for the purpose of conducting DOE work

30. FAQ: DOE-Owned Leased Facilities The Reasoning… This FAQ simply clarifies the language of the Order.

31. FAQ: Annual Inventories for DOE- Owned Leased Facilities The Background… For DOE-owned leased facilities, DOE O 151.1C requires that tenant's hazardous material inventories be reported to site emergency management organization annually and prior to significant changes to the facility or inventories.

32. FAQ: Annual Inventories for DOE- Owned Leased Facilities The Question… What does the "annual inventory" requirement mean? What constitutes a "significant change" in facility inventory?

33. FAQ: Annual Inventories for DOE- Owned Leased Facilities The Answer (in brief)… The "annual inventory" requirement exists in the Requirements (General) section of the Order [paragraph 4.1 (15)b] and must be implemented through "arrangements with lessees" Represents a minimum obligation on the part of the leased facility for effectively integrating its activities into the site-wide emergency management program The inventory should be as detailed and comprehensive as the input required for the Hazards Survey process for an onsite DOE facility

34. FAQ: Annual Inventories for DOE- Owned Leased Facilities The Answer (con’d) … "Significant changes" in facility or inventory might: Result in an Unreviewed Safety Question (USQ) for a nuclear facility or an Unreviewed Safety Issue (USI) for an accelerator Increase consequences for an analyzed scenario Add potential OEs to technical planning basis New material (not previously screened) Increase quantity of material already screened out

35. FAQ: Annual Inventories for DOE- Owned Leased Facilities The Answer (con’d) … Requirement can be met by establishing maximum quantities not to be exceeded by lessee without notifying site emergency management Then, “significant change" will be equivalent to “exceeds agreed maximum”

36. FAQ: Annual Inventories for DOE- Owned Leased Facilities The Reasoning… Clarification was needed since the "annual inventory" requirement must be implemented through "arrangements with lessees" Definition/interpretation of "significant change" needed to be consistent with that used for site facilities Need for guidance on an acceptable approach for addressing “significant changes”

37. Readiness Assurance

38. FAQ: Role of Evaluation Criteria in Annual Self Assessments The Background… DOE O 151.1C and Contractor Requirements Document (CRD) require annual self-assessment of emergency management programs. CRD requires that program assessments: "…must be based on specific standards and criteria, issued by the Director, Office of Emergency Operations."

39. FAQ: Role of Evaluation Criteria in Annual Self Assessments The Question… What is the role of the evaluation criteria from DOE G 151.1-3, Appendix D, in conducting self-assessments?

40. FAQ: Role of Evaluation Criteria in Annual Self Assessments The Answer (in brief)… The "…specific standards and criteria…" referred to in the CRD are those published in DOE G 151.1-3, Appendix D Order intends that those criteria be used in annual self-assessments Criteria are to be used to judge both anticipated performance (program evaluations) and actual performance (exercise evaluations)

41. FAQ: Role of Evaluation Criteria in Annual Self Assessments The Reasoning… This FAQ simply clarifies the language and intent of the Order.

42. FAQ: Annual Self-Assessments and Exercises The Background… DOE O 151.1C and CRD require annual self-assessment of emergency management programs As clarified by previous FAQ: The "…specific standards and criteria…" referred to in the CRD are those published in DOE G 151.1-3, Appendix D The order intends those criteria to be used in annual self-assessments

43. FAQ: Annual Self-Assessments and Exercises The Question… Does the Order require that ALL of the emergency management Program Elements be self-assessed each year, or can the assessments be spread out over a number of years and still satisfy the Order requirement? What role do exercises play in satisfying the self-assessment requirement?

44. FAQ: Annual Self-Assessments and Exercises The Answer (in brief)… The Order intends that ALL Program Elements be self-assessed by the contractor annually However, each annual assessment of a program element need not address ALL aspects, tasks and functions (as reflected in the evaluation criteria) ALL aspects, tasks, and functions do need to be addressed over a period of not more than 5 years Exercise evaluations can and should be part of annual self-assessments

45. FAQ: Annual Self-Assessments and Exercises The Reasoning… For an effective self-assessment program, the annual self-assessment must address each program element, but only needs to cover ALL aspects, tasks and functions of each (i.e., all evaluation criteria for a specific Program Element) over a 5 year time frame A reliable self-assessment of program readiness should include an evaluation of both the documented program bases, the plans and procedures, and preparedness activities, and actual performance in emergency response (e.g., exercises)

46. Categorization, Classification and the ERG

47. FAQ: Role of the ERG in Categorizing Offsite Transportation OEs The Background… DOE 151.1C defines an Operational Emergency (OE) for offsite DOE transportation activities: "Any accident/incident involving an offsite DOE/NNSA shipment containing hazardous materials that causes the initial responders to initiate protective actions at locations beyond the immediate/affected area."

48. FAQ: Role of the ERG in Categorizing Offsite Transportation OEs The Background (con’d) … The Department of Transportation (DOT) Emergency Response Guidebook (ERG) provides general guidance for first responders upon arrival at a transportation accident Responders will “isolate” the surrounding area by establishing an Initial Isolation Zone. All persons will be directed to move out of the Isolation Zone. Responders will assess the situation to determine the need to extend protective actions beyond the Initial Isolation Zone in order to protect the emergency responders and the public

49. FAQ: Role of the ERG in Categorizing Offsite Transportation OEs The Question… What is the "immediate/affected area" and what would cause first responders to initiate protective actions at locations beyond the "immediate/affected area"?

50. FAQ: Role of the ERG in Categorizing Offsite Transportation OEs The Answer (in brief)… The responsible DOE entity should declare an Operational Emergency (OE) if: On-scene responders establish (using the ERG) an Initial Isolation Zone that extends beyond about 100 m from vehicle or spill, or Protective Action Zone is established in the downwind direction as specified in the ERG

51. FAQ: Role of the ERG in Categorizing Offsite Transportation OEs The Reasoning… The “about 100 m” distance was chosen to define the “immediate/affected area” Initial Isolation Zone or Protective Action Zone extending beyond ~100 m suggests event impact corresponding to the lower bound of a Site Area Emergency for fixed facilities If a Protective Action Zone (PAZ) is established, it should be assumed that the PAZ extends 100 m or greater

52. FAQ: Classification of Onsite DOE Transportation Operational Emergencies The Background… 1. DOT-compliant onsite shipments do not require Hazards Survey/EPHA 2. In any emergency, protective actions would be implemented using ERG recommendations 3. Neither the Order nor EMG provide explicit direction for classification of onsite accidents involving DOT-compliant shipments

53. FAQ: Classification of Onsite DOE Transportation Operational Emergencies The Question… Is it the intent of the order that onsite accidents involving DOT compliant shipments be classified?

54. FAQ: Classification of Onsite DOE Transportation Operational Emergencies The Answer (in brief)… The Order does intend that all onsite transportation accidents involving hazardous materials be classified Classification for such events should be consistent with response to emergency events specifically analyzed in EPHAs

55. FAQ: Classification of Onsite DOE Transportation Operational Emergencies The Reasoning… Planning for onsite transportation accidents needs to be integrated with site's emergency management program The ERG provides recommended protective action distances that are based on consequence-at-distance analyses Classification can be inferred from the ERG protective action distances

56. Notifications, Communications, and Public Information

57. FAQ: Time Requirement for Initial Press Release The Background… DOE O 151.1C requires that "Each DOE/NNSA site/facility must provide accurate, candid and timely information about emergencies to workers and the public.” Contractor Requirements Document (CRD) reiterates the requirement DOE G 151.1- 4 addresses timeliness

58. FAQ: Time Requirement for Initial Press Release The Question… How long does a DOE/NNSA site/facility have before notifying the public and the media of an emergency?

59. FAQ: Time Requirement for Initial Press Release The Answer (in brief)… DOE G 151.1-4, Section 9.5.2: "While the DOE Order does not stipulate that news releases and other associated notifications or news conferences occur in a specific time frame, DOE/NNSA should adhere to the standards of other Federal Agencies and private industry by releasing information within one (1) hour of the declaration of the event."

60. FAQ: Time Requirement for Initial Press Release The Reasoning… This FAQ simply reiterates and reinforces the expectation stated in DOE G 151.1-4 Chapter 9 that initial release of information to the public and news media be done within 1 hour of an emergency declaration.

61. FAQ: Time Requirement for Follow-up Emergency Notifications The Background… The 15/30 minute requirement to notify offsite officials applies to initial emergency notifications only Follow-up notifications not specifically addressed in the Order (general sections) Contractor Requirements Document (CRD) requires that "accurate and timely follow-up notifications" are to be made when conditions change or emergency is terminated

62. FAQ: Time Requirement for Follow-up Emergency Notifications The Question… Does the 15 or 30 minute time requirement apply to follow-up emergency notifications that must be made when conditions change…, when the emergency classification is upgraded, or when the emergency is terminated?

63. FAQ: Time Requirement for Follow-up Emergency Notifications The Answer (in brief)… No time requirement is specified in either Order or CRD for follow-up notifications except that they be accurate and timely Timely: fast enough for response activities to be effective in protecting workers and public health and safety

64. FAQ: Time Requirement for Follow-up Emergency Notifications The Reasoning… No firm time requirement was considered necessary. The FAQ simply reiterates the general definition of "timely."

65. FAQs Under Consideration

66. FAQ Under Consideration Screening Cadmium

67. FAQ Under Consideration Screening Cadmium The Background… The Hazardous Materials Screening process IDENTIFIES materials with the potential to produce a airborne hazardous materials release Screening eliminates chemical solids from consideration based on dispersibility considerations: The substance is a solid at normal temperatures and does not contain or include a significant fraction of small particles (less than about 10 microns in diameter) that can readily be suspended in air No plausible release mechanism/process is identified by which a large fraction of a solid material can be reduced to small particles to be suspended and transported in air Assume no energetic or dispersive event/condition unless it results from the inherent qualities of the material (e.g., pyrophoric properties)

68. FAQ Under Consideration Screening Cadmium The Question… Cadmium metal has relatively high acute toxicity and a correspondingly low PAC value. Can it be screened out on dispersibility even though the boiling point (767? C) suggests that the metal could produce significant amounts of cadmium vapor or fume if subjected to fire?

69. FAQ Under Consideration Screening Cadmium The Answer… (?) In general, cadmium should be screened out Facility-specific circumstances may be recognized prior to application of the screening criteria under which a particular substance might cause impacts consistent with an Operational Emergency (OE)

70. FAQ Under Consideration Screening Cadmium The Reasoning… The dispersibility tests should be applied to a substance as it exists under normal conditions of use or storage Temperature, pressure, particle size, concentration, etc. Dispersiblity determination should not assume any energetic or dispersive event/condition unless Inherent properties (e.g., pyrophoric)

71. FAQ Under Consideration Screening Cadmium The Reasoning (con’d) … High temperatures from a facility fire cannot be considered “normal conditions of use or storage” Fire can transform almost any substance into a toxic fume, vapor or combustion product NOTE: If the properties of a substance under fire conditions (including its combustion products) were to be considered as the basis for screening, virtually nothing would be screened out, everything would need to be analyzed, and every fire would be a hazardous material release event

72. FAQ Under Consideration Screening Cadmium The Reasoning (con’d) … HOWEVER … Because the screening criteria are generic and do not reflect exactly the hazard associated with each individual substance, there may be facility-specific circumstances recognized prior to application of the screening criteria, under which a particular substance that would otherwise be excluded from consideration using the criteria, might cause impacts consistent with an Operational Emergency

73. FAQ Under Consideration Screening Cadmium The Reasoning (con’d) … Draw on the experience of the FIRE PROTECTION community to determine if a fire could represent an extraordinary toxic release threat that would be best managed as a hazardous material release rather than a normal fire event If a Fire Hazards Analysis (FHA) or the Fire Protection staff’s assessment suggests that protective actions beyond those normally applied to structure fire response will be needed, the toxic material release should be addressed in an EPHA

74. FAQ Under Consideration Fire in Screening & Analysis

75. FAQ Under Consideration Fire in Screening & Analysis

76. FAQ Under Consideration Fire in Screening & Analysis The Background (con’d) … Cadmium FAQ question suggested the need to: Show connections/relationships between different EMG sections Explain policy background and specific language used in EMG Led to this FAQ topic addressing and reconciling how fire is dealt with in screening & analysis

77. FAQ Under Consideration Fire in Screening & Analysis

78. FAQ Under Consideration Fire in Screening & Analysis

79. FAQ Under Consideration Fire in Screening & Analysis Possible elements of FAQ response … Although fire CAN create materials of higher toxicity or convert material to more dispersible form, in general screening should NOT consider these fire effects Fire should be considered as release initiator for screened-in materials Defer to FIRE PROTECTION regarding "extraordinary" toxic release potential from fire (DOE G 151.1-2, Section 2.8.1)

80. Open Discussion of Policy/Guidance Issues

81. Open Discussion of Policy/Guidance Issues “Parking Lot Issues”

82. BACK-UP Slides Current FAQ List

83. Hazards Survey/Hazards Assessments Classification of Onsite DOE Transportation Operational Emergencies Chemical Mixture Methodology (CMM) in Emergency Response UF6 Protective Action Criterion (PAC) Beyond Design Basis Malevolent Events Malevolent Events and Denial Protection Strategy Security Vulnerability Assessments and EPHAs Protective Action Recommendations (PARs) Outside the EPZ Screening Chemical Mixtures Annual Inventories for DOE-Owned Leased Facilities DOE-Owned Leased Facilities Current FAQ List

84. Hazards Survey/Hazards Assessments (con’d) Screening Thresholds and Consequence-at-Distance Screening Spent Nuclear Fuel (SNF) Using Chemical Mixture Methodology (CMM) in Screening and EPHAs Selection of ARF, ARR or RF Values for EPHA Analyses Screening Hazardous Materials Not Currently at Facilities, but Listed in Safety Basis Document Classification of a Spill from a Commercial Hazardous Material Shipment on a DOE/NNSA Site Use of the DOT Emergency Response Guidebook (ERG) for Response to Hazardous Material Release Events at Burial Sites DOE-Leased Offsite Commercial Office Space Current FAQ List

85. Program Administration Establish Pre-Authorization Criteria for Initial Decision Making Annual Self-Assessments and Exercises Annual Inventories for DOE-Owned Leased Facilities DOE-Owned Leased Facilities Order Into Contracts and Implementation Schedule Review of Revised Guides Approval and Distribution of Emergency Management Documents Annual Review of Emergency Plans and Emergency Plan Implementing Procedures (EPIPs) DOE-Leased Offsite Commercial Office Space Current FAQ List

86. Training and Drills Annual Requirements for ERO Members Exercises Annual Requirements for ERO Members ERO Member Participation in Annual Site-Level Exercises Approval of Exercise Documentation Site Definition and Facility-Level Exercises Facility Definition and Facility-Level Exercises Annual Exercise and Facility-Level ERO Annual Self-Assessments and Exercises Current FAQ List

87. Readiness Assurance Annual Self-Assessments and Exercises Role of Evaluation Criteria in Annual Self-Assessments Emergency Response Organization (ERO) Onsite Categorization/Classification Decision Maker and Integration with NIMS Establish Pre-Authorization Criteria for Initial Decision Making Annual Requirements for ERO Members ERO Member Participation in Annual Site-Level Exercises Members of the Emergency Response Organization (ERO) Annual Exercise and Facility-Level ERO Current FAQ List

88. Categorization and Classification Onsite Categorization/Classification Decision Maker and Integration with NIMS Establish Pre-Authorization Criteria for Initial Decision Making Classification of Onsite DOE Transportation Operational Emergencies EALs and Planned Initial Protective Actions Time Requirement for Follow-up Emergency Notifications Role of the Emergency Response Guidebook (ERG) in Categorizing Offsite Transportation Operational Emergencies Classification of a Spill from a Commercial Hazardous Material Shipment on a DOE/NNSA Site Use of the DOT Emergency Response Guidebook (ERG) for Response to Hazardous Material Release Events at Burial Sites Current FAQ List

89. Notifications and Communication Time Requirement for Follow-up Emergency Notifications Submission Requirements for Final Emergency Reports Consequence Assessment Chemical Mixture Methodology (CMM) in Emergency Response UF6 Protective Action Criterion (PAC) Current FAQ List

90. Protective Actions and Reentry EALs and Planned Initial Protective Actions UF6 Protective Action Criterion (PAC) Protective Action Recommendations (PARs) Outside the EPZ Use of the DOT Emergency Response Guidebook (ERG) for Response to Hazardous Material Release Events at Burial Sites Emergency Public Information (EPI) Time Requirement for Initial Press Release Current FAQ List

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