ML19351F043
| ML19351F043 | |
| Person / Time | |
|---|---|
| Issue date: | 12/01/1980 |
| From: | Grimes B Office of Nuclear Reactor Regulation |
| To: | Mcconnell J Federal Emergency Management Agency |
| Shared Package | |
| ML19351F044 | List: |
| References | |
| NUDOCS 8012240442 | |
| Download: ML19351F043 (6) | |
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d UNITED STATES
[ 4.-g i NUCLEAR REGULATORY COMMISSION WASWNGTON, D. C. 20555
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December 1, 1980 Mr. John McConnell, Chairman Federal Radiological Preparedness Coordinating Committee Federal Emergency Management Agency Plans and Preparedness Washington, D. C.
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Dear Mr. McConnell:
This letter is in response to your request of October 8, 1980, for review and comment on the draft document " Draft Guidance on Offsite Radiation Measurement Systems, Phase 2, Monitoring and Measurement of Radioiadine to Determine Dose Commitment in the Milk Pathway", dated August 1980. My office has coordinated the review and comments for the U. S. Nuclear Regulatory Commission.
In general, the NRC finds that this initial effort is a well defined and scoped document. However, the following major changes are recommended to improve this guidance:
1.
More emphasis should be placed on handling the management and, logistics of monitoring the milk shed from the standpoint of monitoring team deployment, communications, data collection and the use of the Federal resources described in Appendix C of the document.
2.
The problem of managing of the milk pathway for the smaller, more limited releases of radiciodine from the plant site is not covered adequately. This type of incident scenario has a higher probability of occurrence than the larger, core extensive type incident that might cover the entire ingestion EPZ.
3.
The fact that the CDV-700 type instrumentation is the only instrument that has been evaluated to-date for the rapid, direct field approxi-mation of radioiodine concentration in bulk milk shipments and stcrage needs additional explanation and clarification so that the reader understands that use of this particular instrument is not the only way of making-the measurement.
A number of specific cocinents and suggested changes on the details of the document are attached to this letter. We hope the coments and corrections l
will be helpful in revising this document.
Sincerely, h'
401n 40 [f Brian K. Grimes, Director Division of Emergency preparedness N
Attachment:
As stated cc w/ attachment:
K. Siebentritt
SPECIFIC COMMENTS AND CHANGES 1.
Pg. 2-1, it recommended that the decription of the problem on this page be modified to paraphase the introduction to Appendix C, Milk Control in NCRP #55 (a copy is attached for your information). This is an excellent suc.inct statement of the problem from a well recognized authority.
2.
Pg. 2-3, Section 2.2, 1st paragraph, last sentence should be changed to read:
"Should the projected dose reach the emergency PAG level, the food stuff shall be withheld from commerce until..."
3.
Pg. 2-4, Section 2.3, 1st paragraph, first sentence should be changed to read:
"Radiciodine can be a major contributor to the ingestion pathway, particularly via the air-pasture-cow-milk pathway."
4.
Pg. 2-5, 16th line from top, the conservative meteorological conditions used generate the deposited activity levels in Table 2 should be given in terms of stab;11ty class, wind speed, etc.
5.
Pg. 2-5, Section 2.4,1st paragraph, first and second sentence should be changed to read:
"The hazard immediately after an accident will be greater for radiciodine than for strontium, cesium and the heavy metals under most reactor accident scenarios. This is because these radionuclides are not as abundant in the reactor core as radiofodine and will be released as particulates in smaller fractions than the radiciodine which will be in both the particulate and gaseous phase."
6.
Pg. 2-5, Section 2.4, 1st paragraph, 3rd sentence bases the percentage of elemental radioiodine on the Reactor Safety Study, NUREG-75/014.
There has been considerable controversy about the amount of radiofodine which would be released in this chemical form. This paragraph should be expanded to indicate that the radiciodine levels in Table 2 are based on very conservative release estimates and may not be as over-I whelming as indicated.
7.
Pg. 2-9, Section 2.4, last paragraph, 2nd sentence should be changed to read:
... ether radionuclides will not be a problem; however, in accident scenarios, such as fuel pool accidents where the radiciodine has decayed to insignificant levels, cesium and strontium nuclides become the govern-ing release constitutents."
8.
Pg. 2-9, Section 2.4, last paragraph, 3rd sentence should be changed to read:
...the PAG levels have been reached but should be continued as long as significant dose reductions can be achieved."
9.
Pg. 2-13,~Section 2.6.2, 2nd paragraph, 2nd and 3rd sentences omit the word "only" in front of "2.6"." and "about 1-2"." in these sentences.
- 10. Pg. 2-15, Section 2.6.4, 1st paragraph, 1st sentence should be changed to read: "Although there are a number of technical problems with regard to making rapid assessment measurements at PAG 1evel, the problem of bgistics and management of the large number of monitoring teams and the size of the area to be monitored is of a considerable higher magnitude."
. 11. Pg. 3-1, Section 3, 2nd paragraph snould be expanded to provide detail on how to manage the large monitoring resources needed to handle this problem, particularly after the extensive Federal response arrives.
- 12. Pg. 3-1, Section 3.1, 2nd paragraph should go into detail on procedures for handling smaller accidents down to those that may only require monitoring of a limited amount of pasture on several farms.
- 13. Pg. 3-2, Section 3.1, 3rd paragraph, 1st sentence should be changed to read: "The substitution of uncontaminated forage will slowly reduce the production of contaminated milk from cows originally contaminated by the release. However, some milk may continue to be produced with contamination levels above the PAG."
- 14. Pg. 3-2, Section 3.1, 3rd paragraph following the comment in Item #13 above should provide a discussion of the effective half-life of radio-iodice in the cow and an estimation on the decrease in the amount of radioiodine in milk with time after the milk shed is placed on stored feed.
- 15. Pg. 3-2, Section 3.1, 4th paragraph should contain information on the use of the AMS aircraft to identify family farms which should be notified that they should not drink the milk produced on their farms.
16.
Pg. 3-2, Section 3.1, 5th paragraph, 2nd sentence should be changed to read: " Major decisions on procedures and general techniques to ce followed should be made prior to an accident so that the necessary information will be collected to determine the necessary actions to mitigate the effects of a contaminated milk shed."
17.
Pg. 3-3, 2nd paragraph, 2nd sentence shoald be changed to read:
"This dilution will be accomplished at the expense of contaminating additional uncontaminated milk and if carried out with foreknowledge would be considered adulteration by the FDA."
- 18. Pg. 4-1, 1st paragraph, last sentence should be changed to read:
"...but will result in the potentially greatest benefit, other than the immediate removal of all dairy herds from any suspected contaminated pasture."
- 19. Pg. 4-1, Sectiun 4.1, 2nd paragraph, 2nd listing, item 1, should be changed to read:
"1) limits of sensitivity to measure radiciodine concentrations in milk."
- 20. Pg. 4-2, Table 5 add a footnote to the last coluren as follows: Preventive PAG = 0.012 u Ci/1; Emergency PAG e 0.12 u Ci/1.
- 21. Pg. 4-3, Section 4.1.6, 5th paragraph,1st sentence should be changed' to read:
...are capable of detecting contamination of milk at the emer-gency PAGs level..."'
- 22. Pg. 4-3, Section 4.1, 5th paragraph, 3rd sentence should be changed to read:
...will be capable of monitoring milk at the preventive PAG level."
l
- 23. Pg. 4-6, Section 4.1, 7th paragraph should be expanded to include some statement about the infiuence of fluid temperature on the collection efficiency of resin for this purpose and whether this is a consideration.
- 24. Pg. 4-8, Section 4.1, 12th paragraph, 2nd sentence should be changed to read: "...in the event that contaminated milk is detected providing he is given clear limits and is properly trained."
- 25. Pg. 4-12, Section 4.3, 1st paragraph, 6th sentence should be changed to read:
"The release information, the offsite plume monitoring data and the meteorological information will serve as input for computer pre-dictions of the radiciodine concentrations..."
- 26. Pg. 4-12, Section 4.3, 1st paragraph, 14th sentence should be changed to read:
a two hour exposure, the plume concentration necessary to deposit {g{IatthePAGlevelcanbeestimatedas:"
- 27. Pg. 4-13, Section 4.5, 1st paragraph, last 3 lines are repeated on this page and should be omitted.
- 28. Pg. 4-13, Section 4.6, is very general and does not go into the specifics of handling smaller accidents. This section should be rewritten and expanded since this is the higher probability-incident and more likely to occur.
- 29. Pg. 5-1, Reference, Item No. 3, add "NUREG-75/014" to this reference.
- 30. Pg. A-1, Appendix A, Section A.1, 1st paragraph should be rewritten to include the information on other laboratory type systems which could be used and the reasons for not using them such as the amount of time required to do the evaluation. Also, it should state that the CDV-700 with the 6306 G tube and anion resin system is the only one that has been evaluated specifically for this type of emergency monitoring of fluid milk but this does not exclude the use of other instruments.
- 31. Pg. C-1, Appendix C, 1st paragraph should also site and summarize Public Law 93-288.
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MII.K CONTROL
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43 requ,irementa covering protective actions in effect and instruct.
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ing them not to accept milk from farmers having cattle on 1 i panture in the affected area.
(4) Anniating the indust 4y in entablishing a procedure for collec-tion of contaminated milk in excess of acceptable levels and Milk Control diversion to a non-fluid milk processing plant.
<si e#suri"# th t the crece eed miik vred"<t co"t i"i"# """c-ceptable levels be stored to await decay of radioindines 9nd monitoring of these products prior to release for public con-sumption.
Countermeasures to avoid milk contamination and the rink of ir:dittion exposure to milk usera resulting from a nuclear facility (6) Initiating a sampling program. including the collection of rep-i sccident must be implemented immediately after such an accident if renentative samples of the finished product and the sampling of raw milk na needed and based upon capacity of the labora-i
.they cie to be efTective. The protective actions to be considered re-
- tory to handle namples.
'quira breaking the cycle through which contamination sprenda-Ifit han been determined through monitoring and sampling that i
n:mily, the panture-cow-milk-man pathway.
nome fluid milk han been contaminated, then appropriate local ofTi.
Since the potential for accidental radiation exposure of the popula-cials should requent the milk industry to import uncontaminated tior' through milk may extend for many milen from the accident site; fluid milk and/or only powdered and canned milk products. Chil-and Emce the magnitude of exponure through milk may be 400-700 dren, lactating mothers and pregnant women can be placed on times gratter than through inhalation, the need for appropriate pro-evapora'ed or powdered dry skim milk until imported fluid milk in tectiva rction in of paramount importance (lengemann and Thomp -
brought m. Uncontaminated refrigerated fluid milk, frozen whole son,1963; Bernhardt cf al.,1971).
milk concentrate and canned sterile whole milk can also be used.
Fir t, a pre-determined emergency communications plan munt be i r.et in motion on an area-by-area basis whereby dairy farmern in the
'efTected land area are alerted immediately and instructed by the
! appropriate atate and local ofTicials to move their cattie from pasture to stored feed. This breaks the cycle of transminnion of radioactivity i rontamination at the root and must be accomplished immediat ly e
Within 48-72 hours, contaminated land areas can be identified by j ground and aerial surveillance. Only those farmers in contaminated land arcts would be required to keep their cattle on stored feed. This
- obvi:unly reduces the possibility of fluid milk contamination.
In order to provide surveillance of all milk produced in the affected i area, ttxte or local sanitarians or milk control specialista should be immedintely nanigned to one or more of t he milk receiving or process-ing planta likely to receive milk from contaminated farms. The sanitarians would be responsible for:
(I) Establishing immedicte lininon with the industry and the ofii-l 4
cilla responsible for taking protective actions.
(2) Identifying the dairy farms in the afTected aren shipping milk 4
to the plant and determining if the cattle on thene farms have been placed on stored feed.
(3) Providing drivern of bulk milk tanka with guidelinen and 42 t
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REMARKS.
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' Enclosed for your review and comment';is.the. initial ~
.draf t. version of the. Phase 2-Guidance for Monitoring"
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and Measuremcot of Radioiodine to Determine. Dose,
l Committ:nent in the Milk Pathway.'This guidance. has --
been developed by the Exxon Nuclear Idaho Co.,IInc.',-
INEL, under contract. to NRC-and coordinated with..t'~
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Federal Interagency Task Force on Off-site Emerg. d Instrumentation for Nuclear Incidents.
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Please forward your comments / suggested. changes to m_e
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November 28, 1980.
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