ML20198S191

Forwards Info Re Contamination During Nov 1985 Emergency Exercise & Discusses Guidance for Use of Radioactive Matls During Exercises.Guidance Will Be Provided Pending NMSS & FEMA Coordination.W/O Encls

ML20198S191
Person / Time
Site:	Browns Ferry
Issue date:	02/05/1986
From:	Jordan E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Hind J, Martin T, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20198B122	List: ML20198B118 ML20198S191
References
NUDOCS 8602180515
Download: ML20198S191 (2)

Text

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%.....j; FEB 5 1986 MEMORANDUM FOR: Thomas T. Martin, Director, DRSS, Region 1 J. Philip Stohr, Director, DRSS, Region II John A. Hind, Director, DRSS, Region III Richard L. Bangart, Director, DRSS, Region IV Ross A. Scarano, Director, DRSS, Region V FROM: Edward L. Jordan, Director  ;

Division of Emergency Preparedness '

and Engineering Response Office of Inspection and Enforcement

SUBJECT:

GUIDANCE FOR USE OF RADI0 ACTIVE MATERIALS DURING REACTOR EMERGENCY EXERCISES During the November 1985 Browns Ferry emergency exercise licensed radioactive material was used by the State of Alabama staff. Exercise participants and private property were contaminated. The enclosed correspondence is provided for your information regarding these activities.

Guidance on the use of radioactivity in emergency exercises will be provided in the near future pending coordination with the NRC Office of Nuclear Materials Safety and Safeguards (NMSS) and the Federal Emergency Management Agency (FEMA). The regions will be provided an opportunity to review the proposed guidance prior to issuance. Nothwithstanding this process, it is IE's position that unsealed sources or sources with removable contamination should not be used during an emergency exercise except for spiking environmental or food samples for lab analysis. This policy applies regardless of whether the radioactive material is regulated by NRC or the Agreement State or is " exempt" from regulation. To our knowledge, with the exception of the State of Alabama, this has been the accepted practice.

Regarding the use of " sealed" sources, we are aware that instrument " check" sources and thorium mantles have been concealed on the contaminated, injured l " victim" during exercises. While there appears to be no need for this usage from the standpoints of NRC and FEMA requirements, we understand from FEMA that some states find this a valuable training tool. However, one issue raised in the enclosed information is whether this is consioered a " human use" under NRC and Agreement State regulations. We are requesting clarification on this matter from NMSS and the Office of the Executive Legal Director. In the interim, because of the negligible personnel exposures, the use of these types of " sealed" sources should not be prohibited.

CONTACT: Edward M. Podolak, IE 492-7290

.- ENCLOSURE 2

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• The Regional Directors Until we provide further guidance, please review future emergency exercise scenarios to determine if unsealed sources will be used other than for spiking laboratory samples. If such use is planned or encountered during an exercise, NRC staff should make the above position clear to those managing the exercise and to the participants who might be exposed during such use. Also please inform us when such uses are contemplated or occur.

Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement

Enclosures:

1. 12/4/85 Inspection Report

2. 12/5/85 Letter from RII to Alabama

3. 1/15/86 Memo SP to IE w/ enclosure

4. 1/21/86 Memo SP to IE w/o enclosure DISTRIBUTION:

RHVollmer, IE JGPartlow, IE BKGrimes, IE ELJordan, IE SASchwartz, IE 08Hatthews, IE KEPerkins, IE JAAxelrad, IE WLFisher, IE-CRVan Niel, IE FKantor, IE EMPodolak, IE JNGrace, RII DNussbaumer, SP JGDavis, NMSS RECunningham, NMSS GHCunningham, ELD WJ0lmstead, ELD EW8rach, ED0 DCS DEPER R/F EPB R/F SEE PREVIOUS CONCURRENCES IE *EP8/IE *EP8/IE *DD/DEPER/IE D/DEPER/IE C..odolak:sc CRVan Niel DBMatthews SASchwartz ELJordan 1/31/86 1/31/86 1/31/86 2/3/86 2/4/86