ML20138P310

Policy Statement on Respiratory Protection

ML20138P310
Person / Time
Site:	Braidwood
Issue date:	11/15/1985
From:	Krimm R Federal Emergency Management Agency
To:
Shared Package
ML20138P302	List: ML20138P299 ML20138P310
References
RTR-NUREG-0654, RTR-NUREG-654 NUDOCS 8512260044
Download: ML20138P310 (3)

Text

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$ Federal Emergency Management Agency Washington, D.C. 20472 f

November 15, 1985 ICLICY STATEMENT ON RESPIRAIORY PROI1DCTION The Federal Emergency Managenent Agency (FEMA) has been ordered by the Braid-wood Station Atanic Safety and Licensing Board (ASLB) to file a written expla-nation on how the Agency interprets the phrase, " respiratory protection," as used in NUREG-0654/ FEMA-REP-1, Rev.1, section G.l.c. This policy statement contains fem's explanation of respiratory protection as used in this section.

Background

The use of " respiratory protection" .in G.1.c. is addressed within the context of disseminating information to the public on protective measures to be used during a radiological energency. Information on protective measures is provided to the public through various means such as prepared materials and ptblic meetirgs. The focas of the ALSB's discussion on respiratory protec-tion is on the content of Com1onwealth Edison's emergency information brochure for Braidwood. The specific issue raised is whether or not the brochure should contain an explicit reference to respiratory protection since it does not at the present time.

Issue Definition FEMA's answer to the Braidwood ASLB is provided through answers to these questions:

o In NUREG-0654/ FEMA-REP-1, Bev.1, is respiratory protection equated with sheltering and evacuation?

o What is the context of G.l.c. for providing public information on respiratory protection?

o Is the larguage in G.l.c. a reconmendation or a mandate that respira-tory protection be incitded in brochures?

Since the concerns raised by the ASLB are limited to providing information to the public, the policy provided in this statement does not pertain to the use of respiratory protection by emergency workers.

Interpretation of Language in G.I.c. on Respiratory Protection As stated, FEMA's policy on respiratory protection is provided below through answers to the posed questions.

1. In NUREG-0654/ FEMA-REP-1, is respiratory protection equated with sheltering and evacuation?

Ingically, both evacuation and particularly sheltering of fer mme degree of respiratory protection. Further, respiratory protection is closely related to sheltering and evacuation in that it may sucolenant either of these latter two 8512260044 e51219 PDR ADOCK 05000456 G PDR

r actions by serving a ccmnon function to all protective measures in preventing or minimizing the inhalation of certain types of airborne radioactive materials. It is noteworthy, however, that both evacuation and sheltering offer protection on a much broader range.

In a specific sense, respiratory protection is a type of protective measure distinct from either sheltering or evacuation. His is reflected in how the phrase is used in G.l.c. and E.7. In G.l.c., respiratory protection is listed as one of four distinct types of protective neasures, i.e., evacuation, shelterirg, radioprotective drugs and respiratory protection. In E.7. , an exanple (handkerchief over mouth) is provided.

Reference is also made at the end of evaluation criterion E.7. to guidance on respiratory protection published by the American Industrial Hygiene Asso-ciation (AIHA). An examination of the AIHA guidance shows that respiratory protection is discussed through the use of ccumon household and personal items (e.g., hankerchiefs and towels) to reduce the inhalation of airborne toxic materials including radioactive materials.

2. What is the context of G.l.c. for providing public information on respira-tory protection?

Were are two contexts in NURD3-0654/PEMA-REP-1, Rev.1 in which the provision of information to the public on respiratory protection is addressed. In G.l.c.,

the context is the anrual dissmination of information to the pi1>l1c such as information comonly provided through brochures. In E.7., the context is the provision of information durirg an mergency through the Emergency BroaJeast System (EBS). R us, it is clear that in G.l.c. the context for providing public information is the repetitive distribution of prepared materials on at least an annual basis as distinct from the content of EBS nessages provided at the time of an actual radiological emergency. m ile the specific type and form of disseminated materials is not specified in G.l.c., the most ccmton method for accanplishing su:h a dissnination is through mergency information brochures that are developed through a coordinated effort by licensees and State and local goverrments.

3. Is the language in G.l.c. a reconmendation or a mandate that respiratory protection measures be included in brochures?

De intent of the larguage in G.l.c. is to set forth the types of topic coverage considered essential for incorporation into public information materials. 21s is expressed in the phrase, "his information shall include

. . . ." Rus, it is necessary to include inforTretion on protective measures in these materials. With respect to addressirg specific types of protective neasures, the intent of the language in G.I.c. is structured to suggest various trotective measures or conponents of protective neasures that may be included in these materials. B is is expressed in the abbreviation, "e.g."

which means "for example." inis intent is further witnessed by the two references (" evacuation routes" and " relocation centers") to components of evacuation. Rese two references, like the other references within this level of G.l.c., are provided as illustrative topics that nay be used in discussiry protective measures.

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While infonnation on protective measures in general nust be included in brochures, it is not required that information specific to a form of respira-tory protection be included. However, if the information is included, it must be consistent with the governing emergency plan for the area. Protective actions information included in the brochure, like all the information in the brochure, is required to be a reflection of the public policy for protective actions. A jurisdiction might feel that a particular action is not acceptable.

Thus requiring information within the brochure on protective actions not interded for general use within jurisdictions might confuse rather than inform.

Consistent with the above, the inclusion of information on each of the indi-vidual types of protective measures is not mandated in G.l.c. Pbreover, the absence of language on respiratory protection in brochures will not constitute a basis per se for FEMA to irdicate a planning inadequacy. However, FEMA recemnends that the brochures reflect language on protective measures contained in the energency response plan.

Conclusion Wille not specifically mandated in NUREG-0654/ FEMA-REP-1, Rev.1, FEMA recon-mends that language on respiratory protection be incorporated in brochures.

As stated, the absence of language on respiratory protection in brochures will rnt constitute a basis per se for FEMA to indicate a plannirg inadequacy.

We are more concerned, in reviewing brodiures, that references to protective neasures be couched in a manner that help persons to be prepared to take specific types of protective actions but yet cautions than to listen to EBS messages in order to follow the specific protective actions recomended for the particular accident circumstances.

APPROVED J

Assistant Kssocia'te Director Office of Natural and Technological Hazards Program State and Iocal Prograns and Support Directorate