DOE G 151.1-1B, Comprehensive Emergency Management System Guide
The DOE Comprehensive Emergency Management System provides a framework within which to address all hazards, from natural, technological, and human caused, and all the components of an effective emergency management program. The standard components of a DOE emergency management program are planning, preparedness, response, and readiness assurance. Cancels DOE G 151.1-1A, DOE G 151.1-2, DOE G 151.1-3, DOE G 151.1-4, DOE G 151.1-5.
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Document text
Text extracted from the attached file. Refer to the original document for the authoritative version.
Section 1
AVAILABLE ONLINE AT: INITIATED BY:
www.directives.doe.gov National Nuclear Security Administration
DOE G 151.1-1B
7-26-2022
Comprehensive Emergency Management System
Guide
[This Guide describes suggested non-mandatory approaches for meeting requirements. Guides
are not requirements documents and are not to be construed as requirements in any audit or
appraisal for compliance with the parent Policy, Order, Notice, or Manual.]
U.S. Department of Energy
Washington, D.C.
NOT MEASUREMENT
SENSITIVE
DOE G 151.1-1B i
7-26-2022
Table of Contents
Emergency Management Fundamentals .............................................................. 1-1
1.1. DOE Comprehensive Emergency Management System ............................................ 1-1
1.1.1. Introduction .................................................................................................................. 1-1
1.1.2. Requirements and Guidance ......................................................................................... 1-3
1.1.3. Application of Guidance ............................................................................................... 1-4
1.1.4. Conceptual Foundation of DOE Emergency Management .......................................... 1-5
1.1.5. Emergency Management Programs .............................................................................. 1-6
1.1.6. Emergency Management Program Elements ................................................................ 1-9
1.1.7. DOE/NNSA Emergency Management and Integrated Safety Management (ISM) ... 1-14
1.1.8. DOE/NNSA Emergency Management and National Incident Management
System ........................................................................................................................ 1-15
1.2. Core Program Facilities .............................................................................................. 1-17
1.2.1. Introduction ................................................................................................................ 1-17
1.2.2. Program Elements ....................................................................................................... 1-17
1.3. Hazardous Materials Program Facilities ................................................................... 1-19
1.3.1. Introduction ................................................................................................................ 1-20
1.3.2. Program Elements ....................................................................................................... 1-20
1.4. Leased Facilities ........................................................................................................... 1-23
1.4.1. Introduction ................................................................................................................ 1-23
1.4.2. Application of Emergency Management Guidance .................................................... 1-24
1.5. Closure Activities ......................................................................................................... 1-29
1.5.1. Introduction ................................................................................................................ 1-29
1.5.2. All-Hazards Planning/Technical Planning Basis ........................................................ 1-30
1.5.3. Programmatic Elements .............................................................................................. 1-31
1.5.4. Response Elements ..................................................................................................... 1-33
Section 2
1.6. Biosafety Facilities ....................................................................................................... 1-35
1.6.1. Introduction ................................................................................................................ 1-36
1.6.2. General Approach ....................................................................................................... 1-36
All Hazards Planning/Technical Planning Basis ................................................. 2-1
2.1. All-Hazards Planning Basis .......................................................................................... 2-1
2.1.1. Introduction .................................................................................................................. 2-1
2.1.2. General Approach — All-Hazards Planning Basis....................................................... 2-1
2.1.3. Step 1: Describe the Facility and Identify its Hazards.................................................. 2-2
2.1.4. Step 2: Screen Hazardous Materials to Determine Need for an Emergency Planning
Hazards Assessment (EPHA) ....................................................................................... 2-3
2.1.5. Step 3: Identify Applicable Types of Emergency Incidents and Conditions ................ 2-4
2.1.6. Step 4: Qualitatively Describe Potential Impacts ......................................................... 2-6
2.1.7. Step 5: Identify Applicable Planning and Preparedness Requirements ........................ 2-6
2.1.8. All-Hazards Survey Documentation ............................................................................. 2-7
2.1.9. Threat and Hazard Identification and Risk Assessment (THIRA) ............................... 2-7
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2.2. Technical Planning Basis ............................................................................................. 2-12
2.2.1. Introduction ................................................................................................................ 2-12
2.2.2. General Approach - Technical Planning Basis ........................................................... 2-14
2.2.3. Step 1: Define and Describe Facility and Operations ................................................. 2-16
2.2.4. Step 2: Characterize the Hazardous Materials ............................................................ 2-17
2.2.5. Step 3: Select Scenarios for Analysis ......................................................................... 2-19
2.2.6. Step 4: Analyze Scenarios .......................................................................................... 2-27
2.2.7. Step 5: Document the Results of the Analysis ............................................................ 2-38
2.2.8. Special Topics............................................................................................................. 2-43
2.2.9. Using Safety Analysis Results in EPHAs ................................................................... 2-46
2.2.10. Using Security Risk Assessment in EPHAs ............................................................... 2-47
2.3. Emergency Planning Zones ......................................................................................... 2-49
2.3.1. Background ................................................................................................................. 2-49
2.3.2. General Emergency Planning Zones (EPZ) Concepts ................................................ 2-50
2.3.3. Developing Facility EPZs ........................................................................................... 2-51
Section 3
2.4 Maintaining All-Hazards Surveys and EPHAs ......................................................... 2-56
Programmatic Elements ........................................................................................ 3-1
3.1. Program Administration and Management ................................................................ 3-1
3.1.1. Introduction .................................................................................................................. 3-1
3.1.2. General Approach - Program Administration and Management .................................. 3-1
3.1.3. Planning Responsibilities ............................................................................................. 3-3
3.1.4. Preparedness Responsibilities ....................................................................................... 3-8
3.1.5. Readiness Assurance Responsibilities ........................................................................ 3-11
3.1.6. Response Responsibilities .......................................................................................... 3-13
3.1.7. Document Control Systems ........................................................................................ 3-15
3.1.8. Classified/Controlled Unclassified Information ......................................................... 3-16
3.2. Training and Drills ...................................................................................................... 3-16
3.2.1. Introduction ................................................................................................................ 3-16
3.2.2. General Approach- Training and Drills ...................................................................... 3-17
3.2.3. Training Program Management .................................................................................. 3-18
3.2.4. Training Needs Assessment ........................................................................................ 3-23
3.2.5. Specific Training Requirements ................................................................................. 3-24
3.2.6. Training Development ................................................................................................ 3-29
3.2.7. Training Delivery ....................................................................................................... 3-32
3.2.8. Drills ......................................................................................................................... 3-33
3.3. Readiness Assurance .................................................................................................... 3-37
3.3.1. Introduction ................................................................................................................ 3-37
3.3.2. General Approach - Readiness Assurance .................................................................. 3-39
3.3.3. Readiness Assurance Program .................................................................................... 3-40
3.3.4. Evaluations ................................................................................................................. 3-51
3.3.5. Evaluation Process ...................................................................................................... 3-56
3.3.6. Self-Assessments ........................................................................................................ 3-64
3.3.7. Performance Indicators ............................................................................................... 3-66
3.3.8. Exercise Program ........................................................................................................ 3-68
Section 4
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3.3.9. Types of Exercises ...................................................................................................... 3-70
3.3.10. Exercise Planning ....................................................................................................... 3-75
3.3.11. Exercise Documentation ............................................................................................. 3-82
3.3.12. Post-Emergency Evaluation ....................................................................................... 3-91
3.3.13. Exercise Objectives .................................................................................................... 3-92
3.3.14. Exercise Preparation ................................................................................................... 3-94
3.3.15. Conduct of the Exercise .............................................................................................. 3-96
3.3.16. Exercise Evaluation .................................................................................................. 3-100
3.3.17. Follow-up Activities ................................................................................................. 3-107
Response Elements ................................................................................................. 4-1
4.1. Emergency Operations Systems ................................................................................... 4-1
4.1.1. Introduction .................................................................................................................. 4-1
4.1.2. General Approach – Emergency Operations System ................................................... 4-2
4.2. Emergency Response Organization.............................................................................. 4-2
4.2.1. Introduction .................................................................................................................. 4-2
4.2.2. General Approach – Emergency Response Organization (ERO) ................................. 4-2
4.2.3. ERO Structure............................................................................................................... 4-3
4.2.4. Staffing the ERO ........................................................................................................ 4-10
4.2.5. Operational Aspects of the ERO................................................................................. 4-12
4.2.6. Maintenance of the ERO ............................................................................................ 4-14
4.2.7. Special Response Function/Positions ......................................................................... 4-15
4.3. Offsite Response Interfaces ......................................................................................... 4-20
4.3.1. Introduction ................................................................................................................ 4-20
4.3.2. General Approach – Offsite Response Interfaces ....................................................... 4-20
4.3.3. Offsite Agencies and Organizations ........................................................................... 4-21
4.3.4. Support Agreements ................................................................................................... 4-23
4.3.5. Interface Information and Issues to Address .............................................................. 4-24
4.3.6. Interfaces during Response ......................................................................................... 4-26
4.3.7. Offsite Response during Severe Events ...................................................................... 4-27
Section 5
4.4. Emergency Facilities and Equipment/Systems ......................................................... 4-28
4.4.1. Introduction ................................................................................................................ 4-28
4.4.2. General Approach – Emergency Facilities and Equipment/Systems ......................... 4-28
4.4.3. Role of the All-Hazards Survey/EPHA ...................................................................... 4-29
4.4.4. Emergency Facilities .................................................................................................. 4-31
4.4.5. Emergency Equipment ............................................................................................... 4-36
4.4.6. Maintenance of Facilities and Equipment .................................................................. 4-42
4.5. Emergency Categorization and Classification .......................................................... 4-42
4.5.1. Introduction ................................................................................................................ 4-42
4.5.2. General Approach – Emergency Categorization and Classification .......................... 4-43
4.5.3. Operational Emergency Definition ............................................................................. 4-44
4.5.4. Emergency Categorization ......................................................................................... 4-44
4.5.5. Classification of Hazardous Material Operational Emergencies ................................ 4-55
4.5.6. Development of Emergency Action Levels ................................................................ 4-60
4.5.7. Testing Categorization Criteria and EALs ................................................................. 4-68
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4.6. Notifications and Communications ............................................................................ 4-68
4.6.1. Introduction ................................................................................................................ 4-68
4.6.2. General Approach – Notifications and Communications ........................................... 4-68
4.6.3. Notifications ............................................................................................................... 4-70
4.6.4. Communications ......................................................................................................... 4-75
4.6.5. Response Documentation ........................................................................................... 4-77
4.7. Consequence Assessment ............................................................................................ 4-78
4.7.1. Introduction ................................................................................................................ 4-78
4.7.2. General Approach – Consequence Assessment .......................................................... 4-78
4.7.3. Decision-Making in an Emergency Environment ...................................................... 4-79
4.7.4. General Consequence Assessment Process ................................................................ 4-81
4.7.5. Initial Incident Recognition, Categorization/Classification, and Protective Actions . 4-84
4.7.6. Timely Initial Assessment .......................................................................................... 4-84
4.7.7. Continuous Ongoing Assessment (COA) ................................................................... 4-89
4.7.8. Documentation.......................................................................................................... 4-106
4.7.9. Quality Assurance ..................................................................................................... 4-106
Section 6
4.8. Protective Actions ...................................................................................................... 4-107
4.8.1. Introduction .............................................................................................................. 4-107
4.8.2. General Approach – Protective Actions ................................................................... 4-108
4.8.3. Protective Actions..................................................................................................... 4-109
4.8.4. Reentry ..................................................................................................................... 4-130
4.9. Emergency Medical Support .................................................................................... 4-137
4.9.1. Introduction .............................................................................................................. 4-137
4.9.2. General Approach- Emergency Medical Support ..................................................... 4-137
4.9.3. Site Emergency Medical Support ............................................................................. 4-138
4.9.4. Interfaces and Coordination ...................................................................................... 4-143
4.9.5. Medical Records and Treatment History .................................................................. 4-146
4.9.6. Emergency Medical Response Preparedness Activities ........................................... 4-147
4.9.7. Federal Medical Assistance ...................................................................................... 4-148
4.10. Emergency Public Information ................................................................................ 4-149
4.10.1. Introduction .............................................................................................................. 4-149
4.10.2. General Approach - Emergency Public Information (EPI) ...................................... 4-149
4.10.3. EPI Functions and Staffing ....................................................................................... 4-151
4.10.4. EPI Response ............................................................................................................ 4-153
4.10.5. Media Relations ........................................................................................................ 4-159
4.10.6. EPI/JIC Facilities and Equipment ............................................................................. 4-162
4.10.7. EPI Preparedness Activities ...................................................................................... 4-164
4.11. Termination and Recovery........................................................................................ 4-167
4.11.1. Introduction .............................................................................................................. 4-167
4.11.2. General Approach – Termination and Recovery ...................................................... 4-168
4.11.3. Termination .............................................................................................................. 4-169
4.11.4. Recovery ................................................................................................................... 4-172
4.11.5. Resumption of Normal Operations ........................................................................... 4-177
DOE G 151.1-1B v
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Section 7
Biosafety Facilities .................................................................................................. 5-1
5.1. Biosafety .......................................................................................................................... 5-1
5.1.1. Introduction .................................................................................................................. 5-1
5.1.2. General Approach – Biosafety Facilities ...................................................................... 5-2
5.2. Hazardous Biological Materials and Biosafety ........................................................... 5-3
5.2.1. Hazardous Biological Agents and Toxins .................................................................... 5-3
5.2.2. Select Agent Regulations .............................................................................................. 5-3
5.2.3. Principles of Biosafety, Containment, and Barriers ..................................................... 5-5
5.3. Operational Emergencies Involving Biological Materials.......................................... 5-6
5.3.1. DOE O151.1D and Hazardous Biological Materials .................................................... 5-6
5.3.2. Emergency Management Issues ................................................................................... 5-6
5.3.3. Biological Operational Emergencies .......................................................................... 5-10
5.3.4. Biological Agent/Toxin Transport Mechanisms ........................................................ 5-10
5.3.5. Environmental Dispersion .......................................................................................... 5-11
5.3.6. Infected Host .............................................................................................................. 5-12
5.3.7. Contamination ............................................................................................................ 5-13
5.3.8. Biological Agent Release Scenarios ........................................................................... 5-13
5.3.9. Recognizing Operational Emergencies ....................................................................... 5-18
5.3.10. Initial Protective Actions ............................................................................................ 5-20
5.3.11. Public Health Response .............................................................................................. 5-22
5.4. Biosafety Facilities: All Hazards Planning /Technical Planning Basis ................... 5-24
5.4.1. All-Hazards Survey .................................................................................................... 5-24
5.4.2. Emergency Planning Hazards Assessment (EPHA) ................................................... 5-25
5.4.3. Example Release Scenarios ........................................................................................ 5-27
5.5. Biosafety Facilities: Programmatic Elements ........................................................... 5-37
5.5.1. Program Administration and Management ................................................................. 5-37
5.5.2. Training and Drills...................................................................................................... 5-39
5.5.3. Readiness Assurance .................................................................................................. 5-39
Section 8
5.6. Biosafety Facilities: Response Elements .................................................................... 5-41
5.6.1. Emergency Response Organization (ERO) ................................................................ 5-41
5.6.2. Emergency Operations Systems ................................................................................. 5-42
5.6.3. Offsite Response Interfaces ........................................................................................ 5-42
5.6.4. Emergency Facilities and Equipment/Systems ........................................................... 5-43
5.6.5. Emergency Categorization and Classification ............................................................ 5-43
5.6.6. Notifications and Communications ............................................................................ 5-44
5.6.7. Consequence Assessment ........................................................................................... 5-45
5.6.8. Protective Actions....................................................................................................... 5-47
5.6.9. Emergency Medical Support ...................................................................................... 5-48
5.6.10. Emergency Public Information ................................................................................... 5-49
5.6.11. Termination and Recovery ......................................................................................... 5-49
Appendix A. Hazardous Material Screening Process ......................................................... A-1
Appendix B. Onsite Transportation Analysis ...................................................................... B-1
Appendix C. Consequence Thresholds ................................................................................. C-1
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Appendix D. Combustion Products and Toxicity in Hazards Assessments ...................... D-1
Appendix E. Integration of Incident Categorization/Classification with Normal
Operations ......................................................................................................... E-1
Appendix F. Methods and Examples for Implementation of Incident Categorization and
Classification, including Barrier Approach to Emergency Action Level
Development ....................................................................................................... F-1
Appendix G. Ingestion Pathway Calculations for Radioactive Releases ........................... G-1
Appendix H. Field Monitoring .............................................................................................. H-1
Appendix I. Operational Emergency Scenarios for Biosafety Facilities ............................ I-1
Appendix J. Acronyms ............................................................................................................ J-1
List of Tables and Figures
Table 2-1 Example Threats and Hazards by Category……………. ....................................... 2-8
Table 3-1 Documents for Field Element Manager/Federal Manager ...................................... 3-5
Table 3-2 Focus and Limitations of Evaluation Tools ................................................... 3-453-45
Table 3-3 Sample Planning Schedule for a Site-level Annual Exercise ............................... 3-81
Table 4-1 Summaries of Emergency Classes ........................................................................ 4-59
Section 9
Table 4-2 Examples of Incident-Based and Symptom-Based EAL Statements for the Same
Initiating Condition ........................................................................................ 4-634-63
Table 4-3 Example Symptom-Based EALs for Different Severity Levels for the Same
Initiating Condition ........................................................................................ 4-644-64
Table 4-4 Example Incident-Based EALs for Different Severity Levels for the Same Initiating
Condition........................................................................................................ 4-654-65
Table 4-5 Infiltration Rates – Air Change/Hr .............................................................. 4-654-116
Table 4-6 Air Changes per Hour .................................................................................. 4-654-117
Table 4-7 Concentration vs Dose ................................................................................. 4-654-118
Table 4-8 Decision Aid – Checklist ............................................................................. 4-654-123
Table 4-9 Typical Contents of an Emergency Public Information Plan ............................ 4-153
Table 5-1 Transport Mechanisms and Barriers / Controls .................................................... 5-17
Table 5-2 Eight BSC Scenarios from DOE O 151.1D .......................................................... 5-31
Table 5-3 Source and Release Parameters ............................................................................ 5-32
Table 5-4 Recognition Factors .............................................................................................. 5-34
Table 5-5 Example Protective Actions .................................................................................. 5-35
Table 5-6 Examples of Generic Initial Protective Actions – Standard Initial Protective
Actions .................................................................................................................. 5-36
Table 5-7 Airborne Release Scenarios .................................................................................. 5-37
Table D-1 Yields of HCN and HCl from NIST Room Fire Tests ........................................... D-3
Table D-2 Amount of Toxic Gases Needed to Exceed Applicable ERPG-2 Value at Various
Distances ................................................................................................................ D-3
Table D-3 Mass of Combustibles to Produce a 15-Minute Average Concentration of Specified
Toxic Gases Equal to ERPG-2 at 100 meters ........................................................ D-4
Table F-1 Example SAE EALs Two Barriers Failed ............................................................ F-12
Table F-2 Example EAL Sub-Categories for Category Number 1 ....................................... F-13
DOE G 151.1-1B vii
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Figure 1-1 Emergency Management Program Overview ......................................................... 1-8
Figure 4-1 Emergency Operations System Structure ............................................................... 4-1
Figure 4-2 Basic Functions in the Timely Initial Assessment Process ................................... 4-86
Figure 4-3 Basic Functions in the Continuous Ongoing Assessment ..................................... 4-91
Figure 5-1 Schematic Representation of Biological Release Scenario .................................. 5-17
Section 10
Figure A-1 Hazardous Material Screening Process ................................................................ A-10
DOE G 151.1-1B 1-1
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Emergency Management Fundamentals
1.1. DOE Comprehensive Emergency Management System
1.1.1. Introduction
The United States Department of Energy (DOE), including the National Nuclear Security
Administration (NNSA), manages a wide variety of sites, facilities, and activities
throughout the country. These include:
• National Laboratories;
• Nuclear weapons complex;
• Legacies of the Manhattan project and the early days of the Nation's atomic energy
program;
• Transportation of hazardous materials:
– Office of Secure Transportation
– Hazardous waste shipments
• Power Marketing Administrations (PMAs); and
• Strategic Petroleum Reserve (SPR).
The National Laboratories conduct basic and applied research, ranging from high energy
particle physics to the human genome, alternative sources of energy, and applications of
technology to homeland security. Activities at other sites include development,
stockpiling, and dismantling of nuclear weapons, production of nuclear power sources for
space vehicles, environmental cleanup at legacy sites, transportation of waste materials
generated by Departmental operations, and storage and isolation of radioactive waste.
The Department also manages the national SPR, which stores reserves of petroleum
product in case of a national emergency that impacts normal supplies, and is the home of
the PMAs, which function both as distributors of electric power and brokers of regional
energy supplies. Finally, the DOE/NNSA is involved in energy restoration activities
following major disruptions of supply or distribution.
The diversity of these activities indicates DOE/NNSA sites and facilities store, use,
produce, and dispose of many different hazardous substances, including radioactive
materials, toxic chemicals, and biological agents and toxins. In managing these hazards,
DOE holds the safety of workers and the public to be paramount. By maintaining high
standards of facility design, conduct of operations, safety oversight, and personnel
training, DOE activities consistently achieve accident and injury rates that compare very
favorably with those of similar operations in the private sector. In addition to the systems
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of workplace hazard controls that prevent incidents and ensure worker safety, the DOE
Comprehensive Emergency Management System superimposes additional protections over
all operations involving dispersible hazardous materials in quantities that could harm
people outside the immediate workplace.
The overall mission of DOE/NNSA emergency management is to be ready to respond
promptly, efficiently, and effectively to any emergency involving or affecting
DOE/NNSA sites, facilities, or activities (SFAs) by applying the necessary resources to
mitigate the consequences and protect workers, the public, the environment, and national
security. It is important to note that not all DOE/NNSA activities occur within
DOE/NNSA site boundaries. DOE is also the coordinating agency for Emergency Support
Function #12 - Energy, under the National Response Framework and the Sector Specific
Agency for the energy sector under Presidential Policy Directive (PPD) 21, PPD-41, and
the Fixing America’s Surface Transportation Act.
The DOE Comprehensive Emergency Management System provides a framework within
Section 11
which to address all hazards, from natural, technological, and human caused, and all the
components of an effective emergency management program. The standard components
of a DOE emergency management program are planning, preparedness, response, and
readiness assurance. DOE/NNSA will directly and indirectly employ unique technical
expertise and resources that are specific to a radiological incident occurring locally,
nationally, or internationally.
• Planning involves determining, in advance, what will be done in response to specific
emergencies.
• Preparedness is putting in place procedures, equipment, and personnel capabilities
that will be needed to respond.
• Response is the actual mobilization of personnel including people, equipment, and
resources to take action during an emergency, emergency termination, and when
initiating recovery to return the site/facility/activity operations to normal.
• Readiness Assurance is the ongoing process of validating and demonstrating readiness
to respond.
The current DOE emergency management requirements are the result of the evolution that
began after the Three Mile Island reactor accident in 1979. At that time, the Department
was still operating several reactors and producing materials for nuclear weapons.
Accordingly, throughout the early- and mid-1980’s, DOE emergency management
requirements focused heavily on nuclear and radiological hazards. The Department
expanded its emergency management requirements in 1991 to include toxic chemicals
after the 1984 tragedy involving a methyl isocyanate gas leak in Bhopal, India, that
resulted in numerous deaths and injuries, and other accidents that turned the world’s
attention to chemical release hazards. After the Occupational Safety and Health
Administration (OSHA) enhanced its worker protection regulations and included
hazardous waste operations, DOE expanded its emergency management requirements to
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stipulate a level of basic emergency planning for all sites/facilities/activities (SFAs), with
more specific and detailed requirements for activities using radioactive materials and
toxic chemicals. Current emergency management requirements also address biological
toxins and infectious agents, since research is ongoing at some DOE/NNSA laboratories
using these materials to develop detectors and support other homeland security-related
programs.
The DOE comprehensive, all-hazards approach to emergency management became firmly
established with the issuance of DOE O 151.1 in 1995. The Order was subsequently
updated several times, culminating in DOE O 151.1D, which incorporated emergency
management lessons learned from international events such as Hurricane Katrina (2005),
and Japan’s Fukushima Daiichi disaster (2011), and direction from DOE. The Order
established DOE policy that provides a general structure and framework for response to
any emergency at a DOE site, facility, or activity, and specific requirements to address
protection of the workers, the public, and the environment from the release of hazardous
materials.
Note: This guide uses the term site/facility/activity (SFA) similarly to DOE O 151.1D.
The use of this term is meant to encompass all labs/plants/sites/Program Secretarial
Offices (PSO) involved throughout the DOE/NNSA Complex. The purpose for this is to
limit the ambiguity that could be construed through the constant use of different terms.
1.1.1.1. Cancellation
Section 12
This guide was updated to reflect the changes in DOE O 151.1D. It cancels and
supersedes the following:
DOE G 151.1-1A, Emergency Management Fundamentals and the Operational
Emergency Base Program, dated 7-11-07
DOE G 151.1-2, Technical Planning Basis Emergency Management Guide, dated
7-11-07
DOE G 151.1-3, Programmatic Elements Emergency Management Guide, dated
7-11-07
DOE G 151.1-4, Response Elements Emergency Management Guide, dated 7-11-07
DOE G 151.1-5, Biosafety Facilities Emergency Management Guide, dated 7-11-07
1.1.2. Requirements and Guidance
DOE O 151.1D, Comprehensive Emergency Management System, current version (the
Order) establishes policy, assigns roles and responsibilities, and provides the framework
for the development, coordination, control, and direction of the DOE Emergency
Management System. This Guide does not provide requirements; instead, the Order
establishes requirements for emergency planning, preparedness, readiness assurance, and
response, and describes the approach for effectively integrating these activities under a
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comprehensive, all-hazards emergency concept. DOE SFAs, Field Elements, and DOE
(HQ) offices are required to develop emergency management programs as components of
an integrated and comprehensive emergency management system.
Together, these elements ensure that DOE emergency management is prepared to respond
promptly, efficiently, and effectively to any emergency involving DOE SFAs to protect
workers, the public, the environment, and national security.
The Order requires that SFA emergency management programs be developed
commensurate with the hazards at that particular SFA. To assist SFAs in implementing
the Order requirements, DOE/NNSA has developed this comprehensive guidance
applicable to all DOE/NNSA SFAs and generally applicable at DOE/NNSA
organizational levels, including Field Elements and Headquarters (HQ) offices.
If official interpretation of the requirements in DOE O 151.1D or guidance in the
associated Emergency Management Guide 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 Management, Office of Policy. Questions and accompanying interpretations
will be posted as Frequently Asked Questions (FAQs) on the Enterprise Data
Management System (EDMS) by the Office of Emergency Management Policy.
1.1.3. Application of Guidance
The Emergency Management Guide (EMG) provides acceptable approaches to
emergency planning, preparedness, readiness assurance, and response activities at
DOE/NNSA SFAs, including DOE transportation activities, Field Elements, and HQ
offices. This EMG provides preferred, non-mandatory, supplemental information about
acceptable methods for implementing requirements of the DOE Comprehensive
Emergency Management System. This EMG “does not impose requirements but may
quote requirements as long as the sources are adequately cited.” (DOE O 251.1D) Thus,
the DOE/NNSA guide is not a requirements document and may not be construed as
establishing requirements in any audit or assessment of compliance with the associated
Order. Further, the guide provides needed clarification regarding the intent of
DOE O 151.1D requirements.
Guidance contained in this EMG is generic in nature because detailed guidance on every
Section 13
conceivable type of emergency for every SFA cannot be provided. Other equivalent
approaches for meeting the Order requirements may be acceptable to accommodate the
wide range and diversity of DOE operations and activities, facility types and missions,
hazards, and site characteristics. Features such as local and state political structures,
geography, and local demography may also contribute to unique SFA-specific solutions
for developing and maintaining an acceptable emergency management program that
complies with the Order requirements. Using phrases such as “must” or “shall,”
throughout this guide that seem to establish new requirements actually reiterate
requirements from DOE O 151.1 current version, emphasize steps in a required process,
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or promote steps as part of previously identified best practices. Must or shall, within the
context of this guide, when choosing to implement a best practice methodology contained
within this document, is deliberately intended to represent those specific actions that
when executed deliver best practice and compliance with established requirements in
DOE O 151.1. For a best practice to prove reliable, the identified specific actions,
procedures, and deliverables for the specified best practice must or shall be performed.
Using either the guidance contained in this EMG or another acceptable approach to
implement the Order requirements, the resulting emergency management program should
be integrated and coordinated with regulations and plans developed by other Federal
agencies, states, local authorities, and other DOE offices. These regulations and plans
may establish requirements similar to those required within the Emergency Management
Core Program and Emergency Management Hazardous Materials Program, and should be
integrated, where applicable, to ensure a standard approach and continuity of effort.
Newly issued or revised DOE Orders, regulations, or plans should be incorporated in
accordance with corresponding implementation requirements at least by their
implementation deadline, or otherwise, as soon as reasonably achievable (e.g., during the
performance of the all-hazards survey(AHS) and EPHA reviews/updates).
1.1.4. Conceptual Foundation of DOE Emergency Management
The DOE approach to emergency management is built upon three guiding principles or
conceptual foundation stones of emergency management. These key concepts are:
• Effective response is the last line of defense against adverse consequences.
Regardless of how sound the fundamental safety programs and controls may be,
incidents will sometimes happen that have adverse health effects on people or the
environment. This principle expresses the DOE position that if controls should fail,
the SFA must be prepared to take actions to limit or prevent adverse health and safety
impacts to workers and the public. The application of this principle requires some
level of emergency response planning even for those incidents whose severity exceeds
the design basis for safety controls.
• Planning, preparedness, response, and recovery must be specific to and
commensurate with the hazards. The Department is responsible for a large number of
different hazards that could threaten the health and safety of workers or the public if
not controlled. These hazards are varied in the nature of the potential impacts on
people, their behavior in the environment, and the distance at which adverse impacts
Section 14
may be experienced. While the basic emergency management framework is the same
for all DOE SFAs, the specific planning and response measures for each hazard are to
be tailored to the hazard, such that they are specific ( technically appropriate) to the
hazard and commensurate with (in size, scope, or scale) the magnitude of the hazard
and its potential impacts.
• Early recognition is vital to timely, effective, and commensurate response. In
many cases, warning potentially affected workers and the public and directing them to
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take actions to prevent or limit their exposure is the only way of mitigating the
adverse health effects. Hence, the early recognition of an incident is essential if
warnings are to be delivered in time to be executed effectively. By developing a full
understanding of possible scenarios and the indications that would point to an actual
or impending incident, emergency management will increase the likelihood of
successful warning and intervention to prevent or limit health impacts. This analysis
of scenarios and development of recognition indicators provides the basis for tailoring
the response to the actual or potential hazard (commensurate response).
1.1.5. Emergency Management Programs
The DOE Comprehensive Emergency Management System is based on a three-tiered
management structure consisting of SFA, Field Element, and HQ, with each tier having
specific roles and responsibilities during an emergency. Each organizational tier provides
management, direction, and support of emergency response activities. The SFA develops
an emergency management program, which manages the tactical response to the
emergency by directing the mitigative actions necessary to resolve the problem, protect
the workers, the public, and the environment, and return the SFA to a safe condition. The
Field Element Manager oversees the SFA response, provides local assistance, guidance,
operational direction to the SFA management, and coordinates the tactical response to the
incident with Tribal, State, and local governments. DOE HQ provides strategic direction
to the response, provides assistance and guidance to the Field Element Managers, and
evaluates the broad impacts of the emergency on the DOE complex. DOE HQ also
coordinates with other Federal agencies on a national level, provides information to
representatives of the executive and legislative branches of the Federal Government, and
responds to inquiries from the national media.
DOE O 151.1D requires that emergency management programs are established and
maintained at each organizational level to implement requirements pertaining to the
comprehensive emergency management system. Because DOE/NNSA and its contractors
are involved in a variety of operations and activities incorporating a broad range of
hazards to be considered in effective emergency management, the Order requires that the
emergency management program for a specific SFA be commensurate with the hazards
present at that SFA (a tailored approach.)
Each DOE SFA is required by DOE O 151.1D to have an Emergency Management Core
Program, which provides the framework for evaluating hazards that pose serious threats,
or conditions that involve the health and safety of workers and the public, the
environment, and safeguards and security. Although DOE O 151.1D establishes several
DOE-unique requirements and a minimum set of generic requirements for the Core
Section 15
Program, the framework for response results mainly from the implementation of the
requirements of DOE regulations, other DOE orders, and applicable non-DOE Federal,
Tribal, State, and local laws/regulations/ordinances. The specific requirements that
constitute the Emergency Management Core Program are the emergency planning and
preparedness aspects of these Orders and laws/regulations/ordinances. Examples of
emergency response features addressed in other DOE Orders and
laws/regulations/ordinances include medical support, worker evacuation plans, fire drills,
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worker notification systems, hazardous material communication, contingency planning
for oil spills, environmental spill drills and exercises, and DOE security and safeguards
requirements. The objective of the Core Program is to achieve an effective integration of
emergency planning and preparedness requirements into an emergency management
program that provides capabilities for All-Hazards emergency response, through
communication, coordination, and an efficient and effective use of resources.
DOE O 151.1D requires an SFA-specific EPHA be conducted for each DOE SFA where
identified hazardous materials are present in quantities exceeding the amounts that can be
“easily and safely manipulated by one person” and whose potential release would cause
the impacts and require response activities characteristic of an Operational Emergency
(OE). An EPHA is a quantitative analysis that includes the identification and
characterization of hazardous materials specific to an SFA, analyses of potential accidents
or incidents, and evaluation of potential consequences. The results of the EPHA
determine whether an Emergency Management Hazardous Materials Program is required.
If the analysis results indicate that no potential incidents and conditions would be
classified as an Alert or higher (as defined in DOE O 151.1D), then the Core Program
(including 29 Code of Federal Regulations (CFR) 1910.120 requirements) constitutes the
appropriate emergency management program for the SFA. If the analysis results
associated with an SFA indicate the potential for an Alert, Site Area Emergency, or
General Emergency (GE) as defined in DOE O 151.1D, an Emergency Management
Hazardous Materials Program is required; the analysis results will also provide the
technical planning basis for the program.
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Figure 1-1. Emergency Management Program Overview
1
1 BHA Bounding Hazards Analysis (BHA) is an LBNL-specific term for what is more commonly referred to as the
"PAC-30 Analysis" at other DOE sites. This is an example of an Emergency Management Program Overview and is
not meant to be universal across the DOE/NNSA complex.
DOE G 151.1-1B 1-9
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1.1.6. Emergency Management Program Elements
The DOE/NNSA emergency management system consists of four standard components:
• Emergency planning including the identification of hazards and threats, hazard
mitigation, development and preparation of emergency management plans and
procedures, and identification of personnel and resources needed for an effective
response
• Emergency preparedness including the acquisition and maintenance of resources
and training and drills
• Emergency response including the application of resources to mitigate
consequences to workers, the public, the environment, and national security, and
the initiation of recovery from an emergency
Section 16
• Readiness assurance including evaluations, exercises, improvements, and
documentation to assure that stated emergency capabilities are sufficient to
implement emergency plans
In order to more clearly indicate the roles that the fifteen (15) Program Elements of the
emergency management program perform, they are separated into the following three
groups: Technical Planning Basis (Planning), Programmatic Activities (Planning,
Preparedness, Readiness Assurance), and Response Activities.
Within each of the program elements, specific activities, tasks, products, etc., and their
related plans, procedures, and tools contribute to the successful accomplishment of the
intended product(s) in each specific area. Examples of individual products can include:
incident classification, press briefings, source term estimates, Protective Action
Recommendations (PARs), consequence versus distance calculations, exercise programs
for the site, training plans, effectively trained ERO personnel, detection equipment
requirements, meetings with public or offsite response organizations, EPZ, etc.
The intended objective from each function or activity is evaluated in terms of the desired
qualitative or quantitative performance characteristics of each of the products. These
performance characteristics are determined by the role that the goal plays in meeting the
overall emergency management performance objective. The resulting evaluations will be
referred to as performance-based evaluations where the focus of the evaluation
methodology is not on specific prescriptive details of plans, procedures, calculation
techniques, administrative structure, etc., but on the desired performance characteristics of
the resulting output.
The collective performance associated with the program elements supports the overall
performance goal of emergency management programs. In order to provide a logical
structure for evaluating the overall emergency management program, an individual
performance objective has been developed for each program element. These goals were
derived from the requirements of DOE O 151.1D, Comprehensive Emergency
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Management System, augmented with additional guidance from this EMG (Chapter 2 All
Hazards Planning/Technical Planning Basis), other DOE-directives, and other Federal,
Tribal, State, and local regulations.
As indicated above, these groups represent the core emergency management activities and
encompass the fifteen (15) Program Elements of the DOE/NNSA emergency management
program:
• ALL-HAZARDS PLANNING/TECHNICAL PLANNING BASIS
– All-Hazards Survey/Emergency Planning Hazards Assessment
• PROGRAMMATIC - activities that sustain the program
– Program Administration and Management
– Training and Drills
– Readiness Assurance
• RESPONSE - elements that respond or contribute to response as needed in an
emergency
– Emergency Response Organization (ERO)
– Emergency Operations System
– Offsite Response Interfaces
– Emergency Facilities and Equipment/Systems
– Emergency Categorization and Classification
– Notifications and Communications
– Consequence Assessment
– Protective Actions
– Emergency Medical Support
– Emergency Public Information
– Termination and Recovery
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Comprehensive Emergency Management Program (CEMP) Elements
All-Hazards Planning/Technical Planning Basis
1. All-Hazards Survey. An examination of the features and characteristics of the SFA
Section 17
that identifies the generic emergency incidents and conditions, and the potential
effects of such emergencies is to be addressed by the DOE Comprehensive
Emergency Management System. The All-Hazards Survey identifies key components
of the Emergency Management Core Program that provide a foundation of basic
emergency management requirements and an integrated framework for response to
serious incidents involving health and safety, the environment, safeguards, and
security. For SFAs involved in producing, processing, handling, storing, or
transporting hazardous materials that have the potential to pose a serious threat to
workers, the public, or the environment, the All-Hazards Survey provides a hazards
screening process for determining whether further analysis of the hazardous materials
in an EPHA is required.
2. Emergency Planning Hazards Assessment (EPHA). Performed for each SFA
involving at least one qualifying hazardous material, as identified through the
hazardous material screening process and indicated in the All-Hazards Survey.
EPHAs involve the application of rigorous hazards analysis techniques that provide
sufficient detail to assess a broad spectrum of postulated incidents or conditions
involving the potential onsite release of (or loss of control over) hazardous materials
and analyzing the resulting potential consequences. Each EPHA reflects both the
magnitude and the diversity of the hazards and the complexity of the processes and
systems associated with the hazards, and provides the technical planning basis for
determining the necessary plans/procedures, personnel, resources, equipment, and
analyses (determination of an EPZ) for the Emergency Management Hazardous
Materials Program.
Programmatic Elements
1. Program Administration and Management. Effective organizational management
and administrative control of the SFA emergency management program is
provided by establishing and maintaining authorities and necessary resources
commensurate with the responsibility to plan, develop, implement, and maintain a
viable, integrated, and coordinated comprehensive emergency management
program.
2. Training and Drills. A comprehensive, coordinated, and documented program of
training and drills is an integral part of the emergency management program to
ensure that preparedness activities for developing and maintaining program-
specific emergency response capabilities are accomplished.
3. Readiness Assurance. A Readiness Assurance program provides a framework and
associated mechanisms to assure that emergency plans, implementing procedures,
and resources are adequate and sufficiently maintained, exercised, and evaluated
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(including evaluations and assessments), and that appropriate and timely
improvements are made in response to needs identified through coordinated
comprehensive emergency planning, resource allocation, exercises, and
evaluations.
4. Exercises. All elements of an emergency management program are validated over
a multi-year period through a formal exercise program. The exercise program
validates SFA-level emergency management program elements by initiating
response to simulated, realistic emergency incidents/conditions in a manner that
replicates an integrated emergency response to an actual incident as nearly as
possible. Planning and preparation use an effective, structured approach that
includes documentation of specific objectives, scope, timelines, injects, controller
Section 18
instructions, and evaluation criteria for realistic scenarios. Each exercise is
conducted, controlled, evaluated, and critiqued effectively and reliably. Lessons
learned are developed, resulting in corrective actions and improvements.
Response Elements
1. Emergency Response Organization. An ERO, a structured organization with overall
responsibility for initial and ongoing emergency response and mitigation, is
established and maintained. The ERO establishes effective control at the
event/incident scene and integrates local agencies and organizations providing onsite
response services. An adequate number of experienced and trained primary and
alternate response personnel are available on demand for timely and effective
performance of ERO functions.
2. Emergency Operations System. All the systems and logistical support needed to
provide an effective emergency response by Emergency Operations Center (EOC)
staff, Incident Command, first responders, site managers, and building emergency
organizations including all the necessary facilities, systems, and equipment.
3. Offsite Response Interfaces. Effective interfaces are established and maintained to
ensure that emergency response activities are integrated and coordinated with the
Federal, Tribal, State, and local agencies and organizations responsible for emergency
response and protection of workers, the public, and the environment.
4. Emergency Facilities and Equipment/Systems. Facilities and equipment adequate to
support emergency response are available, operable, and maintained. Specifically, an
adequate and viable command center and personal protective equipment (PPE) are
available and operable to meet the needs of the responders.
5. Emergency Classification & Categorization. Major unplanned or non-routine events
or conditions involving or affecting DOE or NNSA SFA by causing, or having the
potential to cause, serious health and safety impacts onsite or offsite to workers or the
public, serious detrimental effects on the environment, direct harm to people or the
environment as a result of degradation of security or safeguard conditions, or release
of (or loss of control over) hazardous materials, are recognized promptly, categorized,
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and declared as Operational Emergencies (OE). In addition to being categorized as
OE, incidents involving the actual or potential airborne release of (or loss of control
over) hazardous materials from an SFA also require prompt and accurate classification
based on health effect thresholds (for initiating protective actions) measured or
estimated at specific receptor locations (i.e., site and facility boundaries, etc.).
Predetermined conservative onsite and offsite protective action recommendations are
associated with the classification of OE.
6. Notifications and Communications. Prompt, accurate, and effective initial emergency
notifications are made to workers and emergency response personnel/organizations,
including appropriate DOE or NNSA elements, and other Federal, Tribal, State, and
local organizations and authorities. Accurate and timely follow-up notifications are
made when conditions change or when the classification is upgraded, or the
emergency is terminated. Continuous, effective, and accurate communications among
response components or organizations are reliably maintained throughout an OE.
7. Consequence Assessment. Estimates of onsite and offsite consequences of actual or
Section 19
potential releases of hazardous materials are correctly computed and assessed in a
timely manner throughout the emergency. Consequence assessments are integrated
with incident classification and protective action decision-making, incorporate facility
and field indications and measurements, and are coordinated with offsite agencies.
8. Protective Actions. Protective actions are promptly and effectively implemented or
recommended for implementation, as needed, to minimize the consequences of
emergencies and to protect the health and safety of workers and the public. Protective
actions can be implemented individually, or in combination, to reduce exposures from
a wide range of hazardous material types and include evacuation, sheltering,
decontamination of people, medical care, ad hoc respiratory protection, control of
access, shielding, radioprotective prophylaxis administration of stable iodine,
chelating agents, or diuretics), control of foodstuffs and water, relocation,
decontamination of land and equipment, and changes in livestock and agricultural
practices. Protective actions are reassessed throughout an emergency and modified as
conditions change. Reentry activities are planned, coordinated, and accomplished
properly and safely.
9. Emergency Medical Support. Medical support is provided for workers contaminated
by hazardous materials. Arrangements with offsite medical facilities to transport,
accept, and treat contaminated, injured personnel are documented.
10. Emergency Public Information. Accurate, candid, and timely information must be
provided to workers, the news media, and the public during an emergency to establish
facts and avoid speculation. Emergency public information efforts must be
coordinated with State, Tribal, and local governments, and be part of Federal
emergency response plans as appropriate. Workers and the public are informed of
emergency management plans and planned protective actions before emergencies.
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11. Termination and Recovery. An OE is terminated only after a predetermined set of
criteria has been met and termination has been coordinated with offsite agencies.
Recovery from a terminated OE involves communication and coordination with
Tribal, State, local, and other Federal agencies; planning, management, and
organization of the associated recovery activities; and ensuring the health and safety
of workers and the public.
1.1.7. DOE/NNSA Emergency Management and Integrated Safety Management (ISM)
As the last line of defense in protecting workers, the public, and the environment, the
comprehensive emergency management program at each DOE/NNSA SFA is a key
element of work planning and execution in accordance with ISM. Emergency
management (like quality assurance, maintenance, personnel training, conduct of
operations, fire protection, and waste management) should be a specific function
addressed by the safety management program necessary to ensure the safe operation of an
SFA. The DOE emergency management system ensures consistency across the complex
through a common understanding of emergencies and expected DOE response at all
organizational levels, including the local worker and SFA level, which are the primary
focus of ISM.
The approach begins with identifying the type and nature of the emergencies that could
affect DOE SFAs followed by analyses of the resultant hazards to workers, the public, the
Section 20
environment, and national security. Based on the hazards analyses, the requirements in the
Order are tailored to develop an emergency management program that addresses the
unique hazards and operating environment of each SFA. The All-Hazards Survey and
Emergency Planning Hazards Assessment (EPHA), which are integral parts of the
commensurate with hazards or tailoring approach, provide the recognition tools and
define the appropriate response to potential releases of hazardous materials. Such hazard
controls are essential components in the last line of defense in protecting workers, the
public, and the environment.
Continuous Improvement is a fundamental concept embedded in ISM and the DOE
emergency management system. In DOE emergency management, continuous
improvement is provided through the readiness assurance program required of all
DOE/NNSA SFA emergency management programs. Readiness assurance provides the
framework and associated mechanisms to assure that planning and resources are adequate
and sufficiently maintained, exercised, and evaluated, and that appropriate, timely
improvements are made in response to needs identified. A structured and focused program
of evaluations (Criteria Review and Approach Document (CRAD) and exercise
evaluations) and reliable lessons learned via process ensure that an effective program of
continuous improvement maintains DOE/NNSA emergency management programs.
Thus, the fundamental concepts that characterize DOE emergency management and the
requirements contained in DOE O 151.1D set forth DOE/NNSA expectations for
emergency management and provide effective mechanisms for integrating emergency
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management objectives effectively and seamlessly with ISM fundamental concepts and
core safety management functions.
1.1.8. DOE/NNSA Emergency Management and National Incident Management System
1.1.8.1. National Response Framework
The National Response Framework (NRF) provides a single, comprehensive approach to
domestic incident management. It is an all-hazards plan built on the template of the
National Incident Management System (NIMS). The NRF, using NIMS, provides the
structure and mechanisms for national-level policy and operational direction for incident
management. The NRF can be partially or fully implemented in response to an incident
requiring a coordinated Federal response.
The NRF is based on the premise that incidents are typically handled at the lowest
jurisdictional level, with first responders using existing authorities. Consequently, when
an Operational Emergency occurs at a DOE/NNSA SFA, the initial response is conducted
by the site/facility/activity using plans and procedures developed commensurate with the
hazards at the SFA and according to the requirements of the DOE Comprehensive
Emergency Management System. These plans could include use of response capabilities
from the surrounding jurisdictions. Most OE should be resolved using these plans and
capabilities.
There may be situations where the DOE/NNSA Nuclear Emergency Support Team
(NEST) are needed to augment the local response. Requested NEST teams are generally
directed through the appropriate DOE Regional Coordinating Office to the DOE HQ
EOC. All other requests for the NEST go directly to the DOE HQ EOC. When other
agencies receive requests for Federal radiological monitoring and assessment assistance,
they notify the DOE HQ EOC.
Section 21
The DOE serves as the coordinating agency for the Federal response to radiological
incidents involving DOE/NNSA SFAs, or material otherwise under its jurisdiction
(transportation of material shipped by or for DOE/NNSA). The National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), found in 40 CFR Part 300,
provides similar planning guidance and operational concepts for Federal response to other
hazardous material incidents, including incidents involving source, by-product, or special
nuclear material, or other ionizing radiation sources requiring Federal coordination.
DOE O 151.1D contains requirements for the Field Element Managers to pre-designate
personnel to oversee the SFA response and assign tasks to those Federal assets that are
deployed to support the SFA, under the authority of the full NRF, the
Nuclear/Radiological Annex to the Response and Recover Federal Interagency Operations
Plans, or the NCP. As part of the DOE O 151.1D planning process, DOE/NNSA SFAs
and Field Elements should identify the scenarios where response capabilities may be
exceeded and broader assistance from the Federal Government would be needed. The
scenarios requiring these response capabilities are likely to be limited to the high-
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consequence end of the spectrum of potential incidents. It is possible that, commensurate
with the hazards at the DOE/NNSA SFAs, Federal response capabilities or assistance may
not be needed.
Implementation of the NRF reveals concepts that are not directly addressed within the
DOE Comprehensive Emergency Management Program. As part of the change to an all-
hazards approach at the Federal level, the NRF broadened concepts related to incident
management and began the process of establishing a common terminology related to
emergency management. The National Preparedness System describes a framework that
includes: Prevention, Protection, Mitigation, Response, and Recovery. Where the DOE
emergency management program names the standard components as planning,
preparedness, response, and readiness assurance, the NRF includes two other concepts,
prevention and mitigation. These are defined in the NRF as follows:
Prevention includes capabilities necessary to avoid, prevent, or stop a threatened or actual
act of terrorism. Within the context of national preparedness, the term prevention refers to
dealing with imminent threats.
Mitigation is the effort to reduce loss of life and property by lessening the impact of
incidents. Mitigation includes any activities that prevent an emergency, reduce the chance
of an emergency incident occurring, or reduce the damaging effects of unavoidable
incidents.
Prevention involves the use of information and data to avoid an incident or to intervene to
stop an incident from occurring. The primary focus of activity in incident management
involves the use of intelligence data or other types of surveillance activities to anticipate
and stop/avoid the incident.
Prevention activities are more closely related to activities undertaken in the security,
safety, or health programs, before the incident rises to the seriousness of an emergency.
On the other hand, DOE activities, representing the standard components of a DOE
emergency management program, explicitly incorporate the NRF concept of mitigation.
Examples include:
• The planning analysis associated with a hazards assessment can identify
Section 22
opportunities to reduce the consequences of a potential hazardous material release
incident using hazard mitigation activities such as inventory reduction or
inventory dispersal.
• Response activities include the execution of incident mitigation activities designed
to limit the loss of life, personal injury, property damage, and other unfavorable
outcomes.
• Readiness assurance activities include incorporating lessons learned from
evaluations and actual emergencies to improve the response and, perhaps,
identifying vulnerabilities in hazardous materials safety procedures and systems.
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These and other NRF concepts and terminology will be more fully integrated into the
DOE emergency management system in future versions of the Order and this guidance.
1.1.8.2. National Incident Management System
For years, DOE requirements and guidance have discussed the need to have an incident
command system at the SFA level that could seamlessly integrate response assets from
the surrounding jurisdictions. NIMS is designed to achieve the same integration at all
levels of government. The Department of Homeland Security (DHS) promulgated NIMS,
3rd Edition, in October 2017, under the authority of Homeland Security Presidential
Directive 5. NIMS is the nationwide template enabling Federal, State, local, and Tribal
governments and private-sector and nongovernmental organizations to work together
effectively and efficiently to prevent, prepare for, respond to, and recover from
emergencies.
1.2. Core Program Facilities
1.2.1. Introduction
Emergency management programs for each DOE/NNSA SFA are documented in an
emergency management plan. The plan describes provisions for response to OEs and
activities for maintaining the emergency management program. The recommended
emergency management plan content for Core Program Facilities is provided in this
section. A Departmental SFA with no additional requirements for an Emergency
Management Hazardous Materials Program must develop and implement an emergency
management plan for a Core Program.
1.2.2. Program Elements
1. All-Hazards Planning Basis
List all hazards that are applicable to the operation of a given entity and establish
the planning basis for an emergency management program. This list can cover
single facilities, multiple facilities and activities, or an entire site. Conduct a
Threat and Hazard Identification and Risk Assessment (THIRA) as described by
Comprehensive Preparedness Guide (CPG) 201.
2. Program Administration and Management
State the overall function and mission of the facility or site. Broadly describe the
facility or site; for a site, this includes the buildings and facilities within the site.
State the name, position, mailing address, and telephone number of the emergency
management program administrator at the facility or site level. (This information
should also be in the appendix that lists Emergency Management Personnel.)
3. Training and Drills
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List drills and training programs that are provided to employees. Indicate refresher
training for employees who are certified operators or supervisors and those
workers who are likely to witness a hazardous material release.
4. Readiness Assurance
Ensure that the procedure for annual self-assessments is listed in this section. The
formal improvement program consisting of lessons learned from evaluations and
Section 23
drills/exercises should be described. Describe the process for identifying and
implementing relevant lessons learned from external sources. Exercises—
Describe the exercise program. Describe how exercises will be controlled and
evaluated and how lessons learned from exercises, improvements, or corrective
actions are incorporated into emergency planning. List all offsite agencies
involved in the exercise program (i.e., HQ, other Federal agencies, and local
agencies). List annual testing of all emergency notification equipment.
5. Emergency Response Organization
List the individual who has been assigned to manage and control all aspects of the
SFA response. Indicate how the individual will fit into the responding Incident
Command System (ICS).
6. Emergency Operations Systems
List the process for centralized collection, validation, analysis, and coordination of
information relating to an emergency supporting on scene responses.
7. Offsite Response Interfaces
Outline all coordination with Tribal, State, and local agencies and organizations
responsible for emergency response or protection of the health and safety of the
public. If there is no offsite coordination, provide a brief justification statement.
8. Emergency Facilities and Equipment/Systems
Identify the SFA capabilities and specific equipment in place that is used to
support an emergency response, including systems and equipment used to notify
and evacuate employees.
9. Emergency Categorization
This section should provide criteria for determining quickly if an incident is an
Operational Emergency (OE) and how categorization is accomplished within 15
minutes.
10. Notifications and Communications
Discuss the required and documented notification process for onsite and offsite
notifications for all OEs. Identify positions responsible for both initiating and
receiving notifications. Discuss the method of notification. Discuss notification
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procedures for termination of an incident. Include copies of all notification forms,
particularly those used in response to DOE O 231.1B Admin Chg. 1,
Environment, Safety and Health Reporting, and its successors. Describe the
communications systems and equipment that would be employed by emergency
personnel at the site or any specific facility for any notifications, sirens, or
warnings to the public, including a description of primary and alternate systems.
Discuss communications interface with onsite and offsite organizations. Identify
what portions of the system are dedicated to emergency management. Describe
the equipment, back-up equipment, quality assurance, and testing procedures.
11. Consequence Assessment
Since there are no minimum requirements specified for this area, this section
would contain only references to types of consequence assessment functional
areas required by other Departmental Orders or Federal regulations.
12. Protective Actions
Describe the procedures to determine personnel accountability and evacuation.
Discuss the method and procedures for accountability of onsite personnel and
visitors, locations of shelters, and other conditions. Describe access control
procedures for evacuated areas. Describe the system to ensure safe shutdown of
operations following the declaration of an emergency. Describe the plan and
criteria for reentry at each facility and, where applicable, for the entire site;
identify all reentry plans.
13. Emergency Medical Support
Section 24
Identify onsite medical support, if applicable, as well as offsite medical response
agencies and facilities responsible for providing support in normal and mass
casualty situations.
14. Emergency Public Information
List all onsite organizations and personnel (by position) responsible for providing
information to the media during an emergency incident. Additionally, maintain
lists of the offsite organizations’ Public Information Officers (PIOs) for rapid
coordination in event of an emergency.
15. Termination and Recovery
Detail notifications associated with termination of an OE and the criteria for
resumption of normal operations.
1.3. Hazardous Materials Program Facilities
1-20 DOE G 151.1-1B
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1.3.1. Introduction
Emergency management programs for each DOE/NNSA SFA are documented in an
emergency management plan. The plan describes provisions for response to OEs and
activities for maintaining the emergency management program. The recommended
emergency management plan content for Emergency Management Hazardous Materials
Programs is provided in this section. The requirements for Core Programs and Emergency
Management Hazardous Materials Programs should be seamlessly integrated into one
emergency management plan for the facility or site with hazardous materials that require a
more substantial level of planning and response capabilities.
1.3.2. Program Elements
1. Technical Planning Basis
An All-Hazards Survey shall be used by the site, facility, or activity Emergency
Manager to identify the planning requirements addressed in the Emergency
Management Core Program. A Departmental site, facility, or activity may then be
required to establish and maintain a quantitative Emergency Planning Hazards
Assessment (EPHA). The quantitative EPHA analyzes hazards significant enough
to warrant consideration in an SFA or activity Emergency Management
Hazardous Materials Program.
Include or summarize the results of the All-Hazards Survey. Describe known
hazards originating outside the Departmental facility that could impact the health
and safety of onsite personnel or other Departmental interests.
List or summarize the significant radiological and non-radiological hazards
present. Describe the system for updating the EPHA. Identify technical supporting
documents that describe the methodology and information of EPHAs used as the
basis for emergency planning.
2. Program Administration and Management (Same as Core)
Hazardous Material Facilities will follow the same format for this as previously
mentioned in the Core Program requirements.
3. Training and Drills
Describe the goals and objectives of the facility or site training and drills program.
Describe the overall approach to the design of the training and drill program,
including training analysis methodology, overall curriculum design, and
qualifications.
(a) Defense Nuclear Facilities
DOE G 151.1-1B 1-21
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Describe the goals and objectives of the facility using a graded approach
and incorporate all aspects of emergency staff as mentioned in
DOE O 151.1D.
4. Readiness Assurance
Describe the procedures for developing a structured readiness assessment
program, including program and exercise evaluations.
Describe the emergency management exercise program and how it conforms to
the requirements of DOE O 151.1D and any other applicable Federal, State, and
local regulations. Describe how exercises will be controlled and evaluated and
Section 25
how lessons learned from exercises (improvements or corrective actions) are
incorporated into emergency planning.
(a) Defense Nuclear Facilities
Describe how the site exercise program meets additional requirements
provided by DOE O 151.1D (involvement of staff, involving Department
Radiological Emergency Response Assets no less than once every 3 years,
causal analysis for corrective actions, etc.).
5. Emergency Response Organization (Same as Core)
Hazardous Material Facilities will follow the same format for this as previously
mentioned in the Core Program requirements.
6. Emergency Operations Systems (Same as Core)
Hazardous Material Facilities will follow the same format for this as previously
mentioned in the Core Program requirements.
7. Offsite Response Interfaces
Provide an overview of relationships, both formal and informal, with offsite
organizations, including other Departmental elements and other Federal
government, Tribal, State, and local organizations with emergency management or
emergency planning responsibilities. Mutual Aid Agreements (MAAs),
Memoranda of Agreements (MOAs), and Memoranda of Understanding (MOUs)
should be described in this section.
8. Emergency Facilities and Equipment/Systems
List and provide a brief description of all emergency-related facilities EOC,
Alternate EOC, Joint Information Center (JIC). Distinguish between dedicated
and non-dedicated facilities. Maps and floor plans of facilities should be included
when a complete description of the facility will be useful in a response.
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List and describe the equipment likely to be used for responding to emergencies.
Include in the list equipment capability and limitations, quantity of equipment,
locations (both fixed and portable equipment), consumables, maintenance
requirements, certification requirements, expiration dates, and
computer/communications compatibilities.
(a) Defense Nuclear Facilities
List shutdown or walkaway strategies for equipment and facilities during
emergencies and provide a description for a transition of responsibilities
and required actions between normal work activities, incident activities,
and recovery operations.
9. Emergency Classification
State the definitions of OEs and emergency classes per DOE O 151.1D. In the
interest of consistency, the definitions as provided in the Departmental Orders can
be repeated.
10. Notifications and Communications
Discuss the required and documented notification process for onsite and offsite
notifications for all OEs. Identify personnel (positions) responsible for both
initiating and receiving notifications. Discuss the method of notification. Discuss
the notification procedure for termination of an incident. Discuss the procedure
variance for classified notifications. Include copies of all notification record
forms, particularly those forms used in response to DOE O 231.1B Admin Chg. 1,
and its successors.
Describe the communications systems and equipment employed by emergency
personnel at the site or any specific facility for any notifications, sirens, or
warnings to the public, including a description of primary and alternate systems.
Discuss communications interface with offsite organizations; describe the
integration of the site’s communications with offsite response resources, such as
the police, fire, and offsite EROs.
Identify what portions of the system are dedicated to the Emergency Management
Section 26
System. Describe the equipment, back-up equipment, readiness assurance, and
testing procedures. Describe the troubleshooting system for ensuring that
problems noted during tests and drills are identified, tracked, and resolved.
Reference to any listing of communication equipment in the Emergency
Equipment chapter is acceptable. Describe the procedures and plans for
communicating classified information.
11. Consequence Assessment
Describe the procedures used to determine the potential consequences based on
the results of emergency planning hazards assessments and input from all other
DOE G 151.1-1B 1-23
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pertinent areas, such as intelligence and meteorological information. Describe the
methodologies used for consequence assessment and reference technical
supporting documentation.
Describe the expected utilization of the National Atmospheric Release Advisory
Center capabilities during a response. Describe the procedures for continually
(and in real time, where appropriate) monitoring an emergency or a continuing
situation to update the consequence assessment. Describe the processes for
initiating and performing field monitoring for both radiological and chemical
releases. When appropriate, include a discussion of any special circumstances
associated with coordination and execution of offsite field monitoring.
Describe the procedure to coordinate with other Federal, Tribal, State, and local
organizations information necessary to make accurate and timely consequence
determinations.
12. Protective Actions
Identify the purpose and intended use of protective actions. Describe protective
actions used at the SFA and under what circumstances they are implemented.
13. Emergency Medical Support (Same as Core)
Hazardous Material Facilities will follow the same format for this as previously
mentioned in the Core Program requirements.
14. Emergency Public Information
Maintain information on hazardous materials facilities, programs, and personnel
by position who can provide information to the media and general public as
related to the emergency. The PIO will maintain documented procedures for
release of information, personnel by position who may clear information for
release, and timelines for release of information (i.e., first tweet, first press
release, press conference).
15. Termination and Recovery
Describe the plan and criteria for declaring the emergency condition terminated
and transitioning to recovery at each facility, where applicable, and for the entire
site. Provide references to technical supporting documentation if applicable.
1.4. Leased Facilities
1.4.1. Introduction
Leasing facilities within DOE/NNSA sites for non-DOE/NNSA work presents some
unique difficulties for those responsible for implementing site-wide emergency
management programs. In accordance with the Guidance on Protection of Workers
1-24 DOE G 151.1-1B
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Utilizing DOE Leased Facilities, issued through the Department’s Safety Council on
August 6, 1999, each Field Element Manager, in consultation with the Lead PSO, should:
• Develop evaluation criteria that result in leasing conditions that provide protection to
workers at leased facilities from radioactive, chemical, and biological hazardous
materials; and,
• Determine the appropriate level of protection by grading facilities being leased by
hazard to worker safety and health. Prior to leasing a facility for private use, each
Section 27
Field Element Manager is required to make a determination that the facility is suitable
for reuse and that worker safety and health will be protected.
To ensure protection of worker health and safety in the event of an emergency involving
or affecting the leased facility, arrangements with lessees should effectively integrate the
activities of the leased facilities into the DOE/NNSA site-wide emergency management
program. These arrangements should ensure consistent interfaces with offsite EROs and
establish and sustain an effective working partnership for emergency planning,
preparedness, readiness assurance, and response activities.
Arrangements with lessees should include:
• Integration of each of the lessee’s emergency management program elements into the
site-wide program;
• Annual reporting of the tenant’s hazardous materials inventories to the site emergency
management organization; and
• Means for reporting significant changes to the facility or to hazardous materials
inventories to the site emergency management organization prior to implementing the
changes.
Incorporating leased facilities into site-wide emergency management programs should be
addressed consistently across the DOE/NNSA complex. To promote this consistency,
emergency management factors that should be considered by DOE/NNSA elements with
responsibility for leasing facilities at DOE/NNSA sites for non-DOE or non-NNSA work
are presented in Section 1.4.2.
1.4.2. Application of Emergency Management Guidance
Leased facilities at DOE/NNSA sites should be included in site-wide emergency
management programs using criteria from DOE O 151.1D, whether the leased facility
uses significant quantities of hazardous materials or not. DOE/NNSA should share
information standards with lessee, or consider document procedures to carry out their own
assessment. Specifically, the following factors should be considered for selected elements
of the emergency management program.
DOE G 151.1-1B 1-25
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1.4.2.1. All-Hazards Planning/Technical Planning Basis
• DOE/NNSA ensures:
– Security vulnerability assessments (VAs) are changed as appropriate to reflect
leased facility conditions;
– Emergency responders and medical treatment providers have appropriate
information to plan and respond to an emergency incident involving or affecting
the leased facility.
• DOE/NNSA provides:
– An assessment of potential hazards to the leased facility from DOE/NNSA
facilities and activities, and from DOE/NNSA onsite transportation activities, with
periodic updates;
– Information on hazards and medical concerns that DOE/NNSA, other emergency
responders, or medical treatment providers may encounter.
• The lessee provides:
– Information on hazards and activities that could affect DOE/NNSA facilities and
activities, with periodic updates.
1.4.2.2. Programmatic Elements Training, Drills, and Readiness Assurance
• DOE/NNSA provides:
– Initial and refresher training on the site emergency management plan for
personnel at the leased facility;
– Opportunity for personnel at the leased facility to participate as appropriate in site
drills and exercises for postulated emergency incidents affecting the leased
facility;
– Opportunity for personnel at the leased facility to participate as appropriate in the
planning and critique processes for emergency response exercises involving
incidents that affect the leased facility.
• DOE/NNSA ensures:
Section 28
– Site responders and decision-makers receive training on all hazards associated
with the leased facility and all facets of emergency response associated with
incidents involving or affecting the leased facility, and that these factors are
practiced during drills and tested during exercises;
1-26 DOE G 151.1-1B
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– Leased facilities and personnel are incorporated in site emergency response drills
and exercises as appropriate;
– DOE/NNSA travels to lessee facilities and conducts periodic tests and
assessments that lessee staff and facilities are complying with sites/DOE/NNSA
emergency management plans.
• The lessee ensures:
– Personnel at the leased facility attend initial and refresher training on the site
emergency management plan;
– Personnel at the leased facility participate as appropriate in site drills and
exercises for postulated emergency incidents involving or affecting the leased
facility.
1.4.2.3. Response Elements ERO
• DOE/NNSA ensures:
– Designated Incident Commanders (ICs) have access to hazards related to leased
facilities;
– Lessee emergency response resources are effectively integrated through plans,
procedures, drills, and exercises with site and other emergency response
resources;
– The emergency management plan and implementing procedures contain
provisions for personnel from the leased facility to be integrated into the site ERO
as appropriate during emergency incidents involving or affecting the leased
facility.
• The lessee ensures:
– The scope of emergency services provided through the site-wide emergency
management program and associated incident command is fully understood and
effectively integrated in the emergency response plan and implementing
procedures, practiced during drills, and tested through exercises for the leased
facility;
– The emergency management plan and implementing procedures contain
provisions for a representative to interact with site emergency management
personnel during emergency incidents involving or affecting the leased facility.
Offsite Response Interfaces
• DOE/NNSA ensures:
DOE G 151.1-1B 1-27
7-26-22
– Local agencies, law enforcement officials, and offsite mutual aid and support
organizations are aware of the relationship and the respective emergency
management roles and responsibilities between the site and the leased facility for
response and notifications to hazardous material and security incidents. This
includes information on hazards and medical concerns that offsite emergency
responders or medical treatment providers may encounter.
• The lessee ensures:
– Information concerning unique facility-specific hazards is made available to
offsite emergency responders and emergency medical personnel.
Communication/Notifications
• DOE/NNSA ensures:
– Site-wide plans and procedures contain provisions and assignment of
responsibilities to contact representatives of the lessee in event of a site
emergency affecting the leased facility, and that these provisions are practiced
during drills and tested during exercises;
– Site-wide plans and procedures, and those of potentially affected DOE/NNSA
facilities, contain provisions for receipt of notification of an emergency at the
leased facility;
– Coordination with the lessee on communication equipment and protocols and
messages for timely and effective notifications of emergency incidents.
• The lessee ensures:
– Plans and procedures contain provisions to notify and protect personnel in
Section 29
accordance with OSHA requirements for hazards at the leased facility.
Consequence Assessment
• DOE/NNSA ensures:
– Site-wide consequence assessment models include the leased facility locations for
emergency management decision makers;
– Site-wide consequence assessment models include appropriate hazards
information specific to the leased facility;
– Site-wide field monitoring (radiological, chemical, and biological) plans,
personnel, equipment, and resources appropriately consider leased facility hazards
and site hazard impacts on the leased facility.
• The lessee ensures:
1-28 DOE G 151.1-1B
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– Facility-specific consequence assessment models and field monitoring plans,
personnel, equipment, and resources are available to DOE/NNSA for integration
into the site-wide consequence assessment capability.
Protective Actions
• DOE/NNSA ensures:
– Pre-determined protective actions are identified for the leased facility based on
site hazards that could impact the leased facility, and that these actions are
coordinated with the lessee;
– Pre-determined protective actions are identified for site facilities that could be
affected by hazards at the leased facility;
– Provisions for protection (appropriate protective equipment, monitoring
equipment, hazard information, potential exposure information, safe routes of
entry/egress) of site and other emergency responders and security personnel are
incorporated into plans and procedures, practiced during drills, and tested during
exercises involving leased facility hazards;
– Site evacuation planning includes consideration of personnel at the leased facility;
– Plans and procedures for site medical facilities appropriately consider hazards and
personnel at the leased facility;
– Lessee plans for personnel accountability in the event of an emergency involving
or affecting the leased facility are understood and integrated into site plans and
procedures, practiced during drills, and tested during exercises involving the
leased facility;
– Potential responders have access to leased facility hazard information and building
layout for safe search and rescue and emergency mitigation.
• The lessee ensures:
– Pre-determined protective actions are identified for the leased facility based on
site hazards that could affect the leased facility, and that these actions are
coordinated with the lessee;
– Protective actions are identified in accordance with OSHA requirements for
hazards at the leased facility.
• The lessee provides:
– Hazard information and building layout to permit safe search and rescue and
emergency mitigation;
DOE G 151.1-1B 1-29
7-26-22
– Plans for personnel accountability in the event of an emergency involving or
affecting the leased facility.
Emergency Public Information
• DOE/NNSA provides:
– Access to the JIC for emergencies at the leased facility.
• DOE/NNSA ensures:
– Ongoing and coordinated planning between PIOs of the site and leased facilities;
– Emergency information released through news releases and statements to the press
is coordinated with leased facility representatives when the emergency directly
impacts the lessee;
– Site PIOs are aware of designated lessee emergency contacts as well as hazards
specific to leased facilities.
• The lessee ensures:
– News releases and statements to the press regarding an emergency incident at the
leased facility are coordinated with the site PIO;
Section 30
– Complete and accurate information concerning emergencies at the leased facility
is made available in a timely manner to support DOE/NNSA response to public
inquiries.
1.5. Closure Activities
1.5.1. Introduction
Closure activities and conditions can pose significant challenges to emergency planners.
Often, the changes inherent in SFA closure affect the planning basis for emergency
response as well as the response itself. The critical problem is to ensure that inevitable
reductions in response capabilities do not overtake the decrease in hazards posed by the
SFA processes and materials, resulting in an inadequate emergency response capability.
The planner should recognize that the resolution of issues included in this chapter should
be in total concert with a basic tenet of the DOE emergency management systems,
namely: planning, preparedness, and response must be specific to and commensurate with
the hazards.
The purpose of this chapter is to address important issues that should be considered when
planning changes to an emergency management program based on the projected closure
of the SFA. The approach for addressing a closure’s impact on emergency management is
to provide precautionary statements that give emergency planners thought-provoking
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considerations that may apply to specific elements of emergency management at their
closure facilities/sites. The following sections present a number of these important
reminders related to the impact of closure activities on DOE emergency management
program elements.
Note that there is a different effect on the emergency management program when there is
a closure of an entire site versus the closure of a single facility or group of facilities on a
site that will continue to operate. The closure of an entire site will affect both site-level
and facility-level programs and assets, whereas the closure of a facility on a site may
leave site-level programs intact, since these would likely support Emergency Management
Hazardous Materials Programs at other facilities on the site. When necessary, this
distinction will be specifically addressed in the following sections.
1.5.2. All-Hazards Planning/Technical Planning Basis
All-Hazards Surveys and EPHAs. Frequent and often dramatic physical changes at
closure SFAs challenge the efforts of emergency planners to keep all-hazards surveys
information current. It is imperative, therefore, that emergency planning be a priority
consideration for managing change at a closure SFA. Examples of physical changes that
may affect emergency planning and preparedness include:
• Dismantling any item that will alter process unit safety, facilities, or information;
• Change in a critical instrumentation device or alarm;
• Dismantling that may reopen closed/sealed systems or components containing
contamination;
• Addition or deletion of piping connections, drains;
• Change in firefighting equipment or capacity; and
• Temporary use of equipment not covered by existing procedures.
The introduction of short-term hazards during the Decontamination and
Decommissioning (D&D) process can add to the planning basis for the program,
requiring temporary response measures. Site/facility changes can result in the
introduction of common usage hazardous materials that pose a new threat as an initiator
for a hazardous material release.
Since changing inventories of toxic chemicals may occur frequently at closure
Section 31
facilities/sites, administrative systems should be in place to ensure that emergency
managers are informed of these changes in a timely manner. The importance of reliable
and comprehensive methods of hazardous material identification during closure activities
cannot be overemphasized. Past methods or systems may not be reliable for identifying
changes in hazardous material inventories when an SFA is involved in D&D.
DOE G 151.1-1B 1-31
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Communication of changes in hazards to emergency response personnel is critical and
can only be ensured if a reliable system is in place to communicate change to those
responsible for the technical planning basis for the program. One method for tracking
progress is to have an emergency planner attend the periodic production planning
meetings, which address the hazards that will be encountered with the next dismantling
activities.
Changes may be subtle or can occur quickly at a closure SFA. Barriers to release of
hazardous materials, storage locations and mixes, engineering controls, administrative
controls, and safeguards and inventory systems may change. A production facility may be
closed, and process equipment removed, but hazards may still reside as holdup in
ductwork or piping. The release of those hazards becomes a potential emergency when
piping is cut during final dismantlement. The EPHA that applies for a production facility
does not apply when the same building is empty. If hazards still exist, based on a revised
All-Hazards Survey, then a new EPHA may be needed. Similarly, the EPHA that applies
when the building is empty would likely not apply after it is demolished. During the
dynamic progression of D&D activities, a facility should not be expected to update the
EPHA document constantly. However, the emergency management program must remain
prepared to respond to whatever emergency current hazards present. Hence, as hazards
are removed during closure, facilities/sites should develop and implement a timely,
efficient, and effective process that facilitates the modification of the emergency
management program using associated criteria for initiating changes.
A possible approach for tracking changes associated with the closure activities is to
ensure that emergency management is integrated with the safety hazards analysis and
work order processes used by facility management (ISM systems). Before closure begins
at an SFA, a generic hazards analysis is required to identify potential hazards to be
encountered. Additionally, at each step in the process of D&D, there should be a work
order that includes a specific safety hazard analysis for the work to be performed. For
example, safety analyses of many DOE/NNSA sites/facilities, which use or store
radioactive materials, will include criticality analyses to address accumulation and
movement of nuclear materials in piping. If emergency planners at the closure SFA are
involved in review of these work orders and hazards analyses and are prepared to use this
information to ensure readiness to respond to emergencies, then it is reasonable that they
take credit for the safety management processes used during D&D.
1.5.3. Programmatic Elements
Program Administration and Management. An emergency management administrator at a
closure SFA needs to ensure that changes taking place will not adversely impact the
ability of the program to respond effectively to an emergency. Emergency administrators
Section 32
need to have access to the appropriate level of management to make decision makers
aware, on an ongoing basis, of facility, equipment, materials, personnel, and resource
issues that may impact SFA ability to respond to an emergency.
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Also, emergency management administrators at closure facilities/sites may be tasked with
collateral duties that could interfere with and affect responsibilities to ensure that the
emergency management program readiness is maintained. Efficient planning by the
program administrator becomes critically important. Administrators should ensure that
provisions are in place for rapid development, approval, and issuance of changes to
response procedures, and timely scheduling of training to ensure these changes are
implemented. Maintaining plans and procedures can become a significant task when
frequent change is occurring involving people, facilities, materials, and expertise at an
SFA.
Training and Drills. Emergency response training programs should be reviewed and
updated periodically, based on the frequent change characteristic of such facilities/sites.
Emergency management administrators should have frequent input to General Employee
Training programs for changes in basic emergency response. Drill programs should be
dynamic to address the needs of the SFA and issues identified in real incidents, exercises,
and reinforce training. This should include both operational and closure facilities. For
example, aggressive milestones may not allow time for a regular drill schedule. As a
result, shorter drills that are focused on changes to areas and materials may provide a
solution for some facilities/sites.
Facility and organizational experience and knowledge may be lost when an SFA
transitions from production to closure. Facilities/sites may need to put in place a means to
capture critical knowledge before the transition is made and to incorporate some of this
knowledge in training for emergency managers and responders.
Training of offsite emergency responders may become more critical as site resources for
emergency response are reduced. Offsite responders may be expected to have an
increased role in response to SFA OEs.
Readiness Assurance. Maintaining, updating, and testing/validating plans and procedures
can become a virtually continuous task at a closure SFA because the nature of closure
activities may mean frequent changes in hazards, physical facilities, organizational
expertise, management, number of personnel at the site, and ERO resources available to
support response. Evaluation and improvement programs at closure SFAs need to be
vigilant in adjusting to change and its impact on the readiness of the SFA to respond to
emergencies, as well as on new vulnerabilities that require adjustments in resources.
These programs will by necessity be driven by short-term objectives to ensure readiness
through careful attention to focused evaluations of the modified aspects of the planned
response. Improvements and lessons learned would be implemented on a schedule that
should coincide with the schedule of changes caused by the closure activities.
As a site undergoes changes from an operational site to a site focused on demolition and
closure processes, the exercise requirements and community expectations will change.
However, exercises do help reassure the community that the site can still respond and
mitigate the hazards in an emergency. Hence, participation in the annual site-level
Section 33
exercise should be maintained at an acceptable level to provide assurances that response
DOE G 151.1-1B 1-33
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will be adequate in the event of an emergency. This level of participation might be
ensured by tracking a performance measure or as an explicit inclusion as part of
contractual agreements.
The demolition and closure of an individual or group of facilities on an operating site
should have no effect on the site-wide programs. However, closure facilities will, at some
point, be excluded from being the source of the hazards, but should still participate in the
exercise as a collocated facility responding to an OE incident elsewhere on the site.
1.5.4. Response Elements
Emergency Response Organization. Ensuring that an adequate number of primary and
alternate response personnel are available, prepared, and qualified becomes a challenge
for closure facilities/sites emergency management programs. Responsive and creative
programs are needed in the ERO organizational structure when a site transitions from
production to closure. For example, some programs may need to consider moving to a
dedicated and specialized emergency response brigade when organizational changes
create conditions in which the usual volunteer ERO is not available or reliable.
Reduction in hazards may drive an SFA to tailor its cadre of emergency responders. These
types of changes should be considered as part of the site Closure Plan, and emergency
management professionals should have an active role in site closure planning.
Responsibility for control of operations, monitoring, and repair teams should be vested
with a single individual; however, at a closure SFA, it is possible that personnel who
would staff these teams will be subcontractors. In this case, organizational changes or
provisions would need to be made to ensure resource availability and adequate
organizational controls in an emergency.
The dynamic nature of closure facilities/sites may also create conditions in which tools,
parts, and even PPE needed by repair and maintenance teams are not readily available for
mitigating an emergency. There should be ongoing dialog with operations and
maintenance managers on these types of issues. Emergency planners should be
particularly cognizant of possible changes in the effectiveness of emergency fire response
on closure sites. Changes in SFA hazards due to closure activities should be
communicated to the Fire Department. Physical facility and site changes may affect
timely fire response as well as security. SFA changes could also impact the usability and
reliability of pre-arranged fire preplans for facilities undergoing D&D.
Emergency Operations Systems. Sites that are transitioning toward closure should
maintain the function of the emergency operations system such that it is scalable to the
emergency.
Offsite Response Interfaces. Sites that are transitioning toward closure generally
experience changes in the contracting process, budgeting for emergency management,
management priorities, and the nature of site hazards. These changes can result in
significant changes in the relationship with local and state offsite EROs. If resources for
emergency management are reduced overall, there may be an impact on agreements for
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mutual assistance and a site’s ability to supplement offsite emergency response programs.
However, during closure, MOU for offsite resources, such as emergency medical support,
Section 34
often become even more critical as onsite resources diminish. These impacts may not
result from the closure of a single facility or a group of facilities, since offsite interfaces
may be implemented and maintained at the site-level.
In any closure situation, if SFA hazards change significantly, there may be a need to
inform offsite agencies. Similarly, the ultimate impact of closure on offsite communities
may be significant and affect offsite relations that are important to emergency
preparedness. Discussing these issues with offsite agency contacts early during the
closure planning process will help preserve relationships that must be maintained for
effective response.
Emergency Facilities and Equipment/Systems. Within the D&D environment of a closure
SFA, there is still the need to maintain operational capability, staffing and support
systems for communications, protection, and utilities at emergency operations facilities.
Facility reference materials at the EOC, such as site maps and facility drawings, must be
kept current and available to responders. The operability of public address systems and
alarm systems needs to be maintained and not allowed to become vulnerable in a
deconstruction environment. Similarly, storage locations for response equipment may
change. Emergency management staff must stay aware of such changes. Surveillance of
emergency response facilities, communication systems, and equipment may be needed
more frequently. Ultimately, as the site-wide hazards on a closure site are significantly
reduced, the need to maintain a state-of-the-art EOC may not be warranted, and a simple
command center location may be adequate.
Emergency Categorization and Classification. At a closure SFA, the readily available
indications or observable conditions that provide decision-makers’ criteria for
categorization of OEs may change. The SFA-specific criteria must be kept up to date and
responsible persons kept informed and trained on the changes. Site-/facility-specific
EALs may also require updating and decision-makers must be knowledgeable of these
changes.. As initiating conditions and emergency scenarios may change, emergency
planners may need to intensify programs for reviewing and testing criteria to categorize
OEs and EALs for classification of closure of SFAs.
Notifications and Communications. Impacts on communication and notification systems
can result from a D&D modified environment. This could involve changes to the
effectiveness of an SFA’s public address systems, facility alarm systems, or offsite
communications. Lines of communication and notification are essential for timely
notifications. On a site where selected facilities are undergoing D&D, it is essential that
workers at a closure facility are not isolated from the rest of the site, even if the closure
facility emergency management program is no longer required for its own hazards. A
release at a nearby operating facility can still affect the closure facility.
Consequence Assessment. Because of the potential dynamic conditions at closure
facilities/sites, indicators necessary to assess emergency consequences may continually
change, or at least the ability of responders to monitor the indicators may be affected.
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Emergency planners should also be alert to the need for changes to input data
requirements for the consequence assessment process (source term estimates) when
Section 35
hazards change. Emergency planners should ensure that the Consequence Assessment
Team has access to the most current planning basis documents. A process should be
developed and implemented to ensure that consequence assessment tools reflect changes
in an SFA’s hazards due to closure activities in a timely manner.
Protective Actions. Changes to SFA physical characteristics may affect worker and
responder access and egress procedures. The D&D conditions may force changes in
evacuation routes. Emergency planners should look for SFA changes that may pose new
hazards or impediments along established evacuation routes. Any changes to these
logistical aspects of protective actions need to be communicated to the workforce.
Similarly, receptor locations for predicted hazardous material consequences may change
when physical SFA changes occur. The potential for changes in the pre-planned initial
protective actions for onsite areas and protective action recommendations for offsite areas
should also be recognized.
Emergency Medical Support. Emergency planners should be cognizant of SFA changes
on emergency medical response capabilities. Changes in facility hazards should be
communicated to the site medical director. Physical SFA changes may affect timely
medical response; for example, location for landing a life-flight helicopter at a closure site
could change. The SFA changes could also affect the usability and location of pre-
arranged decontamination facilities. Agreements with offsite medical providers may still
be needed during the closure process and those offsite providers should be made aware of
the impact of SFA changes on possible medical emergency needs.
Emergency Public Information (EPI). Emergency planners should ensure the EPI staff
(both onsite and offsite) are informed of any significant changes in SFA hazards,
emergency response capabilities, and plans/procedures, and be prepared to address these
in the event of an emergency. A PIO should be part of the closure planning team. As
facilities/sites downsize during closure, adequate emergency public information resources
may still be needed to provide a public information response should an emergency occur.
A media center should be designated and available for use in the event of an emergency,
even when a closure site emergency management program is reduced to a Core Program.
Termination and Recovery. The termination of an Operational Emergency on a closure
site will be based on many of the same general criteria that an operational site will use.
However, the criteria, and subsequent recovery, will not have as their ultimate goal to
return a facility undergoing D&D to operating status, but to restart and continue the
closure processes. Senior management will need to determine the level of termination
criteria that is consistent with protecting the workers, the public, and the environment, and
performing the D&D activities safely. The termination criteria will likely be similar to
criteria for planning, scheduling, and accomplishing D&D work on a daily basis.
Recovery planning may only include the determination of the cause of the incident to
prevent reoccurrence in future closure operations.
1.6. Biosafety Facilities
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1.6.1. Introduction
The primary requirements specific to DOE/NNSA biosafety facilities using or storing
select agents or toxins are contained in 10 CFR Part 851, Appendix A, Section 7,
Section 36
Biological Safety, and the regulations from the U.S. Department of Health and Human
Services (HHS) and the U.S. Department of Agriculture (USDA) regarding certain
hazardous biological agents and toxins and their possession and use in the United States
(U.S.), receipt from outside the U.S., and transfer within the U.S. of certain hazardous
biological agents and toxins. For purposes of this guidance, the rules that address the HHS
and USDA requirements will be referred to collectively as the Select Agent Rules. At a
minimum, an entity registering under these requirements needs to develop and implement
an incident response plan. For DOE/NNSA sites, the biosafety facility incident response
plan needs to be coordinated and integrated with the implemented site-wide emergency
management plan.
The required contents of an incident response plan are described in brief statements
related to various emergency management issues. Emergency management personnel at
sites with planned, or currently operating biosafety labs, will recognize that a DOE/NNSA
emergency management program addresses many of the same issues in the Program
Elements defined in DOE O 151.1D and the other guidance chapter in this EMG.
Although the major focus of the current DOE emergency management Order and EMG is
on radioactive and chemical hazardous materials, requirements and guidance are generally
valid for biosafety facilities through modifications to account for the unique properties
and issues related to biological hazards.
1.6.2. General Approach
Integration of hazardous biological materials into the emergency management program is
directed by 10 CFR Part 851, Worker Safety and Health Program, Appendix A, 7.
Biological Safety. According to this rule, contractors must establish and implement a
biological safety program that establishes an Institutional Biosafety Committee (IBC) or
equivalent. The IBC must review the site’s security, safeguards, and emergency
management plans and procedures to ensure they adequately consider work involving
biological etiologic (i.e., disease causing) agents. In addition, the biological safety
program confirms that the site safeguards, security plans, and emergency management
programs address biological etiologic agents, with emphasis on biological select agents.
Other Federal regulations that govern the use and storage of select agents and toxins (to
be introduced in subsequent chapters) require that mandated incident response planning
be “integrated with any site-wide emergency response plans.”
For purposes of DOE O 151.1D and this Guide, a biosafety facility can include a
standalone building with a single research activity, a floor in a building, or simply a
laboratory consisting of a single room or several rooms on a floor in a building where
storage is maintained, or work/research is performed involving biological etiologic agents
or hazardous biological toxins. A biosafety facility will have an assigned containment
level consistent with applicable guidelines provided in Biosafety in Microbiological and
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Biomedical Laboratories (BMBL), U.S. Department of Health and Human Services
(HHS), Public Health Service (PHS), Centers for Disease Control and Prevention (CDC)
and National Institutes of Health (NIH), Fifth Edition, Revised 2009. The primary focus
in this guidance is on biosafety facilities that store or support activities involving
Section 37
biological select agents or toxins, although the approach can also be applied to other
etiologic agents and hazardous toxins.
Other activities in a building containing a biosafety facility may be using or storing
radioactive or toxic chemical hazardous materials. The Emergency Management
Hazardous Materials Program for the building/facility should represent an integration of
planning, preparedness, and response activities for all hazardous materials. For example, a
single EPHA should be produced for the facility covering analyses of all hazardous
materials identified in the All-Hazards Survey.
As indicated above, complications influencing application of the traditional DOE
hazardous materials approach to biological releases dictates that each agent be analyzed
and researched to examine variations in agent characteristics that may not be bounded by
a standard hazardous materials planning and response approach. Hence, emergency
management planners need to familiarize themselves with the specifics of each agent in
use in the biosafety facility to augment the standard planning and response template, as
necessary.
The guidance contained here is aimed at both biosafety and emergency management
professionals responsible for implementing the Select Agent Rules and DOE O 151.1D.
To satisfy the needs of both disciplines, the general subject of biosafety is covered in the
Biosafety Facilities, Chapter 5. Biosafety concepts of containment and barriers, biosafety
levels (BSLs), and biosafety controls are introduced in the context of the Select Agent
Rules and are taken directly from the BMBL. Note that descriptions of facility operations
or biosafety programs are provided to support examples and concepts discussed in
Chapter 5. However, these descriptions should not be interpreted as necessarily
representing actual DOE/NNSA biosafety facility operations and programs.
According to 10 CFR Part 851 Appendix A, 7. Biological safety, DOE/NNSA biosafety
facilities are required to establish an IBC to review any work with biological etiologic
agents for compliance with appropriate CDC (i.e., BMBL), NIH, World Health
Organization (WHO), and other international, Federal, Tribal, State, and local guidelines
and the site security, safeguards, and emergency management plans and procedures.
Understanding the basic biosafety concepts contained in these guidelines are essential for
interpreting and implementing the guidance to be presented in this guidance document.
In addition, because of the impact that agent characteristics and diverse
transport/transmission mechanisms have on specific emergency management planning
issues (threshold quantities, measures of severity, protective actions), a brief discussion of
these issues are provided in Chapter 5 to support the approach contained in
DOE O 151.1D. Agents and their relevant general characteristics are discussed with
special emphasis on potential transport/transmission mechanisms. OEs related to the
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release of biological agents to the environment, the characterization of biological release
scenarios, and tools for their recognition are also discussed.
This analysis and the Emergency Management Hazardous Materials Program, which are
required for any DOE/NNSA facility subject to the Select Agent Rule(s), address the
actual or potential release of biological agents outside of the secondary barriers of
biocontainment. Results of the EPHA will form the basis for the emergency management
Section 38
program that will be commensurate with the biological hazards in the facility. Planning,
preparedness, and response activities will reflect the characteristics and release
transport/transmission mechanisms of the potential hazards.
Biological select agents are emphasized in the guidance contained in Chapter 5; biological
toxins are essentially extremely toxic chemicals generally covered by guidance contained
throughout this guide. However, clarifications and discussions in this Guide will
specifically address the release of toxins when necessary. In addition, further discussion
in Chapter 5 will focus on planning for human or overlap select agents. Future guidance
will include toxins and agents that are solely animal and plant pathogens.
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All Hazards Planning/Technical Planning Basis
2.1. All-Hazards Planning Basis
2.1.1. Introduction
The purpose of this chapter is to assist Department of Energy (DOE) and National
Nuclear Security Administration (NNSA) field elements in complying with the
DOE O 151.1D requirement that an All-Hazards Survey be prepared, maintained, and
used for emergency planning purposes. The Order requires that emergency management
efforts begin with the identification and qualitative assessment of the site/facility/activity
(SFA) specific hazards and the associated emergency conditions that may require a
response, and that the scope and extent of emergency planning and preparedness at a
DOE facility reflect these facility-specific hazards. The first step in the implementation of
this commensurate with hazards approach to emergency management is an All-Hazards
Survey.
Based on an examination of the features and characteristics of the facility, the All-
Hazards Survey identifies the generic types of emergency incidents and conditions
(including natural phenomena such as earthquakes and tornadoes, wildland fires, and
other serious incidents involving or affecting health and safety, the environment, and
safeguards and security at the facility) and the potential impacts of such emergencies to
be addressed by the DOE Comprehensive Emergency Management System. The All-
Hazards Survey also identifies key components of the Emergency Management Core
Program that provide a foundation of basic emergency management requirements and an
integrated framework for response to serious emergency incidents or conditions. For
facilities involved in producing, processing, handling, storing, or transporting hazardous
materials that may pose a serious threat to workers, the public, or the environment, the
All-Hazards Survey provides a screening process to determine if further analysis of the
hazardous materials in an Emergency Planning Hazards Assessment (EPHA) is required.
This guidance is directed at operations and emergency management staff responsible for
DOE and NNSA facilities at field offices, service centers, and operating contractor
organizations. It is expected that emergency management staff will obtain support from
site and facility management in addition to a variety of scientific and technical disciplines
within their respective organizations. Appendix A provides recommended screening
approaches for radioactive and chemical hazardous materials.
2.1.2. General Approach — All-Hazards Planning Basis
Every facility and activity on a DOE/NNSA site should be included in a documented All-
Hazards Survey. Much of the information necessary to generate an All-Hazards Survey
Section 39
will already have been developed and documented in the course of meeting other DOE
and Federal agency requirements relating to facility safety, occupational safety,
environmental and effluent controls, and hazardous materials management. However, the
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intent of the Order will not be met by simply defining existing documents or analyses as
the All-Hazards Survey document.
The All-Hazards Survey process involves the review of facility programs already in place
to meet Federal, State, and local requirements related to worker health and safety,
environmental protection, and hazardous materials reporting. It is not suggested that
emergency management departments assume increased responsibility and authority for
ensuring compliance with the Resource Conservation and Recovery Act, the
Comprehensive Environmental Response, Compensation, and Liability Act, the National
Pollutant Discharge Elimination System (NPDES), and the Occupational Health and
Safety Requirements (OSHA) requirements. The SFA management may find it useful to
incorporate the All-Hazards Survey process into its program of internal oversight and
compliance monitoring for hazardous materials, environmental protection, and worker
safety regulations (See DOE-STD-3009-2014).
The All-Hazards Survey should be a distinct document that contains or references the
information specified in this chapter.
Recommended Steps:
Step 1 Briefly describe each facility and identify their hazards.
Step 2 Screen hazardous materials to determine the need for further analyses in a facility-
specific quantitative Emergency Planning Hazards Analysis (EPHA).
Step 3 Identify the generic types of emergency incidents and conditions for each facility.
Step 4 Qualitatively describe the potential effects of applicable emergencies to health,
safety, environmental, or national security.
Step 5 Document the applicable Core Program planning and preparedness requirements.
An All-Hazards Survey may address a single facility, multiple facilities, or may even
cover an entire site. A tabular/matrix presentation can be used to efficiently summarize
and document the survey information.
2.1.3. Step 1: Describe the Facility and Identify its Hazards
Each facility or activity covered by the All-Hazards Survey should be identified and a
brief description of its operations provided. Detailed descriptive information should be
included by reference. A general understanding of the facility and its associated hazards
can be adequately presented in a table or matrix. That information should include:
• A general characterization of the facility and its operations;
• The number of workers normally assigned;
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• Special designations, such as nuclear facility; radiological facility; hazardous waste
site; Treatment, Storage, or Disposal facility; etc.; and
• Whether hazardous materials other than standard office products and cleaning
supplies are used or stored in the facility.
The use or storage of radioactive, chemical hazardous materials, or hazardous biological
agents or toxins in the facility should be noted and described. Sources of information on
hazardous materials include documents such as Basis for Interim Operations (BIO),
Safety Analysis Reports (SARs), Safety Assessment Documents (SADs), Documented
Safety Analyses (DSAs), Design Basis Threats (DBTs), process safety management/risk
management analyses documentation, and databases including chemical and radioactive
Section 40
material inventories. Facility walk-downs enable emergency management staff and
hazards analysts to familiarize themselves first-hand with actual facility systems,
processes, practices, equipment and, especially, material inventories. Periodic walk-
downs can provide checks on the accuracy of documentation and material inventory
databases and may identify additional hazards from by-products of chemical processes or
potential accidental mixing interactions.
If hazardous materials other than office products/cleaning supplies are identified, further
screening should be done in accordance with Section 2.1.4 below to determine if a facility
specific quantitative EPHA is required.
2.1.4. Step 2: Screen Hazardous Materials to Determine Need for an Emergency Planning
Hazards Assessment (EPHA)
Due to the myriad forms and quantities of hazardous materials in use throughout
DOE/NNSA facilities and activities, the Comprehensive Emergency Management System
provides a screening process to reduce the number of hazardous materials quantitatively
analyzed for emergency planning purposes. Use of the screening process described here is
not intended to avoid analyses of hazardous materials, but to allow emergency
management resources to be focused on analyzing materials that, because of their
quantity, toxicity, and dispersibility, have the potential to harm people who are outside the
immediate workplace where the materials are used or stored. The hazardous material
screening process identifies inventories of specific materials in an SFA that, if released,
could cause a hazard significant enough to warrant specific consideration in an
Emergency Management Hazardous Materials Program.
To determine whether a facility requires a quantitative analysis of its hazardous materials
in an EPHA, the screening process must identify at least one hazardous material that
requires further analysis. The results of the EPHA will then determine if the release of
each identified material could cause a hazard significant enough to be included as part of
the Emergency Management Hazardous Materials Program planning basis.
DOE O 151.1D requires a quantitative emergency planning hazards assessment if the all-
hazards survey screening process identifies specific hazardous materials and quantities
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that could produce impacts consistent with the definition of an Operational Emergency
(OE). In general, an OE involving an uncontrolled release of a hazardous material must
immediately threaten or endanger those in close proximity of the incident; have the
potential for dispersal beyond the immediate vicinity of the release in a quantity that
threatens the health of onsite personnel or the public in co-located facilities, activities, on
or offsite; and have a potential rate of dispersal sufficient to require a time-urgent
response to implement protective actions for workers and the public. (For guidance on co-
located workers and facilities see DOE-STD-3009-2014.)
All radioactive materials and chemicals with known or suspected toxic properties should
be subjected to a hazardous material screening process that identifies all hazardous
materials in an SFA that are to be considered for further analysis in an EPHA. Some
materials may be excluded from analysis in an EPHA based on use, form, dispersibility,
or toxicity. Radioactive materials requiring further analysis include those listed in DOE-
Section 41
STD-1027-2018 Chg. Notice 1, in quantities greater than Category 3 values. Chemicals
assigned Health Hazard Ratings 0, 1, or 2 based on the handbook of the National Fire
Protection Association (NFPA) 704, Standard System for the Identification of Hazardous
Materials for Emergency Response, may be excluded from further EPHA analysis. With
some exceptions for extraordinarily high toxicity, chemicals in quantities less than those
that can be easily and safely manipulated by one person, also referred to as laboratory
scale quantities, may be excluded from further analysis. Appendix A provides a
discussion of the hazardous material screening process and describes a recommended
screening approach. If the screening process identifies at least one hazardous material
requiring further quantitative analysis, the All-Hazards Survey should indicate that an
EPHA is needed for that SFA. A description of the screening process and the results of its
application should be provided in the All-Hazards Survey or supporting documents.
2.1.5. Step 3: Identify Applicable Types of Emergency Incidents and Conditions
The generic types of emergency incidents and conditions that may occur at each facility
for which some planning and preparedness may be required should be identified and
documented. The word incident is used by sites and facilities for an unexpected
occurrence, natural or manmade, that requires a response to protect life or property that
affect a site. For planning purposes, SFAs should always plan for events as they would
normally happen (weather events, change in normal operations, severe incidents,
demonstrations, etc.) Hazardous materials not specifically addressed in a quantitative
EPHA should also be considered when identifying the emergency conditions. At a
minimum, the following types of emergency conditions should be considered:
• Structure fires and explosions;
• Natural phenomena impacts;
• Environmental releases (of oil or other pollutants that degrade the environment);
• Hazardous material (HAZMAT) releases;
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• National Security impacts (see definition in DOE O 460.1D);
• Multiple facility/building incidents;
• Malevolent acts (see DOE O 470.3C for applicable scenarios);
• Workplace accidents/mass casualty incidents (explosion, release of toxic fumes, high
energy system failure);
• Hazards external to the SFA; and
• Accidental criticality.
The DOE/NNSA Comprehensive Emergency Management System emphasizes
emergencies involving the release of hazardous materials. The inventories of materials in
facilities will be subject to the screening process discussed above. If a potential release
may cause a classified OE, then an EPHA is required. If, on the other hand, the facility
contains an aggregation of small quantities (i.e., less than screening thresholds) that may
be released during large-scale destructive incidents, such as a fire or explosion in a
laboratory, an aircraft crashing into a building, or an earthquake that collapses a structure,
this should also be indicated in the All-Hazards Survey. A site may consider defining
such incidents as categorized, but not classified OEs if it appears the condition would
meet all the aspects of an OE. The potential HAZMAT aspect of these destructive
incidents may be used as a qualitative factor or criterion (without the support of detailed
quantitative calculations of consequences) in defining specific OEs related to these
Section 42
incidents. However, even without the inclusion of this category, a site may be required to
categorize such an incident as an OE under one of the existing definitions contained in the
Order.
Some types of emergency conditions will apply to nearly every facility, while others will
only apply to facilities that exceed a threshold inventory of some hazardous material or
environmental pollutant or are located near other hazards. Site-specific risks/hazards,
such as flooding from a nearby dam failure, should be included in the list of potential
emergencies to identify the facilities that are potentially threatened.
Facility and site hazards can be identified by using subject matter experts (SMEs), BIO
reports, SARs, SADs, DSAs, DBTs, Vulnerability Assessments (VAs), chemical and
radioactive material inventory databases, and even Federal Emergency Management
Agency (FEMA), National Weather Service, and insurance industry documents.
Hazards originating outside the DOE facility or site that could affect the health and safety
of onsite personnel or other DOE interests should be identified and examined. At a
minimum, the Local Emergency Planning Committee should be consulted to identify
nearby facilities containing hazardous material inventories that could affect the DOE site.
Railroads, highways, and other transportation arteries that pass through or near a DOE
facility or site should be considered possible locations of hazardous material
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transportation accidents. If the transportation artery is a known corridor for particular
hazardous substances, identify the substance, quantities, approximate shipment
frequencies, and Protective Action Zone distance specified in the Department of
Transportation (DOT) Emergency Response Guidebook (ERG). Protective Action Zone
distances may need to be calculated for hazardous substances not specified in the ERG.
Once this information is collected, determine whether specific arrangements should be
made for protection of onsite personnel. If no specific information can be obtained, the
transportation arteries should be identified as potential sources of hazards to onsite
personnel.
2.1.6. Step 4: Qualitatively Describe Potential Impacts
Qualitatively describe the potential impacts of the emergency conditions identified in
Step 3. These descriptions should relate the potential impacts to the different types of OEs
identified in the Order. Consideration should be given to cascade effects, where the
emergency condition can result in plausible disruption of response capabilities, such as
when an earthquake could result in fires from downed power lines while rupturing fire
mains.
Examples of potential impacts of several emergency conditions include:
Facility Type Emergency Qualitative Description of Impact Condition
Office Building Structure Fire Workers killed/injured by smoke inhalation and
burns.
Waste Incinerator Earthquake Workers killed/injured/ trapped by building
collapse; release of hazardous materials;
contamination of facility and surroundings; spill of
fuel oil into streams/wetlands.
Onsite Transportation Activity Collision Actual or potential release of hazardous materials;
exposures exceeding Protective Action Criteria
(PAC).
2.1.7. Step 5: Identify Applicable Planning and Preparedness Requirements
Various Federal, State, and local regulations include requirements that pertain to planning
and preparedness for emergencies. The Order recognizes these as Core Program
Section 43
requirements and directs that they be incorporated into the site emergency management
programs. Emergency planners should correlate All-Hazards Survey results with the
relevant planning and preparedness requirements from other Federal, State, or local
regulations that apply to a specific facility, and provide a summary of the required scope
of emergency planning and preparedness at the site. Examples of possible Core Program
planning and preparedness requirements are listed in the Order. The All-Hazards Survey
should serve as a guide for assessing site compliance with a variety of DOE and non-DOE
emergency planning and preparedness requirements that are integral parts of the
Comprehensive Emergency Management System.
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2.1.8. All-Hazards Survey Documentation
As noted in Section 1.2, a single All-Hazards Survey document may address multiple
facilities with the results presented in several ways. The tabular/matrix presentation
format is an efficient method of summarizing and documenting survey information for
many facilities. Using this approach, the All-Hazards Survey document can consist of
brief descriptions of the facilities, types of hazards that apply, potential impacts of
hazards, applicable regulations, and other common information, followed by a table or
matrix indicating which items apply to each facility. If the number of facilities is small,
separate text section(s) can be devoted for each. For facilities with hazardous materials,
the All-Hazards Survey document should identify the sources of inventory information
and summarize the hazardous material screening methods and results.
Sites are not expected to reproduce extensive texts from original sources to incorporate in
the All-Hazards Surveys. Instead, existing site documents or record systems such as
facility descriptions, building pre-incident plans, and hazardous material inventories may
be included in a table or matrix in the All-Hazards Survey. Hazardous material inventory
information for an SFA or activity should be documented to support the results of the
hazardous material screening process. The inventory information need only be
documented in the All-Hazards Survey to the extent necessary to indicate whether a
quantitative EPHA is required. If an EPHA is required, the results of the screening
process for all materials in an SFA should be included in the EPHA. Otherwise, the
screening results can be included as part of the supporting documentation for the All-
Hazards Survey.
Sites must ensure EPHA documentation is reviewed for classified or CUI prior to release,
when required, with particular emphasis on the quantity and location of hazardous
materials (especially nuclear materials) and malevolent acts scenarios associated with
these materials.
2.1.9. Threat and Hazard Identification and Risk Assessment (THIRA)
2.1.9.1. Introduction
The purpose of the THIRA is to provide a strategic-level view of identified threats and
hazards impacting the area, and anticipated capabilities necessary to address these threats
and hazards. Requirements for performing an All-Hazards Survey, including conducting a
THIRA, are described in Attachment 3, Section 2 of DOE O 151.1D.
Information provided through the THIRA will serve as the baseline for NA-41 (HQ)
development of the Department’s comprehensive, enterprise-wide threat and risk
Section 44
assessment that supports Presidential Policy Directive 8 (PPD-8) and the National
Preparedness System in accordance with its guiding principles of a risk-informed culture
and risk-informed decision making. The DOE Enterprise THIRA will create a common
operating picture for DOE leadership for strategic planning purposes such as formulation
of level direction and priorities.
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The DHS Comprehensive Preparedness Guide (CPG) 201 provides guidance for
developing a THIRA that is flexible and scalable. The intent of the Order requirement is
to allow flexibility in how the guidance in CPG 201 is applied to each SFA, while
maintaining a common framework and a consistent approach for identifying and assessing
risks and impacts.
For information on an over-pressurization hazard and on how it is presented in
DOE O 151.1D, and how to account for it in a THIRA, SFAs should refer to the analysis
in DOE-STD-1212-2012.
2.1.9.2. Step 1: Identify Threats and Hazards of Concern
For the purposes of the THIRA, the CPG 201 organizes threats and hazards into three
categories.
• Natural hazards: acts of nature
• Technological hazards: accidents or the failures of systems and structures
• Human-caused incidents: the intentional actions of an adversary
SFAs can use scenarios previously derived from SAR/SAD/DSA/DBT development to fit
into these categories to help meet the requirements of the THIRA.
Table 2-1 provides examples of the types of threats and hazards that an SFA may
encounter (the list is not all-inclusive).
Table 2-1 Example Threats and Hazards by Category
Natural Technological Human-caused
• Avalanche
• Drought
• Earthquake
• Epidemic
• Flood
• Hurricane
• Landslide
• Pandemic
• Tornado
• Tsunami
• Volcanic eruption
• Wildland fire
• Winter storm
• Airplane
• Dam failure
• Levee failure
• Mine accident
• Hazardous materials
release
• Power failure
• Radiological release
• Train derailment
• Urban conflagration
• UAS-Incursions
• Active shooter / threat
• Biological attack
• Chemical attack
• Cyber incident
• Explosives attack
• Radiological attack
• Sabotage
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Likelihood of a Threat or Hazard Affecting a Site/Facility Activity (SFA)
For the purposes of the THIRA, likelihood is defined as “the chance of a given threat or
hazard affecting an SFA.” Considering likelihood is critical because SFAs must allocate
limited resources strategically.
Likelihood of occurrence should be the determining factor in allocating resources for
threats and hazards. Through the THIRA, SFAs identify threats and hazards that are
challenging enough to expose capability gaps, and likely enough to justify investing in the
capabilities necessary to manage them.
The ability to predict the likelihood of a specific incident varies. Some hazards have
mature prediction models that allow SFAs to calculate the probability of a specific
incident with a moderate degree of accuracy. Other hazards, such as terrorism, are more
difficult to predict and may be most easily expressed either on a logarithmic or ordinal
scale. Regardless of how SFAs express the probability of a specific incident,
understanding the likelihood of threats and hazards can help understand capability
requirements and prioritizations of investments.
Including estimates of probability in the THIRA is not necessary but may be included if
deemed appropriate. SFA staff may consider additional sources for useful likelihood and
Section 45
consequence information to inform threat and hazard selections, such as hazard mitigation
plans. Regardless of whether probability is included in the THIRA process, SFA staff
should only consider the threats and hazards that could realistically occur.
The Impacts of a Threat or Hazard
The projected impacts of threats and hazards determine the level of capability an SFA will
need to address impacts. To understand risks effectively, the staff at the SFA should
identify and select threats and hazards that most challenge their capabilities. Different
incidents present different challenges. In some cases, the sheer magnitude of the incident
may be substantial; in other cases, there may be operational or coordination complexities
or economic and social challenges. When assessing potential impacts, SFA staff may
include as many threats or hazards in the THIRA as they desire but include as many as
necessary to challenge each of the 32 core capabilities.
2.1.9.3. Step 2: Give Threats and Hazards Context
Context Descriptions
Threats and hazards were identified in Step 1. In Step 2 of the THIRA, create context
descriptions and estimate the impacts of the threats and hazards.
If an element of the scenario is essential to understanding the effect of an incident and the
capabilities required to manage it, the element should be included in the context
description.
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For example: How would the location of an incident affect the SFA’s ability to manage
it? Which locations would be most likely to have the greatest impacts (populated areas,
isolated areas, or areas with large amounts of hazardous materials)?
Estimate Impacts
SFA staff write impacts in the language of common emergency management metrics, for
example, the affected population, the number of people requiring shelter, or the number of
people requiring screening. The standardized impact language communicates metrics
estimated and, in most cases, across multiple threats and hazards.
SFA staff will develop capability targets in Step 3 based on estimated impacts. As such,
they will identify a specific number for the standardized impact when estimating impacts
before proceeding to Step 3. Ideally, SFA staff estimate all standardized impacts for each
threat or hazard scenario. However, at a minimum, to develop capability targets in
THIRA Step 3, they will develop an estimate for each standardized impact at least once
across all included threats and hazards.
In addition to impacts for which standardized language exists, other impacts may be
included in the THIRA as deemed appropriate. Non-standardized language may be used
to describe impacts when not included in the standardized impact language. If SFA staff
choose to estimate an impact using data from a single scenario, they should choose the
scenario that could create the most challenging impact.
2.1.9.4. Step 3: Establish Capability Targets
Capability targets are not a reflection of current capabilities, but represent a long-term
desired proficiency level. Capability targets are established to describe the level of
competence to work toward to achieve core capabilities. When developing capability
targets SFA staff should consider what is required to address the impacts of threats and
hazards.
Impacts, Objectives, and Timeframe Metrics
Each capability target describes a critical task that, when completed, helps successfully
manage a threat or hazard. These critical tasks:
Section 46
(1) Are based on the activities that emergency managers plan for; and
(2) Define activities that must be performed for a wide variety of threats and hazards, not
only the ones identified in the THIRA.
Additionally, SFAs estimate which threat or hazard most challenges their ability to
achieve the critical task described in each capability target. This adds more utility to the
THIRA during real-world incidents. Capability targets are specific and measurable, and
can be built by combining impacts, which represent the size of the capability requirement,
and timeframe metrics, which represent the timeframe in which the action must be
performed.
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Impacts and Objectives
For each capability target, SFAs should identify the level of capability they want to work
toward. To determine this desired level of capability, consider the impacts of threats and
hazards, estimated resource requirements, expected available resources, and other relevant
factors. The impact that is selected as a target does not need to match the impacts
previously identified. However, SFAs should ensure they understand the risk posed by
their threats and hazards and use that knowledge to inform the impacts they include in
their capability targets. If an impact is selected that is different from the one previously
identified, describe how it was chosen and the sources used. THIRA capability targets
should reflect the SFAs’ unique planning and investment strategies.
In addition to capability targets, SFAs may also set an additional target called a maximum
requirement target. The maximum requirement reflects the highest level of a potential
capability requirement. This maximum requirement reflects the impacts of the threat or
hazard that most challenge the critical task described in the capability target.
It is important to note that not all capability targets are impact-based. While most targets
use post-incident quantitative impacts as explained above, some capabilities focus on
preventing an occurrence, or lessening the vulnerabilities that affect the scale of a threat
or hazard. Instead of a traditional standardized impact, these targets include a measurable
objective that represents a goal that has been set for that core capability.
Timeframe Metrics
Timeframe metrics describe the timeframe or level of effort needed to successfully deliver
core capabilities. When constructing targets, it is not enough to know how much of an
objective you plan to accomplish, you may also need to know how quickly you must be
able to activate that capability, and how long you need to be able to sustain it. The
answers to these questions will be unique to the capability target in question. When
considering timeframes, SFAs should not be constrained by their current ability to meet
timeframes or other conditions of success; rather, they should identify the timeframe that
they desire to achieve. The SFA should use the type of metric that is most appropriate for
the given capability. For the core capability Mass Search and Rescue Operations, that
might be “search (#) structures within # hours,” while for Threats and Hazards
Identification, a more appropriate timeframe might be “model (#) scenarios every #
years.” The SFA should work with SMEs and stakeholders to determine time-based
metrics that are most appropriate for each capability.
Developing Capability Targets
In the THIRA, SFAs create capability targets for the core capabilities listed in the
Section 47
National Preparedness Goal. The SFA should use standardized language and their own
specific metrics to construct these targets.
In addition to setting capability targets using the standardized target language for each of
the 32 core capabilities, certain SFAs may also want to develop additional targets. These
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additional targets can capture goals to achieve additional capabilities or critical tasks that
are specific to the SFA’s needs.
2.1.9.5. Conclusion
An SFA THIRA is intended to be a separate, stand-alone document, conducted on a site-
wide basis, which characterizes a limited set of events that would stress the internal
capabilities of the site, (i.e., most likely, worst-case incidents). The All-Hazards Survey is
intended to provide a comprehensive evaluation of hazards applicable to individual
facilities/activities and includes hazardous material screening. The goal of the THIRA is
to provide a common operating picture to local authorities for emergency management
and emergency scenarios.
The THIRA may reveal scenario hazard gaps in the existing EPHA. If, based on the
professional judgement of Field Element Manager (FEM), scenario hazard gaps are
revealed, then they are to be added to an existing EPHA or detailed in a new EPHA. If no
scenario hazard gaps are revealed, then there is no further action required by the FEM
than the conduct of the THIRA.
Specific guidance on how to conduct a THIRA for DOE SFAs is provided through
templates located on the Enterprise Data Management System SharePoint site.
2.2. Technical Planning Basis
2.2.1. Introduction
The purpose of this chapter is to assist DOE and NNSA field elements in complying with
DOE O 151.1D whenever a facility-specific quantitative assessment of the potential
release of hazardous materials is required. An EPHA must be performed for an SFA when
at least one hazardous material requiring quantitative analysis is identified through the
hazardous material screening process conducted as part of the All-Hazards Survey. The
Order requires special planning and preparedness for DOE emergency management
programs that need to respond to emergency incidents or conditions involving the
unplanned release of hazardous materials. The scope and extent of these programs will be
based on facility-specific hazards through a commensurate with hazards approach. The
first step in the implementation of this approach for hazardous materials is the
quantitative analysis of potential emergencies in an EPHA.
EPHAs involve the application of rigorous hazards analysis techniques that provide
sufficient detail to assess a broad spectrum of postulated incidents or conditions involving
the potential release of hazardous materials and to analyze the resulting consequences.
The screening process and the analysis of identified hazardous materials in an SFA
determine the potential for producing an OE classified as an Alert, Site Area Emergency
(SAE), or General Emergency (GE). If the hazardous material does not screen out, is not
covered by the exclusions in Attachment 3 of DOE Order 151.1D, and a potential
classifiable OE associated with an SFA or onsite activity is identified, an Emergency
Management Hazardous Materials Program needs to be developed and maintained that
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establishes additional, more detailed emergency management program requirements than
those imposed by the Emergency Management Core Program.
Section 48
The EPHA performs three roles in a DOE emergency management program.
1. By summarizing the processes and systems associated with the hazardous materials,
together with the nature and magnitude of the hazards, the EPHA provides the
technical planning basis for establishing a graded approach that will determine the
necessary plans/procedures, personnel, resources, equipment, and analyses that
comprise the Emergency Management Hazardous Materials Program.
2. The documented EPHA provides an archival record of the data, assumptions, and
methods used in developing the technical planning basis for the program; it also
reflects the reasoning used to modify the program in response to changes in operations
and hazards. The documented EPHA should enable an emergency management
program to survive the inevitable turnover of hazards assessment personnel without
the loss of continuity that can result from uncertainty about past analyses and
decisions.
3. The EPHA performs a key readiness assurance role by providing clear evidence that
facility-specific hazards are well understood by the responsible emergency
management planners, and that, if used correctly, the EPHA represents a valid
technical foundation for developing an emergency management program that is
commensurate with hazards.
Of particular importance in performing hazards assessments, especially for sites with
multiple facilities, is consistency in the selection and application of analysis techniques,
hazardous material release scenarios, and the assumptions and input data used in
consequence calculations. A recommended approach for ensuring consistency is to
standardize and document ground rules and criteria prior to performing the hazards
assessment analyses. The selection and subsequent documentation of EPHA release
criteria and analysis techniques, beforehand, ensures both consistency between EPHAs
for common scenarios and analyses and consensus among diverse site functions.
An effective method for accomplishing consistency and for ensuring consensus among
diverse disciplines involved with the EPHAs is through interaction and coordination with
a broad scope of interested facility or site functions, including operations, programs,
Safeguards and Security (S&S), safety, fire protection, and authorization basis and
emergency management analysts. Most sites, especially those with multiple facilities, can
benefit from the issuance of a formal site-wide procedure for performing hazards
assessments. Such a procedure should specify standard analysis methods, inputs, and
criteria for performing the hazards assessment analyses, as well as a step-by-step hazards
assessment approach and documentation standard that will ensure consistency among the
site’s EPHAs. This documented procedure can also streamline the required DOE review
and approval process for revised and updated EPHAs, which should significantly
decrease the time required to implement approved changes in emergency management
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plans and procedures and emergency response tools such as Emergency Action Levels
(EALs).
To the maximum extent possible, the hazards assessment process should make use of
facility description and accident scenarios from SARs/SADs/DSAs/DBTs, consequence
assessment methods used during emergency response, and existing hazardous materials
inventories maintained for other purposes. Information available from sources such as
Section 49
SARs/SADs/DSAs/DBTs, BIO documents, Probabilistic Risk Assessments (PRAs), VAs,
Fire Hazard Analyses (FHAs), Environmental Impact Statements (EISs), and other
documents that address SFA hazards or potential consequences may be used to ensure
consistency of basic input data. The analyses contained in these sources should be used
with caution, however, because the assumptions and methodology applicable to their
intended purposes may not be fully compatible with emergency management planning
needs.
When scheduling EPHA preparation, the schedules for the preparation, review, and
update of other safety and regulatory compliance documents should be considered.
Integrating the EPHA effort with these schedules can increase preparation efficiency and
reduce cost. Where possible, the same release parameters and analysis techniques may be
used to minimize the differences between the EPHAs and safety/authorization-basis
analyses.
In order to advance the level of understanding and the capability of performing integrated
hazards analysis, a handbook was developed by DOE to emphasize the efficiencies and
advantages associated with integrating the numerous hazard analysis methodologies
performed under various requirements. This handbook, DOE-HDBK-1163-2003,
Integration of Multiple Hazard Analysis Requirements and Activities, focuses on data
exchange among the various analysis methodologies under multiple standards and
requirements, where applicable. It is the intention of the handbook to promote further
discussion and hands-on experience in encouraging the concept of the integration of
hazards analysis. The hazards assessment process for emergency management discussed
in this guide promotes this concept of analysis integration.
The guidance in this section is directed at operations and emergency management staff
responsible for DOE and NNSA facilities at field offices, service centers, and operating
contractor organizations. It is expected that emergency management staff will obtain
support from site and facility management and from a variety of scientific and technical
disciplines within their respective organizations as they conduct and document the
analyses described herein.
2.2.2. General Approach – Technical Planning Basis
DOE Emergency Management System policy and Order 151.1 (current version) require
that hazardous material emergency management programs are responsive to the full range
(spectrum) of potential hazardous material release scenarios, including applicable
hazardous material types, release magnitudes, and initiating incidents. The term release is
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used here to mean, primarily, an airborne release. The airborne release pathway typically
represents the most time-urgent situation and requires a rapid, coordinated emergency
response on the part of the facility, co-located facilities, and surrounding jurisdictions to
protect workers, the public, and the environment. Releases to aquatic and ground
pathways, although a matter of serious concern in terms of potential environmental and
long-term public health consequences, in most instances do not have the same time
urgency as the airborne release. When a release to an aquatic or ground pathway could
have a near-term effect on the workers or the public, then it should be considered in the
hazards assessment.
For a single facility, there may be hundreds of different possible hazardous material
Section 50
release scenarios. To address this range of possibilities, facilities should develop and
document a technical planning basis for the facility-specific emergency management
program consisting of a manageable number of systematically selected and realistically
analyzed release scenarios to represent a spectrum of severity and initiators. The purpose
of this chapter of the EMG is to provide guidance that will address the process for
conducting and documenting the selection and quantitative analysis of potential release
scenarios associated with the hazardous materials identified by the All-Hazards Survey
screening process.
The recommended steps in the EPHA process are the following:
Step 1 Define and describe the facility and operations
Step 2 Characterize the hazardous materials
Step 3 Select scenarios for analysis
Step 4 Analyze Scenarios
– Estimate Source term
– Calculate consequences
– Identify recognition factors
– Finalize technical planning basis scenarios
Step 5 Document the results of the analysis
Although the basic steps of the process should be accomplished and documented in the
order presented, within any given step of the process, there is substantial leeway within
which the unique features of the facility, operations, and site can be accommodated.
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The EPHA should address factors such as:
• Initiating incidents (e.g., security incidents, natural phenomena, technological
hazards, etc.)
• Contributing events
• Accident mechanisms
• Equipment, system failures, or engineered safety system failure
• Source terms
• Material release chemistry and characteristics
• Environmental transport and diffusion
• Emergency incident or condition observable indicators
• Exposure considerations
• Health effects
Conservative consequence calculations should be performed for the purposes of incident
classification, initial protective action determinations, response decision-making, and
special planning (co-located facilities, special offsite populations, EPZ determination).
The results of the hazards assessment are to be used to determine the EPZs for each
facility and site, as well as the emergency classification and initial protective actions for
each analyzed incident. The observable indicators, or recognition factors, of each
analyzed incident or condition are identified for use as incident classification criteria
(EALs).
The EPHA should be prepared and documented in a manner that permits critical review of
the analyses and results and, if necessary, reconstruction by independent analysts.
However, detailed descriptions of the methods, assumptions, and models need not be
included if they are documented elsewhere and referenced.
2.2.3. Step 1: Define and Describe Facility and Operations
A clear, accurate, and unambiguous written and schematic description of the facility,
activity, or operation that represents the scope of the EPHA should be provided. This
description should provide sufficient detail to support the identification, location, and
characterization of all hazards (radiological, biological agent/toxin, chemical and
explosive) and their potential consequences. For many facilities, the descriptions of the
facility and its operations from current SAR/SAD/DSA/DBT or environmental reports
should serve this purpose and may be briefly summarized and incorporated by reference.
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In some cases, the boundaries of the facility and operations in question will have been
Section 51
previously defined. Facility definitions used for SAR/SAD/DSA/DBT purposes may be
applicable. However, the boundaries should be reexamined with the objectives of the
EPHA in mind.
Sites may group their facilities, activities, and hazards in any of several ways for hazards
assessment purposes. Several structures or component units with a common or related
purpose may be defined as single facility, such as a waste tank farm consisting of a
number of units of approximately the same nature and purpose under common
management and operational control. On the other hand, a group of dissimilar buildings,
operations, and equipment, such as a research reactor with its associated cooling tower,
fuel handling and waste storage buildings, laboratory, and hot machine shop may also be
considered as one facility for purposes of the hazards assessment. Finally, all the hazards
within a single building or structure containing several tenant activities or units, such as
process lines, hot cells, or hazardous material storage may be analyzed and documented
as one facility, even though the tenant activities have little in common, technically or
organizationally.
The written facility description should include general information related to the site
mission, operations, and physical characteristics, including an assessment of the site
exposure to external and natural phenomena hazards. It should include the location of the
facility relative to other facilities on the same site, the site boundaries, the nearest public
access locations, and transportation networks, such as highways, railroads, and rivers.
Particular attention should be paid to including facility-specific information critical to
understanding and reconstructing the consequence calculations and to information
necessary to aid emergency planners in using the analysis results to develop other
emergency management program elements. This information should include:
• Descriptions and physical parameters for facility containment/confinement systems
• Potential leak paths and release points
• Protective/mitigative systems or features
• Technical, physical, or administrative limits on use/storage of hazardous materials
• Installed process monitors, alarms, or detection systems.
2.2.4. Step 2: Characterize the Hazardous Materials
After the facility hazards have been screened, using the hazardous material screening
process outlined in Attachment 3 of DOE O 151.1D, the characterization of both
radioactive and chemical hazardous materials should include the following information:
• The maximum quantity of the material in appropriate units (pounds or kilograms,
curies or becquerels) and its storage or process locations.
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• A description of the conditions under which the material is stored or used, including
process systems or containers that hold the material, and barriers that may impact its
release or dispersion, such as shipping containers, buildings, berms, sumps, or catch
basins. Where applicable, security and access controls for the storage and use
locations should be identified.
• The properties of the material that are needed for determination of source term and
consequence analysis, such as the physical form and chemical characteristics of the
material (e.g., solid, liquid, gaseous, particle size, flammability, chemical reactivity,
density, combustion and explosion byproducts, vapor pressure, boiling point, freezing
Section 52
point), radiological characteristics, and the temperature and pressure conditions under
which it is stored, processed, used, or transported.
• A description of engineered controls, safeguards, or safety systems designed to
prevent or mitigate a hazardous material release. These may include both automatic
and manually activated mitigative systems, as well as passive mitigative features and
engineered geometry or configuration controls for fissionable materials. Instruments
and systems that would detect actual or potential emergency conditions should be
identified.
• A description of administrative controls that would prevent or mitigate the initiation
of a hazardous material release, such as limits on the total quantity of a material in a
single place or container, or restrictions on where certain materials can be used or
stored.
For criticality accidents, the inventory of interest is the total yield of gaseous and volatile
fission products from the postulated criticality incident(s). Analyses of these postulated
criticality incidents would generally be available in the facility SAR, SAD, or DSA.
Where the material consists of a reactor core or irradiated fuel containing mixed fission
products, the relevant factors that define the radiotoxicity of the mixture should be
analyzed and the case that produces the largest impact selected. The actual isotopic
composition of the mixture used for consequence calculations can then be included as an
appendix and referenced.
For those facilities having a documented vulnerability analysis, the identified targets may
include both hazardous materials and essential parts of the system of barriers, controls,
and protection features that keep them in a safe condition. The target list is a potential
source of information regarding both the quantity of certain hazards and the conditions
under which they are stored, handled, and used.
Other materials and hazard sources, such as flammable or explosive materials, energy
sources, processes containing oil, and non-toxic hazardous materials (i.e., NFPA health
hazard rating ≤2 in quantities greater than a quantity that can be easily and safely
manipulated by one person), should also be included in the characterization. The potential
for these materials/hazards initiating releases of radioactive or chemically toxic materials
contributing to the dispersal of those materials, degrading the effectiveness of safety
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systems, incapacitating workers causing a process upset, or posing an asphyxiation hazard
to collocated workers, should be considered. Available information concerning the
reactive properties of the hazardous materials should be assessed and the possibility of
interactions between substances considered.
2.2.5. Step 3: Select Scenarios for Analysis
The objective of this step in the hazards assessment process is to select potential release
scenarios associated with the hazardous materials characterized in Step 2. These analysis
cases will ultimately represent a spectrum of possible scenarios that will serve as the
technical planning basis for the SFA emergency management program.
The specific scenarios/cases to be analyzed in the EPHA should be chosen through a
systematic examination of:
• All the hazardous materials in the facility;
• Primary barrier(s) that maintain each material in a safe condition;
• Modes by which each primary barrier could fail;
Section 53
• Initiating incidents or conditions that could cause barrier failure modes; and
• Release conditions associated with the failure mode or the initiating incident,
including pathways and mitigation devices through which the substance could be
released to the environment.
Applicable combinations of the hazardous materials in the facility and potential scenario
characteristics will define a set of analysis cases, where each release scenario will be
represented by combinations of the following four terms:
• Hazardous material [Material-At-Risk (MAR)]
• Failure mode
• Initiating incident or condition
• Release condition(s)
This process of developing potential scenarios by constructing combinations of these four
parameters will ultimately lead to a complete listing of the applicable cases.
2.2.5.1. Types of Incidents and Conditions to Be Considered
A set of incidents and conditions should be postulated and analyzed that represents the
full spectrum of possible initiators and severity levels involving releases of hazardous
materials that could affect workers, the public, or the environment. A spectrum of
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potential incidents ranging from low-consequence, high-probability incidents to high
consequence, low-probability incidents, including those considered to be beyond-design
basis, should be postulated and realistically analyzed. The spectrum of incidents and
conditions analyzed should include those exclusively affecting onsite personnel, as well
as those also affecting the offsite public. Analysis of a spectrum of incidents does not
mean analysis of every imaginable incident. The goal is to create a comprehensive picture
of the types of incidents and a range of associated consequences that could occur at a
facility. This comprehensive picture of incidents and consequences will then serve as the
basis for emergency response planning.
The All-Hazards Survey described in Section 1 of this Chapter, identifies the types of
emergency incidents and conditions and the potential impacts of such emergencies to be
addressed by the DOE emergency management program for the facility. If facilities have
sufficient quantities of hazardous materials, some of those types of emergencies will have
the potential to cause the airborne release of hazardous materials with significant health
and safety consequences outside the facility. Thus, the All-Hazards Survey for a facility
provides an initial set of potential release incidents and initiators to be considered for
analysis.
Initiating incidents and failure mechanisms considered in the hazard assessment should
include traditionally defined accidents, as well as incidents arising from external causes
and malevolent acts. Scenarios should be included that represent both the success and the
failure of control measures and engineered safety systems. A minimum set of incidents is
recommended for analyzing hazardous material releases identified as candidates for a
hazard assessment. The incidents that are appropriate to the specific facility should be
selected from the following groups:
1. Incidents:
• Fire
• Explosion
• Loss of confinement or containment
• Process upsets
• Criticality
• Onsite transportation accidents
Accident event initiators include failure causes such as corrosion, manufacturing
defects, malfunctioning equipment or control systems, interaction of reactive
materials, external impact, incapacitation of workers, and procedural or human error.
Section 54
(The analysis of onsite transportation accidents is addressed in Appendix B.)
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2. Events:
• Earthquakes
• Tornadoes
• Lightning and Hail
• Floods
• Wildland Fires
• Winter Storms
Most natural phenomena events to be analyzed can be selected from the SAR/SAD/
DSA/DBT (if available) for the facility. Typically, two events are defined for each
type of natural phenomenon — DBE used to determine safety control systems, as well
as an extreme, beyond-DBE, considered incredible in SAR/SAD/DSA/DBT analysis.
Both events are derived from historical data. If no SAR/SAD/DSA/DBT is available,
the event(s) can be obtained directly from historical data for the region.
3. External Events:
• Aircraft crash
• Offsite transportation accidents
• Offsite commercial facility or utility accidents
External events have the potential to be the initiating incident for the onsite release or
loss of control of hazardous material, either directly or by disruption of operations or
processes onsite. Historical data can provide information on the susceptibility of the
area to wildland fires and potential aircraft sizes can be determined from experience
with aircraft operating in the vicinity. A review of road, river, and railway
transportation networks near the site boundary (or through the site) provides
indications of potential hazardous material transport accidents. In addition, nearby
commercial facilities or utilities (chemical plants, pipelines, water treatment plants)
may contain hazardous materials that pose a threat to facilities onsite.
Incidents originating offsite that affect the site may not meet the requirement to have
an EPHA. The ERG may be used by emergency responders to analyze offsite releases
of hazardous materials that impact the site. Offsite transportation accidents may
involve nuclear weapons, their components, or special nuclear weapons, and require
assistance from the Office of Secure Transportation (OST). Refer to DOE O 151.1D
Attachment 5 for requirements regarding the OST EPHA.
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4. Malevolent Acts:
Malevolent acts, including the use of explosives or flammable material, are possible
hazardous material release initiators within the scope of the emergency planning and
the EPHA. More examples of potentially malevolent scenarios can be found in the
current version of DOE O 470.3C, Design Basis Threat (DBT) Order. The Office of
Emergency Management Policy defines the term extreme malevolent acts within the
context of catastrophic incidents that can be further categorized as man-made
deliberate criminal acts.
Severe Incident Scenarios
Low-probability, high-consequence incidents should be addressed in facility emergency
management plans (and in EPHAs) because of their potential effects on workers in the
affected facility and those nearby. Both malevolent acts, which are seldom analyzed in
SARs/SADs/DSAs, and beyond-DBEs should also be included in the EPHA. Extreme
malevolent acts and beyond-DBEs typically represent the upper end of the consequence
spectrum for which prompt recognition and response may be essential to the mitigation of
both the incident and its health and safety consequences. By adding these scenarios to an
EPHA, planners can:
• Gain perspective of the residual risk associated with the operation of the facility.
• Gain additional perspectives for accident mitigation.
These analyses provide valuable insights and can serve as bases for cost-benefit
Section 55
evaluation of improvements, modifications, or enhanced emergency management
response capabilities.
2.2.5.2. Selection of a Spectrum of Scenarios
A process consisting of the following sequence of steps is an acceptable method for
selecting a spectrum of scenarios related to the hazardous materials in the facility:
1. Identify MAR(s) in the facility;
2. Identify primary barrier(s);
3. Select failure mode(s);
4. Identify initiating incident(s); and
5. Identify release condition(s).
This selection process is described in detail below.
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A. Identify Material-at-Risk (MARs) in Facility
The selection process begins by identifying the hazardous substances at each location
within the facility. Each quantity or unit of a hazardous substance is the MAR, as that
term is used in DOE-HDBK-3010-94 (and discussed in Section 2.6, below), for one or
more possible release scenarios. Examples of MARs include:
• Nitric acid in an outdoor storage tank
• Radioactive liquid in a processing system
• Chlorine in a cylinder attached to a gas manifold
A facility can contain one or multiple MARs. In some instances, the MAR for an incident
affecting the entire facility might include all the material located in the facility. This will
be addressed in the discussion of the source terms in Section 2.6.
B. Identify Primary Barriers
The physical or administrative features that maintain the hazardous substance in a safe
condition should be identified for each MAR. The primary barrier is generally the one
physically nearest to the material. In the case of gaseous or liquid materials, the tank,
cylinder, process piping, or other container is usually the primary barrier. For materials
that are prevented from being released by their own structure or physical form, that form
or structure can be regarded as the primary barrier.
C. Select Failure Modes
Failure modes are the ways in which the primary barrier might lose its integrity or its
ability to perform the function of controlling or confining the hazardous material. Failure
modes should be selected that are applicable to the primary barrier for the MAR being
addressed. The following are examples of failure modes of the primary barrier that might
apply to the MAR examples given above and the types of release that might be produced:
• Puncture (of the nitric acid tank, causing spill of liquid)
• Fatigue crack (in the pipe carrying pressurized radioactive liquid, causing spray leak)
• Impact fracture (of the chlorine cylinder stop valve, venting a pressurized gas)
• Combustion (of solid radioactive waste material, releasing contaminants)
For radioactive materials, identification of the failure modes is necessary to make use of
the source term information from DOE-HDBK-3010-94. It also helps align the EPHA
consequence calculations with authorization basis safety analyses, a key element in the
integration of facility hazards analyses. See DOE-HDBK-1163-2003, Integration of
Multiple Hazard Analysis Requirements and Activities, for guidance on this subject.
Selecting failure modes and their size/degree is also an initial step in modeling chemical
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releases using calculation methods such as those described in Environmental Protection
Agency (EPA) 550-B-99-009, Risk Management Program Guidance for Offsite
Consequence Analysis.
The first and most important failure mode to be identified for each MAR is the one that
Section 56
produces the bounding (largest possible) source term, either in terms of total amount of
material released or the rate of release to the environment. For facilities covered by
authorization basis safety analyses, this case is likely to correspond to an analyzed
bounding event (DBE or Beyond-DBE). Using the earlier MAR and failure mode
examples, reasonable bounding source terms might correspond to the following cases:
• Spill of the entire contents of the nitric acid on a flat surface at the highest average
daily temperature, producing the largest expected evaporative (airborne vapor) source;
• Spray from a pipe crack of the size that will produce the maximum mass release rate
of respirable-size aerosol droplets, continuing for a time corresponding to the
expected duration of the liquid transfer operation;
• Release of the entire contents of a chlorine cylinder over a period of 15 minutes (the
averaging time used for comparison with the applicable exposure criterion); and
• Burning of the entire contents of a waste accumulation area, with release of the
bounding fraction (from DOE-HDBK-3010-94) of the largest amount of radioactive
material expected to be in the waste material.
Once the bounding release is identified, one or more additional cases may be needed to
adequately represent the range of possibilities. If the consequences of the bounding case
are below the threshold for classification at the Alert level, there is little reason to analyze
additional cases, because any smaller releases will also fall below the threshold for
classification. However, this may only become evident when final consequence
calculations are performed.
The following represents a set of failure modes that might apply to a nitric acid tank:
• Puncture (or crack) low on the tank, which would produce an evaporative source
limited by the area of the confinement curb/berm
• Puncture/crack at a higher level, which would produce splash/spray source of
aerosols, in addition to the evaporative source
• Overturning/toppling, such that all or most of the tank contents end up outside the
curb, producing a larger evaporation surface and source
The choice of the spectrum of sizes or degrees of failure (modes) that will apply to the
MAR under consideration is the key to the selection approach. If this initial selection of
the spectrum of failure modes is done carefully and methodically, based on a clear
understanding of the features/characteristics of the primary barrier and the MAR, then the
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spectrum of selected scenarios that is the final product of the process will provide a solid
foundation/basis for emergency planning.
The results of this step include combinations of MAR and failure modes for each MAR
and its associated failure modes identified in the facility.
D. Identify Initiating Incident(s)
The next step in the process is to identify initiating incidents/conditions that could apply
to each failure mode (i.e., cause the failure). The analyst should postulate a range of
initiators applicable to the specific SFA, starting with the guidance presented in Section
2.5.1 and identifying those that could produce the failure mode under consideration. In
addition, the analysis should indicate whether a specific failure mode would be
exclusively or most likely associated with a particular initiating incident or condition, OR,
conversely, if th