part I and part II IEMA B-42637.pdf

Sole Source Justification Form

Version 7.01 Page 1 of 7

Bulletin Reference Number 24-588IEMA-RADSA-B-42637

Requesting Agency/University Emergency Management and Homeland Security

Sole Source Justification Form - Part I Section I - General Information

Department/Bureau/Section: Office of Nuclear Safety/Radiological Emergency Preparedness Program

Need Identified Date: 04/01/2024 Supply/Service Need By Date: 05/01/2024

Project Title: Dosimetry Badge Service

Vendor: Landauer, Inc.

Provide a description of the supplies or services required: Use of 8,400 Landauer InLight Dosimetry Badges, InLight 200 Automatic Reader, CAl and QC Set, dosimetry badges

Value: Estimated Value of Initial Term, this Change Order or Amendment: 105,840

Will this Sole Source amend a Professional or Artistic Services contract? Yes No

*Sole Source may not be used for amendments for Professional or Artistic Services if the amendment would increase the value by more than 5% of the initial award or extend the term by more than 60 days.

Type: One-Time Amendment or Change Order

Section II - Proposed Term

One-Time Purchase Term Contract

Estimated Contract Begin Date: May 1, 2024

Estimated Contract End Date: Jun 30, 2024

Number of Potential Renewals: 0

Length of Each Renewal in Months: 0

Total Value of All Renewals: 0

If a Term Contract, does the term, including renewals, exceed 12 months? Yes No

Section III - Funding Source Select the type of funding to be used (Check all that apply): State Appropriate Funds Federal Funds Other (Explain):

Section IV - Sole Source Justification

This purchase is economically only available from a single source primarily because it is: (If "Other" explain in one sentence)

Items are Copyrighted or Patented and the Items are Only Available from the Holder

Are there secondary justification(s) for this sole source? Yes No

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Bulletin Reference Number 24-588IEMA-RADSA-B-42637

Requesting Agency/University Emergency Management and Homeland Security

Section V - Purchase History

Has the Agency or University Purchased these supplies or services in the past? Yes No

Term Term From Term To Value Description Contract Number Type

1 07/01/2023 06/30/2024 49,000 Dosimetry Badge Service Small Purchase

2 07/01/2022 06/30/2023 45,000 Dosimetry Badge Service Small Purchase

3 07/09/2021 06/30/2022 130,000 Dosimetry Badge Service Sole Source

4 09/18/2020 06/30/2021 40,000 Dosimetry Badge Service Small Purchase

5 07/01/2019 06/30/2020 115,000 Dosimetry Badge Service Sole Source

6 07/01/2018 06/30/2019 80,000 Dosimetry Badge Service Small Purchase

7 07/01/2017 06/30/2018 115,000 Dosimetry Badge Service Sole Source

8 07/01/2016 06/30/2017 35,000 Dosimetry Badge Service Small Purchase

9 05/01/2014 06/30/2016 220,000 Dosimetry Badge Service Sole Source

10 07/01/2013 06/30/2015 49,800 Dosimetry Badge Service Small Purchase

If more than 10, or if other comments, explain:

The Illinois Emergency Management Agency and Office of Homeland Security (IEMA-OHS) has contracted with Landauer since fiscal year 2005.

Section VI - Business Rationale

1. Provide a detailed explanation of the need for the supplies or services:

IEMA-OHS entered into an agreement with Landauer, Inc on July 1, 2023 to provide dosimetry badge service for agency employees through fiscal year 2024. An amendment to that agreement is necessary to provide Landauer's InLight proprietary Optically Stimulated Luminescent Dosimetry badge service to all external users. The Agency is required by the Code of Federal Regulations (44 CFR 350.5 and 10 CFR 50.47) to provide two different types of dosimeters for emergency workers responding to an off-site accident at a nuclear power station in Illinois. The Agency currently provides a direct-read dosimeter and the InLight dosimeter from Landauer, Inc. The Agency currently utilizes the InLight dosimetry to passively monitor emergency responders exposure to ionizing radiation located within the 10-mile emergency planning zones of Exelon's six operating nuclear power stations and IEMA facilities in Springfield and West Chicago.

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Bulletin Reference Number 24-588IEMA-RADSA-B-42637

Requesting Agency/University Emergency Management and Homeland Security

2. Provide a list and describe in detail the specifications required to satisfy the need:

Vendor will provide the following:

• InLight 200 Automatic Reader and system maintenance. This covers annual on-site maintenance on the InLight 200 automatic reader system and any needed repairs. The annual preventative on-site visit will include:

a) Thorough cleaning of the InLight Automatic 200 reader

b) Inspection of all parts to insure they are working properly and repair, if needed

c) Correct any timing issues between slides and insure all slides work properly and repair, if needed.

• CAL and QC Set- The delivery of monthly calibration and quality control (QC) sets of dosimeters used by IEMA-OHS to be received by the 15th of the month.

• Dosimetry badges- Perform Occupational Radiation Monitoring service for IEMA-OHS and Illinois State Police employees per the exchange periods deemed appropriate by each department.

• Use of 8,400 Landauer InLight Dosimetry Badges and Group ID Report to the Agency. Vendor will perform certified laboratory analysis within twenty-four (24) hours to determine the type and amount of radiation exposure received. Exposure readings shall be telephoned to the designated Agency contact person within 24 hours of vendor’s receipt of dosimeters. Vendor shall submit a Radiation Dosimetry report to Agency in a form acceptable to the Agency, reporting the results of the analysis. Vendor shall provide departmentalized accounting and the report shall be sent to the Agency contact person as designated in this contract. Vendor shall immediately report to Agency any radiation exposure which is reportable to the licensing authority under 32 Ill. Adm. Code 340 and

400. These reports shall be made to the Agency contract person as designated in this contract.

3. Provide detail explaining the justification selected in Section IV to explain why the requested supplies or services are the only ones available that can satisfy the agency or university requirements?

Landauer, Inc. is the patent holder for this technology and the only company that manufacturers and sells the InLight Dosimeter. The continued use of this technology ensures for compatibility with the automated and manual reader units currently maintained and used by the Agency. There are no comparable services that have the capability to read the dosimeter in the field and then later on being able to get a dose of record reading from the Vendor.

This equipment was previously purchased from Landauer in State Fiscal Years prior to 2010 plus 2010, 2012, 2014, 2016, 2018, 2020 and 2022 for distribution to emergency personnel throughout Illinois. The units have a 2-year life. The Vendor was selected because they were the only company that met the need to get a reading in the field and then later on being able to get a dose of record reading from the Vendor. Landauer was previously approved as a sole source for purchases completed in SFY06/07, SFY08 and SFY10, SFY12, SFY14, SFY16, SFY18, SFY20 and SFY22 for this same equipment. This is required by the federal regulations as stated above.

No other company was found that manufactures the type of dosimeter that the Illinois Emergency Management Agency and Office of Homeland Security (IEMA-OHS) is currently using to continue its dosimetry program. The dosimetry equipment allows the Agency to determine nondestructively the exposure each emergency worker could possibly receive at a location impacted by an incident at a nuclear power station.

Upon a search, no other company was found that manufactures the type of dosimeter that IEMA-OHS is currently using to continue its dosimetry program since Landaurer, Inc. is the patent holder for this technology.

Version 7.01 Page 4 of 7

Bulletin Reference Number 24-588IEMA-RADSA-B-42637

Requesting Agency/University Emergency Management and Homeland Security

4. What are the unique features of the supplies or services that are not available in any other product or by any other vendor? Provide specific quantifiable factors/qualifications:

IEMA-OHS is currently using InLight ™ dosimetry technology, a state of the art method of measuring radiation exposure utilizing optically stimulated luminescence. The benefits of this patented technology include greater sensitivity, longer use upon distribution (up to 24 months), and the availability to obtain multiple readings using a field-deployed reader. To our knowledge, no other company has developed a system which incorporates the duality features of addressing both environmental and personnel monitoring, cost savings, or similar reusable feature technology. The contract will contain a provision which mandates the need for a certified reading by the Vendor within a 24 hour period for certification of field readings. Entering into a contractual agreement with Landauer, Inc. to provide the InLight™ dosimetry technology will provide uninterrupted dosimetry services to State and local government emergency workers. Currently, there are no comparable services for TLDs or film that have the capability to read the dosimeter in the field and then later being able to get a dose of record reading from the vendor. There are electronic dosimeters costing approximately $600 each, in bulk, that the agency could purchase to perform this function. In addition to their cost they require an annual calibration which costs about $75 each. An additional piece of equipment costing $200,000 would be needed by the Agency in order to use the instruments for dose of record readings.

IEMA-OHS selected to replace the use of thermoluminescent dosimetry with the InLight™ dosimetry technology because it has the lowest overall system costs and because it provides life-or-death information in 5 minutes, compared to the 72 hour for the 2nd lowest cost technology (thermoluminescent dosimeters or TLDs). The major system cost of thermoluminescent dosimetry are not the dosimeters, but the increased frequent expense of replacement dosimeters every 12 months and the cost of obtaining a reading from the vendor. The Agency overall costs for an emergency TLD read are estimated $25 per dosimeter in vendor costs alone. The InLight™ dosimetry reader cost per read is estimated $3.15. The InLight™ dosimetry readers are more mobile, can read dosimeters anywhere there is 110 V AC power, and require no specialized consumable gases and chemicals. TLDs must be read in a climate controlled facility using a reader that cannot be moved, requires a lot of maintenance, and takes at least 20 times longer to get a reading, while destroying the ability to do a second confirmation reading. The InLight™ dosimetry benefits include greater sensitivity, longer use upon distribution (up to 24 months), and the availability to obtain multiple readings using a field-deployed reader. This allows the emergency worker either to return to work, or be sent to a medical facility in about 5 minutes versus with the thermoluminescent dosimety, being unable to use the person for the 72 hours it takes to collect the dosimeter, transport it to the vendor for reading, transmit the reading information back to the Agency, and then track down the affected emergency worker and take appropriate action.

These dosimetry badges are an integral part of a system maintained by IEMA -OHS that provides critical data during and following accidents and releases at a nuclear power station. The continued use of this technology ensures compatibility with the automated and manual reader units currently maintained and used by the Agency. The readers and 1,350 environmental dosimeters were purchased by the Agency in SYF05 in the amount of $129,300. To change technology at this point in time would require the replacement of these readers and environmental dosimeters in addition to the 8,400 dosimeters that are currently distributed to emergency workers.

In addition, if the purchase is not completed for the currently used equipment, IEMA-OHS publications related to the dosimetry program will need to be revised (Emergency Worker Participant Manual and Guidelines for a Dosimetry Control Officer). Also, the Illinois Plan for Radiological Accidents (IPRA) relevant to each nuclear power station and the State (Volume I) and Standard Operating Procedures (SOP’s) utilized by the Radiological Task Force would require revisions. The IPRA Plans are currently issued using “controlled copies”. Approximately 130 copies of the State (Volume I) would need to be revised, printed, and distributed. Approximately 100-130 copies for each nuclear power station would also require revisions, printing, and distribution. Additional, in-depth training would also be required for emergency workers if a new product is to be purchased.

5. Has the Agency or University considered alternative supplies or services to satisfy their need? Yes No

5a. If no, why weren't alternatives evaluated?

Landauer, Inc. is the patent holder for this technology and the only company that manufacturers and sells the InLightDosimeter.

6. Are there resellers or distributors?

Yes No N/A

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Bulletin Reference Number 24-588IEMA-RADSA-B-42637

Requesting Agency/University Emergency Management and Homeland Security

7. What efforts were made to get the best possible price (i.e. did the agency/university negotiate) and how did you determine the price for this purchase is considered fair and reasonable?

In previous fiscal years, costs for lease, analysis and reporting of personnel monitoring badges has increased by 20%. Emergency response dosimetry lease has not increased in those years.

8. Will this purchase obligate the State to this vendor for future purchases such as maintenance, licensing or continuing need?

Yes No

8a. If yes, please provide details regarding future obligations and/or needs:

The agency owns dosimeter readers manufactured by and the only compatible with Landauer products. The agency will continue to use Landauer products until other products advance technologically and economically to make replacement of current equipment feasible.

9. What will be the financial or other impact to the State if this sole source is not approved and a competitive bid is required?

If the purchase is not completed for the currently used equipment, IEMA-OHS publications related to the dosimetry program will need to be revised (Emergency Worker Participant Manual and Guidelines for a Dosimetry Control Officer). Also, the Illinois Plan for Radiological Accidents (IPRA) relevant to each nuclear power station and the State (Volume I) and Standard Operating Procedures (SOP’s) utilized by the Radiological Task Force would require revisions. The IPRA Plans are currently issued using “controlled copies”.

Approximately 130 copies of the State (Volume I) would need to be revised, printed, and distributed. Approximately 100-130 copies for each nuclear power station would also require revisions, printing, and distribution. Additional, in-depth training would also be required for emergency workers if a new product is to be purchased.

10. Is there any additional information you would like to add to justify this sole source?

As previously mentioned IEMA-OHS entered into an agreement with Landauer, Inc on July 1, 2023 to provide dosimetry badge service for agency employees through fiscal year 2024. An amendment to that agreement is necessary to provide Landauer's InLight proprietary Optically Stimulated Luminescent Dosimetry badge service to all external users.

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Bulletin Reference Number 24-588IEMA-RADSA-B-42637

Requesting Agency/University Emergency Management and Homeland Security

Section VII

Requesting Department Representative

Requesting Department Signature Required

I know and understand the contents of this Sole Source Justification and attest that all statements are true and correct and the fairness and reasonableness of the price was adequately confirmed.

Date Apr 11, 2024

Printed Name Lance Wilson E-mail Address Lance.wilson@illinois.gov

Phone Number 217-685-4658

State Agency Bureau/Division Head or University Purchasing Director Approval and Signature Required

I know and understand the contents of this Sole Source Justification and attest that all statements are true and correct and the fairness and reasonableness of the price was adequately confirmed. (All prior form fields will lock once this e-signature is completed)

E-mail Address tricia.leezer@illinois.gov

Phone Number 217-720-0569 Date

Printed Name Tricia Leezer

Agency Bureau/Division Head or University Purchasing Director and Not a Designee

SPO Approval and Signature Required

I have reviewed and understand the contents of this Sole Source Justification and agree with the State Agency or University determination.

I have reviewed and understand the contents of this Sole Source Justification and do not agree with the State Agency or University determination. As a result, the State Agency or University must explore other sourcing methods to satisfy their need.

State Purchasing Officer Signature Phone Number 217-720-6643 Date Apr 15, 2024

Printed Name David Papp E-mail Address David.Papp@Illinois.gov

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Bulletin Reference Number 24-588IEMA-RADSA-B-42637

Requesting Agency/University Emergency Management and Homeland Security

Sole Source Justification Form - Part II Section I - General Information

Project Title Dosimetry Badge Service

Vendor Landauer, Inc.

Initial Date of Procurement Bulletin Posting 04/16/2024

Was a Sole Source hearing held per 30 ILCS 500/20-25?

Yes - Complete Section II and III below (Section II will only be visible when this option is selected)

No - Section II not required, go to Section III below Section III - CPO Approval and Signature Required

Based on my review, I authorize the Agency/University to proceed in accordance with the published Notice referenced above.

Based upon my review, I authorize the Agency/University to proceed with the following Changes.

Based on my review, the Agency/University is not authorized to proceed with this sole source as presented and my recommendation is that it be cancelled.

Other

CPO Signature CPO Phone 217-558-2231

Printed Name Ellen H. Daley Date

CPO E-mail Ellen.H.Daley@illinois.gov

Version 7.01 Page of Sole Source Justification Form - Part I Section I - General Information Will this Sole Source amend a Professional or Artistic Services contract?

If yes, what was the original contract value?

*Sole Source may not be used for amendments for Professional or Artistic Services if the amendment would increase the value by more than 5% of the initial award or extend the term by more than 60 days.

Section II - Proposed Term If a Term Contract, does the term, including renewals, exceed 12 months?

If yes, provide a detailed justification including any economic benefit received for agreeing to a multi-year term:

Section III - Funding Source Select the type of funding to be used (Check all that apply):

Section IV - Sole Source Justification Are there secondary justification(s) for this sole source?

Section V - Purchase History Has the Agency or University Purchased these supplies or services in the past?

Term Term From Term To Value Description Contract Number Type Section VI - Business Rationale

1. Provide a detailed explanation of the need for the supplies or services:

2. Provide a list and describe in detail the specifications required to satisfy the need:

3. Provide detail explaining the justification selected in Section IV to explain why the requested supplies or services are the only ones available that can satisfy the agency or university requirements?

4. What are the unique features of the supplies or services that are not available in any other product or by any other vendor? Provide specific quantifiable factors/qualifications:

5. Has the Agency or University considered alternative supplies or services to satisfy their need?

5a. If yes, name the alternative vendors whose supplies or services were evaluated:

5b. If yes, what were the alternatives for each vendor and why were they unacceptable? Be specific with regard to features, characteristics, requirements, capabilities and compatibility:

5c. Explain how the market evaluation was conducted?

*This evaluation is to determine available options within a market. If the evaluation is to determine quality or best suited option, this is not the appropriate source selection. Under no circumstances shall the evaluation consist of testing alternative options. These activities must be conducted in a competitive transparent environment (i.e. IFB or RFP).

5a. If no, why weren't alternatives evaluated?

6. Are there resellers or distributors?

7. What efforts were made to get the best possible price (i.e. did the agency/university negotiate) and how did you determine the price for this purchase is considered fair and reasonable?

8. Will this purchase obligate the State to this vendor for future purchases such as maintenance, licensing or continuing need?

8a. If yes, please provide details regarding future obligations and/or needs:

9. What will be the financial or other impact to the State if this sole source is not approved and a competitive bid is required?

10. Is there any additional information you would like to add to justify this sole source?

Section VII Requesting Department Signature Required I know and understand the contents of this Sole Source Justification and attest that all statements are true and correct and the fairness and reasonableness of the price was adequately confirmed.

State Agency Bureau/Division Head or University Purchasing Director Approval and Signature Required I know and understand the contents of this Sole Source Justification and attest that all statements are true and correct and the fairness and reasonableness of the price was adequately confirmed. (All prior form fields will lock once this e-signature is completed) SPO Approval and Signature Required Sole Source Justification Form - Part II Section I - General Information Was a Sole Source hearing held per 30 ILCS 500/20-25?

Section II - Sole Source Hearing Details The State posted to the Illinois Procurement Bulletin a description of the State's need, the justification for the sole source decision, and information regarding the opportunity to submit comments and testify at a public hearing. Notice of the hearing was also posted outside of the hearing room 48 hours prior to the hearing.

The public hearing was conducted for the purpose of receiving testimony regarding the sole source determination. The Hearing Officer recommends the following:

The following relevant documents are attached:

Section III - CPO Approval and Signature Required 9.0.0.2.20101008.1.734229 Ellen.H.Daley@illinois.gov

• InLight 200 Automatic Reader and system maintenance. This covers annual on-site maintenance on the InLight 200 automatic reader system and any needed repairs. The annual preventative on-site visit will include:

a) Thorough cleaning of the InLight Automatic 200 reader

b) Inspection of all parts to insure they are working properly and repair, if needed

c) Correct any timing issues between slides and insure all slides work properly and repair, if needed.

• CAL and QC Set- The delivery of monthly calibration and quality control (QC) sets of dosimeters used by IEMA-OHS to be received by the 15th of the month.

• Dosimetry badges- Perform Occupational Radiation Monitoring service for IEMA-OHS and Illinois State Police employees per the exchange periods deemed appropriate by each department.

• Use of 8,400 Landauer InLight Dosimetry Badges and Group ID Report to the Agency. Vendor will perform certified laboratory analysis within twenty-four (24) hours to determine the type and amount of radiation exposure received. Exposure readings shall be telephoned to the designated Agency contact person within 24 hours of vendor’s receipt of dosimeters. Vendor shall submit a Radiation Dosimetry report to Agency in a form acceptable to the Agency, reporting the results of the analysis. Vendor shall provide departmentalized accounting and the report shall be sent to the Agency contact person as designated in this contract. Vendor shall immediately report to Agency any radiation exposure which is reportable to the licensing authority under 32 Ill. Adm. Code 340 and 400. These reports shall be made to the Agency contract person as designated in this contract.

Q3Answer: Landauer, Inc. is the patent holder for this technology and the only company that manufacturers and sells the InLight Dosimeter. The continued use of this technology ensures for compatibility with the automated and manual reader units currently maintained and used by the Agency. There are no comparable services that have the capability to read the dosimeter in the field and then later on being able to get a dose of record reading from the Vendor.

This equipment was previously purchased from Landauer in State Fiscal Years prior to 2010 plus 2010, 2012, 2014, 2016, 2018, 2020 and 2022 for distribution to emergency personnel throughout Illinois. The units have a 2-year life. The Vendor was selected because they were the only company that met the need to get a reading in the field and then later on being able to get a dose of record reading from the Vendor. Landauer was previously approved as a sole source for purchases completed in SFY06/07, SFY08 and SFY10, SFY12, SFY14, SFY16, SFY18, SFY20 and SFY22 for this same equipment. This is required by the federal regulations as stated above.

No other company was found that manufactures the type of dosimeter that the Illinois Emergency Management Agency and Office of Homeland Security (IEMA-OHS) is currently using to continue its dosimetry program. The dosimetry equipment allows the Agency to determine nondestructively the exposure each emergency worker could possibly receive at a location impacted by an incident at a nuclear power station.

Upon a search, no other company was found that manufactures the type of dosimeter that IEMA-OHS is currently using to continue its dosimetry program since Landaurer, Inc. is the patent holder for this technology.

Q4Answer: IEMA-OHS is currently using InLight ™ dosimetry technology, a state of the art method of measuring radiation exposure utilizing optically stimulated luminescence. The benefits of this patented technology include greater sensitivity, longer use upon distribution (up to 24 months), and the availability to obtain multiple readings using a field-deployed reader. To our knowledge, no other company has developed a system which incorporates the duality features of addressing both environmental and personnel monitoring, cost savings, or similar reusable feature technology. The contract will contain a provision which mandates the need for a certified reading by the Vendor within a 24 hour period for certification of field readings. Entering into a contractual agreement with Landauer, Inc. to provide the InLight™ dosimetry technology will provide uninterrupted dosimetry services to State and local government emergency workers. Currently, there are no comparable services for TLDs or film that have the capability to read the dosimeter in the field and then later being able to get a dose of record reading from the vendor. There are electronic dosimeters costing approximately $600 each, in bulk, that the agency could purchase to perform this function. In addition to their cost they require an annual calibration which costs about $75 each. An additional piece of equipment costing $200,000 would be needed by the Agency in order to use the instruments for dose of record readings.

IEMA-OHS selected to replace the use of thermoluminescent dosimetry with the InLight™ dosimetry technology because it has the lowest overall system costs and because it provides life-or-death information in 5 minutes, compared to the 72 hour for the 2nd lowest cost technology (thermoluminescent dosimeters or TLDs). The major system cost of thermoluminescent dosimetry are not the dosimeters, but the increased frequent expense of replacement dosimeters every 12 months and the cost of obtaining a reading from the vendor. The Agency overall costs for an emergency TLD read are estimated $25 per dosimeter in vendor costs alone. The InLight™ dosimetry reader cost per read is estimated $3.15. The InLight™ dosimetry readers are more mobile, can read dosimeters anywhere there is 110 V AC power, and require no specialized consumable gases and chemicals. TLDs must be read in a climate controlled facility using a reader that cannot be moved, requires a lot of maintenance, and takes at least 20 times longer to get a reading, while destroying the ability to do a second confirmation reading. The InLight™ dosimetry benefits include greater sensitivity, longer use upon distribution (up to 24 months), and the availability to obtain multiple readings using a field-deployed reader. This allows the emergency worker either to return to work, or be sent to a medical facility in about 5 minutes versus with the thermoluminescent dosimety, being unable to use the person for the 72 hours it takes to collect the dosimeter, transport it to the vendor for reading, transmit the reading information back to the Agency, and then track down the affected emergency worker and take appropriate action.

These dosimetry badges are an integral part of a system maintained by IEMA -OHS that provides critical data during and following accidents and releases at a nuclear power station. The continued use of this technology ensures compatibility with the automated and manual reader units currently maintained and used by the Agency. The readers and 1,350 environmental dosimeters were purchased by the Agency in SYF05 in the amount of $129,300. To change technology at this point in time would require the replacement of these readers and environmental dosimeters in addition to the 8,400 dosimeters that are currently distributed to emergency workers.

In addition, if the purchase is not completed for the currently used equipment, IEMA-OHS publications related to the dosimetry program will need to be revised (Emergency Worker Participant Manual and Guidelines for a Dosimetry Control Officer). Also, the Illinois Plan for Radiological Accidents (IPRA) relevant to each nuclear power station and the State (Volume I) and Standard Operating Procedures (SOP’s) utilized by the Radiological Task Force would require revisions. The IPRA Plans are currently issued using “controlled copies”. Approximately 130 copies of the State (Volume I) would need to be revised, printed, and distributed. Approximately 100-130 copies for each nuclear power station would also require revisions, printing, and distribution. Additional, in-depth training would also be required for emergency workers if a new product is to be purchased.